UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029



DATE:

	February 12, 2013



SUBJECT:

	Technical Support Document for the Allegheny County, Pennsylvania
Reasonably Available Control Technology Under the 8-hour Ozone National
Ambient Air Quality Standard	 	 

 FROM:

	Melissa Linden, Life Scientist  

Office of Air Program Planning (3AP30)

TO:

REVIEWED BY:	SIP Docket File

              /s/                        

Cristina Fernandez, Associate Director  

Office of Air Program Planning (3AP30)



I.	Affected Regulation

The revision to the Allegheny County section of the Pennsylvania State
Implementation Plan (SIP), submitted on May 5, 2009, applies to the
demonstration that the area meets the requirements of reasonably
available control technology (RACT) for nitrogen oxides (NOx) and
volatile organic compounds (VOCs) set forth by the Clean Air Act (CAA)
for the 1997 8-Hour Ozone National Ambient Air Quality Standard (NAAQS).

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 ozone nonattainment areas.  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, 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 ozone
transport regions (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.

  

The first RACT requirement for ozone nonattainment areas, contained in
section 182(a)(2)(A) of the CAA, required Allegheny County to submit a
SIP revision correcting RACT rules prior to the CAA amendment in 1990. 
The second RACT requirement for ozone nonattainment areas, set forth in
section 182(b)(2) of the CAA, requires the Commonwealth of Pennsylvania
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.  

On July 18, 1997 (62 FR 38856), EPA promulgated the new 8-hour NAAQS for
ozone.  Under the 8-hour ozone NAAQS, Allegheny County was designated
nonattainment for the 8-hour ozone standard and is required to submit to
EPA a SIP revision that demonstrates how the County meets the RACT
requirements under the 8-hour ozone standard.  

EPA requires under the 8-hour ozone NAAQS that states meet the CAA RACT
requirements, either through a certification that previously adopted
RACT controls in their SIP approved by EPA under the 1-hour ozone NAAQS
represent adequate RACT control levels for 8-hour attainment purposes,
or through the adoption of new or more stringent regulations that
represent RACT control levels.  See, Final Rule To Implement the 8-Hour
Ozone National Ambient Air Quality Standard--Phase 2; Final Rule To
Implement Certain Aspects of the 1990 Amendments Relating to New Source
Review and Prevention of Significant Deterioration as They Apply in
Carbon Monoxide, Particulate Matter and Ozone NAAQS; Final Rule for
Reformulated Gasoline (Phase 2 Rule) 70 FR 71612, 71655, November 29,
2005.  Sections 172(c)(1) and 182(b)(2) of the CAA require that all SIPs
satisfy the NOx and VOCs RACT requirements that apply in areas that have
not attained the NAAQS for ozone.  See, 42 U.S.C. 7502(c)(1), 42 U.S.C.
7511a(b)(2), and 42 U.S.C. 7511a(f).  EPA has determined that States
that have RACT provisions approved in their SIPs for 1-hour ozone
nonattainment areas have several options for fulfilling the RACT
requirements for the 8-hour ozone NAAQS.  If a State meets certain
conditions, it may certify that previously adopted 1-hour ozone RACT
controls in the SIP continue to represent RACT control levels for
purposes of fulfilling 8-hour ozone RACT requirements.  Alternatively, a
State may adopt new or more stringent regulations that represent RACT
control levels, either in lieu of or in conjunction with a
certification.

  

As set forth in the preamble to the Phase 2 Rule, a certification must
be accompanied by appropriate supporting information such as
consideration of information received during the public comment period
and consideration of new data (70 FR 71655).  This information may
supplement existing RACT guidance documents that were developed for the
1-hour standard, such that the State’s SIP accurately reflects RACT
for the 8-hour ozone standard based on the current availability of
technically and economically feasible controls.  Adoption of new RACT
regulations will occur when states have new stationary sources not
covered by existing RACT regulations, or when new data or technical
information indicates that a previously adopted RACT measure does not
represent a newly available RACT control level.  Another 8-hour ozone
NAAQS requirement for RACT is to submit a negative declaration if there
are no CTG major sources of VOC and NOx emissions in lieu of or in
addition to a certification.

VOC CTG RACT Controls

Allegheny County’s Regulations codified at Article XXI, contain the
County’s CTG VOC RACT controls that were implemented and approved in
the Allegheny County SIP under the 1-hour ozone NAAQS.  Table 1 lists
Allegheny County’s VOC RACT controls for which Allegheny County has
provided the required evaluation and is certifying as meeting the 8-hour
ozone NAAQS RACT requirements.  Revisions to the CTG VOC RACT
regulations were made after the May 6, 2009 submittal and were approved
by EPA on December 28, 2010 (75 FR 81480) and supersede the current
action being taken by EPA.  

