UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania  19103

					Date:  September 28, 2006

Subject:  Technical Support Document (TSD)

	Revision to Maryland SIP 

	NOx SIP Call Allocations for 2008

		

From:     Marilyn Powers, Environmental Engineer /s/

	    Air Quality Planning Branch (3AP21)

To:	    File

 

Reviewed by:  ___________________________________

		Makeba Morris, Chief

                        Air Quality Planning Branch (3AP21)	

I.  INTRODUCTION

On June 21, 2006, the Maryland Department of the Environment (MDE)
submitted a formal revision to its State Implementation Plan (SIP)
revision for its NOx SIP Call 2008 allocations.  The revision consists
of NOx allowance allocations for the 2008 ozone season.

II.   DISCUSSION OF REVISION

1. Background

Maryland(s NOx Reduction and Trading Program under COMAR 26.11.29 and
26.11.30 was approved as meeting the NOx SIP Call (66 FR 1866, January
10, 2001).  These rules set forth NOx reduction requirements beginning
on May 1, 2003 and established allowance allocations for affected
trading sources for ozone seasons 2003 thru 2005.  Thereafter,
Maryland(s approved rule requires that allocations be revised for every
two year period, starting in 2006, and that the allocations be submitted
three years in advance.

2.  Description of Revision

The SIP revision to COMAR 26.11.30.09 consists of allocations for the
control period 2008 for each of the affected sources for which
allocations were provided in the initial control period (2003 through
2005).  The allocations for electric generating units (EGUs) were
derived using each source(s average actual heat input from the 2002 and
2003 ozone seasons multiplied by an emission rate of 0.15 pounds
NOx/MMBTU,  adjusted as a percentage of the total budget. The
allocations for non-electric generating units (non-EGUs)+ are unchanged
from the initial control period.  For most sources the 2008 allocations
do not differ significantly from the initial 3-year allocations.  

EPA analysis

Although Maryland is required to establish 2008 and 2009 allocations,
the State has established only the 2008 allocations in this SIP revision
because the state will be required to meet the Clean Air Interstate Rule
(CAIR) starting in 2009.  This will insure that its NOx Reduction and
Trading program does not conflict with CAIR requirements.  EPA has, in
its Notice of Data Availability (71 FR 44283 dated August 4, 2006) for
the Federal Implementation Plan promulgated under CAIR, proposed
allocations for the 2009 control period for sources in all affected CAIR
States, however Maryland has indicated it plans to develop its own CAIR
rule to establish allocations starting in 2009.

The model trading program under CAIR applies to EGUs that are larger
than 25 MW, and will include most of the units that are currently
subject to COMAR 26.11.29 and 26.11.30.  The NOx SIP Call will still
apply to the non-EGUs that are included in the State’s trading program
as well as the large stationary internal combustion engines and large
Portland cement kilns in the State.  Before implementation of CAIR, the
State must revise its NOx Trading Program rule at COMAR 26.11.29 and
26.11.30 to reflect the programmatic changes that are associated with
CAIR (i.e. that EPA will no longer administer a NOx SIP Call trading
program).  The State must also revise the rule as necessary to insure
that its NOx SIP Call 2007 State budget is maintained.  

The total amount of 2008 allocations established for the sources in
Maryland that are subject to its NOx Budget Trading Program are
consistent with the State’s budget under the NOx SIP Call.  This SIP
revision satisfies the requirement for the State to update its NOx
trading program allocations.

III.  CONCLUSION

Based on the above analysis, EPA has determined that the revisions to
COMAR 26.11.30.09, submitted on June 21, 2006 is approvable as a
revision to the Maryland SIP. 

 IV.  RECOMMENDATION

It is recommended that EPA approve Maryland(s revised regulation .09
under COMAR 26.11.30 (Policies and Procedures Relating to Maryland(s NOx
Reduction and Trading Program( into the Maryland SIP. 

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