                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  REGION III
	1650 Arch Street
	Philadelphia, Pennsylvania  19103

DATE:	4/12/12

SUBJECT:	Technical Support Document for Maryland's Reasonable Available Control Technology for the 1997 8-hour Ozone National Ambient Air Quality Standard 

FROM:	Jacqueline Lewis, Environmental Engineer /s/
            Office of Air Program Planning (3AP30)

TO:	State Implementation Plan (SIP) Docket File
			
THRU: 	Cristina Fernandez, Associate Director  /s/
            Office of Air Program Planning (3AP30)


I.	Affected Regulation
On October 17, 2011, Maryland submitted a revision to its SIP that meets the requirements of Reasonable Available Control Technology (RACT) set forth by the Clean Air Act (CAA) for the 1997 8-hour Ozone National Ambient Air Quality Standards (NAAQS).  The entire state of Maryland is located within the Ozone Transport Region (OTR).  Therefore, the entire state is subject to the CAA's RACT requirements.  Three areas were classified as moderate and one as marginal.  Maryland also had an Early Action Compact area.  All other remaining counties are part of the OTR.  The three moderate 1997 8 hour ozone nonattainment areas are Baltimore, Washington, D.C., and Cecil County (part of the Philadelphia nonattainment area).  The one marginal 1997 8-hour ozone nonattainment area consists of Kent and Queen Anne's Counties.  Washington County was part of the Early Action Compact program.          


		II.	 Background
    
Ozone is formed in the atmosphere by photochemical reactions between volatile organic compounds (VOC), oxides of nitrogen (NOx), and carbon monoxide (CO) in the presence of sunlight.  In order to reduce ozone concentrations in the ambient air, the CAA requires all nonattainment areas to apply control on VOC/NOx emission sources to achieve emission reductions.  Among effective control measures, RACT controls are a major group for reducing VOC and NOx emissions from stationary sources.
    	
Since the 1970's EPA has consistently interpreted RACT to mean the lowest emission limit that a particular source is capable of meeting by the application of the control technology that is reasonably available considering technological and economic feasibility.  See 72 FR 20586 at 20610, April 25, 2007.  Section 182 of the CAA sets forth two separate RACT requirements for an ozone nonattainment area.  The first requirement, contained in section 182(a)(2)(A) of the CAA, and referred to as RACT fix-up, requires the correction of RACT rules for which the Environmental Protection Agency (EPA) identified deficiencies before the CAA was amended in 1990.  The second requirement, referred to as RACT catch-up set forth in section 182(b)(2) of the CAA, requires that moderate (or worse) ozone nonattainment areas, as well as marginal and attainment areas in OTR established pursuant to section 184 of the CAA, implement RACT controls on all major VOC and NOx emission sources and on all sources and source categories covered by a control technique guideline (CTG) issued by EPA.
    
All Maryland counties were subject to RACT requirements under the 1-hour ozone standard.  The Baltimore, Washington D.C., and Cecil County, Maryland nonattainment areas were designated as severe 1-hour ozone nonattainment areas.  Kent and Queen Anne's Counties were designated as a marginal 1-hour ozone nonattainment area.  All remaining Maryland counties were identified as part of the OTR.  Since the early 1990s, Maryland has implemented numerous RACT controls throughout the State to meet the CAA's RACT requirements.  Maryland also implemented controls necessary to meet the requirements of the NOx SIP Call (40 CFR 51.121).  
    