Table 1.  Allegheny County’s CTG VOC RACT Controls

Article XXI

Section	Existing Stationary Sources – 40 CFR 52.2020 (c)

	CTG for RACT Basis	State Effective Date	Federal Register Date for SIP
Approval	Citation

2105.10 VOC Sources Surface Coating Processes	Control of Volatile
Organic Emissions from Existing Stationary Sources, Volume II: Surfact
Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty
Trucks

Control of Volatile Organic Emissions from Existing Stationary Sources,
Volume III: Surface Coating of Metal Furniture

Control of Volatile Organic Emissions from Existing Stationary Sources,
Volume IV: Surface Coating for Insulation of Magnet Wire

Control of Volatile Organic Emissions from Existing Stationary Sources,
Volume V: Surface Coating of Large Appliances

Control of Volatile Organic Emissions from Existing Stationary Sources,
Volume VI: Surface Coating of Miscellaneous Metal Parts and Products
10/20/1995

07/10/03	11/14/2002

06/24/2005	67 FR 68935

70 FR 36511

2105.11 VOC Sources Graphic Arts Systems	Control of Volatile Organic
Emissions from Existing Stationary Sources, Volume VIII: Graphic Arts
– Rotogravure and Flexography	10/20/1995	11/14/2002	67 FR 68935

2105.12

VOC Sources VOC Storage Tanks	Control of Volatile Organic Emissions from
Petroleum Liquid Storage in External Floating Roof Tanks	10/20/1995
11/14/2002	67 FR 68935

2105.13

Gasoline Loading Facilities 	Control of Volatile Organic Emissions from
Bulk Gasoline Plants

Design Criteria for Stage I Vapor Control Systems – Gasoline Service
Stations	10/20/1995	11/14/2002	67 FR 68935

2105.15 Degreasing Operations 	Control of Volatile Organic Emissions
from Solvent Metal Cleaning	10/20/1995	11/14/2002 	67 FR 68935

2105.16 Cutback Asphalt Paving	Control of Volatile Organic Compounds
from Use of Cutback Asphalt	10/20/1995	11/14/2002	67 FR 68935

2105.17 Ethylene Production Facilities

10/20/1995	11/14/2002	67 FR 68935

2105.19 Synthetic Organic Chemical and Polymer Manufacturing –
Fugitive Emissions	Control of Volatile Organic Compound Fugitive
Emissions from Synthetic Organic Chemical Polymer and Resin
Manufacturing Equipment	10/20/1995	11/14/2002	67 FR 68935

2105.70 Petroleum Refineries

10/20/1995	11/14/2002	67 FR 68935

2105.71 Pharmaceutical Products	Control of Volatile Organic Emissions
from Manufacture of Synthesized Pharmaceutical Products	10/20/1995
11/14/2002	67 FR 68935

2105.72 Manufacture of Pneumatic Rubber Tires	Control of Volatile
Organic Emissions from Manufacture of Pneumatic Rubber Tires	10/20/1995
11/14/2002	67 FR 68935

2105.74 Aerospace Manufacturing and Rework	Aerospace	07/10/2003
06/24/2005	70 FR 36511

2105.75 Mobile Equipment Repair and Refinishing	ACT: Automobile Body
refinishing	07/10/2003	06/24/2005	70 FR 36511

2105.76 Wood Furniture Manufacturing Operations	Wood Furniture
07/10/2003	06/24/2005	70 FR 36511



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, Allegheny County included ACTs in their
review of applicable RACT requirements in this submittal.

	Allegheny County also submitted a negative declaration certifying that
the following VOC CTG major sources do not exist in the county and
therefore there is no need to adopt CTGs for these sources.  Table 2
lists VOC CTG major sources in Allegheny County’s negative
declaration.  A separate submittal was made by Allegheny County
submitting the negative declaration for Volatile Organic Emissions from
Large Petroleum Dry Cleaners on January 8, 2009. 

Table 2.  VOC CTG sources for which no Applicable Facilities Exist in
Allegheny County



Control of Volatile Organic Compound Emissions from Large Petroleum Dry
Cleaners

Control of Volatile Organic Emissions from Existing Stationary Sources,
Volume II: Factory Surface Coating of Flat Wood Paneling

Control of Volatile Organic Compound Equipment Leaks from Natural
Gas/Gasoline Processing Plants 

Processing Plants 

Control of Volatile Organic Compound Emissions from Air Oxidation
Processes in Synthetic Organic Chemical Manufacturing Industry

Control of Volatile Organic Compound Emissions from Reactor Processes
and Distillation Operations Processes in the Synthetic Organic Chemical
Manufacturing Industry 

