Technical Support Document 

for New Jersey’s Regional Haze State Implementation Plan

Air Programs Branch, EPA Region 2

July 2011

INTRODUCTION

Three Technical Support Documents

Technical Support Documents (TSD) describe EPA’s supporting
documentation for its proposed approval of New Jersey’s Regional Haze
State Implementation Plan (SIP), and provide more detailed evaluations
of the SIP submitted by New Jersey.  In addition, EPA should propose
approval of New Jersey’s sulfur in fuel regulation, which, by reducing
sulfur emissions, has the multiple purpose of improving visibility and
reducing particulate matter.   

There are three Technical Support Documents that evaluate New Jersey’s
Regional Haze SIP.  First, this document evaluates the approvability of
the SIP overall, focusing on the reasonable progress portion of the SIP.
 A second document, attached, evaluates New Jersey’s application of
Best Available Retrofit Technologies.  A third document, also attached,
evaluates New Jersey’s development and use of emission inventories.

Overview of New Jersey’s State Implementation Plan

New Jersey’s SIP includes emission controls measures that will reduce
pollutants that impair the view at certain National Parks and wilderness
areas, particularly the Brigantine Wilderness Area of the Edwin B.
Forsythe National Wildlife Refuge, located in coastal New Jersey.  New
Jersey adopted some of these controls specifically as part of its
Regional Haze SIP.  There are other controls listed in the SIP that were
recently adopted (separately from this SIP) or were already existing;
those also reduce haze.  This portion of the TSD evaluates how well
those emission measures reduce impairments to visibility at Brigantine
and other areas.  Additional documents evaluate the emission inventories
New Jersey used and the emission controls on sources eligible for
control using Best Available Retrofit Technologies (BART).  

Material Submitted by New Jersey

New Jersey’s Department of Environmental Protection (DEP) prepared the
Regional Haze SIP, which the Commissioner submitted for the State of New
Jersey.  The main submittal was on July 28, 2009, containing the main
document and Appendices A through O.  The submittal was automatically
declared complete six months after New Jersey’s submittal date.  New
Jersey submitted additional information about BART sources on March 2,
2011; and its sulfur in fuel rule was adopted on September 20, 2010 and
submitted to EPA on December 9, 2010. 

Background Information on the Nature of Regional Haze

Regional haze is visibility impairment that is produced by a multitude
of sources and activities which are located across a broad geographic
area and emit fine particles (PM2.5) (e.g., sulfates, nitrates, organic
carbon, elemental carbon, and soil dust) and their precursors (e.g.,
sulfur oxides (SOx), nitrogen oxides (NOx), and in some cases, ammonia
(NH3) and volatile organic compounds (VOC)).  Fine particle precursors
react in the atmosphere to form fine particulate matter which impairs
visibility by scattering and absorbing light.  Visibility impairment
reduces the clarity, color, and visible distance that one can see. 
PM2.5 can also cause serious health effects and mortality in humans and
contributes to environmental effects such as acid deposition and
eutrophication. 

The average visual range in many Class I areas (i.e., national parks and
memorial parks, wilderness areas, and international parks meeting
certain size criteria) in the eastern United States, is less than 30
kilometers or about one-fifth of the visual range that would exist under
estimated natural conditions (64 FR 35714, July 1, 1999).  In section
169A of the 1977 Amendments to the Clean Air Act (CAA), Congress created
a program for protecting visibility in the nation’s national parks and
wilderness areas.  This section of the CAA establishes as a national
goal the “prevention of any future, and the remedying of any existing,
impairment of visibility in mandatory Class I Federal areas which
impairment results from manmade air pollution.”  On December 2, 1980,
the Environmental Protection Agency (EPA) promulgated regulations to
address visibility impairment in Class I areas that is “reasonably
attributable” to a single source or small group of sources, i.e.,
“reasonably attributable visibility impairment” (45 FR 80084). 
These regulations represented the first phase in addressing visibility
impairment.  

The requirement to submit a regional haze SIP applies to all 50 states,
the District of Columbia, and the Virgin Islands.  Section 51.308(b)
required states to submit the first implementation plan addressing
regional haze visibility impairment no later than December 17, 2007. 
Regional haze SIPs must assure reasonable progress towards the national
goal of achieving natural visibility conditions in Class I areas. 
Section 169A of the CAA and EPA’s implementing regulations require
states to establish long-term strategies for making reasonable progress
toward meeting this goal.  Implementation plans must also give specific
attention to certain stationary sources that were in existence on August
7, 1977, but were not in operation before August 7, 1962, and require
these sources, where appropriate, to install Best Available Retrofit
Technology (BART) controls for the purpose of eliminating or reducing
visibility impairment. 

STATE’S SUBMITTAL

The SIP revision addresses regional haze for the first implementation
period.  New Jersey has a Class I areas within its borders, the
Brigantine National Wildlife Refuge Class I area, and so is responsible
for calculation of baseline and natural visibility conditions,
establishment of reasonable progress goals, monitoring requirements, and
meeting RAVI requirements.  Also, New Jersey is responsible for
developing a regional haze SIP that addresses this Class I area, that
describes its long-term emission strategy, its role in the consultation
processes, and how the SIP meets the other requirements in EPA’s
regional haze regulations.   

Measures Adopted to Address Long-Term Strategy 

The LTS is a compilation of state-specific control measures relied on by
the state to obtain its share of emission reductions to support the RPGs
established by New Jersey and other Class I states.  New Jersey’s LTS
for the first implementation period addresses the emissions reductions
from federal, state, and local controls that take effect in the State
from the baseline period starting in 2002 until 2018.  

 

The LTS was developed by New Jersey in coordination with other states
working together as the Mid-Atlantic NorthEast Visibility Union
(MANE-VU), as they identified emission controls that were reasonable and
addressed the goal of meeting the RPG for the Brigantine National
Wildlife Refuge Class I area.  

On June 20, 2007, the MANE-VU states agreed to adopt emission control
strategies that MANE-VU modeled to determine the amount of progress that
the MANE-VU states would make toward improving visibility by the end of
the first control period, ending in 2018.  

By adopting all the measures identified in the MANE-VU analysis and
applying BART to eligible sources, New Jersey’s LTS achieves its share
of emissions reductions that are reasonable and which modeling shows
will achieve the reasonable progress goals for the Brigantine National
Wildlife Refuge Class I area.  The following chart compares measures
adopted by New Jersey with the measures agreed to by the MANE-VU states
(often referred to as the MANE-VU ‘ask’).  



MANE-VU Measures

	Measures Adopted or Action Taken by New Jersey

Timely implementation of BART on all sources identified as BART
–eligible	Implementing BART on all eligible sources, except those that
have emission limits less than the 250 tons per year BART eligibility
thresholds in their permits.

Low sulfur fuel oil strategy:  for NJ distillate oil to 0.05% sulfur by
2012 and to 15ppm by 2016, #4 residual oil to 0.25% sulfur no later than
2012, #6 residual oil to 0.3 to 0.5% by 2012 	No. 2 & lighter: 0.05
percent by 2014; 0.0015 percent (15 ppm) by 2016

No. 4: 0.25 percent by 2014

No. 5, No. 6 & heavier: 0.5 percent by 2014

All lower sulfur targets met well before 2018.

90% or more reduction in SO2 emissions from 167 stacks or alternative
measures	90% or greater reductions of sulfur emissions at the four
stacks located in New Jersey at: BL England, PSEG (2) - Hudson, and PSEG
– Mercer.  Plus nearly 90% reduction of other pollutants responsible
for haze.

Continued evaluation of other measures, including energy efficiency,
alternative clean fuels, reduce SO2 and NOx from coal units by 2018 and
NSPS for wood combustion if reasonable and cost-effective	Energy Master
Plan and Greenhouse Gas Plan

Smoke Management Plan and Construction Activities

Residential Wood Burning Strategies

Measures to Reduce Organic Carbon Emissions

These measures were agreed-to by MANE-VU states and tribes on June 20,
2007.



New Jersey Adoption of Measures

• BART Controls 

A more detailed review of New Jersey’s implementation of BART is found
in the companion Technical Support Document:  Review of Application of
Best Available Retrofit Technology in New Jersey’s Regional Haze State
Implementation Plan, July 29, 2011, which is attached to this TSD.

In summary, New Jersey initially identified eleven sources that could be
subject to BART (letter to EPA, September 8, 2005).  Of these, the five
sources listed in EPA’s Notice of Proposed Rulemaking were determined
to be potentially subject to BART controls.  From the five sources, two
had - or are in the process of taking - permit limits that reduce their
BART-eligible emissions to less than the 250 ton per year BART
eligibility limit.  New Jersey evaluated three sources for controls
under the BART rules.  

EPA, in a separate review, found two sources that might meet
BART-eligibility requirements.  New Jersey had not evaluated these two
sources, since they were to be shutdown or controlled under other
programs.  One source had additional controls under New Jersey’s EGU
strategy described in Section 9-2 of New Jersey’s SIP.  As described
in companion Technical Support Document on BART, New Jersey has since
evaluated these two sources with respect to BART controls and is
documenting the appropriate level of control for these two sources in
permit modifications to be submitted to EPA.  

While BART controls were included in the modeling that forecasted
visibility in the reasonable progress goal year of 2018, emission
reductions due to New Jersey’s BART controls were not included in the
2018 modeling.  (See Figure 5-3 in MANE-VU Modeling for Reasonable
Progress Goals, submitted by New Jersey as Appendix N-2 in its SIP and
at   HYPERLINK
"http://www.nescaum.org/documents/modeling-for-reasonable-progress-final
-021208.pdf" 
http://www.nescaum.org/documents/modeling-for-reasonable-progress-final-
021208.pdf .)  Thus,  emission reductions from New Jersey’s
application of BART will result in additional improvements in visibility
beyond that predicted by the modeling and will provide additional
likelihood that the Brigantine Class I area will meet or exceed the
Progress Goal for 2018.  

• Electric Generating Units 

New Jersey is home to four of the 167 EGU stacks identified in the
setting of the 2018 reasonable progress goals for Brigantine and five
other Class I areas in MANE-VU. New Jersey has addressed emissions from
these stacks through Advanced Consent Orders or Consent Decrees that
require all four facilities to meet performance standards for sulfur,
nitrogen and particulate emissions. 

EPA proposed that states could use their involvement under the Clean Air
Interstate Rule to fulfill their commitment to implementing controls on
EGUs.  However, New Jersey chose to implement control on each of its
EGUs, outside of EPA’s CAIR.  Thus the court remand of CAIR, and
EPA’s development of an improved transport rule to replace CAIR, does
not affect the amount of control that New Jersey implemented on its
sources and has no negative impact on New Jersey’s efforts to meet the
visibility Progress Goals.  

The four EGU stacks are located in the following facilities: BL England,
PSEG - Hudson, and PSEG – Mercer. These facilities all have coal-fired
EGU boilers. The BL England facility is under an Administrative Consent
Order (ACO) [New Jersey Department of Environmental Protection
Administrative Consent Order (ACO) NEA 040002-73001, effective January
24, 2006] to meet performance standards for SO2, NOx, and PM. The Hudson
and Mercer facilities are under a Consent Decree to also meet
performance standards for SO2, NOx and PM 
[http://www.epa.gov/compliance/resources/decrees/amended/psegfossil-amen
ded-cd.pdf]

 

These orders/decrees will require more than a 90 % SO2 emission
reduction by 12/15/2012, in addition to about 90% reduction of NOx and
PM.  New Jersey has also adopted a mercury rule that sets performance
standards for coal-fired boilers, for companies which choose the
multi-pollutant strategy in that rule. The four of the167 EGU stacks
located in New Jersey are committed to multi-pollutant controls, as part
of their mercury rule compliance plan.  For the other electric
generating units not specifically identified, New Jersey adopted new
rules (April 20, 2009 New Jersey Register) to implement a
multi-pollutant control strategy to reduce allowable NOx, SO2, and
particulate emissions from all coal-fired boilers. Details regarding
this rule proposal are available at NJDEP’s website,
http://www.state.nj.us/dep/aqm/index.html. 

• Sulfur in Fuel Oil  - Proposed Approval of Subchapter 9 – Sulfur
in Fuels

NJDEP proposed revisions to Subchapter 9 on November 16, 2009 at 41
N.J.R. 4156(a) which established a comment period running until January
15, 2010.  A public hearing was held on January 5, 2010.  The public
comment period was extended to March 15, 2010 and New Jersey held an
informal stakeholder meeting on March 8, 2010.  New Jersey evaluated all
the comments received throughout this period and adopted the revisions
on September 20, 2010 at 42 N.J.R. 2244 with an operative date of
October 25, 2010.  New Jersey’s responses to the public comments and
stakeholder recommendations are posted at  HYPERLINK
"http://www.nj.gov/dep/aqm/1997adop.html"
http://www.nj.gov/dep/aqm/1997adop.html  under ‘Sulfur in Fuels’.

New Jersey proposed these amendments to help the State attain and
maintain the Federal health-based National Ambient Air Quality Standards
(NAAQS) for fine particles (particles smaller than 2.5 microns in
diameter (PM2.5)), SO2 and ozone, and to reduce haze in New Jersey and
the region.  The rulemaking is part of a regional effort to reduce
regional haze and fine particles through the implementation of a low
sulfur fuel strategy.  New Jersey committed to propose this course of
action as a member of MANE-VU.