A.  RACT Fix-Up
The first RACT requirement for ozone nonattainment areas, contained in section 182(a)(2)(A) of the CAA, required Maryland to submit a SIP revision correcting RACT rules prior to the CAA amendment in 1990.  On April 5, 1991, September 20, 1991, April 2, 1992, January 18, 1993, June 8, 1993, and July 19, 1993, the Maryland Department of the Environment submitted several SIP revisions consisting of revised VOC emission regulations applicable in the State of Maryland.  Portions of Maryland's June 8, 1993 and July 19, 1993 submittals also address the RACT catch-up requirements.  EPA proposed to approve the revisions to Maryland's SIP as meeting the RACT fix-up requirements of the amended CAA through numerous notices.  These revisions included amendments to the Code of Maryland Regulations (COMAR), specifically revisions to Title 26, subtitles11, chapters 1, 2, 4, 6, 8, 10, 13,14, 19, and Test Method 91-01(See 58 FR 34392, June 25, 1993; 58 FR 50307, September 27, 1993; and 58 FR 51028, September 30, 1993).  On March 31, 1994, September 7, 1994, and November 29, 1994, EPA published final rulemaking notices approving the State of Maryland's SIP revisions (See 59 FR 15117, March 31, 1994; 58 FR 50307, September 27, 1993; 59 FR 46180, September 7, 1994; and 59 FR 60908, November 29, 1994).  
    
B.  RACT Catch-Up
The second RACT requirement for ozone nonattainment areas, set forth in section 182(b)(2) of the CAA, requires Maryland to implement RACT for each category of VOC sources covered by a CTG document issued between the date of the 1990 Amendments and the date of attainment, for VOC sources covered by any CTG issued before the 1990 Amendments, and for all other major stationary sources of VOCs.  Because Maryland is in the OTR, the entire State is subject to the RACT catch-up provisions of the section 182(b)(2) of the CAA.  The Baltimore and Philadelphia nonattainment areas were classified as severe.  Therefore, a major source in these areas is a source having the potential to emit 25 tons per year (TPY) of VOC or more.  In the remainder of the State, a major source was defined as a source having the potential to emit 50 TPY of VOC or more.  As mentioned above portions of Maryland's June 8, 1993 and July 19, 1993 submittals address the RACT catch-up requirements.  These submittals included amendments to chapters 11, 13, and 19 under Title 26, subtitle 11.  EPA approved these amendments through Direct Final Rulemaking on January 6, 1995 (60 FR 2018).  On July 12, 1995, Maryland submitted additional amendments to satisfy the RACT catch-up provisions.  This submittal contained amendments to the definition of the term "major stationary source of VOC" and Maryland's major source VOC RACT regulations COMAR 26.11.19.01B(4) and 26.11.19.02G, respectively.  On May 13, 1998, EPA published a direct final notice to approve COMAR 26.11.19.01B(4) of Maryland's SIP as meeting the RACT "catch-up" provisions of the CAA (63 FR 26462).  
    
    
C.  Conditional Limited Approval
On March 1, 1996, EPA proposed conditional approval of Maryland's April 5, 1991 and June 8, 1993 revision submittals pertaining to COMAR 26.11.19.02G and COMAR 26.11.06.06 (61 FR 8009).  Approval was conditioned on the State of Maryland certifying that it has determined and imposed RACT for all the major VOC sources covered by the VOC RACT regulation and submitted those enforceable RACT determinations to EPA as SIP revisions.  That certification was to be made by Maryland no later than one year from the date EPA promulgated final conditional approval of the SIP revision.  Because proposed conditional approval does not comply with EPA's generic RACT policy, EPA withdrew its March 1, 1996, proposed conditional approval on September 4, 1998 (63 FR 47174) and at the same time also conditionally and limitedly approved the April 5, 1991, June 8, 1993, and July 12, 1995 submittals. 
    
This September 4, 1998, direct final notice withdrew the March 1, 1996, proposed conditional approval and conditionally and limitedly approved the Maryland major source VOC RACT regulation and minor source VOC regulations, COMAR 26.11.19.02G and COMAR 26.11.06.06 respectively.  On February 7, 1996, Maryland submitted a letter to EPA committing to:  (1) complete submission of the SIP revisions required by COMAR 26.11.19.02G containing RACT determinations for the major VOC sources in the State that are subject to the RACT rule; and (2) provide a written statement to EPA that, to the best of its knowledge, it has completed submission of the SIP revisions described above within one year of the effective date (November 3, 1998) of the final conditional limited approval of the Maryland generic major source VOC RACT regulation.   
    
