UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
REGION
III
1650
Arch
Street
Philadelphia,
Pennsylvania
19103
Date:
May
17,
2006
Subject:
Technical
Support
Document
(
TSD)
Revisions
to
Pennsylvania
SIP
Additional
NOx
Emission
Reductions
for
the
Philadelphia­
Trenton­
Wilmington
One­
Hour
Nonattainment
Area
and
Remaining
NOx
SIP
Call
Requirements
From:
Marilyn
Powers,
Environmental
Engineer
Rose
Quinto,
Environmental
Engineer
Air
Quality
Planning
Branch
(
3AP21)

To:
File
Reviewed
by:
___________________________________
Makeba
Morris,
Chief
Air
Quality
Planning
Branch
(
3AP21)

I.
INTRODUCTION
On
March
29,
2005,
the
Pennsylvania
Department
of
Environmental
Protection
(
PADEP)
submitted
the
following
State
Implementation
Plan
(
SIP)
revisions:

A.
To
satisfy
its
commitments
under
the
Commonwealth's
approved
SIP
for
the
Philadelphia­
Trenton­
Wilmington
one­
hour
ozone
nonattainment
area
(
Philadelphia
Area),
PADEP
submitted
additions
to
Chapter
121
(
definitions)
and
new
Sections
129.201,
129.202,
129.203,
and
129.204
(
Additional
NOx
Requirements)
under
Chapter
129.

Also
included
in
this
submission
are
requirements
pertaining
to
zero­
emission
renewable
energy
production
within
the
five
counties
that
comprise
the
Pennsylvania
portion
of
the
Philadelphia
area.
These
are
set
forth
in
new
Section
129.205
(
Zero
Emission
Renewable
Energy
Production
Credit).

B.
Chapter
145
(
Pennsylvania's
NOx
Budget
Trading
Program)
is
amended
as
follows:
Section
145.42
is
amended
to
assure
accountability
that
zero­
emission
renewable
energy,
where
credited
under
Section
129.205,
replaces
NOx
emissions
from
the
sources
identified
in
Sections
129.201
thru
129.203;
and
new
Subchapter
B
(
Emissions
of
NOx
From
Stationary
Internal
Combustion
Engines)
and
Subchapter
C
(
Emissions
of
NOx
From
Cement
Manufacturing)
are
added
to
address
the
State's
remaining
NOx
emission
reduction
obligations
under
the
NOx
SIP
Call.
2
On
February
6,
2006,
PADEP
submitted
a
letter
providing
supplementary
information
clarifying
alternative
calculation
and
recordkeeping
procedures
to
determine
actual
emissions.

II.
DISCUSSION
OF
REVISIONS
A.
Additional
NOx
Requirements
under
Chapter
129
(
Standards
for
Sources)
to
satisfy
the
Philadelphia
SIP
1.
Background
Amendments
to
Sections
129.201,
129.202,
129.203,
and
129.204
are
additional
NOx
requirements
submitted
to
satisfy
the
Commonwealth's
commitments
under
the
attainment
demonstration
EPA
approved
for
the
Philadelphia
Area
SIP.
These
requirements
will
apply
in
Bucks,
Chester,
Delaware,
Montgomery
and
Philadelphia
Counties
(
five­
county
Southeast
Pennsylvania
area),
which
comprise
the
Pennsylvania
portion
of
the
Philadelphia
Area.
New
definitions
associated
with
these
additional
NOx
requirements
are
included
as
amendments
to
Chapter
121.
These
NOx
requirements
establish
additional
emission
reductions
needed
to
support
the
attainment
demonstration
for
the
Philadelphia
Area
(
64
FR
70428,
December
16,
1999
and
66
FR
54143,
October
26,
2001).
Sections
129.201,
129.202,
and
129.203
are
based
on
the
model
rule
for
additional
NOx
control
measures
developed
by
the
Ozone
Transport
Commission
(
OTC)
intended
to
address
ozone
problems
in
the
Ozone
Transport
Region
(
OTR).

As
part
of
its
commitment
to
reduce
NOx
emissions
in
the
Philadelphia
Area,
Pennsylvania
established
an
incentive
program
that
will
promote
new
zero­
emission
renewable
energy
production
in
this
area.
Section
129.205
is
intended
to
spur
development
of
clean
energy
projects
within
this
five­
county
area
by
allowing
a
source
to
take
credit
for
generating
zero­
emission
renewable
energy.
To
provide
accountability
for
emissions
that
qualify
to
be
credited,
Section
142.42
(
Allocation
of
Allowances
under
the
NOx
Budget
Trading
Program)
is
revised
to
require
retirement
of
NOx
allowances.