New Jersey included the MANE-VU states’ long term strategy for
reducing the sulfur content in fuel in the 1997 fine Particulate Matter
(PM2.5) SIP that was submitted to EPA on April 1, 2009.   New Jersey had
specifically noted that NJDEP planned to propose to amend NJAC 7:27-9,
Sulfur in Fuels, specifically section 9.2, anticipating lowering the
maximum allowable sulfur content in fuel and the maximum allowable SO2
emissions from fuel combustion in order to reduce the emissions of SO2
and other pollutants from the combustion of fuel in New Jersey.   

Under the MANE-VU agreement on the proposed standards, phase one
establishes limits of 0.05 percent sulfur by weight (500 ppm) for
distillate oil (No. 2 and lighter); 0.25 percent sulfur by weight (2,500
ppm) for No. 4 residual oil; and between 0.3 and 0.5 percent sulfur by
weight (3,000 to 5,000 ppm) for No. 6 residual oil.  Under the MANE-VU
strategy, these standards are to go into effect no later than 2012.  New
Jersey proposed additional time, until July 1, 2014, to achieve these
standards to ensure sufficient time for production and distribution of
lower sulfur fuel oil.

In addition, the MANE-VU strategy provides for a phase two reduction by
2016 for distillate oil (No. 2 and lighter) to 15 ppm.  The proposed new
standards for maximum allowable SO2 emissions at N.J.A.C. 7:27-9.2 Table
2B represent, as do the existing standards, the emissions level for each
grade of fuel oil under combustion scenarios without add-on SO2 air
pollution control equipment.

The amendments to N.J.A.C. 7:27-9.2 include the addition of Tables 1B
and 2B, which contain the new maximum allowable sulfur-in-fuel and
maximum allowable SO2 emission standards, effective July 1, 2014 and
July 1, 2016. The new standards at Table 1B are given in parts per
million by weight (ppm), rather than percent sulfur by weight, as the
existing standards are described.  In addition, the existing standards
in Table 1 have been converted to equivalents in parts per million (now
Table 1A) for greater ease in comparing the existing standards to the
new standards in effect in 2014 and 2016. For sources that chose to
control their emissions by use of control equipment, Table 2B contains
the new maximum allowable sulfur dioxide emissions that are release to
the atmosphere in pounds per million BTU.

These new standards in Tables 1B and 2B are consistent with the MANE-VU
emission management strategy for new standards for maximum allowable
sulfur in fuel, which would reduce sulfur content in the inner zone
states (including New Jersey).

New Jersey has repealed section 9.5 which allowed the limited use of
higher content sulfur fuel for units that were converting to coal.  This
provision was counter to the new sulfur standards.  New Jersey included
a “sell-through” provision, which allows the storage, sale,
distribution, delivery or use of newly-noncompliant fuel that is already
in tanks in New Jersey as of July 1, 2014 and July 1, 2016.

It should be noted that EPA’s current SIP approved version of
Subchapter 9 has a condition that sulfur dioxide “bubble” permits
issued by the State pursuant to section 9.2 and not waived under the
provisions of section 9.4 become applicable parts of the SIP only after
receiving EPA approval as a SIP revision. See 7/8/83, 48 FR 31400.  This
is necessary because detailed air quality simulation modeling involves
many factors that can impact the results, such as, source location,
stack height, distance between stacks and local topography and EPA
review is required to insure replicable results.  This provision has not
changed in the latest revision and EPA is continuing its previous
finding as it appears in 40 CFR 52.1605, under Subchapter 9 in the
comment column. 

New Jersey asked for a longer period of time than agreed to in the
MANE-VU ‘ask’ to implement these rules that reduce sulfur in fuels. 
EPA notes that New Jersey has provided a reasonable justification for
the new effective dates and that they will be in place well before the
end of the first planning period in 2018.  

With the limitation that sulfur dioxide bubbles must continue to be
approved on a case-by-case basis as SIP revisions, EPA is proposing to
approve the revisions to Subchapter 9 as part of the Regional Haze SIP
and the PM2.5 SIP. 

• Additional Measures 

The following additional measures also are part of New Jersey’s
Regional Haze Plan, but were not adopted specifically for the Plan.  The
following summaries are excerpted from New Jersey’s Regional Haze
Plan, July 2009:

• Energy Master Plan and Greenhouse Gas Plan 

New Jersey developed an Energy Master Plan2 (EMP) to address New
Jersey’s electricity and heating challenges. The draft plan was
released on April 17, 2008, and finalized on October 22, 2008. One
component of the Energy Master Plan addresses ways to increase energy
efficiency in the State. New Jersey is also developing a Greenhouse Gas
Reduction Plan pursuant to the Global Warming Response Act. Measures
which will be implemented as a result of these plans will reduce
multiple air contaminants and improve visibility. 

• Smoke Management Plan and Construction Activities 

Since New Jersey is home to the federally protected visibility area, the
Brigantine Wilderness Area, New Jersey is required by the USEPA rules
to: Develop and implement a smoke management plan and address emissions
from construction activities. 

New Jersey addresses smoke management through its Open Burning rules at
N.J.A.C. 7:27-2. New Jersey addresses “fugitive dust” emissions from
construction activities through its “Soil Erosion and Sediment Control
Standards: Standards for Dust Control.” The USEPA has promulgated
several regulations which limit exhaust emissions from non-road
vehicles, such as those used at construction sites.  In addition, New
Jersey has existing rules to limit the idling of vehicles and equipment.
 New Jersey will consider additional mitigating measures for
construction activities on a case-by-case basis depending on the size
and nature of the construction work, and the review of the potential
emissions on the property in relation to any potential off-site impacts.
 New Jersey is considering amendments to its Open Burning Rule. 

• Residential Wood Burning Strategies 

Residential wood burning from woodstoves and fireplaces is one of the
largest sources of direct fine particulate matter, PM2.5, emissions in
New Jersey. New Jersey is considering strategies to reduce the emissions
of wood smoke. Implementation of these strategies will reduce fine
particle emissions and improve visibility. One strategy under
consideration is a Home Wood Heating Advisory Program, similar to those
in Oregon and Washington states. In general, these programs request wood
burning be limited during times when unhealthy air quality is forecast
or monitored. Other control measures under investigation include
woodstove and fireplace change-out programs. 

• Measures to Reduce Organic Carbon Emissions 

Even though the focus of the Reasonable Progress Goal is to reduce
emissions of sulfur dioxide, the largest contributor to regional haze,
for the 2018 reasonable progress plan, New Jersey is taking actions to
reduce emissions of organic carbon, the second largest contributor to
visibility impairment at Brigantine Wilderness Area. Some of New
Jersey’s existing and proposed rules which reduce emissions from
organic carbon include: 

• Existing Diesel Idling Rule

N.J.A.C 7:27-14.3 removes or further limits the exemptions to the
State’s idling restrictions, removes sleeper berth exemption from
vehicles effective May 1, 2010, and includes additional idling
restrictions for gasoline vehicles. 

• Existing Open Burning Rule

N.J.A.C 7:27-2 limits open burning. 

• Existing Industrial, Commercial and Institutional (ICI) Boilers 

N.J.A.C. 7:27-16.8, -19.7 sets performance standards for NOx, CO and VOC
which ensure good combustion, and requires annual tune ups to reduce NOx
emission and may also help reduce fuel consumption. 

• Existing Heavy Duty Diesel Trucks Rule

N.J.A.C 7:27-14 sets tighter opacity standards for the Inspection and
Maintenance (I/M) program. 

Emissions Inventory for 2018 with Federal and State Control Requirements


The emissions inventory used in the regional haze technical analyses was
developed by Mid-Atlantic Regional Air Management Association (MARAMA)
for MANE-VU with assistance from the MANE-VU states.  The 2018 emissions
inventory was developed by projecting 2002 emissions, and assuming
emissions growth due to projected increases in economic activity as well
as applying reductions expected from federal and state regulations
affecting the emissions of VOC and the visibility-impairing pollutants
NOx, PM10, PM2.5, and SO2.  The BART guidelines direct states to
exercise judgment in deciding whether VOC and NH3 impair visibility in
their Class I area(s).  MANE-VU demonstrated that anthropogenic
emissions of sulfates are the major contributor to PM2.5 mass and
visibility impairment at Class I areas in the Northeast and Mid-Atlantic
region.  It was also determined that the total ammonia emissions in the
MANE-VU region are extremely small. In addition, since VOC emissions are
aggressively controlled through New Jersey’s ozone SIPs, the
pollutants New Jersey considered under BART are NOx, PM10, PM2.5, and
SO2.    

Additional information on the emission inventory used in the Regional
Haze SIP, see the companion Technical Support Document, attached: 
Review of New Jersey State-wide 2002 and 2018 Projection Modeling
Inventories and Reasonable Progress Goal Inventory Demonstration for the
Regional Haze SIP, December 7, 2010.

Modeling to Support the LTS and Determine Visibility Improvement for
Uniform Rate of Progress

MANE-VU performed modeling for the regional haze LTS for the 11
Mid-Atlantic and Northeast states and the District of Columbia. The
modeling analysis is a complex technical evaluation that began with
selection of the modeling system.  MANE-VU used the following modeling
system:

Meteorological Model:  The Fifth-Generation Pennsylvania State
University/National Center for Atmospheric Research (NCAR) Mesoscale
Meteorological Model (MM5) version 3.6 is a nonhydrostatic, prognostic
meteorological model routinely used for urban- and regional- scale
photochemical, PM2.5, and regional haze regulatory modeling studies.

Emissions Model:  The Sparse Matrix Operator Kernel Emissions (SMOKE)
version 2.1 modeling system is an emissions modeling system that
generates hourly gridded speciated emission inputs of mobile, non-road
mobile, area, point, fire and biogenic emission sources for
photochemical grid models.

Air Quality Model:  The EPA’s Models-3/Community Multiscale Air
Quality (CMAQ) version 4.5.1 and REMSAD modeling system is a
photochemical grid model capable of addressing ozone, PM, visibility and
acid deposition at a regional scale.  

Air Quality Model:  The Regional Model for Aerosols and Deposition
(REMSAD), version 8 is a Eulerian grid model used for a source
apportionment analysis.

Air Quality Model: The California Puff Model (CALPUFF), version 5 is a
non-steady-state Lagrangian puff model used to access the contribution
of individual states’ emissions to sulfate levels at selected Class I
receptor sites.

The MANE-VU was tasked with the assignment of preparing a PM2.5 modeling
platform that all member states could use to model their LTSs to
demonstrate reasonable progress by 2018 in meeting the ultimate goal of
natural visibility conditions by 2064.  The New York State Department of
Environmental Conservation (NYSDEC) was the lead agency for coordinating
and running the modeling platform used by the MANE-VU RPO.  Modeling
centers responsible for running the platform included the NYSDEC, the
University of Maryland at College Park (UMD), the Northeast States for
Coordinated Air Use Management (NESCAUM), the New Jersey Department of
Environmental Protection (NJ DEP), and the Virginia Department of
Environmental Quality (VA DEQ).  Each modeling center was responsible
for installing the modeling platform, conducting diagnostic tests and
completing a benchmark run to ensure accurate results.  

                                                                        
                                                       

MANE-VU used the CMAQ version 4.5.1 as its photochemical grid model. 
The model uses simulations of chemical reactions, emission of PM2.5  
and PM2.5 precursors and a sophisticated meteorological model (The
Pennsylvania State University/National Center for Atmospheric Research
Mesoscale Meteorological Model) to produce speciated PM2.5
concentrations over the eastern United States.  The meteorological data
used in the meteorological model was for the 2002 base year.  The
photochemical grid model was run with the base year meteorology and base
year emissions to determine if the model performance was satisfactory. 
Once the model performance was determined to be adequate, PM 2.5
concentrations were modeled by running the model with projected
emissions for 2018 and the original 2002 meteorology. The meteorology
was held constant so that the results of changing the emissions would
not be influenced by changing meteorology.

Conceptual Description of the Problem

A conceptual model describes how weather patterns affect the formation
and transport of PM2.5, accounting for emissions and photochemistry.

 

New Jersey’s SIP includes, in Chapter 7, numerous methods that provide
information about how haze occurs in New Jersey and the sources of haze.
 The methods include emissions information (and the distance to
sources), trajectory analyses, and impacts predicted by dispersion and
various grid models.  Monitoring data is used to show that sulfates are
the predominate species that reduce visibility at the Brigantine Class I
area.  The various models support the hypothesis that many sources
across a wide range of states in the eastern United States contribute to
haze in New Jersey.  

Modeling Platforms

Two  regional-scale air quality models were evaluated and used by
NESCAUM to perform air quality simulations. These are the Community
Multi-scale Air Quality modeling system (CMAQ; Byun and Ching, 1999) and
the Regional Modeling System for Aerosols and Deposition (REMSAD; SAI,
2002). CMAQ was developed by EPA, while REMSAD was developed by ICF
Consulting/Systems Applications International (ICF/SAI) with EPA
support.  CMAQ has undergone extensive community development and peer
review (Amar et al., 2005) and has been successfully used in a number of
regional air quality studies (Bell and Ellis, 2003;

Hogrefe et al., 2004; Jimenez and Baldasano, 2004; Mao and Talbot, 2003;
Mebust et al., 2003). REMSAD has also has been peer reviewed (Seigneur
et al., 1999) and used by EPA for regulatory applications
(www.epa.gov/otaq/regs/hd2007/frm/r00028.pdf and 

 HYPERLINK "http://www.epa.gov/clearskies/air_quality_tech.html"
www.epa.gov/clearskies/air_quality_tech.html ) to study ambient
concentrations and deposition of sulfate and other PM species.