On December 19, 2008, Maryland submitted a letter certifying that it has imposed RACT for all major category-specific and generic VOC sources and submitted those enforceable RACT determinations to EPA as SIP revisions for approval.  In addition to this letter, Maryland also provided a list of VOC RACT regulations submitted and approved by EPA and a list of all major sources of VOC and NOx and the applicable RACT regulations.  EPA Region 3 has determined that this letter satisfies all requirements, and on March 25, 2009, EPA converted the conditional limited approval status of COMAR 26.11.19.02G and COMAR 26.11.06.06 to full approval.  See 63 FR 47174.



D. Maximum Achievable Control Technology (MACT) Standards

On September 8, 1999 (69 FR 48714), EPA published approval of COMAR 26.11.19.20, "Control of Landfill Gas Emissions from Municipal Solid Waste Landfill," as a section 111(d) plan in  40 CFR part 62 and not as a part 52 SIP revision.  Thus this rule is federally enforceable, but under a different requirement of the CAA.  However, in November 2008, EPA published a guidance document titled, "Guidance For Estimating VOC and NOx Emission Changes From MACT Rules."  This document was develop in part because EPA recognized that nonattainment areas should be able to take credit for MACT standards under section 112 of the CAA in meeting the above-mentioned requirements for the attainment demonstration, RACT and reasonable further progress (RFP).  This guidance document estimates a national VOC reduction of 75% for this source category.  Therefore, EPA Region 3 has determined that this rule approved under 40 CFR part 62 also serves to satisfy the requirements under 40 CFR part 52. 
    
III. VOC RACT Controls
Most of Maryland's Regulations and Statues, under COMAR 26.11.06, 26.11.10, 26.11.11, 26.11.13,  26.11.14, 26.11.19 and 26.11.24 contain the VOC RACT controls that were implemented and approved in Maryland's SIP under the 1-hour ozone NAAQS.  However, COMAR 26.11.19.20 ("Control of Landfill Gas Emissions from Municipal Solid Waste Landfill") which was approved by EPA on September 18,1999, contain the VOC RACT controls that were implemented and approved in Maryland's SIP under section 111(d) using EPA's MACT standards under 40 CFR 60.752 and 40 CFR 60.755 as the RACT basis.  
    
Although Alternative Control Technology (ACTs) are not regulatory documents and have no legal effect on state regulations, EPA requires that states verify that ACTs have been considered in the RACT program development process.  Therefore, Maryland included ACTs in their review of applicable RACT requirements in this submittal.
    
Table 1 lists Maryland's VOC RACT controls using EPA's CTGs as the RACT basis.  This list also includes the date the rule became affective in the state of Maryland and the Federal Register publication date and citation.    
    