2.
Description
of
Revision
Chapter
121
is
amended
to
add
the
following
new
definitions:

1.
MWH
­
megawatt
hour.
2.
ppmvd
­
parts
per
million
dry
volume.
3.
Stationary
internal
combustion
engine
­
An
internal
combustion
engine
of
the
reciprocating
type
that
is
either
attached
to
a
foundation
at
a
facility
or
is
designed
to
be
capable
of
being
carried
or
moved
form
one
location
to
another
and
is
not
a
mobile
air
contamination
source.
4.
Tradable
renewable
certificate
­
A
certificate
issued
by
a
tradable
renewable
certificate
issuing
body
in
recognition
of
renewable
energy
generation.
A
certificate
represents
a
specific
amount
of
electricity
or
thermal
power
equivalent
that
was
generated.
5.
Tradable
renewable
certificate
issuing
body
­
An
entity
approved
by
PADEP
to
issue
and
account
for
tradable
renewable
certificates
in
accordance
with
a
protocol
consistent
with
the
laws
3
and
renewable
energy
programs
of
the
Commonwealth.

Sections
129.201,
129.202,
and
129.203
are
additional
NOx
requirements
to
satisfy
the
Commonwealth's
commitments
under
the
EPA­
approved
SIP
revision
for
the
Philadelphia
Area.
These
NOx
requirements
establish
additional
emission
reductions
needed
to
support
the
attainment
demonstration
for
the
Philadelphia
Area
(
64
FR
70428,
December
16,
1999
and
66
FR
54143,
October
26,
2001).
Sections
129.201,
129.202,
and
129.203
are
based,
in
part,
on
the
model
rule
for
additional
NOx
control
measures
developed
by
the
OTC,
of
which
Pennsylvania
is
a
member.
The
OTC
was
created
to
address
ozone
problems
in
the
Ozone
Transport
Region
(
OTR).

Sections
129.201,
129.202,
and
129.203
establish
ozone
season
(
May
1
through
September
30)
emission
limits
for
NOx
from
boilers,
turbines
and
stationary
internal
combustion
engines
located
at
industrial,
utility
and
commercial
sites
in
the
five­
county
Southeast
Pennsylvania
area.
The
emission
limits
are
required
to
be
implemented
by
May
1,
2005
and
shall
comply
with
Section
129.204
(
relating
to
emission
accountability).
Sections
129.201,
129.202,
and
129.203
do
not
affect
the
large
sources
that
are
regulated
under
Chapter
145.
In
addition,
Sections
129.201,
129.202,
and
129.203
establish
methods
in
determining
NOx
allowable
emissions.
The
owner
or
operator
of
a
unit
covered
by
these
sections
is
required
to
calculate
the
difference
between
NOx
allowable
emissions
and
NOx
actual
emissions
under
Section
129.204.
Boilers
and
turbines
with
an
emission
rate
of
greater
than
250
million
Btu/
hour
heat
input
may
demonstrate
compliance
through
the
opt­
in
provisions
of
Sections
145.80
through
145.88.

Section
129.201
is
designed
to
reduce
the
emissions
of
NOx
from
industrial
boilers.
This
section
applies
to
any
person
that
owns
or
operates
boilers
with
a
rated
capacity
of
greater
than
100
million
Btu/
hour
but
less
than
or
equal
to
250
million
Btu/
hour.
This
section
does
not
apply
to
units
that
combust
municipal
waste
at
a
facility
that
is
permitted
as
a
resource
recovery
facility
under
Part
I,
Subpart
D,
Article
VIII
(
relating
to
municipal
waste).

The
owner
or
operator
subject
to
Section
129.201
shall
calculate
allowable
emissions
by
multiplying
the
unit's
cumulative
heat
input
for
the
period
by
the
applicable
emission
rate
set
forth
below:

1.
The
emission
rate
for
a
boiler
with
a
rated
capacity
of
greater
than
100
Btu/
hour
but
less
than
or
equal
to
250
million
Btu/
hour
shall
be
as
follows:

a.
For
a
boiler
firing
natural
gas
or
a
boiler
firing
a
noncommercial
gaseous
fuel,
0.10
pounds
NOx
per
million
Btu
heat
input.

b.
For
a
boiler
firing
solid
or
liquid
fuel,
0.20
pounds
of
NOx
per
million
Btu
heat
input.