Five modeling centers, worked collectively to maximize efficiency of
computing resources in MANE-VU for SIP modeling.  These centers include
NY DEC, NJ DEP/Rutgers, VA DEQ, UMD, and NESCAUM.  

Use of Air Quality Models:  Contribution Assessment

The 1999 Regional Haze Rule requires State Implementation Plans to
include a “contribution assessment” to identify those states or
regions that may be influencing specially protected federal lands known
as Federal Class I areas. These states or regions would then be subject
to the consultation provisions of the Haze Rule. The Haze Rule also
requires a “pollution apportionment” analysis as part of the
long-term emissions management strategy for each site.

As described in the Conceptual Description portion of this TSD, sulfate
alone accounts for anywhere from one-half to two-thirds of total fine
particle mass on the 20 percent haziest days at MANE-VU Class I sites.
As a result of the dominant role of sulfate in the formation of regional
haze in the Northeast and Mid-Atlantic region, MANE-VU concluded that an
effective emissions management approach would rely heavily on
broad-based regional SO2 control efforts in the eastern United States.

Use of Air Quality Models:  Area of Influence for MANE-VU Class I Areas 

States with Class I areas calculate the baseline and natural visibility
for their Class I areas, and the determination of reasonable progress
goals. 

Class I States calculated baseline visibility conditions for the period
between 2002 and 2004. The average impairment for the most and least
impaired days were determined for each calendar year and compiled into
the average of three annual averages (40 CFR 51.308 (d)(2)(i)). The
natural visibility conditions were determined for the same baseline
period with the most and least impaired days determined by available
monitoring data or an appropriate data analysis technique (40 CFR 51.308
(d)(iii-iv)). 

There are seven Class I areas located in the Mid-Atlantic and Northeast,
of which Brigantine in New Jersey is one.  In order to identify states
whose emissions are most likely to influence visibility in MANE-VU Class
I areas, MANE-VU prepared the Contributions to Regional Haze in the
Northeast and Mid-Atlantic United States (Contribution Assessment). The
full report can be found in Appendix H-1 of the New Jersey Regional Haze
SIP. 

Based on that work, MANE-VU concluded that it was appropriate to define
an “Area of Influence” (AOI) including all of the states
participating in MANE-VU plus other states outside MANE-VU for which
modeling indicated they contributed at least two percent (2%) of the
sulfate ion in MANE-VU Class I areas in 2002. The Visibility Improvement
State and Tribal Association of the Southeast (VISTAS) also conducted an
AOI analysis, which used a level of one percent (1%) to assess whether
an upwind state significantly contributed. The VISTAS AOI did not show
New Jersey to be a contributor to any VISTAS Class I area. 

The primary contribution assessment tool used in the New Jersey Regional
Haze SIP was the Regional Modeling System for Aerosols and Deposition
(REMSAD) (SAI, 2002). A significant feature of the REMSAD work used to
evaluate regional contributions is that NESCAUM reprocessed the SO2
emission data from each state to take advantage of REMSAD’s tagging
capabilities. Thus, all SO2 emissions included in the model for the
eastern half of the country were tagged according to state of origin,
and emissions from Canada and the boundary conditions were also tagged.
This allowed for a rough estimation of the total contribution from
elevated point sources in each state to simulated sulfate concentrations
at eastern receptor sites. Using identical emission and meteorological
inputs to those prepared for the CMAQ SIP modeling platform, described
earlier in this TSD, REMSAD was used to simulate the annual average
impact of each state’s SO2 emission sources on the sulfate fraction of
PM2.5 over the northeastern United States.  A more in-depth description
of the REMSAD modeling used for contribution assessment can be found in
Appendix H-1 of New Jersey’s SIP.

The REMSAD contribution assessment modeling used by New Jersey’s
Regional Haze SIP conforms to EPA modeling requirements and is
acceptable to EPA.  

Use of Air Quality Models:  REMSAD Contribution Assessment Results

New Jersey determined that a number of states contributed to haze in the
Brigantine Class I area, and notified these states via the letters
included in Appendix I-1 of New Jersey’s plan.  Many states responded
(Appendix I-2).  New Jersey also contributes to haze in a number of
Class I areas in MANE-VU.  These impacts were determined using a variety
of methods as described below.  

MANE-VU States decided that any state or region that contributed at
least 2 percent of total sulfate observed on 20 percent worst visibility
days in 2002 is contributing significantly to the haze problem in that
particular Class I area.  With respect to sulfate, the Contribution
Assessment estimated emissions from within MANE-VU in 2002 were
responsible for about 25-30 percent of the sulfate at Class I areas
located within and nearby to the MANE-VU region. The contribution of
sulfate at these Class I areas from other regions, Canada, and outside
the modeling domain were also significant.  

Use of Air Quality Models:  CMAQ Modeling of Relative Contributions of
Pollutants to Visibility Impairment

An important step toward identifying reasonable progress measures is to
identify the key pollutants contributing to visibility impairment at
each Class I area.  To understand the relative benefit of further
reducing emissions from different pollutants, MANE-VU developed emission
sensitivity model runs using CMAQ to evaluate visibility and air quality
impacts from various groups of emissions and pollutant scenarios in the
Class I areas on the 20 percent worst visibility days.  

Regarding which pollutants are most significantly impacting visibility
in the MANE-VU region, MANE-VU’s contribution assessment, demonstrated
that sulfate is the major contributor to PM2.5 mass and visibility
impairment at Class I areas in the Northeast and Mid-Atlantic region. 
Sulfate particles commonly account for more than 50 percent of
particle-related light extinction at northeastern Class I areas on the
clearest days and for as much as or more than 80 percent on the haziest
days. In particular, for the Brigantine National Wildlife Refuge Class I
area, on the 20 percent worst visibility days in 2000 – 2004, sulfate
accounted for 66 percent of the particle extinction.  After sulfate,
organic carbon (OC) consistently accounts for the next largest fraction
of light extinction. Organic carbon accounted for 13 percent of light
extinction on the 20 percent worst visibility days for Brigantine,
followed by nitrate that accounts for 9 percent of light extinction.  

   

The emissions sensitivity analyses conducted by MANE-VU predict that
reductions in SO2 emissions from EGU and non-EGU industrial point
sources will result in the greatest improvements in visibility in the
Class I areas in the MANE-VU region, more than any other
visibility-impairing pollutant.  As a result of the dominant role of
sulfate in the formation of regional haze in the Northeast and
Mid-Atlantic region, MANE-VU concluded that an effective emissions
management approach would rely heavily on broad-based regional SO2
control efforts in the eastern United States.  

Use of CMAQ Modeling to Develop 2018 Control Case Predictions:

Meteorological Time Periods Used in the Modeling

All of 2002, which represents the baseline period from 2000 to 2004, was
included in CMAQ modeling.  2002 was divided into five periods. UMD is
responsible for modeling the period from January 1 to February 28; NJ
DEP/Rutgers are responsible for the period from March 1 to May 14; NY
DEC is responsible for the period from May 15 to September 30; VA DEQ is
responsible for the period from October 1 to October 31; and NESCAUM is
responsible for the period from November 1 to December 31. Each period
uses a 15 day spin up run to minimize the impact of the default initial
concentration fields. Each group performs CMAQ simulations on its period
for a series of scenarios including 2002 Base Case, 2009 Base Case, 2018
Base Case, 2009 Control Case, and 2018 Control Case. All scenarios adopt
the same meteorological field (2002) and boundary conditions, varying
only emission inputs. To ensure consistency between modeling groups, a
benchmark test was conducted by each group.

Meteorological Data Used in the CMAQ Air Quality Model

The MANE-VU states decided to use a prognostic meteorological model that
provides life-like meteorological inputs to the photochemical grid
model.  The Pennsylvania State University/National Center for
Atmospheric Research Mesoscale Meteorological Model version 3.6 was
chosen for the modeling analysis.  The MM5 model provides a reasonable
representation of weather conditions at the surface and aloft.  

Use of CMAQ Modeling to Develop 2018 Control Case Predictions:

Domain of the Model, Horizontal/Vertical Resolution and the Initial and
Boundary Conditions

MANE-VU adopted the Inter-RPO domain description for its modeling runs. 
This 36-km domain covers the continental United States, southern Canada
and northern Mexico. The dimensions of this domain are 145 and 102 cells
in the east-west and north-south directions, respectively. A 12-km inner
domain was selected to better characterize air quality in MANE-VU and
surrounding RPO regions. This domain covers the eastern region, which
includes the northeastern, central, and southeastern U.S., as well as
southeastern Canada. It extends from 66W - 94W in longitude and 29N -
50N in latitude with 172 × 172 grid cells.

                                                                        
                                                        

Vertical resolution is the number of layers and the size of each layer
in the model.  The layers in the photochemical grid model were set up to
be compatible with the model that produced weather conditions for the
photochemical grid model.  The vertical resolution used in the modeling
exercise followed EPA’s modeling guidance and therefore adequately
represents the atmosphere where PM2.5 is emitted, forms and is
transported.  

Baseline and Future Year Emission Inventories for CMAQ Modeling 

Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires the
States to identify the baseline emission inventory on which strategies
are based. The baseline inventory is intended to be used to assess
progress in making emission reductions. Based on EPA guidance entitled,
2002 Base Year Emission Inventory SIP Planning: 8-hour Ozone, PM 2.5,
and Regional Haze Programs, which identifies 2002 as the anticipated
baseline emission inventory year for regional haze, MANE-VU and New
Jersey are using 2002 as the baseline year. Future year inventories were
developed for the years 2009, 2012 and 2018 based on the 2002 base year.
These future year emission inventories include emissions growth due to
projected increases in economic activity as well as the emissions
reductions due to the implementation of control measures. 

The 2002 emissions were first generated by the individual states in the
MANE-VU area. MARAMA then coordinated and quality assured the 2002
inventory data. The 2002 emissions from non-MANE-VU areas within the
modeling domain were obtained from other Regional Planning Organizations
for their corresponding areas. These Regional Planning Organizations
included the Visibility Improvement State and Tribal Association of the
Southeast (VISTAS), the Midwest Regional Planning Organization and the
Central Regional Air Planning Association. 

Version 3 of the 2002 base year emission inventory was used in the
regional modeling exercise. Technical support documentation for the
MANE-VU 2002 base inventory is presented in Technical Support Document
for 2002 MANE-VU SIP Modeling Inventories, Version 3, which is Appendix
F-1 of the New Jersey SIP.  This document explains the data sources,
methods, and results for preparing this version of the 2002 base year
criteria air pollutant and ammonia emissions inventory. Documentation
for the future year estimations of EGUs is presented in Appendix F-2 of
the SIP – MARAMA’s Development of Emission Projections for 2009,
2012, and 2018 for Non-EGU Point, Area, and Nonroad Source in the
MANE-VU Region Final Report, February, 2007. 

The emission inventory submitted by New Jersey is evaluated in the
attached technical support document:  Review of New Jersey State-wide
2002 and 2018 Projection Modeling Inventories and Reasonable Progress
Goal Inventory Demonstration for the Regional Haze SIP, December 7,
2010.

CMAQ Model Performance Evaluation

The modeling is described in MANE-VU Modeling for Reasonable Progress
Goals, prepared by NESCAUM, listed as Appendix N-2 of New Jersey’s
SIP.  

NESCAUM evaluated the 2002 annual 12 km resolution meteorological fields
generated by MM5 using ENVIRON's METSTAT program. Model results of
surface wind speed, wind direction, temperature, and humidity were
paired with measurements from EPA’s Clean Air  Status and Trends
Network (CASTNET) and National Center for Atmospheric Research’s  
Techniques Data Laboratory (TDL) network by hour and by location and
then statistically compared. Based on this statistical comparison
between model prediction and data from the two networks for wind speed,
wind direction, temperature, and humidity, MM5 performs well. An
acceptable small bias, high index of agreement and strong correlation
with CASTNET and TDL data are shown. Since MM5 uses TDL data for
nudging, the model predictions are in better agreement with TDL data
than with CASTNET data. MM5 performs better in Midwest and Northeast
than Southeastern US.

 evaluation suggested by Boylan and Baker (2004) were adopted by every
RPO for SIP modeling. The performance goals are: Mean Fractional Error
(MFE) ≤ +50%, and Mean Fraction Bias (MFB) ≤ ±30%; while the
criteria are proposed as: MFE ≤ +75%, and MFB ≤ ±60%. CMAQ
prediction of PM2.5 species from 40 STN sites and 17 IMPROVE sites
within the MANE-VU Region were paired with measurements and
statistically analyzed to generate MFE and MFB values. Considering CMAQ
performance in terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and
PM2.5 all had the majority of data points within the goal curve, some
were between the goal and acceptable criteria, and only a few were
outside the criteria curve. Only fine soil has the majority of points
outside the criteria curve, but there were some sites still within the
goal. For the MANE-VU region, CMAQ performs best for PM2.5 sulfate,
followed by PM2.5, EC, nitrate, OC, and then fine soil. Regional haze
modeling also requires CMAQ performance evaluation for aerosol
extinction coefficient (Bext) and the haze index.  Modeled daily aerosol
extinction at each improve site was calculated following the IMPROVE
formula with modeled daily PM2.5 species concentration and relative
humidity factors from IMPROVE. The approach used natural background
visibility estimates and the haze index following EPA Guidance. The
modeled Bext showed a near 1:1 linear relationship (slope of 0.78 and r2
of 0.46) with IMPROVE observed Bext. The regression excluded three
points from July 7, 2002; the monitors were directly impacted by
Canadian fires whose emissions were not modeled. 