Shipbuilding/Repair 



B.  Source-Specific RACT Controls

Table 3.  Source-Specific RACT Controls

Facility Name	State Effective Date	Pollutant	Federal Register Date
Citation

Allegheny Ludlum Corporation	12/19/1996	NOx/VOC	10/18/2001	66 FR 52857

Ashland Specialty Chemical Co.	12/30/1996	NOx/VOC	10/16/2001	66 FR 52506

Bay Valley Foods	06/09/2005	NOx	05/11/2006	71 FR 27394

Bellefield Boiler Plant	12/19/1996	NOx	10/12/2001	66 FR 52044

Eastman Chemical Resins, Inc.	11/01/1999	NOx/VOC	10/16/2001	66 FR 52506

GE Lighting LLC	12/19/1996	NOx	10/16/2001	66 FR 52527

Guardian Industries Corp.	08/27/1996	NOx	10/16/2001	66 FR 52527

Koppers Industries, Inc.	08/27/1996	VOC	10/17/2001	66 FR 52700

Neville Chemical Co.	12/13/1996	NOx/VOC	10/16/2001	66 FR 52506

NRG Energy Center	06/09/2005	NOx	05/11/2006	71 FR 27394

Orion Power Brunot Island	08/27/1996	NOx/VOC	10/15/2001	66 FR 52327

Orion Power Cheswick	03/08/1996	NOx	10/18/2001	66 FR 52867

PACT – Pennsylvania Allegheny County Thermal	03/04/1996	NOx	10/12/2001
66 FR 52044

Port Glenshaw Glass, LLC	03/10/2000	NOx/VOC	10/16/2001	66 FR 52527

PPG Industries, Inc Springdale	12/19/1996	VOC	10/12/2001	66 FR 52050

Pressure Chemical Company	06/11/1997	VOC	10/17/2001 	66 FR 52700

Shenango Inc.	12/30/1996	NOx/VOC	10/16/2001	66 FR 52511

US Steel Clairton	12/30/1996	NOx/VOC	10/16/2001	66 FR 52511

US Steel Edgar Thomas	12/30/1996	NOx/VOC	10/16/2001	66 FR 52511

US Steel Irvin	12/30/1996	NOx/VOC	10/16/2001	66 FR 52511



The sources in Table 3, required a re-evaluation of the 1-hour RACT
determinations for 8-hour RACT and EPA’s summary of those is provided
below. 

Allegheny Ludlum 

	The facility is a major source for VOC and NOx. The only change at the
facility affecting VOC and NOx emissions was the replacement of four
electric arc furnaces by two larger capacity electric arc furnaces. The
1-hour RACT determination was good engineering and air pollution control
practices for electric arc furnaces and that remains the determination
for 8-hour RACT because the selective non-catalytic reduction (SNCR) and
selective catalytic reduction (SCR) have not been applied to control NOx
emission from an electric arc furnace before. For VOC emission the
catalytic oxidizer is technically infeasible and the thermal oxidizer is
economically infeasible. For details of this evaluation please see
Allegheny County’s supplemental information dated March 9, 2012. 

Ashland Inc.

	The facility shut down the Maleic Anhydride Plant in 2006 and with the
facility closure the potential-to-emit (PTE) for VOCs is below the
threshold for a major source.  Ashland also agreed in the Title V
process to limit the fuel use in two boilers as well as a facility-wide
limit of 98 tons per year (tpy) of NOx, which makes it a synthetic minor
source. 

Bay Valley Foods

	This facility is a NOx RACT source.  Allegheny County evaluated flue
gas recirculation (FGR), combustion optimization which is already being
done on all boilers, ultra-low nitrogen fuels, SCR, SNCR, and fuel
switching for NOx controls.  It was determined that all of these control
options were either economically or technically infeasible for this
facility.  For details of this evaluation please see Allegheny
County’s supplemental information dated March 9, 2012. 

Bellefield Boiler Plant

	This facility is a major source for NOx.  The plant has 6 boilers which
fire coal, natural gas, No.2 fuel oil or combinations of fuels. 
Allegheny County evaluated SNCR, SCR, wet scrubbing, gas-fired
combustors/Low NOx Burners/FGR, fuel switching and natural gas only.  It
was determined that all of control options were either economically or
technically infeasible for this facility.  For details of this
evaluation please see Allegheny County’s supplemental information
dated March 9, 2012. 

Eastman Chemical Resins, Inc. 

	This facility is a major source for VOC.  It was determined for the
polymerization processes, resin hydrogenation process, five finishing
processes and an emulsion process that there were no additional controls
that were not cost prohibitive.  For storage tanks in the facility about
40 are subject to section 2105.12 Article XXI, “VOC Storage Tanks”
and the rest have been determined to have no additional control options
that were reasonable for RACT.  It would be cost prohibitive to install
covers and a refrigerated condenser system on the wastewater treatment
plant so RACT is still proper operation and maintenance.  For details of
this evaluation please see Allegheny County’s supplemental information
dated March 9, 2012.