2.
The
emission
rate
for
a
boiler
with
a
rated
capacity
of
greater
than
250
million
Btu/
hour
that
is
not
subject
to
Sections
145.1
­
145.7,
145.10
­
145.14,
145.30,
145.31,
145.40
­
145.43,
145.50
­
145.57,
145.60
­
145.62
and
145.70
­
145.76
shall
be
0.17
pounds
per
NOx
per
million
Btu
heat
input.
4
Section
129.202
is
designed
to
reduce
the
emissions
of
NOx
from
stationary
combustion
turbines.
This
section
applies
to
any
person
that
owns
or
operates
stationary
combustion
turbines
with
a
rated
capacity
of
greater
than
100
million
Btu/
hour.

The
owner
or
operator
subject
to
Section
129.202
shall
calculate
allowable
emissions
by
multiplying
the
unit's
cumulative
heat
input
for
the
period
by
the
applicable
emission
rate
set
forth
below:

1.
The
emission
rate
for
a
stationary
combustion
turbine
with
a
rated
capacity
of
greater
than
100
Btu/
hour
but
less
than
or
equal
to
250
million
Btu/
hour
shall
be
as
follows:

a.
A
combined
cycle
or
regenerative
cycle
stationary
combustion
turbine:

­
When
firing
natural
gas
or
a
commercial
gaseous
fuel,
0.17
pounds
NOx/
MMBtu
or
1.3
pounds
NOx/
MWH.

­
When
firing
oil,
0.26
pounds
NOx/
MMBtu
or
two
pounds
NOx/
MWH.

b.
A
simple
cycle
stationary
combustion
turbine:

­
When
firing
natural
gas
or
a
commercial
gaseous
fuel,
0.20
pounds
NOx/
MMBtu
or
2.2
pounds
NOx/
MWH.

­
When
firing
oil,
0.30
pounds
NOx/
MMBtu
or
three
pounds
NOx/
MWH.

2.
The
emission
rate
for
a
stationary
combustion
turbine
with
a
rated
capacity
of
greater
than
250
million
Btu/
hour
that
is
not
subject
to
Sections
145.1
­
145.7,
145.10
­
145.14,
145.30,
145.31,
145.40
­
145.43,
145.50
­
145.57,
145.60
­
145.62
and
145.70
­
145.76
shall
be
0.17
pounds
per
NOx
per
million
Btu
heat
input.

Section
129.203
is
designed
to
reduce
the
emissions
of
NOx
from
stationary
internal
combustion
engines.
This
section
applies
to
any
person
that
owns
or
operates
stationary
internal
combustion
engines
rated
at
greater
than
1,000
horsepower.
This
section
does
not
apply
to
stationary
combustion
engines
regulated
under
Chapter
145,
Subchapter
B
(
relating
to
emissions
of
NOx
from
stationary
internal
combustion
engines).

The
owner
or
operator
subject
to
Section
129.203
shall
calculate
allowable
emissions
by
multiplying
the
cumulative
hours
of
operations
for
the
unit
by
the
horsepower
rating
of
the
unit
by
the
applicable
emission
rate
set
forth
below:

1.
For
a
spark­
ignited
engine,
3.0
grams
of
NOx
per
brake
horsepower­
hour.

2.
For
a
compression
ignition
stationary
internal
combustion
engine
firing
diesel
fuel
or
a
combination
of
diesel
fuel
and
natural
gas,
2.3
grams
of
NOx
per
brake
horsepower­
hour.
5
Emissions
from
a
stationary
internal
combustion
engine
that
has
been
replaced
by
an
electric
motor
may
be
counted
as
allowable
emissions:

1.
For
a
replaced
spark­
ignited
engine,
3.0
grams
of
NOx
per
brake
horsepower­
hour
of
the
replacement
motor,
less
1.5
pounds
of
NOx
per
MWH
of
electricity
consumed
by
the
replacement
motor.