How to Calculate Uniform Rate of Progress Goals

The key difference between SIPs from States with Class I areas and those
States without Class I areas, but may have sources that impact
visibility on Class I areas, is the calculation of the baseline and
natural visibility for their Class I areas and the determination of
uniform rate of progress goals - expressed in deciviews - that provide
for reasonable progress towards achieving natural visibility by 2064. 
It is the Class I states’ responsibility to assess these calculations.
The Class I States must also consult with those States which may
reasonably be anticipated to cause or contribute to visibility
impairment in their Class I areas (40 CFR 51.308 (d)(1)(i-vi)). 

The baseline visibility conditions are calculated for the baseline
period between 2002 and 2004. The average impairment for the 20 most and
20 least impaired days are determined for each calendar year and
compiled into the average of three annual averages (40 CFR 51.308
(d)(2)(i)). The natural visibility conditions are determined for the
same baseline period with the most and least impaired days determined by
available monitoring data or an appropriate data analysis technique (40
CFR 51.308 (d)(iii-iv)). 

The calculations used to determine the natural conditions used as the
2064 visibility goal are described at the MANE-VU SIP Template document,
June 10, 2004:  NATURAL BACKGROUND VISIBILITY CONDITIONS CONSIDERATIONS
AND PROPOSED APPROACH TO THE CALCULATION OF NATURAL BACKGROUND
VISIBILITY CONDITIONS AT MANE-VU CLASS I AREAS, following EPA’s
guidance at: U.S. EPA (2003). Guidance for Estimating Natural Visibility
Conditions under the Regional Haze Rule. EPA-454/B-03-005. September
2003.

EPA released guidance on June 7, 2007 to use in setting reasonable
progress goals. The goals must provide improvement in visibility for the
most impaired days, and ensure no degradation in visibility for the
least impaired days over the SIP period. The following figure
illustrates an example of how Uniform Rate of Progress is calculated.  

                                                                       

Example Calculation of Uniform Rate of Progress

CMAQ Modeled Visibility Projections for 2018

The CMAQ air quality model was used to simulate base period emissions
and future emissions.  The modeling results for the base year period
(2002) and the year representing the end of the first planning period
(2018) are used to develop relative response factors (RRF) for each
component of particulate matter identified previously in this TSD.  The
relative response factors are multiplied by the measured species
concentration data during the base period (for the measured 20% best and
worst days). This results in daily future year species concentrations
data. The projected concentrations are then used to derive daily
visibility in deciviews and are averaged across all best and worst days
to create the projected future visibility. The results of this procedure
are plotted along with the uniform progress glide slope below, and in
Table 8.4 and Figure 8.1 in New Jersey’s SIP, taken from Figure 3-2,
and 4-1B in 2018 Visibility Projections, Appendix J-1 in New Jersey’s
SIP.

Reasonable Progress Goals and Projected Future Visibility for the
Brigantine Wilderness Area

	Baseline Visibility 

(2000-2004)	Natural Background Conditions for 2064	Reasonable Progress
Goal for 2018 	2018 CMAQ Projections 

20% Worst Days 	29.0 	12.2 	25.1 	25.1 

20% Best Days 	14.3 	5.5 	14.3 	12.2 



(All values expressed as deciviews – lower deciviews means better
visibility.) 

From:  2018 Visibility Projections (NESCAUM for MANE-VU States, May
2008), Appendix J-1 in New Jersey’s SIP.

By interpolating between the base year of 2004 and the natural
background year of 2064, the Progress Goal for 2018 is 25.1 deciviews,
3.9 deciviews lower than the 29.0 deciviews starting point.  State plans
must adopt all reasonable controls, with the objective of improving
visibility to equal to, or better than, the Progress Goal.  MANE-VU
modeled the effects of reducing emissions on air quality and visibility.
 Based on the emission controls agreed-to by the MANE-VU states,
visibility at the Brigantine Class I area is forecast to improve to 25.1
deciviews in 2018, meeting the Progress Goal.  New Jersey evaluated the
control measures agreed-to by the MANE-VU states and implemented all the
agreed-to measures and placed BART controls on its BART-eligible
sources.  Thus, New Jersey has met the test of Reasonable Progress by
adopting all reasonable measures, as well as meeting the 2018 progress
goal.  Since NJ’s BART sources were not included in the modeled
reductions and New Jersey achieved 90 percent or better control at its
CAIR-eligible sources, NJ is likely to have exceeded the modeled
reductions.  If other states implemented the MANE-VU measures, then
visibility in the Brigantine area is likely to exceed the progress goal
in 2018.

                                                                        
             

The modeling results presented in 2018 Visibility Projections, Appendix
J-1 in New Jersey’s SIP, show all MANE-VU sites are projected to meet
or exceed the uniform rate of progress goals for 2018 on the 20 percent
worst days. In addition, no site anticipates increases in visibility
impairment relative to the baseline on the 20 percent best days. 

Summary of Photochemical Grid Modeling Results

In summary, the photochemical grid modeling, documented in New
Jersey’s Regional Haze SIP, follows EPA’s modeling guidance and is
acceptable to EPA.  All MANE-VU sites impacted by New Jersey are
projected to meet or exceed the uniform rate of progress goal for 2018
on the 20 percent worst days. In addition, no site anticipates increases
visibility impairment relative to the baseline on the 20 percent best
days. 

Monitoring

In section 10.2.3 of its SIP, New Jersey commits to operate and maintain
the monitoring site at the Brigantine Wilderness Area for the
foreseeable future.  New Jersey contends that this commitment is
contingent upon continued Federal and State funding.  SIPs cannot place
obligations on EPA when the rules and guidance require states to be
responsible for continued assessment of visibility impairment.  At
present, visibility assessment is based on IMPROVE network monitoring at
the Class I area in Brigantine.  We acknowledge and appreciate New
Jersey’s support for monitoring at this location.  EPA agrees that
monitoring to assess visibility impairment will be included in the
annual network review process between EPA and New Jersey.  

RAVI

EPA requires that states take responsibility for assessing and
preventing visibility impairment reasonably attributable to a source or
group of sources.  This includes a commitment for New Jersey to insure
that new sources do not affect the achievement of reasonable progress
goals and continued coordination with the Federal Land Manager on issues
with reasonably attributable visibility impairment (RAVI).  

New Jersey, in section 10.2.1, commits to continue to review the impact
of new sources on visibility under its prevention of significant
deterioration program for all major new or modified sources in New
Jersey within 100km of the Brigantine Class I area, or further from
Brigantine on a case-by-case basis.   This commitment is affirmed in the
New Jersey’s recently modified new source review delegation agreement.
 

Public Hearing and Response to Comments and Consultation with Federal
Land Manager

In Appendix O of the New Jersey Regional Haze SIP, New Jersey addressed
the comments from the public, stakeholders, EPA and the Federal Land
Manager.

On May 10, 2006, the MANE-VU State Air Directors adopted the Inter-RPO
State/Tribal and FLM Consultation Framework that documented the
consultation process within the context of regional phase planning, and
was intended to create greater certainty and understanding among RPOs.  
MANE-VU states held ten consultation meetings and/or conference calls
from March 1, 2007 through March 21, 2008.  In addition to MANE-VU
members attending these meetings conference calls participants from
VISTAS, Midwest RPO and relevant Federal Land Managers were also in
attendance at many of these meetings and conference calls.  In addition
to the conference calls and meeting, the FLMs were given the opportunity
to review and comment on each of the technical documents developed by
MANE-VU.  

In addition to the conference calls and a meeting, the FLMs were given
the opportunity to review and comment on each of the technical documents
developed by MANE-VU and included as appendices in New Jersey’s SIP
submittal.  

New Jersey consulted with the FLMs in person at a meeting that EPA
Region 2 attended on October 20, 2009 during the development of the
Regional Haze SIP.  In addition, New Jersey submitted the draft plan for
review by the FLMs for the required ninety-day review period before New
Jersey submitted the SIP to EPA.  These actions fulfill EPA’s
requirements in 40 CFR 51.308(i).    

New Jersey held a public hearing on this proposed SIP revision on
October 27, 2008 at the New Jersey Department of Environmental
Protection Public Hearing Room, Trenton, New Jersey.  Written comments
relevant to the proposal were accepted through November 28, 2008.  The
only comments were submitted by USEPA, the Fish and Wildlife Service and
one of the potential BART sources.  New Jersey responded to the
comments, as listed in Appendix O-3 of New Jersey’s Regional Haze
Plan.  New Jersey commits in their SIP to ongoing consultation with the
FLMs on Regional Haze issues throughout the implementation of the SIP as
required in 40 CFR 51.308(i)(4).   

Periodic SIP Revisions and Five-Year Progress Reports 

Consistent with the requirements of 40 CFR 51.308(g), New Jersey
committed to submitting a report on reasonable progress (in the form of
a SIP revision) to the EPA every five years following the initial
submittal of its regional haze SIP.  The reasonable progress report will
evaluate the progress made towards the RPGs for the Brigantine National
Wildlife Refuge Class I area.  	

CONCLUSIONS AND RECOMMENDED AGENCY ACTION

New Jersey’s Regional Haze SIP establishes the reasonable progress
goal for the Brigantine Wilderness Area Class I area in New Jersey.  New
Jersey’s SIP adopts long-term strategies assuring reasonable progress
towards the national goal of achieving natural visibility conditions in
Class I areas affected by New Jersey.  The SIP includes all measures
necessary to obtain New Jersey’s share of emissions reductions needed
to meet the RPGs of the Brigantine Wildlife Refuge class I area.
Furthermore, the submittal meets the requirements for New Jersey’s
contribution toward meeting the reasonable progress goals for other
Class I areas in the northeastern United States.  This submittal also
meets the applicable visibility-related requirements of the CAA and EPA
regulations.  In order for EPA to give final approval to New Jersey’s
SIP, New Jersey needs to adopt its BART controls as described in its
plan as SIP submittals.   When that requirement is met, EPA can approve
New Jersey’s Regional Haze SIP, including its BART determinations.   

Attachment

  Review of Application of Best Available Retrofit Technology 

in New Jersey’s Regional Haze State Implementation Plan, July 29, 2011

BART 

Best Available Retrofit Technology (BART) is an element of New
Jersey’s Long Term Strategy (LTS).  The BART Regional Haze requirement
consists of three components:  (a) identification of all the BART
eligible sources; (b) an assessment of whether the BART eligible sources
are subject to BART; and (c) the determination of the BART controls.  

BART Eligible Sources 

The first component of a BART evaluation is to identify all the BART
eligible sources.  The BART eligible sources were identified utilizing
the criteria in the BART Guidelines (70 FR 39158-39161; July 6, 2005) as
follows:

Determine whether one or more emissions units at the facility fit within
one of the 26 categories listed in the BART Guidelines;

Determine whether the emission unit(s) was in existence on August 7,
1977 and begun operation after August 6, 1962;

Determine whether potential emissions of SO2, NOx, and PM10 from subject
units are 250 tons or more per year (tpy).

The BART Guidelines recommend addressing SO2, NOx, and PM10 as
visibility-impairment pollutants and leave it up to the discretion of
states to evaluate VOC or ammonia emissions.  Because of the lack of
tools available to estimate emissions and subsequently model VOC and
ammonia effects on visibility, and because New Jersey is aggressively
addressing VOCs through its ozone SIPs, New Jersey determined that SO2,
NOx and PM10/2.5 are the only reasonable contributing visibility
impairing pollutants to target under BART.  

New Jersey identified five facilities as BART eligible in their July
2009 RH SIP but New Jersey later determined in its March 2011 supplement
to the RH SIP that two of these facilities, namely Amerada Hess and
Sunoco Eagle Point, had potential emissions of  SO2, NOx, and PM10 below
the 250 tpy threshold and therefore were not BART eligible.  Of the
remaining three facilities that are BART eligible, one is an electric
generating facility and the other two are petroleum refineries, as
described in Table 1.  Electric generating units and petroleum
refineries fit within the 26 categories listed in the BART Guidelines. 
For additional details regarding New Jersey’s identification of
sources that are BART eligible, the reader is referred to pp 2-14 of New
Jersey’s technical support document (TSD) located in the electronic
docket for this rulemaking.  On March 2, 2011, New Jersey submitted the
TSD to EPA for approval as a supplement to the July 2009 RH SIP. 



	Table 1. New Jersey’s BART Eligible Facilities

Facility 	Pollutants	Facility

Category	Location (County)	Facility I.D.