    
Table 1.  Maryland's VOC RACT Controls Based on EPA's CTGs
Regulation

COMAR

Existing Stationary Sources

Title of Regulation
State Effective Date
Federal Register Date
Citation
26.11.11
Control of Petroleum Products Installation, including Asphalt Paving and Asphalt Concrete Plants
8/1/88
&
4/26/93
11/3/92
&
1/6/95
57 FR 49651
&
60 FR 2018
26.11.13.03
Control of Gasoline and VOC Storage and Handling-Large Storage Tanks
8/1/88
11/3/92
57 FR 49651
26.11.13.04
Control of Gasoline and VOC Storage and Handling  -  Loading Operations
8/11/97
12/22/98
63 FR 70667
26.11.13.05
Control of Gasoline and VOC Storage and Handling -  Loading Operations - Gasoline Leaks from Tank Trucks
2/15/93
1/6/95
60 FR 2018
26.11.19.03
Automotive Light Duty Truck Coating
9/22/97
11/5/98
63 FR 59720
26.11.19.04
Can Coating
8/1/88
11/3/92
57 FR 49651
26.11.19.05
Coil Coating
8/1/88
11/3/92
57 FR 49651
26.11.19.06
Large Appliance Coating
10/1/10
5/12/11
76 FR 27610
26.11.19.07
Paper, Fabric, Vinyl, and Other Plastic Parts Coating
5/16/11
10/17/11
76 FR 64022
26.11.19.08
Metal Furniture Coating
8/1/88
11/3/92
57 FR 49651
26.11.19.09
Cold and Vapor Degreasing
6/5/95
8/4/97
62 FR 41853
26.11.19.10
Flexographic and Rotogravure
4/19/10
9/27/10
75 FR 59086
26.11.19.11
Lithographic Printing
6/5/95
9/2/97
62 FR 46199
26.11.19.12
Dry Cleaning Installations
9/22/97
9/2/98
63 FR 46662
26.11.19.13
Miscellaneous Metal Coating
5/16/11
10/17/11
76 FR 64017
26.11.19.13-1
Aerospace Coating Operations
10/2/00
11/7/01
66 FR 56220
26.11.19.14
Manufacture of Synthesized Pharmaceutical Products
5/8/91
11/29/94
59 FR 60908
26.11.19.23
Control of VOC Emissions from Vehicle Refinishing
5/22/95
8/4/97
62 FR 41853


Table 2 lists Maryland's VOC RACT controls using Maryland's RACT analysis as the RACT basis.  This list also includes the date the rule became affective in the State of Maryland and the Federal Register publication date and citation.

Table 2.  Maryland's VOC RACT Controls Based on Maryland RACT Analysis
Regulation

COMAR

Existing Stationary Sources

Title of Regulation
State Effective Date
Federal Register Date
Citation
26.11.10
01,.06 and .07
Control of VOCs from Iron and Steel Production Installations
12/5/00
11/7/01
66 FR 56222
26.11.13.08
Control of VOC Emissions from Marine Vessel Loading
10/18/07
7/18/08
73 FR 41268
26.11.14.01 and .06
Control of VOC Emissions from Kraft Pulp Mills
1/8/01
11/7/01
66 FR 56220
26.11.19
.01B(4) and .02G
Control of Major Stationary Sources of Volatile Organic Compounds
12/10/01
3/25/09
74 FR 12556
26.11.19.07-1
Solid Resin Decorative Surface Manufacturing
6/15/98
6/17/99
64 FR 32415
26.11.19.09
Control of VOC Emissions from Cold Vapor Degreasing
6/5/95
8/4/97 
62 FR 41853
26.11.19.10
Flexographic and Rotogravure
4/19/10
9/27/10
75 FR 59086
26.11.19.13-2
Brake Shoe Coating Operations
8/24/98
6/17/99
64 FR 32415
26.11.19.13-3
Control of VOC from Structural Steel Coating Operations
6/29/98
6/17/99
64 FR 32415
26.11.19.15

Paint, Resin and Adhesive and Adhesive Application
4/19/10

10/18/11 
76 FR 64237
26.11.19.16
Control of VOC Equipment Leaks
8/19/91
9/7/94
59 FR 46180
26.11.19.17
Control of VOC Emissions from Yeast Manufacturing
9/12/05
3/31/06
71 FR 16237
26.11.19.18
Control of VOC Emissions from Screen Printing and Digital Imaging
6/10/02
1/15/03
68 FR 1972
26.11.19.19
Control of VOC Emissions from Expandable Polystyrene Operations
10/2/00
5/7/01