2.
For
a
replaced
compression
ignition
stationary
internal
combustion
engine
that
fired
diesel
fuel
or
a
combination
of
diesel
and
natural
gas,
2.3
grams
of
NOx
per
brake
horsepower­
hour,
less
1.5
pounds
of
NOx
per
MWH
of
electricity
consumed
by
the
replacement
motor.

Section
129.204
establishes
emissions
accountability
for
small
sources
of
NOx
that
are
subject
to
Section
129,
and
apply
in
the
five­
county
Southeast
Pennsylvania
area.
This
section
sets
forth
the
methodologies
available
to
an
owner
or
operator
to
determine
actual
emissions
of
a
source,
and
requires
that
actual
emissions
during
the
ozone
season
be
reconciled
against
allowable
emissions.
An
owner
or
operator
may
apply
unused
allowable
emissions
to
its
other
facilities,
but
if
actual
emissions
exceed
allowable
emissions,
NOx
allowances
in
the
amount
of
the
exceedance
must
be
surrendered
to
the
State
by
November
1
of
each
year
starting
in
2005.
Failure
to
surrender
the
required
allowances
by
this
date
triggers
a
requirement
to
surrender
three
allowances
for
every
one
ton
of
excess
NOx
emitted.
These
small
NOx
sources
are
not
part
of
the
State's
NOx
Budget
Trading
Program,
do
not
receive
allowances
from
the
State's
NOx
budget,
and
must
therefore
secure
NOx
allowances
on
the
open
market.

Section
129.205
establishes
requirements
for
an
owner
who
generates
zero­
emission
renewable
energy
to
deduct
from
its
actual
emissions
an
equivalent
amount
of
emissions
that
would
be
attributable
to
each
MWH
of
electricity
or
thermal
energy
generated
via
conventional
means.
This
section
establishes
certain
conditions
that
must
be
met
in
order
for
an
owner
or
operator
to
apply
such
a
deduction
to
its
actual
emissions,
including:

1.
Certification
that
the
zero
emission
renewable
energy
produced
with
a
tradable
renewable
certificate,
2.
Certification
that
the
renewable
energy
source
was
brought
into
production
after
December
11,
2004
and
located
within
one
of
these
five
counties,
3.
The
renewable
tradable
certificate
must
be
surrendered
to
the
State,
and
4.
Certification
that
all
of
these
conditions
have
been
met.

Section
142.42
is
amended
to
require
that
for
each
ton
of
NOx
deducted
under
Section
129.205
(
i.
e.,
the
credit
for
zero­
emissions
renewable
energy
produced),
the
State
will
retire
one
NOx
allowance
from
the
State's
new
source
set­
aside
pool
(
under
its
NOx
Budget
Trading
Program)
for
the
subsequent
ozone
season.
6
3.
EPA
analysis
The
March
29,
2005
submittal
and
February
6,
2006
supplemental
letter
pertaining
to
amendments
to
Chapters
121
and
129
satisfy
the
Commonwealth's
commitments
under
its
attainment
demonstration
for
the
Philadelphia
Area
and
establish
emission
reductions
that
are,
in
part,
integral
in
maintaining
EPA's
approval
of
the
Philadelphia
SIP.
This
control
measure
is
based
on
the
model
rule
developed
by
the
OTC
to
reduce
NOx
emissions
from
certain
existing
and
new
boilers,
turbines
and
stationary
internal
combustion
engines.

The
requirement
that
an
equivalent
amount
of
NOx
allowances
be
retired
for
every
ton
of
NOx
that
is
deducted
from
a
source's
actual
emissions
provides
assurance
that
zero­
emissions
renewable
energy
replaces
NOx
emissions
from
conventional
generation.

Section
129.204
sets
forth
a
provision
that
allows
Director's
discretion
for
approval
of
alternate
calculation
and
recordkeeping
procedures
to
determine
actual
emissions,
based
upon
emission
testing
and
correlations
with
operating
parameters.
PADEP's
February
6,
2006
letter
explains
that
the
process
for
approval
of
such
an
alternate
parametric
monitoring
procedure
would
be
through
its
incorporation
into
a
permit
provision
that
would
be
subject
to
EPA
review.
PADEP
affirms
any
such
requests
would
be
forwarded
to
EPA
when
they
are
received
from
a
source.