PSEG – Hudson	SO2, NOx, PM	Electric Generating	Hudson	12202

Chevron	SO2, NOx, PM	Petroleum

Refinery	Middlesex	18058

Conoco Phillips	SO2, NOx, PM	Petroleum 

Refinery	Union	41805

Amerada Hess	SO2, NOx	Petroleum 

Refinery	Middlesex	17996

Sunoco Eagle Point	SO2, NOx, PM	Petroleum 

Refinery	Gloucester	55781



Additional BART Eligible Sources

During EPA’s review of New Jersey’s RH SIP, EPA discovered two other
facilities in New Jersey that might be BART eligible, Vineland Municipal
Electric Utility and BL England Generating Station.  These facilities
had planned to shut down several years ago, but later each facility
withdrew their request.  New Jersey has updated its technical support
document to determine BART for the two facilities.  EPA evaluates New
Jersey’s BART determinations later in this document, following our
review of the initial five BART eligible facilities.       

BART Subject Sources

The second component of the BART evaluation is to identify those BART
eligible sources that may reasonably be anticipated to cause or
contribute to visibility impairment at any Class I area are subject to
BART.  As discussed in the BART Guidelines, a state may choose to
consider all BART eligible sources to be subject to BART. (70 FR 39161) 
Consistent with the MANE-VU Board’s decision in June 2004 that because
of the collective importance of BART sources BART determination should
be made by the MANE-VU states for each BART eligible source.  New Jersey
identified each of its BART eligible sources as subject to BART, except,
as explained in the previous paragraph, for Amerada Hess and Sunoco
Eagle Point.    

Determination of BART

The final component of a BART evaluation is making BART determinations
for all BART subject sources.  In making BART determinations, section
169A(g)(2) of the CAA requires that States consider the following five
factors: (1) the costs of compliance; (2) the energy and non-air quality
environmental impacts of compliance; (3) any existing pollution control
technology in use at the source; (4) the remaining useful life of the
source; and (5) the degree of improvement in visibility which may
reasonably be anticipated to result from the use of such technology.  
Section 51.308(e)(2) of the Regional Haze Rule provides that a State may
opt to implement an emissions trading program or other alternative
measure rather than to require sources subject to BART to install,
operate, and maintain BART.  To do so, the State must demonstrate that
the emissions trading program or other alternative measure will achieve
greater reasonable progress than would be achieved through the
installation and operation of BART.  New Jersey did not opt to implement
any alternative measures or programs to BART.

The following section reviews New Jersey’s BART determinations for the
remaining three BART eligible facilities identified in Table 1 above and
EPA’s evaluation of each determination. 

PSEG-Hudson Generating Station

New Jersey identified four units that are subject to BART at the PSEG
facility located in Hudson County.  The four units include two boilers
(E1 and E2) serving electric generating units (EGUs) and two coal
handling systems (E22 and E23) that support the coal fired boiler (E2). 
The following summarizes New Jersey’s determination of BART for each
of the four units and EPA’s evaluation.  For additional details
concerning New Jersey’s BART determination, the reader is referred to
pp 29-38 of New Jersey’s March 2011 TSD located in EPA’s electronic
docket for this rulemaking.  In addition, the reader is referred to
PSEG’s preliminary BART control plan, submitted to New Jersey on July
15, 2009, located in Appendix G8 of the State’s July 2009 RH SIP.  New
Jersey approved the Significant Modifications to PSEG’s title V permit
for BART on March 8, 2011.  

Boiler Unit 1 (E1)

This unit is a cyclone boiler generating electricity having a rating of
420 MWe and fires natural gas (only natural gas since 2005) but is also
permitted to combust No. 6 Fuel Oil.  Pre-BART control measures do not
include any combustion technology or add-on controls for limiting
emissions of NOx, SO2 or PM, however the use of either natural gas or
low sulfur fuel oil limits emissions of SO2 and PM.  Unit 1 is primarily
a standby unit and the area dispatcher (PJM Interconnection) requested
PSEG to operate this unit on an as needed basis to provide system
reliability through at least 2012, and perhaps longer, otherwise PSEG
would have retired this unit around 2005.  The following summarizes New
Jersey’s BART determinations for NOx, SO2 and PM for this unit.  

NOx

New Jersey evaluated eight control measures as BART for control of NOx
emissions and determined that SCR (or an equivalent control measure),
although not cost effective, would be required to meet an emission limit
of 1.00 pound per megawatt hour (lb/MWh) [equivalent to about 0.10
pounds per million BTU heat input (lb/MMBTU)], as measured on a 24-hr
average, when combusting natural gas by May 1, 2015, pursuant to the New
Jersey Administrative Code, Title 7, Chapter 27, Subchapter 19 (N.J.A.C.
7:27-19).  When Unit 1 combusts No. 6 Fuel Oil, Subchapter 19 requires
compliance with an emission limit of 2.00 lb/MWh (equivalent to about
0.20 lb/MMBTU), as measured on a 24-hr average, by May 1, 2015.  The
aforementioned emission limits and compliance date for gas and oil
firing to meet Subchapter 19 requirements are also New Jersey’s
requirements for Unit 1’s implementation of BART.  In addition to
requiring the installation of SCR (or equivalent), for meeting BART, New
Jersey is requiring PSEG to combust only natural gas in the boiler
unless there is a gas curtailment in which case No. 6 Fuel Oil may be
combusted.  Table 23 on p34 of New Jersey’s March 2011 TSD summarizes
the NOx control measures evaluated for BART and the cost effectiveness
of each.  

SO2

New Jersey determined that the combustion of natural gas and the
restricted use of No. 6 Fuel Oil is BART for controlling emissions of
SO2 from Unit 1.  The BART requirement to combust fuel oil only during
periods of gas curtailment is effective upon New Jersey’s approval of
the permit modification (i.e., March 8, 2011) but no later than December
31, 2011.  In addition, New Jersey restricts the sulfur content of No. 6
Fuel Oil to 0.30% (equivalent to approximately 0.33 lb SO2/MMBTU) by
weight which will further limit emissions of SO2 from Unit 1.  The
unit’s predominant use of natural gas and its low capacity factor
minimize emissions of SO2 (and PM).  SO2 emission limits when combusting
natural gas and No. 6 Fuel Oil are summarized in Table 25 (p 37) of New
Jersey’s TSD. 

PM10

New Jersey determined that the combustion of natural gas and the
restricted use of No. 6 Fuel Oil is BART for controlling emissions of
PM10 from Unit 1.  The combustion of natural gas is inherently low in PM
emissions and the restricted use of low sulfur fuel oil also limits PM
emissions. The State’s BART PM emission limits when combusting natural
gas and No. 6 Fuel Oil are summarized in Table 25 (p 37) of New
Jersey’s TSD.   

Boiler Unit 2 (E2)

(≤ 0.25%) coal to control SO2 emissions; and, optimization of an
existing electrostatic precipitator (ESP) to control PM emissions.  In
July 2002, a Federal consent decree (CD) required PSEG to install
state-of-the-art (SOTA) controls for NOx, SO2 and PM on all coal-fired
boilers in the State of New Jersey, including the PSEG-Hudson facility. 
An amended CD extended the compliance date to December 31, 2010.  The CD
is the basis for New Jersey’s BART determination for reducing
emissions of NOx, SO2 and PM from this unit.   

NOx    

 As a result of the July 2002 CD, PSEG is required to install selective
catalytic reduction (SCR) control technology using ammonia to reduce NOx
emissions.  This is in addition to the existing pre-BART low NOx burner
(LNB) controls installed in 2008.  When combusting coal, Unit 2 must be
in compliance, by December 31, 2010, with an emission limit of 0.15 lb
NOx /MMBTU, measured on a 24-hr average, and 0.10 lb NOx/MMBTU, as
measured on a 30-day average.  New Jersey reports that initial CEMS
results for the first few months of operation have been approximately
0.09 lbs NOx /MMBTU on a 24-hr average.  This compares to EPA’s
“presumptive” level of 0.39 lb/MMBTU (see Table 1 of EPA’s
Appendix Y BART Guidelines) for the same type boiler as Unit 2
(dry-bottom wall-fired unit that combusts bituminous coal).  Therefore,
initial operating results indicate that the BART controls for limiting
NOx emissions are better than EPA’s presumptive level.   

SO2

≤ 2.00%.  When combusting coal, Unit 2 must be in compliance, by
December 31, 2010, with an emission limit of 0.25 lb SO2/MMBTU, measured
on a 24-hr average, and 0.15 lb/MMBTU, as measured on a 30-day average. 
New Jersey indicates that initial CEMS results for the first few months
of operation have been about 0.132 lb SO2/MMBTU on a 24-hr average. 
PSEG indicates that initial results indicate SO2 reductions of
approximately 92%.  EPA’s “presumptive” level for an EGU greater
than 200 MW that is uncontrolled and located at a 750 MW power plant, is
an SO2 emission limit of either 0.15 lb/MMBTU or 95% reduction. 
Therefore, initial operating results indicate that the BART controls for
reducing SO2 emissions are slightly better than EPA’s presumptive
level.   

PM

As a result of the July 2002 CD, PSEG is required to reduce PM emissions
by installing a baghouse.  This baghouse is installed in conjunction
with the installation of the spray dryer absorber for controlling
emissions of SO2.  An existing electrostatic precipitator removes fly
ash upstream of the spray dryer absorber/baghouse combination. When
combusting coal, Unit 2 must be in compliance, by December 31, 2010,
with a BART emission limit of 0.015 lb PM/MMBTU.  PM emission limits for
BART when combusting natural gas and No. 6 Fuel Oil are summarized in
Table 25 (p 38) of New Jersey’s TSD.   

Coal Handling System (E22 and E23)

The coal receiving system (E22) and the coal reclaim system (E23) are
support systems for the Unit 2 (E2) coal fired boiler.  The Coal
Handling System does not have any emissions of NOx or SO2 but does emit
PM when there are wind conditions at the facility.  Since the potential
to emit PM is low (2.7 tpy for E22 and 1.2 tpy for E23), New Jersey has
determined that BART for the Coal Handling System is the continued use
of PSEG’s existing controls including a water dust suppression system
and covers on the conveying systems to minimize PM emissions.  PM
emission limits for BART are the existing title V permit conditions as
summarized in Table 25 (p 38) of New Jersey’s TSD.    

EPA’s Evaluation of New Jersey’s BART Determination for PSEG

EPA agrees with New Jersey’s determinations for establishing BART
requirements on the four units subject to BART at the PSEG-Hudson
facility.  New Jersey did not conduct a 5-factor analysis for
determining BART for any of the units subject to BART since maximum
control technology or control measures have already been implemented as
BART on the two boilers and the PM emissions from the Coal Handling
Systems have very low potential to emits (PTEs) and have adequate
existing PM control systems.  Since EPA guidance does not require a
5-factor analysis whenever maximum controls are determined to be BART,
EPA agrees with New Jersey’s BART determinations.  New Jersey has
included the BART requirements in final title V permits and the
State’s SIP supplement will includes a summary of BART compliance
requirements for monitoring, reporting and recordkeeping.  New Jersey
plans to submit this SIP supplement during November 2011.  Since New
Jersey has established BART requirements, including enforceable permit
limits, in accordance with EPA guidance EPA recommends proposed approval
of New Jersey’s BART determination for the PSEG-Hudson Station.  

Chevron Products Co. – Perth Amboy

New Jersey identified two units that are subject to BART at the Chevron
petroleum refinery located in the city of Perth Amboy, Middlesex County.
 The two units are both fuel gas-fired furnaces (E1501 and E1502), also
referred to as process heaters, serving the petroleum refinery.  The
following summarizes New Jersey’s determination of BART for the two
units and EPA’s evaluation.  For additional details concerning New
Jersey’s BART determination, the reader is referred to pp 8-10 and
17-18 of New Jersey’s March 2011 TSD located in EPA’s electronic
docket for this rulemaking.  New Jersey approved the Significant
Modifications to PSEG’s title V permit for BART on March 4, 2011.

Gas-Fired Furnaces (E1501 and E1502)

For the two BART-subject units, the pre-BART PTEs are as follows: 40.5
tpy SO2, 262.2 tpy NOx, and 32.7 tpy PM.  In addition, the annual
emissions for these two units have been low (see p 17 of New Jersey’s
TSD).  From 2005-2008, the estimated annual emissions as a percentage of
PTE for these two units are as follows: 55%-10.5% (35% average) for
E1501; and 16.8%-2.5% (11.7% average) for E1502.  In 2009, both units
did not operate at all.  Chevron submitted its BART proposal to New
Jersey in March 2009 (see Appendix G8 of New Jersey’s July 2009 RH SIP
revision) but subsequently decided to ”cap-out” the emissions of NOx
to below the BART-eligible threshold of 250 tpy.  Thus, each visibility
impairing pollutant (SO2, NOx and PM) from the two furnaces were
scheduled to be below the BART-eligible PTE threshold of 250 tpy by the
effective compliance date of March 4, 2011.  Since the modification to
the title V permit allowed the facility to avoid becoming subject to a
Federal rule, it was considered a “significant” modification and was
subject to public notice and a 30-day comment period.  New Jersey
reports that no comments were received during this 30-day comment
period.  The title V permit requires Chevron to limit heat input to each
furnace and to monitor and report annual emissions to limit the PTE of
each pollutant to below 250 tpy.  New Jersey requires Chevron to report
the amount of fuel burned and actual emission rates in accordance with
its Emissions Statements program adopted by the State at Subchapter 21
(N.J.A.C. 7:27-21).        