66 FR 22924
26.11.19.20
Control of Landfill Gas Emissions from Municipal Solid Waste Landfill
2/5/98 and 3/21/99
9/8/99
69 FR 48714
26.11.19.21
Control of VOC from Bakery Ovens
7/3/95
10/15/97
62 FR 53544
26.11.19.22
Control of VOC from Vinegar Generators
8/11/97
9/23/99
64 FR 41445
26.11.19.24 
Control of VOC Emissions from Leather Coating
8/11/97
9/23/99
64 FR 41445
26.11.19.25
Control of VOC Emissions from Explosives and Propellant Manufacturing
8/11/97
1/26/99
64 FR 3852
26.11.19.26
Control of VOC Emissions from Reinforced Plastic Manufacturing
8/11/97
8/19/99
64 FR 45182
26.11.19.27
Control of VOC Emissions from Marine Vessel Coating Operations
10/20/97
9/5/01
66 FR 46379
26.11.19.28
Control of VOC Emissions from Bread and Snack Food  Operations
10/2/00
5/7/2001
66 FR 22924
26.11.19.29
Control of VOC Emissions from Distilled Spirits Facilities
10/2/00
10/15/01
11/7/2001
66 FR 56220
26.11.19.30
Control of VOC Emissions from Chemical Production and Polytetrafluoroethylene Installations
4/21/08
10/18/11
76 FR 64237
26.11.19.31
Control of VOC Emissions from Medical Device Manufacturing
6/5/06
1/11/2007
72 FR 1289
26.11.24
Stage II Vapor Recovery at Gasoline Dispensing Facilities
4/15/02
5/7/03
68 FR 24363


Table 3 lists Maryland's negative declaration for VOC CTG categories which no facilities exist in the state.


Table 3.  Documents for which no Applicable Facilities Exist in the State of Maryland
                                Document Title
Control of  Volatile Organic Compound Emission from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry
Control of  Volatile Organic Compound Emission from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment
Control of  Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins
Control of  Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires
Control of  Volatile Organic Compound Leaks from form Natural Gas/Gasoline Processing Plants
Control of  Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations
Control of  Volatile Organic Compound Leaks from Petroleum Refinery Equipment
Control of  Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnaround
Control of  Volatile Organic Compound Emission from Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry 
Control Techniques Guidelines for Shipbuilding and Ship Repair Operations 
Control of  Volatile Organic Compound Emission from Existing Stationary Sources, Volume IV:  Surface Coating of Insulation of Magnet Wire

IV. NOx RACT Controls
Table 4 lists the NOx RACT Regulations under the 1997 8-hour ozone NAAQS and includes the date the rule became affective in the state of Maryland and the Federal Register publication date and citation.

Table 4.  Maryland's NOx RACT Regulations
Regulation

COMAR

Existing Stationary Sources

Title of Regulation
State Effective Date
Federal Register Date
Citation
26.11.09.08A&B
Fuel-Burning Equipment Located at Major Sources  -  General Requirements and Conditions
11/24/03
9/20/04
69 FR 56170
26.11.09.08C
Fuel-Burning Equipment with a Rated Heat Input Capacity of 250 million british thermal units per hour (MMBtu/hr) or Greater
11/24/03
9/20/04
69 FR 56170
26.11.09.08D
Fuel-Burning Equipment with a Rated Heat Input Capacity of Less than  250MMBtu/hr and Greater than 100MMBtu/hr
11/24/03
9/20/04
69 FR 56170
26.11.09.08E
Fuel Burning Equipment with an input capacity of 100 MMBtu/hr or less 
11/24/03
9/20/04
69 FR 56170
26.11.09.08F
Space Heaters
11/24/03
9/20/04
69 FR 56170
26.11.09.08G(1)
Fuel Burning Equipment with a Capacity Factor of 15 % or Less
11/24/03
9/20/04
69 FR 56170
26.11.09.08G(2)
Combustion Turbines with a Capacity Factor Greater than 15 %
11/24/03
9/20/04
69 FR 56170
26.11.09.08H(3)
 Municipal Waste Combustors 
11/24/03
9/20/04
69 FR 56170
26.11.09.08H(4)
 Hospital, Medical and Infectious Waste Incinerators 
11/24/03
9/20/04
69 FR 56170
26.11.09.08I(1) & (2)
Glass Melting Furnaces 
11/24/03
9/20/04
69 FR 56170
26.11.09.08J
Industrial Furnaces and Other Miscellaneous Installations the Cause Emissions of NOx
11/24/03
9/20/04
69 FR 56170
26.11.14.07
Kraft Pulp Mills
7/26/10