B.
Amendments
to
Chapter
145
­
Pennsylvania's
Remaining
NOx
Reduction
Requirements
under
the
NOx
SIP
Call
1.
Background
EPA
issued
the
NOx
SIP
Call
(
63
FR
57356,
October
27,
1998)
to
require
22
Eastern
states
and
the
District
of
Columbia
to
reduce
specified
amounts
of
one
of
the
main
precursors
of
groundlevel
ozone,
NOx,
in
order
to
reduce
ozone
transport
across
State
boundaries.
EPA
found
that
the
sources
in
these
states
emit
NOx
in
amounts
that
contribute
significantly
to
nonattainment
of
the
1­
hour
ozone
national
ambient
air
quality
standard
(
NAAQS)
in
downwind
states.
In
the
NOx
SIP
Call,
the
amount
of
reductions
required
by
states
were
calculated
based
on
application
of
available,
highly
cost­
effective
controls
on
source
categories
of
NOx.

The
NOx
SIP
Call
(
including
the
Technical
Amendments
to
the
2007
EGU
budgets
(
64
FR
26298,
May
14,
1999
and
65
FR
11222,
March
2,
2000))
was
challenged
by
a
number
of
state,
industry,
and
labor
groups.
A
detailed
background
of
the
NOx
SIP
Call,
including
the
court
decisions
that
were
made
in
response
to
challenges
to
the
rule
and
impacts
of
the
court
decisions
on
certain
aspects
of
the
rule
may
be
found
in
EPA's
rulemaking
dated
April
21,
2004
(
69
FR
21604)
entitled
Interstate
Ozone
Transport:
Response
to
Court
Decisions
on
the
NOx
SIP
Call,
NOx
SIP
Call
Technical
Amendments,
and
Section
126
Rules,
and
is
not
included
in
full
here.
The
portions
of
the
April
21,
2004
rulemaking
pertaining
to
Pennsylvania's
obligations
under
Phase
II
of
the
NOx
SIP
Call
are
included
herein
to
provide
a
background
on
the
State's
requirements
for
additional
NOx
reductions.
7
On
March
3,
2000,
the
DC
Circuit
Court
issued
its
decision
on
the
NOx
SIP
Call.
It
ruled
largely
in
favor
of
EPA
in
support
of
its
requirements
under
the
1­
hour
ozone
NAAQS,
but
in
part
ruled
against
EPA
on
several
issues.
The
portions
of
the
NOx
SIP
Call
that
were
upheld
by
the
Court
were
termed
Phase
I
of
the
rule,
and,
with
the
exception
of
the
remand
of
the
EGU
growth
factors
used
in
the
NOx
SIP
Call
and
the
requirements
for
the
8­
hour
ozone
NAAQS
(
which
EPA
stayed
due
to
uncertainty
created
by
the
court
rulings),
the
other
portions
that
were
remanded
for
further
rulemaking
were
finalized
on
April
21,
2004
and
are
termed
Phase
II
of
the
rule.
The
rulings
against
EPA
included
two
areas
of
the
NOx
SIP
Call
that
were
remanded
and
vacated,
and
two
areas
in
which
EPA
was
found
to
have
failed
to
provide
adequate
notice
of
changes
in
the
rule.
In
the
latter
case,
the
rulings
included
a
failure
to
provide
adequate
notice
of
the
change
in
the
definition
of
electric
generating
unit
(
EGU)
as
applied
to
cogeneration
(
cogen)
units
that
supply
electricity
to
a
utility
power
distribution
system
for
sale
in
certain
specified
amounts,
and
a
failure
to
provide
adequate
notice
of
the
change
in
control
level
EPA
assumed
for
large
stationary
internal
combustion
(
IC)
engines,
both
of
which
were
remanded
to
EPA
for
further
rulemaking.

The
two
rulings
pertaining
to
inadequate
notice
potentially
required
additional
adjustments
in
states'
approved
Phase
I
budgets
to
incorporate
the
changed
definition
of
cogen
units
and
to
incorporate
the
changed
control
level
noted
above.

2.
EPA
requirements
The
April
21,
2004
rule
finalized
specific
changes
to
the
definition
of
EGUs
as
applied
to
cogen
units,
finalized
the
control
levels
assumed
for
large
stationary
IC
engines
in
the
NOx
SIP
Call,
adjusted
states'
total
budgets
(
as
necessary)
to
reflect
these
changes,
established
a
SIP
submittal
date
of
April
1,
2005
for
States
to
address
the
Phase
II
portion
of
the
budget,
and
set
a
compliance
date
of
May
1,
2007
for
reductions
to
meet
Phase
II
of
the
NOx
SIP
Call.
As
a
result
of
these
changes,
States
are
required
to
achieve
an
incremental
reduction
of
NOx
emissions,
that,
added
to
their
Phase
I
reductions
would
achieve
the
total
required
reductions
needed
to
fully
meet
the
NOx
SIP
Call.