EPA’s Evaluation of New Jersey’s BART Determination for Chevron

EPA agrees with New Jersey’s BART determination for the two
BART-eligible units at the Chevron facility located in the city of Perth
Amboy.  Chevron has proposed and New Jersey has approved limiting the
PTE of each visibility impairing pollutant from units E1501 and E1502 to
below 250 tpy thereby satisfying BART requirements.  Since the two units
at Chevron have approved and effective title V permits that will result
in limiting the emissions of each visibility impairing pollutants to
less than 250 tpy, the two units no longer meet the criteria for
establishing a unit as being BART eligibility.  Therefore the two units
are not subject to BART and are not required to implement any BART
requirements to further limit emissions of visibility impairing
pollutants.  It should be noted that should Chevron request to operate
the two units such that the cumulative PTE of the two units equals or
exceeds 250 tpy, then E1501 and E1502 shall be subject to BART and the
facility’s title V permit would need to be revised to include new
applicable requirements.  New Jersey’s BART analysis and determination
meets the criteria in EPA’s BART Guidelines (70 FR 39158-39161; July
6, 2005) and is therefore acceptable to EPA.  New Jersey has included
the BART requirements in final title V permits which will be submitted
to EPA in a November 2011 SIP supplement along with a summary of BART
compliance requirements for monitoring, reporting and recordkeeping. 
Since New Jersey has established BART requirements, including
enforceable permit limits, in accordance with EPA guidance and the CAA,
EPA recommends proposed approval of New Jersey’s BART determination
for the two process heaters located at the Chevron facility in the city
of Perth Amboy.  

ConocoPhillips Bayway Refinery

New Jersey identified eleven units that are subject to BART at the
ConocoPhillips (CP) petroleum refinery located in the city of Linden,
Union County.  The eleven units are all refinery fuel gas-fired process
heaters.  The list of process heaters, as well as equipment
descriptions,  determined by the State to be subject to BART are listed
in Table 16 on p 26 of New Jersey’s TSD.  For additional details
concerning New Jersey’s BART determination, the reader is referred to
pp 10-13 and 19-29 of the State’s March 2011 TSD located in EPA’s
electronic docket for this rulemaking.  In addition, the reader is
referred to CP’s proposal for BART submitted to New Jersey and located
in Appendix G8 of the State’s July 2009 RH SIP.  

It should also be noted that, on January 27, 2005, the US Department of
Justice (DOJ), EPA and New Jersey Department of Environmental Protection
(NJDEP) entered into a national enforceable consent decree (CD) with CP,
including its Bayway refinery.  The CD identifies “boilers and
heaters,” as well as other equipment categories, as affected units
requiring reductions in NOx and SO2, precursors of fine PM.  The eleven
process heaters subject to BART are also subject to the requirements of
the CD.  On January 27, 2005, CP discontinued the use of fuel oil
combustion in the eleven process heaters.  In addition, the CD obliges
CP to upgrade the refinery fuel gas system by December 31, 2010 and to
comply with the hydrogen sulfide (H2S) requirements of the NSPS for
petroleum refineries (40 CFR Part 60,Subpart J) by June 30, 2011. 
Absorbers are used as control technology to reduce H2S emissions from
the refinery fuel gas.  Combustion of H2S in the process heaters results
in the formation of SO2 emissions.  The NSPS Subpart J requires that the
H2S concentration of refinery fuel gas to be combusted in process
heaters is to be less than 0.10 grains/dry standard cubic feet (gr/dscf)
which is equivalent to 162 parts per million dry (ppmd).  The SO2
emission concentration resulting from the combustion of refinery fuel
gas containing 162 ppmd H2S would also be 162 ppmd.    

CP submitted an application for Significant Modifications to its title V
permit for the eleven units subject to BART and New Jersey has provided
for a 30-day public comment period that ends on July 30, 2011.  New
Jersey is expected to approve and submit those elements of the title V
permits to EPA, as a supplement to the July 2009 RH SIP, in November
2011.  The following summarizes New Jersey’s determination of BART for
the eleven units and EPA’s evaluation.

NOx

New Jersey considered seven control measures as potentially BART
applicable for control of NOx emissions and determined that ultra low
NOx burners (ULNB) with internal flue gas recirculation (FGR), the
control measure currently being implemented on each of the eleven
process heaters, is BART.  For details, the reader is referred to Table
7 on p 16 of New Jersey’s  TSD and to CP’s analysis found in
Appendix G8 of the State’s July 2009 RH SIP.  New Jersey determined
that SCR was not cost effective and that SNCR was not feasible due to
temperature variations in the process heaters.  In addition, process
heaters combusting refinery fuel gas with a heat input of 50 million BTU
or greater, are subject to the State’s NOx regulation at N.J.A.C.
7:27-19.7(h) requiring NOx emissions of 0.20 lb/MM BTU.  Also, New
Jersey’s State of the Art (SOTA) Manual for Petroleum Refineries
requires process heaters with replacement burners to meet a NOx
performance emission limit of not more than 0.07 lb/MM BTU.  New Jersey
reports that the process heaters at CP’s Bayway refinery have a
measured average overall NOx emission rate of approximately 0.04 lb/MM
BTU (see p 20 of New Jersey’s TSD).  New Jersey has established BART
NOx emission limits, expressed in pounds per hour for any 60-minute
period, for the eleven process heaters and are summarized in Table 16 on
p 26 of the State’s TSD.  The BART requirements for the process
heaters are already included in CP’s title V permit.

SO2

New Jersey considered three control measures as potentially BART
applicable for control of SO2 emissions and determined that CP’s
compliance with the January 2005 CD is BART.  The CD requires upgrading
the existing gas system to comply with the NSPS Subpart J that requires
limiting the H2S concentration in the refinery fuel gas combusted in the
process heaters to less than 0.10 gr/dscf (162 ppmd).  For details, the
reader is referred to Table 7 on p 16 of New Jersey’s TSD and to
CP’s analysis found in Appendix G8 of the State’s July 2009 RH SIP. 
In its BART analysis, New Jersey determined that scrubbers were not
technically feasible and fuel processing was not practically applicable
to individual process heaters.  As indicated above, CP is obligated by
the CD to upgrade the fuel gas system (that provides fuel to the process
heaters) to comply with the NSPS Subpart J that requires reducing the
H2S concentration to not more than 162 ppmd.  Section 60.104 of Subpart
J provides the standards for SO2 emissions at petroleum refineries. 
Subpart J also requires continuous monitoring of the H2S concentration
and the State is requiring H2S concentration measurements on a 3-hour
rolling average.  CP’s current title V permit already requires
monitoring the H2S concentration of the refinery fuel gas.  

New Jersey estimates that when CP’s refinery fuel gas system is fully
upgraded, the SO2 emissions from the process heaters will be
approximately 0.033 lb/MM BTU (see Table 15 on p 25 of New Jersey’s
TSD).  EPA’s RH guidance does not have any presumptive limits for
petroleum refineries but, for comparative purposes, EPA’s presumptive
SO2 limit for a large (200 MW at a 750 MW facility) uncontrolled
coal-fired EGU is either 95% removal or 0.15 lb/MM BTU.  EPA’s
presumptive limit for oil-fired boilers is that the sulfur content
should be limited to 1% (equivalent to about 1.0 lb/MM BTU) or less. 
Therefore, CP’s SO2 emission limit of 0.033 lb/MM BTU compares very
favorably to EPA’s presumptive limits for oil and coal fired boilers. 
 

For BART, New Jersey has established SO2 emission limits, expressed in
pounds per hour for any 60-minute period, and H2S emission limits in the
refinery fuel gas, expressed as ppmd for a three hour rolling average,
for the eleven process heaters, as summarized in Table 16 on p 26 of the
State’s TSD.  New Jersey is requiring CP to be in full compliance with
Subpart J requirements by June 30, 2011.  One of the process heaters
(E258), the largest of the 11 BART subject heaters, was already in
compliance with Subpart J.  As stated earlier, New Jersey is expected to
approve and submit the BART elements of the title V permits to EPA, as a
supplement to the July 2009 RH SIP, in November 2011.   

PM

New Jersey considered three control measures as potentially BART
applicable for control of PM emissions and determined that the continued
requirement of “good combustion practices” and the upgrade to the
refinery fuel gas system represents BART for the eleven process heaters.
 For details, the reader is referred to Table 7 on p 16 of New
Jersey’s TSD and to CP’s analysis found in Appendix G8 of the
State’s July 2009 RH SIP.  New Jersey determined that implementation
of either wet scrubbers or ESPs were not technically feasible with
refinery fuel gas that already has low sulfur concentrations.  In
addition, New Jersey’s NOx regulation, Subchapter 19, requires annual
adjustment of the process heaters in accordance with manufacture’s
recommended procedure and maintenance schedule to ensure complete
combustion through “good combustion practices.” Annual adjustment to
the combustion practice is expected to limit NOx and also PM emissions. 
Furthermore, the upgrade to the refinery fuel gas system will lower SO2
emissions, a precursor of fine PM, from the process heaters.  New Jersey
expects PM emissions to be in the approximate range of 0.01 to 0.02
lb/MM BTU (see Table 16 on p 26 of New Jersey’s TSD).  EPA does not
have any BART presumptive limits for PM.         

New Jersey has established BART PM emission limits, expressed in pounds
per hour, for the eleven process heaters and are summarized in Table 16
on p 26 of the State’s TSD.  As stated above, New Jersey is expected
to approve and submit the BART elements of the title V permits to EPA,
as a supplement to the July 2009 RH SIP, in November 2011.

EPA’s Evaluation of New Jersey’s BART Determination for
ConocoPhillips

EPA agrees with New Jersey’s determinations for establishing BART
requirements on the eleven process heaters subject to BART at the
ConocoPhillips Bayway Refinery.  Since the State determined that the
existing control measures are BART, New Jersey conducted a limited
rather than a full 5-factor analysis for determining BART.  In its
analysis, New Jersey examined applicable control technologies and
established that SCR technology was not cost effective for controlling
NOx emissions.  For SO2 and PM, New Jersey determined that that the
evaluated control technologies were not practically feasible.  In its
March 2011 TSD, and as noted above, New Jersey also established that
either the actual or permitted emission limits are as follows: NOx (0.04
lb/MM BTU measured average; and approximately 0.09 lb/MM BTU permit),
SO2 (0.033 lb/MM BTU equivalent permitted) and PM (0.01-0.02 lb/MM BTU
permit).  EPA considers that these emissions are equivalent to or better
than what could be achieved on a coal fired boiler using maximum
controls, i.e. SCR, scrubber and a baghouse (see discussion above for
the PSEG Hudson Unit 2 that has the SCR, scrubber and baghouse
configuration that EPA considers as  maximum controls).  EPA is in
agreement with New Jersey’s limited evaluation for determining BART
for the eleven process heaters at CP for the following reasons: (1)
emission levels of the three visibility impairing pollutants at CP are
low and equivalent to emissions levels at coal-fired EGUs that implement
maximum control technology; and (2) in accordance with EPA guidance, a
state is not required to include a five factor analysis for a BART
source that implements maximum controls; and (3)  New Jersey evaluated
alternative control technologies that were determined to be not
feasible.  

New Jersey will be including the BART requirements in a SIP supplement
including final title V permits and a summary of BART compliance
requirements for monitoring, reporting and recordkeeping.  New Jersey
plans to submit this SIP supplement during November 2011.  Since New
Jersey has establishing BART requirements and is including these
requirements in enforceable permits, in accordance with EPA guidance,
EPA recommends proposed approval of New Jersey’s BART determination
for the ConocoPhillips Bayway Refinery.   

Determination of BART – Additional BART Eligible Facilities in New
Jersey

During EPA’s review of New Jersey’s July 2009 and March 2011 RH SIP,
EPA discovered that two other facilities within the State had units that
were BART eligible. These two facilities were not originally identified
by New Jersey as BART eligible since the facilities indicated they
planned to shut down but later withdrew this request.  EPA has worked
closely with New Jersey in determining BART for these two facilities. 
As a result, in a letter dated July 25, 2011 from the State addressed to
EPA, New Jersey provides an addendum to its March 2011 TSD that
discusses its BART determination for the two additional facilities that
are BART eligible.  For additional details, the reader is referred to
New Jersey’s July 2011 letter to EPA that is located in the electronic
docket for this rulemaking.  In the July 2011 letter, New Jersey has
indicated that its BART determination, as summarized in a new addendum
to the March 2011 TSD, will be submitted to EPA in November for approval
as a supplement to the State’s July 2009 RH SIP, after the opportunity
for public comment.  

Following is New Jersey’s determination of BART for the two
facilities, Vineland Municipal Electric Utility and BL England
Generating Station, as indicated in New Jersey’s July 2011 letter to
EPA, as well as EPA’s evaluation of New Jersey’s BART determination.
    