26.11.29.03
Portland Cement Manufacturing Plants
5/1/00
1/10/01
66 FR 1866
26.11.29.05B&C
Stationary Internal Combustions Engines at Natural Gas Compression Stations
5/1/00
1/10/01
66 FR 1866

COMAR 26.11.09.08  - Control of NOx Emissions for Major Stationary Sources are Maryland's NOx RACT controls that were implemented and approved into the Maryland SIP under the 1-hour ozone NAAQS.  The NOx RACT analyses for these eleven regulations are summarized below and the full analysis can be found on pages 28 through 48 of Maryland's SIP submittal.  

COMAR 26.11.09.08 A & B - Fuel-Burning Equipment located at Major Sources identifies the major source cut-offs and sets standards for the oil, gas and coal fired equipment.  The standards are 0.020 pounds (lbs) NOx per million Btu for gas, 0.025 lbs NOx per million Btu for oil and 0.038 lbs NOx per million Btu for coal fired dry bottom equipment.  

COMAR 26.11.09.08 C - Fuel-Burning Equipment with a Rated Heat Input Capacity of 250 MMBtu/hr or greater identifies standards for various coal-fired, oil and gas/oil units at electric generating stations, and standard fuel burning equipment stacks at non-electric generating facilities.  RACT requirements for some coal fired units are superseded by the more restrictive standards under COMAR 26.11.27 (Healthy Air Act) which is beyond RACT. Two of the dual-fueled units in Maryland are required, through consent orders, to operate on natural gas.

COMAR 26.11.09.08 D - Fuel-Burning Equipment with a Rated Heat Input Capacity of Less than 250 MMBtu/hr and Greater than 100 MMBtu/hr requires coal fired units to meet the standard of 0.65 lbs NOx per Million Btu. 

COMAR 26.11.09.08 E - Fuel Burning Equipment with an input capacity of 100 MMBtu/hr or less requires combustion analysis and optimization of combustion each year. Equipment operators are required to maintain records for a period of two years. Equipment operators are also required to undergo training every three years.

COMAR 26.11.09.08 F - Space Heaters regulation applies to space heater units registered with a facility under the major source category.  Since space heaters are small sources of NOx emissions at major sources, no emissions limits are set in this regulation.  However, application of best management practices is required and sources are required to implement an operating and maintenance plan to minimize NOx emissions, and attend operator training once every 3 years and maintain a record of the training attendance.  

COMAR 26.11.09.08 G(1) - Fuel Burning Equipment with a Capacity Factor of 15 % or Less, requires combustion analysis and optimization for NOx from fuel burning equipment operating greater than 500 hours during a calendar year.

COMAR 26.11.09.08 G(2) - Combustion Turbines with a Capacity Factor Greater than 15 %, requires gas fired turbines to meet a NOx emission rate of 42 ppm, and oil fired turbines are required to meet an emission rate of 65 ppm or meet applicable Prevention of Significant Deterioration limits found in the permit to construct.

COMAR 26.11.09.08 H(3)  -  Control of NOx Emissions for Major Emissions for Major Stationary Sources, Municipal Waste Combustors, references control required under COMAR 26.11.08.08.  This regulation applies to existing large MWCs with a capacity greater than 250 tons per day. The current NOx standard for large MWC is 205 ppmv 24-hr arithmetic average which is based on the maximum achievable control technology (MACT) determination for NOx in emission guidelines for MWC, 40 CFR 60 Subpart Cb, as revised, May 10, 2006, or applicable PSD limits whichever is more restrictive. This standard can be achieved by combustion control and optimization.  RACT for small MWCs are under 40 CFR 62 Subpart JJJ.