The
large
stationary
IC
engines
that
comprise
states'
Phase
II
NOx
SIP
Call
inventory
are
IC
engines
that
emitted
more
than
1
ton
of
NOx
per
average
ozone
season
day
during
the
baseline
1995
ozone
season.
The
amount
of
Phase
II
reductions
required
to
be
made
by
states
is
based
on
controlling
IC
engines
to
the
following
levels,
which
were
determined
by
EPA
to
be
highly
cost
effective:

­
For
lean
burn
engines,
82
percent
reduction
­
For
rich­
burn
engines,
90
percent
reduction
­
For
diesel
and
dual
fuel
engines,
90
percent
reduction
In
Phase
II,
each
state's
total
budget
was
adjusted
downward
to
reflect
the
additional
reductions
that
correspond
to
these
control
levels
as
applied
to
the
engines
in
the
NOx
SIP
Call
inventory.
States
have
flexibility
in
how
to
achieve
the
additional
reductions,
but
must
adopt
rules
that
will,
by
the
start
of
the
2007
ozone
season,
achieve
the
incremental
reduction,
and
submit
the
rules
to
EPA
as
a
SIP
revision.
8
Pennsylvania's
NOx
trading
program
under
the
NOx
SIP
Call
was
approved
as
part
of
the
Pennsylvania
SIP
on
August
21,
2001
(
see
66
FR
43795).
The
Phase
II
change
to
the
definition
of
cogen
units
did
not
affect
the
Phase
I
budget
previously
established
for
Pennsylvania
and
will
not
be
discussed
in
any
detail
here,
but
a
full
discussion
may
be
found
in
the
April
21,
2005
rulemaking.
In
order
to
meet
its
additional
NOx
SIP
Call
Phase
II
obligations,
the
Commonwealth
is
required
only
to
achieve
the
incremental
reductions
that
EPA
calculated
based
on
controlling
large
IC
engines
to
prescribed
levels.

As
part
of
the
NOx
SIP
Call,
States
are
also
required
to
reduce
NOx
emissions
equivalent
to
those
achieved
by
applying
highly
cost
effective
controls
to
cement
kilns
that
emitted
more
than
1
ton
of
NOx
per
day
during
the
1995
ozone
season.
For
this
source
category,
it
was
determined
that
30
percent
reductions
are
available
and
highly
cost
effective.
As
noted
on
page
29066
of
the
May
29,
2002
EPA
rulemaking
proposing
approval
of
Pennsylvania's
NOx
Budget
Trading
Program,
Pennsylvania
was
required
to
submit
SIP
revisions
to
address
any
additional
emission
reductions
to
meet
the
Commonwealth's
overall
emissions
budget.

3.
Description
of
Revisions
The
Pennsylvania
SIP
revision
amends
Chapter
145,
Interstate
Pollution
Transport
Reduction
Requirements
(
Pennsylvania's
approved
cap
and
trade
program
under
the
NOx
SIP
Call),
by
adding
Subchapters
B
and
C.
These
amendments
establish
ozone
season
NOx
emission
limits
for
large
stationary
internal
combustion
engines
and
Portland
cement
kilns
across
the
State
to
satisfy
the
remainder
of
EPA's
requirements
under
the
NOx
SIP
Call.

Subchapter
B,
titled
Emissions
of
NOx
From
Stationary
Internal
Combustion
Engines,
establishes
applicability,
adds
new
definitions
that
apply
to
IC
engines,
establishes
allowable
emissions
for
each
of
the
three
categories
of
large
stationary
internal
combustion
engines,
sets
forth
monitoring
requirements,
establishes
methods
for
calculating
actual
and
allowable
NOx
emissions,
establishes
requirements
for
surrender
of
allowances
when
actual
emissions
exceed
allowable
emissions,
and
establishes
a
ratio
for
surrender
of
NOx
allowances
when,
upon
reconciliation,
a
source
has
excess
emissions.
An
affected
source
must
comply
by
May
1,
2005.