Vineland Municipal Electric Utility

The first BART eligible source, Unit 10 at Vineland Municipal Electric
Utility’s Howard M. Down Station is under a Federal consent decree to
either install additional pollution control measures or to permanently
shut down by September 1, 2012.  On July 1, 2011, Vineland’s Director
submitted written certification to EPA and New Jersey that Unit 10 will
be retired from service by September 1, 2012.  Vineland is required to
submit a permit application by July 30, 2011 and New Jersey plans to
submit this element of the permit to EPA as a supplement to the RH SIP
by November 2011.  It should be noted that after Unit 10 is permanently
shut down, the facility, in accordance with EPA’s Guidelines, will no
longer be BART eligible since the PTE of each visibility impairing
pollutant will be less than 250 tpy.  An additional BART eligible unit
at this facility is a distillate fuel oil-fired emergency generator,
rated at 2.3 MM BTU/hr, that has not operated for more than 10 years. 
Since this emergency generator is small and rarely used, New Jersey and
EPA consider the current operation as BART and therefore does not need
to implement additional controls.  New Jersey requires that the facility
maintain records of emergency use and report any annual emissions. 
Furthermore, as previously stated, once Unit 10 is permanently shut
down, the facility, including the emergency generator, will no longer be
BART eligible.  EPA is in agreement with New Jersey’s BART
determination for the two units at Vineland because it conforms to
EPA’s BART Guidelines.  Therefore, EPA proposes approval of New
Jersey’s BART determination for Vineland.     

BL England Generating Facility

The second BART eligible facility is the BL England Generating Station,
located in Cape May County, owned/operated by RC Cape May Holding.  This
facility has three electric generating units that are BART eligible -
Units 1, 2 and 3 - as well as three miscellaneous units including a coal
handling system that supports Units 1 and 2; a cooling tower that
supports Unit 3; and an emergency fire water diesel engine.  Units 1 and
2 are currently under an administrative compliance order (ACO), as
amended in January 2010, with New Jersey to either repower or meet
performance requirements for NOx, SO2 and PM.  The ACO requirements for
Units 1 and 2 are already included in the title V permit.  New Jersey
has determined that the required future controls on Units 1 and 2, both
coal-fired boilers, and the current and future controls on Unit 3, an
oil-fired boiler, are BART.  New Jersey defines “repowering” to mean
the replacement of an existing coal-fired boiler with a new heat source
(e.g., natural gas or distillate oil) or new coal-combustion technology
(e.g., circulating fluidized bed boilers or integrated gasification
combined-cycle (IGCC) technology.  RC Cape May Holding has indicated to
New Jersey that it is evaluating the conversion of Units 1, 2 and 3 to
either natural gas or No. 2 fuel oil.  It should be noted that the
State’s Sulfur in Fuel Oil regulation, Subchapter 9, limits the sulfur
content of No. 2 Fuel Oil to not more than 0.015% effective July 1,
2016.  To the extent that RC Cap May decides to convert one or all of
the units, New Jersey anticipates that RC Cape May would submit a
specific proposal that addresses applicable requirements including BART.
 For the reasons stated in the discussion below, EPA is proposing
approval of New Jersey’s BART determination for the BL England
facility. 

Following are additional details for each unit.      

Unit 1

Unit 1 is a 129 MW cyclone wet bottom coal fired boiler and permitted to
combust up to 8% tire derive fuel (TDF) or No. 6 Fuel Oil.  Under the
amended ACO, this unit must either repower by December 15, 2011 or meet
performance standards by December 15, 2013.  The new performance
standards are as follows:  (1) for NOx, the existing SNCR will be
replaced with SCR and the existing over fire air (OFA) control system
will remain - to lower NOx emissions from 0.60 lb/MM BTU (seasonal) to
0.11 lb/MM BTU on a 30-day average and 0.15 lb/MM BTU on a 24-hr
average; (2) for SO2, install a circulating dry scrubber to meet an
emission limit of 0.15 on a 30-day rolling average and 0.25 lb/MM BTU on
a 24-hr average; for PM, upgrade the electrostatic precipitator, and
meet an emission limit of 0.03 lb/MM BTU.  As a result, New Jersey’s
TSD indicates that NOx emissions will be reduced by about 85% and SO2
emissions will be reduced by about 97% (see Table 9A in New Jersey’s
TSD).  EPA considers that, by December 15, 2013, Unit 1 will be
implementing maximum control measures for limiting emissions of NOx, SO2
and PM that meet EPA’s BART guidance and therefore EPA agrees with New
Jersey’s determination.  If the owners decide to repower, New Jersey
requires the owners to incorporate advances in the art of air pollution
control and EPA expects that emissions will be at least equal to or
lower than the performance standards indicated above.  

It should be noted that RC Cape May, the owner/operator, has indicated
to New Jersey that there is some uncertainty as to the start-up date of
Unit1 and therefore they believe that this Unit may possibly not be BART
eligible.  However, New Jersey has indicated that until RC Cape May can
provide proper documentation as to the start-up date, Unit 1 will be
considered BART eligible.  

Unit 2

Unit 2 is a 160 MW cyclone wet bottom coal-fired boiler and permitted to
combust up to 8% TDF or No. 6 Fuel Oil.  In accordance with the amended
ACO, Unit 2 must repower by December 15, 2011 or meet performance
standards for SO2 and PM by May 1, 2010, and NOx performance standards
by May 1, 2012. The required performance standards are as follows: (1)
for NOx, upgrade the current controls (selective non-catalytic reduction
(SNCR) by installing selective catalytic reduction (SCR) and continue to
implement the existing over fire air (OFA) controls to achieve an
emission limit of 0.11 lb/MM BTU on a 30-day rolling average and 0.15
lb/MM BTU on a 24-hr average; (2) for SO2, continue utilizing
(compliance as of May 1, 2010) wet flue gas desulfurization (FGD)
controls for limiting emissions to 0.15 lb/MM BTU on a 30-day rolling
average and 0.25 on a 24-hr average; (3) for PM, continue (compliance as
of May 1, 2010) the use of an electrostatic precipitator (ESP) for
controlling emissions to 0.030 lb/MM BTU on a 3-hr average.  EPA
considers that, by May 1, 2012, Unit 2 will be implementing maximum
control measures for limiting emissions of NOx, SO2 and PM that meet
EPA’s BART guidance and therefore EPA agrees with New Jersey’s BART
determination.  If the owners decide to repower, New Jersey requires the
owners to incorporate advances in the art of air pollution control and
EPA expects that emissions will be at least equal to or lower than the
required amended ACO performance standards indicated above.  

Unit 3    

Unit 3 is a 160 MW oil-fired tangential boiler that combusts No. 6 Fuel
Oil and primarily operates during the summer season on days when the
demand for electricity is high (high electric demand days (HEDD)). 
Since 2008, the annual operating capacity factor has averaged about 3%
and has not been more than 32% since 1999.  This unit annually employs
SNCR controls and must meet a NOx permit limit of 2.0 lb/MW-hr
(equivalent to 0.20 lb/MM BTU) by May 1, 2015.  For controlling SO2
emissions this unit combusts No. 6 fuel oil with a sulfur limit of 0.70%
which is lower than EPA’s presumptive limit for an oil fired boiler. 
In accordance with New Jersey’s Sulfur in Fuels regulation, Subchapter
9, this unit will be required to combust No. 6 Fuel Oil with a sulfur
content of not more than 0.50% by July 1, 2014.  PM emissions are
controlled with a mechanical cyclone and permitted at 505 lb/hr
(equivalent to 0.29 lb/MM BTU).  Since this is an HEDD unit that
operates for very limited periods and includes SNCR control and low
sulfur fuel oil, emissions are relatively low.  EPA considers that, by
May 1, 2015, Unit 3 will be implementing maximum control measures for
limiting emissions of NOx, SO2 and PM that meet EPA’s BART guidance
and therefore EPA agrees with New Jersey’s BART determination.   

Coal Handling System

There are nine units in the coal handling system that provides support
to the two coal-fired units.  These units emit PM but not NOx or SO2. 
To minimize PM emissions, these unloading, processing and transfer units
are covered and any fugitive PM emission are controlled with
surfactant-based wet suppression (with the exception of 3 of the 9
units).  New Jersey has indicated that the cumulative PTE for these nine
units is 6.1 tpy.  As with the PSEG coal handling system (see previous
PSEG discussion for BART in this TSD), New Jersey and EPA consider these
fugitive emissions to be minimal and therefore the existing controls are
BART.  

Emergency Fire Water Diesel Engine

When in operation, this diesel engine emits NOx, SO2 and PM.  New Jersey
notes that this unit typically operates for less than two hours per year
and, by July 1, 2016, will be required to combust oil with a sulfur
content not more than 0.015% (15 ppm).  This lower sulfur oil is much
lower than EPA’s presumptive limit (1.0% sulfur) for an oil fired
boiler.  Because of limited use, the implementation of any control on
this emergency engine is most probably not cost effective.  Therefore,
New Jersey and EPA conclude that this engine does not need additional
controls because its emissions are small and it operates very
infrequently.  For these reasons, EPA agrees with New Jersey’s BART
determination.   

Unit 3 Cooling Tower

PM are the only emissions from this unit.  This natural draft cooling
tower circulates treated sea water in a closed loop system and is
equipped with high efficiency mist eliminators.  The use of a high
efficiency mist eliminator minimizes PM emissions and therefore this
control measure is considered BART.  

Recommendation 

In summary, EPA should propose approval of New Jersey’s BART
eligibility determinations and BART requirements as they provide for
maximum controls where feasible.  EPA agrees with New Jersey’s
evaluation of those units which are not eligible for BART or are too
small for control.

   Attachment

Review of New Jersey State-wide 2002 and 2018 Projection Modeling
Inventories 

and Reasonable Progress Goal Inventory Demonstration 

for the Regional Haze SIP, December 7, 2010

PREFACE

This document is to support EPA's evaluation of the 2018 projection
inventories and Reasonable Progress Goal (RPG) Plan included in New
Jersey’s Regional Haze State Implementation Plan (SIP) for the entire
State of New Jersey.  The intended effect of this action is to evaluate
inventory components required by the Clean Air Act (Act) to summarize
the emission reductions needed from 2002 to 2018 to meet the goal of
improving visibility at Class I areas affected by New Jersey.  However,
detailed evaluation of the 2002 inventory will not be addressed in this
document.  The reader is referred to Region 2’s document entitled New
Jersey State 2002 Base Year Inventory SIP Technical Support
Documentation for details on the approval of New Jersey’s 2002 base
year inventory.  EPA proposed to approve New Jersey’s 2002 Base Year
inventories on May 9, 2006, (71 FR 26895) and approved the emission
inventories on July 10, 2006 (71 FR 38770).  

This document contains a detailed review of the New Jersey’s
submittal.  Among the topics discussed below are: background and
criteria for approval and EPA’s final recommendation.	

BACKGROUND

REASONABLE PROGRESS GOALS 

Section 51.308(d)(4)(v) of EPA’s Regional Haze Rule (RHR), 40  CFR
51.308, requires the  establishment of a statewide emissions inventory
of pollutants that are reasonably anticipated to cause or contribute to
visibility impairment in any mandatory Class I area. The pollutants
inventoried by New Jersey include VOC, NOx, PM2.5, PM10, SO2 and NH3. 
In addition, Section 51.308(d)(3)(iii) of RHR  requires the State to
identify a baseline emissions inventory upon which future projections
will be based and from which necessary emission reductions for meeting
reasonable progress goals can be determined.  This document provides
information on the development of a projected inventory for 2018 from
the 2002 base year.

The 2018 Reasonable Progress Goal Plans Inventory Demonstration

The State is required to submit a Regional Haze SIP that includes a
Reasonable Progress Goal (RPG) Plan inventory demonstration for
pollutants that contribute to Regional Haze.  The SIPs must demonstrate
that the 2002 base year inventory, projected to 2018 with growth and
including control measures incorporated in rules that are adequate to
provide for the timely reasonable progress in reducing emissions to
reach 2018 projected emissions inventory control levels. 

There are general and specific components for an acceptable 2018
projection inventory and RPG inventory demonstration.  In general, the
State must submit a revision to its SIP and the aforementioned
components must meet certain minimum requirements for reporting by
source category.  Specifically, the source requirements are detailed
below.

A review process is used to determine that all components of the
projection inventories and RPG inventory demonstration are present.  The
review also evaluates the level of supporting documentation provided by
the State and assesses whether the emissions were developed according to
current EPA or acceptable alternative guidance. 

CRITERIA FOR APPROVAL

Projection and RPG Inventory Demonstration

There are several points that the projection inventories and RPG
inventory demonstration must adequately address.  For the projection
inventories and RPG inventory demonstration to be acceptable they must
pass the following acceptance criteria: 

Were the 2018 projection inventories developed in accordance with the
procedures outlined EPA’s latest guidance 1,3,4,6,7? 

Were the Plans developed in accordance with EPA’s latest guidance for
Growth Factors, Projections, and Control Strategies for Reasonable
Progress Goal Plans 1,3,4,6,7? 

DETAILED ACTION AND EVALUATION

This portion of the report contains a discussion and summary of the
review conducted by EPA for the 2018 projection inventories and RPG
inventory demonstration.

Section 1:	2002 BASE YEAR INVENTORY

Calculation of 2002 Base Year Emission Inventory

The reader is referred to Region 2’s document entitled New Jersey
State 2002 Base Year Inventory SIP Technical Support Documentation for
details on the approval of New Jersey’s 2002 base year inventory.  EPA
proposed to approve New Jersey’s 2002 Base Year inventories on May 9,
2006, (71 FR 26895) and approved the emission inventories on July 10,
2006 (71 FR 38770).  The reader is referred to these rulemakings for
additional information concerning the emission inventories and EPA’s
approval.  