COMAR 26.11.09.08 H(4)   -  Control of NOx Emissions for Major Emissions for Major Stationary Sources Hospital, Medical and Infectious Waste Incinerators (HMIWI), references control required under COMAR 26.11.08.08-1A(2).  RACT for HMIWI is 250 ppm, 24 hour average which is also the current MACT standard.

COMAR 26.11.09.08 I(1) &(2) - Glass Melting Furnaces, currently only one source in Maryland is subject to this regulation.  The source must perform daily oxygen tests and maintain excess oxygen at 4.5 % or less to assure compliance with this regulation.  

COMAR 26.11.09.08 J - Industrial Furnaces and Other Miscellaneous Installations the Cause Emissions of NOx, requires that where possible the equipment be run on natural gas during ozone season, and it also requires good operating practices and operator training. 

COMAR 26.11.14.07 - Kraft Pulp Mill is a NOx trading source that was recently adopted by Maryland, but has not been submitted to EPA.  The emission limit for this regulation is 947 tons of NOx during ozone season (May 1  -  September 30), and the emissions rate of .99 pounds of NOx per million Btu during the remainder of the year (October 1  -  April 30).  The annual trading of NOx allowances is limited to 95 tons of NOx.   See pages 49 and 50 of Maryland's SIP submittal for the full NOx RACT analysis.  

COMAR 26.11.29.03  -  Portland Cement Manufacturing Plants requires cement kilns to install low NOx burners or mid-kiln firing.  For long, dry kilns the maximum emissions of 5.1 lbs per ton clinker is required and for pre-heater and pre-calciner kilns the maximum emissions of 2.8 lbs per NOx per ton clinker is required.

COMAR 26.11.29.05 B & C- Stationary Internal Combustions Engines at Natural Gas Compression Stations.  Sources subject to this regulation had two options for compliance: (1) on or before May 1, 2003, meet the applicable NOx emission standard listed in Table 5 below; or (2) on or before May 1, 2001, submit to Maryland for approval, a proposal to reduce NOx emissions less than 90 percent from the 1995 base year emissions. 


Table 5.  Maryland's Emission Standards for Stationary Internal Combustions Engines at Natural Gas Compression Stations
Type Engine 
Size (brake horsepower (HP)) 
Standard (15 percent oxygen) 
Spark ignited rich burn 
2400 HP or greater 
110 parts per million by volume (ppmv) 
Spark ignited lean burn 
2400 HP or greater 
125 ppmv 
Diesel engines 
3100 HP or greater 
175 ppmv 
Dual fuel engines 
4400 HP or greater 
125 ppmv 
--------------------------------------------------------------------------------
Top of Form
Bottom of Form
EPA has reviewed the NOx RACT analyses developed by Maryland and agrees that the analyses meet the RACT requirements for the 1997 8-hour ozone standard.


V.       EPA Evaluation

Maryland's SIP revision contains the requirements of RACT set forth by the CAA.  Maryland's SIP revision satisfies the 1997 8-hour ozone NAAQS RACT requirements through (1) certification that previously adopted RACT controls in Maryland's SIP that were approved by EPA under the 1-hour ozone NAAQS are based on the currently available technically and economically feasible controls, and that they continue to represent RACT for the 8-hour implementation purposes; (2) a negative declaration demonstrating that no facilities exist in the state for the applicable CTG categories; and (3) adoption of new or more stringent RACT determinations.  Therefore, this revision will help Maryland attain and maintain the NAAQS for ozone.


VI.       Conclusion and Recommended Agency Action

This SIP revision request satisfies all requirements for an acceptable SIP revision.  EPA approval of Maryland's 1997 8-hour Ozone RACT SIP revision is recommended.