Subchapter
C,
entitled
Emissions
of
NOx
From
Cement
Manufacturing,
establishes
emission
limit
requirements
for
large
Portland
cement
kilns
across
the
state,
and
includes
applicability,
new
definitions,
standard
requirements
for
compliance
monitoring,
and
establishes
requirements
for
determing
allowable
and
actual
emissions,
and
establishes
requirements
for
surrender
of
NOx
allowances
to
the
State
when
a
unit
has
excess
emissions.
An
affected
source
must
comply
by
October
31,
2005.

Both
Subchapter
B
and
C
set
forth
methodologies
available
to
the
sources
to
determine
actual
emissions,
and
establish
requirements
for
units
or
sources
to
reconcile
actual
emissions
against
allowable
emissions,
requiring
sources
that
exceed
allowable
emissions
to
surrender
NOx
allowances
to
the
Commonwealth's
NOx
allowance
account.
For
both
source
categories
above,
the
state
allows
an
owner
to
apply
excess
allowable
emissions
at
one
facility
towards
actual
emissions
at
the
owner's
other
facilities
within
the
Commonwealth.
9
4.
EPA
Analysis
of
Revisions
Stationary
IC
engines
There
are
a
total
of
14
IC
engines
that
meet
the
definition
of
"
large
NOx
SIP
Call
engines"
in
Pennsylvania.
Section
145.113
establishes
emission
limits
for
IC
engines
as
follows:

a.
For
a
rich
burn
stationary
IC
engine
with
an
engine
rating
equal
to
or
greater
than
2,400
brake
horsepower
shall
be
1.5
grams
per
brake
horsepower­
hour.
b.
For
a
lean­
burn
stationary
IC
engine
with
an
engine
rating
equal
to
or
greater
than
2,400
brake
horsepower
shall
be
3.0
grams
per
brake
horsepower­
hour
c.
For
a
diesel
stationary
IC
engine
with
an
engine
rating
equal
to
or
greater
than
3,000
brake
horsepower,
or
a
dual­
fuel
stationary
IC
engine
with
an
engine
rating
equal
to
or
greater
than
4,400
brake
horsepower
shall
be
2.3
grams
per
brake
horsepower­
hour
In
the
NOx
SIP
Call
Phase
II,
EPA
determined
an
incremental
reduction
that
States
would
have
to
achieve
to
fully
meet
the
requirements
of
the
NOx
SIP
Call.
The
additional
emission
reductions
were
based
on
application
of
controls
to
several
categories
of
IC
engines
based
on
available
historical
information.

In
the
April
21,
2004
Phase
II
rulemaking,
EPA
determined
that
an
average
emission
rate
of
16.8
g/
hp­
hr
is
appropriate
to
represent
uncontrolled
emissions
from
large
lean
burn
engines.
1
The
available
test
data
on
large
lean
burn
engines
in
the
NOx
SIP
Call
area
indicated
that
highly
costeffective
controls
can
achieve
a
reduction
level
of
82%.
The
emission
limit
of
3.0
g/
hp­
hr
for
leanburn
engines
achieves
this
level
of
control.
For
rich
burn
engines,
the
uncontrolled
emission
rate
is
15.8
g/
hp­
hr
2.
The
emission
limit
of
1.5
g/
hp­
hr
for
rich
burn
engines
achieves
the
90%
control
required
under
Phase
II.
There
were
no
dual­
fuel
engines
in
the
Commonwealth's
NOx
SIP
Call
Inventory.
The
emission
limits
set
forth
in
Section
145.113
achieve
the
reductions
required
under
Phase
II.

Provisions
for
approval
of
alternate
calculation
and
reporting
procedures
are
identical
to
those
in
Chapter
129.
As
addressed
in
PADEP's
February
6,
2006
letter,
the
process
for
approval
of
such
an
alternate
parametric
monitoring
procedure
would
be
through
incorporation
of
the
change
in
a
permit
provision
that
would
be
subject
to
EPA
review.
As
noted
above,
PADEP
affirms
any
such
requests
would
be
forwarded
to
EPA
when
they
are
received
from
a
source.