Table 1 below shows the revised 2002 VOC, NOx, PM2.5, PM10, SO2 and NH3
state-wide modeling base year emission inventories for the New Jersey.

Table 1

2002 New Jersey 

Statewide Base Year Modeling Inventory (Tons/Year)

Pollutant	

Major Point Sources	

Area Sources	

Nonroad Mobile Sources	

Onroad Mobile Sources	

Total

VOC	16,547	167,883	83,919	110,529	378,877

NOx	51,593	26,692	63,479	161,289	303,053

PM2.5	4,779	17,004	4,997	2,529	29,350

PM10	6,072	31,664	5,501	3,785	47,021

SO2	61,217	10,744	15,686	3,627	91,373

NH3	0	17,572	43	7,316	24,931



Section 2:  Calculation of 2018 Projection Year Emission Inventories

A projection of 2002 VOC, NOx, PM2.5, PM10, SO2 and NH3 anthropogenic
emissions to 2018 is required to determine the emission reductions
needed for RPG inventory demonstration.    The 2018 projection year
emission inventories are calculated by multiplying the 2002 base year
inventory by factors which estimate growth from 2002 to 2018.  A
specific growth factor for each source type in the inventory is required
since sources typically grow at different rates.  

Projection Methodology

Point Sources

Electric Generating Units (EGUs)

For the major point source category, the projected emissions inventories
were first calculated by estimating growth in each source category.  As
appropriate, the 2002 emissions inventory was used as the base for
applying factors to account for inventory growth.  The point source
inventory was grown from the 2002 inventory to 2018 for each facility
using growth factors utilized in Integrated Planning Model to forecast
growth based on the following variables/factors: electric demand;
natural gas, oil and coal supply forecasts; pollution control and
performance; capacity cost and performance, and replacement of older
less efficient and polluting power plants with newer more efficient
units to meet future growth and state by state NOx and SO2 caps.

The reader is referred to Section 5 of State of New Jersey Department of
Environmental Protection SIP for Regional Haze Final, dated July 2009,
and Documentation of 2018 Emissions from EGUs in the Eastern United
States for MANE-VU’s Regional Haze Modeling, dated August 15, 2009. 
These documents provide further details and references on how
projections were performed.

Non-Electric Generating Units (Non-EGUs)

For the major point source category, the projected emissions inventories
were first calculated by estimating growth in each source category.  As
appropriate, the 2002 emissions inventory was used as the base for
applying factors to account for inventory growth.  The point source
inventory was grown from the 2002 inventory to 2018 for each facility
based on source classification codes using growth factors generated from
EPA’s Economic Growth Analysis System (EGAS) version 5.0, United
States Department of Energy’s (USDOE) Annual Energy Outlook
Projections (AEO) 2005, state supplied population and employment data,
where appropriate.  

The reader is referred to Section 5 of State of New Jersey Department of
Environmental Protection SIP for Regional Haze Final, dated July 2009
and Development of Emissions Projections for 2009, 2012 and 2018 for
Non-EGU Point, Area and Nonroad Mobile Sources in the MANE-VU Region,
Final Report, dated February 2007.  These documents provide further
details and references on how projections were performed. 

Since these methods and growth indicators are some of the preferred
growth indicators to use as outlined in EPA Guidance, 1,3,4,6,7

EPA finds New Jersey’s methodology for projecting point sources to be
acceptable.

Area Sources

For the area source category, New Jersey projected emissions from 2002
to 2018 using growth factors generated from EPA’s EGAS version 5.0,
USDOE AEO 2005, state supplied population and employment data, where
appropriate.  

This is in accordance with EPA’s recommended growth indicators for
projecting emissions for area source categories as outlined in EPA
Guidance. 1,3,4,6,7   

The reader is referred to Section 5 of State of New Jersey Department of
Environmental Protection SIP for Regional Haze Final, dated July 2009
and Development of Emissions Projections for 2009, 2012 and 2018 for
Non-EGU Point, Area and Nonroad Mobile Sources in the MANE-VU Region,
Final Report, dated February 2007.  These documents provide further
details and references on how projections were performed. 

EPA finds New Jersey’s methodology for projecting area sources to be
acceptable.

Non-Road Mobile Sources								

Non-road vehicle equipment emissions were projected from 2002 to 2018
using the EPA’s National Mobile Inventory Model (NMIM) 2005.  NMIM
2005 contains growth factors, which are based on the historical trends
in nonroad equipment activity. This model was use to calculate past and
future emission inventories for all nonroad equipment categories except
commercial marine vessels, locomotives and aircrafts.  Emissions were
determined on a monthly basis and combined to provide annual emission
estimates.

Aircrafts, Locomotives and Commercial Marine Vessels (CMV)

Aircraft, locomotives and CMV emissions were projected based on combined
growth and control factors from USEPA Clean Air Interstate Rule (CAIR)
by determining the level of emissions and their associated ratios
between 2002 base and 2025 projection year.  From this point, the State
determine the ratio of emissions between 2002 and 2018 projection year
using linear interpolation.  The ratios between 2002 and 2018 were
determined and then multiplied by the 2002 base year to determine 2018
projection year emissions.

The reader is referred to Section 5 of State of New Jersey Department of
Environmental Protection SIP for Regional Haze Final, dated July 2009
and Development of Emissions Projections for 2009, 2012 and 2018 for
Non-EGU Point, Area and Nonroad Mobile Sources in the MANE-VU Region,
Final Report, dated February 2007.  These documents provide further
details and references on how projections were performed. 

EPA finds New Jersey’s methodology for projecting non-road mobile
sources to be acceptable.

Onroad Mobile Sources

For the onroad mobile source category, the primary indicator and tool
for developing on-road mobile growth and expected emissions are vehicle
miles traveled (VMT) and US EPA’s mobile emissions model Mobile 6.2.03
(Mobile6.2).  The 2018 pollutant emission factors were generated by
Mobile6.2 (with the associated controlled measures applied, where
appropriate) and applied to the monthly VMT projections provided by the
State.  Monthly emissions were then combined to develop annual emission
estimates. 

The reader is referred to Section 5 of State of New Jersey Department of
Environmental Protection SIP for Regional Haze Final, dated July 2009
and Development of MANE-VU Mobile Source Projection Inventories for
SMOKE/MOBILE6 Application, June 2006.  This document provides further
details and references on how projections were performed. 

Since these growth indicators are some of the preferred growth
indicators to use, as outlined in EPA Guidance, 1,3,4,6,7  EPA finds New
Jersey’s methodology for projecting on-road mobile sources to be
acceptable.

Table 2A shows 2018 projection emission inventories controlled after
2002 using the aforementioned growth indicators/methodologies for the
New Jersey State.  Table 2B (attached, separately) shows the 2002-2018
control measures.

Table 2A

New Jersey State

2018 Projection Year Modeling Inventory (Controlled)

 (Tons/Year)

Pollutant	

Major Point Sources	

Area Sources	

Nonroad Mobile Sources	

Onroad Mobile Sources	

Total

VOC	20,267	134,089	53,625	31,415	239,396

NOx	31,100	21,684	41,166	30,150	124,100

PM2.5	7,745	15,220	3,143	1,140	27,247

PM10	8,969	31,874	3,489	1,232	45,564

SO2	23,421	1,781	832	735	26,819

NH3	564	21,435	52	8,555	30,606



Section 3:   2008 RPG Inventory Demonstration

Section 3A: Inventory Demonstration Requirements1,2,3,4,5,6,7

For the New Jersey, state-wide Regional Haze pollutant precursors’
annual emissions should be projected from the 2002 base to the future
2018 year.  Provide summary of statewide emissions for point, area,
nonroad and onroad mobile sources.

State must provide a demonstration which shows that the 2002 base
projected to 2018 (with growth and controls) will reach 2018 controlled
emission levels.  Provide state-wide summary of emissions for point,
area, nonroad mobile and onroad mobile sources.

Provide an explanation on how the 2018 point, area, nonroad mobile and
onroad mobile source projection inventories are developed.

Section 3B:  How New Jersey Meets the Criteria for the 2018 RPG
Inventory Demonstration

For the New Jersey, state-wide Regional Haze pollutant precursors’
annual emissions should be projected from the 2002 base to the future
2018 year.  Provide summary of statewide emissions for point, area,
nonroad and onroad mobile sources.

Sections 1 and 2, provide detailed answers to these questions.  New
Jersey has satisfied the criteria for 2002 base year projected to 2018
(controlled) projection inventory requirements.

State must provide a demonstration which shows that the 2002 base
projected to 2018 (with growth and controls) will reach 2018 controlled
emission levels.  Provide state-wide summary of emissions for point,
area, nonroad mobile and onroad mobile sources.

Sections 1 and 2 and Tables 2A and 2B provide detailed answers to these
questions.  New Jersey has satisfied the criteria for 2002 base year
projected to 2018 (controlled) projection inventory requirements.

Provide an explanation on how the 2018 point, area, nonroad mobile and
onroad mobile source projection inventories are developed.

Sections 1 and 2, provide detailed answers to these questions.  New
Jersey has satisfied the criteria for 2002 base year projected to 2018
(controlled) projection inventory requirements.



Emission Inventory Guidance Documents

1Emission Inventory Improvement Program guidance document titled Volume
X, Emission Projections, dated December 1999 

2EPA Checklist for Regional Haze SIPs, dated August 4, 2006

3Guidance for Growth Factors, Projections, and Control Strategies for
the 15 Percent Rate of Progress Plans, dated March 1993

4Guidance on the Post-1996 Rate of Progress Plan and Attainment
Demonstration, dated January 1994?

5Emission Inventory Guidance for Implementation of ozone and Particulate
Matter NAAQS and Regional Haze Regulation, dated August 2005

6EPA’s follow-up memo “8-Hour Ozone National Ambient Air Quality
Standards Implementation-Reasonable Further Progress (RFP), dated August
2006

7Guidance on the Use of Models and Other Analyses for Demonstration
Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze,
dated April 2007 

Visual range is the greatest distance, in kilometers or miles, at which
a dark object can be viewed against the sky.

Areas designated as mandatory Class I Federal areas consist of national
parks exceeding 6000 acres, wilderness areas and national memorial parks
exceeding 5000 acres, and all international parks that were in existence
on August 7, 1977.  42 U.S.C. 7472(a).  In accordance with section 169A
of the CAA, EPA, in consultation with the Department of Interior,
promulgated a list of 156 areas where visibility is identified as an
important value (44 FR 69122, November 30, 1979).  The extent of a
mandatory Class I area includes subsequent changes in boundaries, such
as park expansions.  42 U.S.C. 7472(a).  Although states and tribes may
designate as Class I additional areas which they consider to have
visibility as an important value, the requirements of the visibility
program set forth in section 169A of the CAA apply only to
‘‘mandatory Class I Federal areas.”  Each mandatory Class I
Federal area is the responsibility of a ‘‘Federal Land
Manager.’’  42 U.S.C. 7602(i).  When we use the term “Class I
area” in this action, we mean a “mandatory Class I Federal area.”

Albuquerque/Bernalillo County in New Mexico must also submit a regional
haze SIP to completely satisfy the requirements of section 110(a)(2)(D)
of the CAA for the entire State of New Mexico under the New Mexico Air
Quality Control Act (section 74-2-4).

 The Class I designation applies to national parks exceeding 6,000
acres, wilderness areas and national memorial parks exceeding 5,000
acres, and all international parks that were in existence prior to 1977.
 In the MANE-VU area, this includes: Acadia National Park, Maine;
Brigantine Wilderness (within the Edwin Wilderness, Vermont; Moosehorn
Wilderness (within the Moosehorn National Wildlife Refuge), Maine; B.
Forsythe National Wildlife Refuge), New Jersey; Great Gulf Wilderness,
New Hampshire; Lye Brook Presidential Range – Dry River Wilderness,
New Hampshire; and Roosevelt Campobello International Park, New
Brunswick.

 VISTAS is comprised of the following: the states of Alabama, Florida,
Georgia, Kentucky, Mississippi, North Carolina, South Carolina,
Tennessee, Virginia, West Virginia, and  the Eastern Band of Cherokee
Indians, and Knox County, TN 

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 “Final BART Determinations for Affected BART-eligible Sources in the
State of New Jersey” March 2, 2011.

 From 2007 to 2010, the annual capacity factor for Unit 1 ranged from
1.6% to 6.7% with an arithmetic mean of about 3.6%.  

 PJM Interconnection is a regional transmission organization (RTO) that
coordinates the movement of wholesale electricity in all or parts of 13
states and the District of Columbia, including the State of New Jersey.

  HYPERLINK
"http://www.epa.gov/compliance/resources/cases/civil/caa/psegfs.pdf"
http://www.epa.gov/compliance/resources/cases/civil/caa/psegfs.pdf 

 See EPA’s document “Additional Regional Haze Questions” August
24, 2006.  See Q&A # 15. 

  HYPERLINK
"http://www.epa.gov/compliance/resources/cases/civil/caa/conocophillips.
html"
http://www.epa.gov/compliance/resources/cases/civil/caa/conocophillips.h
tml 

 US District Court in New Jersey, Civil Action 1:11-cv-1826(RMB-JS), see
paragraph 14.  

 See Attachment 5 and 6 to New Jersey’s TSD dated July 25, 2011. 

 See EPA’s document “Additional Regional Haze Questions” August
24, 2001.  See Q&A # 15.

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