1
Stationary
Reciprocating
Internal
Combustion
Engines
TSD
for
NOx
SIP
Call,
October
2003.

2
Alternative
Control
Techniques
(
ACT)
document,
"
NOx
Emissions
from
Stationary
Reciprocating
Internal
Combustion
Egnines,"
EPA­
453/
R­
93­
032,
July
1993,
Table
2­
1
on
page
2­
3.
10
Cement
Kilns
The
NOx
SIP
call
also
identified
large
cement
kilns
as
a
source
category
having
large
contributions
to
transported
emissions
and
determined
that
highly
cost
effective
controls
are
available
on
these
sources
that
achieve
30
percent
emission
reductions.
There
are
19
cement
kilns
within
the
Commonwealth
that
are
subject
to
the
NOx
SIP
Call.
Since
1995,
these
kilns
have
had
varying
levels
of
control
based
on
other
state
or
federal
requirements
 
in
some
cases
levels
of
control
were
more
restrictive
than
that
required
by
the
NOx
SIP
Call.
Of
the
19,
five
are
long
wet
kilns,
eight
are
long
dry
kilns,
four
are
of
the
dry
preheater
type,
and
one
is
a
dry
precalciner
type
of
kiln.
One
kiln
has
shut
down.

The
NOx
SIP
Call
requirements
for
cement
kilns
were
based
on
EPA's
Alternative
Control
Techniques
(
ACT)
guidance
document
that
addressed
NOx
emissions
from
cement
manufacturing
sources.
3
In
the
ACT,
average
uncontrolled
emissions
for
the
four
types
of
kilns
are:

Wet
kilns
­
9.7
pounds
of
NOx
per
ton
of
clinker
produced
Long
Dry
kilns
­
8.6
pounds
of
NOx
per
ton
of
clinker
Dry
preheater
kiln
­
5.9
pounds
of
NOx
per
ton
of
clinker
Dry
precalciner
kiln
­
3.4
pounds
of
NOx
per
ton
of
clinker
The
Commonwealth's
regulation
under
Subchapter
C
establishes
an
emission
limit
of
6
pounds
of
NOx
per
ton
of
clinker
produced
by
a
kiln.
For
the
wet
kiln
and
long
dry
kiln
type
of
process,
this
emission
limit
meets
or
exceeds
the
30%
reduction
requirement
(
i.
e.,
6
pounds
per
ton
of
clinker,
is
at
least
30
percent
less
than
the
average
uncontrolled
emissions
for
these
type
of
kilns,
as
noted
above).
One
cement
kiln,
Kosmos
Cement
Company,
has
shut
down
permanently,
resulting
in
511
tons
of
NOx
that
are
creditable
to
the
Commonwealth
towards
its
reduction
requirements.
The
analysis
of
the
adequacy
of
the
Commonwealth's
submission
then
focused
on
a
comparison
of
total
amount
of
emissions
from
the
dry
preheater
and
dry
precalciner
kilns
taking
into
consideration
the
credits
that
accrue
to
the
State
from
the
shutdown
of
Kosmos,
the
control
of
some
units
as
required
under
other
programs,
and
the
expanded
applicability
beyond
the
original
inventory.
See
Attachment
A
for
a
summary
of
the
analysis
for
these
sources.

As
can
be
seen
in
Attachment
A,
in
the
aggregate,
the
Commonwealth's
regulation
meets
the
reduction
requirements
of
the
NOx
SIP
Call
for
cement
kilns.

III.
CONCLUSION
As
described
above,
the
March
29,
2005
SIP
revisions
and
February
6,
2006
supplemental
letter
submitted
by
the
Commonwealth
of
Pennsylvania
for
revision
of
Chapter
121
(
definitions),
addition
of
new
Sections
129.201
though
129.205
(
Additional
NOx
Requirements),
revision
of
Section
145.42
(
pertaining
to
accountability
of
NOx
credit
under
Section
129.205),
and
addition
of
Subchapters
B
and
C
to
Chapter
145
(
pertaining
to
the
Commonwealth's
remaining
NOx
SIP
Call
3
Alternative
Control
Techniques
document,
"
NOx
Emissions
from
Cement
Manufacturing",
EPA­
453/
R­
94­
004,
March
1994,
Table
2­
1
on
page
2­
3.
11
obligations
for
IC
engines
and
cement
kilns,
respectively),
are
approvable.
These
revisions
strengthen
the
Pennsylvania
SIP.

IV.
RECOMMENDATION
It
is
recommended
that
a
Notice
of
Proposed
Rulemaking
be
published
proposing
approval
of
these
SIP
revisions.