General Electric (GE) Lighting 

	This facility is a major source for NOx.  RACT for the glass melting
furnaces are in Table 4 below.  RACT for the miscellaneous combustion
units shall be installation, maintenance, and operation of the sources
in accordance with manufacturer’s specifications at all times.  For
details of this evaluation please see Allegheny County’s supplemental
information dated March 9, 2012.

Table 4.  Glass Melting Furnaces at GE with Controls being Utilized. 

NOx Emission Unit 	Baseline Level of NOx Control 

F2-8 

Simplex Furnace 	Oxy-firing 

Low Excess Air 

Electric Boost 

Use of Cullet in Batches 

Adherence to Manufacturer’s Specifications 

F3-4 

Gas/Electric Furnace 	Oxy-firing 

Low Excess Air 

Electric Boost 

Use of Cullet in Batches 

Adherence to Manufacturer’s Specifications 

F4-3 

Frit Furnace 	Adherence to Manufacturer’s Specifications 

F6-3 

Germicidal Furnace 	Low Excess Air 

Adherence to Manufacturer’s Specifications 

F7-4 

Special Furnace 	Oxy-firing 

Low Excess Air 

Electric Boost 

Use of Cullet in Batches 

Adherence to Manufacturer’s Specifications 

F8-6 

180 Furnace 	Low Excess Air 

Oxygen Enrichment 

Use of Cullet in Batches 

Adherence to Manufacturer’s Specifications



Guardian Industries Corporation 

	This facility is a major source of NOx and the facility is already
utilizing all technically feasible control options and techniques for
the melting furnace as listed in the Table 5 below.  For details of this
evaluation please see Allegheny County’s supplemental information
dated March 9, 2012.

Table 5.  Glass Melting Furnace at Guardian Industries and Controls
being Utilized.

NOx Emission Unit 	Baseline Level of NOx Control 

S001: Melting Furnace 	Oxy-firing 

Low-NOx burners 

Minimize excess air 

Electric boost 

Maximize cullet in batches 

Minimize nitrates in batches 

Minimize furnace temperatures 

Adherence to Manufacturer’s Specifications 



Koppers, Inc. 

	This facility is a major source for VOC.  Allegheny County evaluated
thermal oxidation, catalytic oxidation, flaring, carbon adsorption,
condensation, scrubbing, and submerged fill as control options and
determined that no control options were both technically and
economically feasible.  RACT for 8-hour ozone NAAQS is to extend the
leak detection and repair program to equipment that was not subject
under 1-hour ozone RACT and for the product loading to be done in a
submerged fill pipe.  For details of this evaluation please see
Allegheny County’s supplemental information dated March 9, 2012.

Neville Chemical Company

	This facility is a major source of NOx and VOC.  For NOx the facility
boilers are subject to presumptive RACT which is in Article XXI, section
2105.06(d)(2).  For VOC Allegheny County evaluated thermal oxidation,
concentrator/oxidation, catalytic oxidation, flaring, carbon adsorption,
condensation and absorption as technically feasible options.  None of
the VOC controls were determined to be economically feasible, so RACT
will be the same as 1-hour requirements.  For details of this evaluation
please see Allegheny County’s supplemental information dated March 9,
2012.

NRG Energy Center

	This facility is a major source of NOx and four boilers and three
generators.  The 8-hour RACT will keep the same limits for boilers 1-3
and add boiler 4 and the emergency generators because they were
installed after 1-hour RACT determinations were made.  For details of
this evaluation please see Allegheny County’s supplemental information
dated March 9, 2012.

Orion Power MidWest, L.P.

	This facility is a major source of NOx and VOC.  Allegheny County has
determined that no NOx controls are technically or economically feasible
for the three turbines using the ACT document for combustion turbines. 
Allegheny County has also determined that no add-on VOC controls would
be cost effective for the turbines due to the low maximum potential of
VOC emissions for those turbines.  For details of this evaluation please
see Allegheny County’s supplemental information dated March 9, 2012.

Cheswick Power Station

	This facility is a major source of NOx.  Since the 1-hour RACT
determination was made the facility’s emissions are regulated during
the ozone season by Pennsylvania Nitrogen Oxide Allowance Program in
permit # 02-0054 and SCR was installed to run during the ozone season
for the main boiler.  The auxiliary boiler will have a 12-month rolling
limit on British thermal units (Btu) input of 438,000 MMBtu.  For
details of this evaluation please see Allegheny County’s supplemental
information dated March 9, 2012.

Pittsburgh Allegheny County Thermal, Ltd. 

	This facility is a major source for NOx.  The facility has four boilers
that burn natural gas as their primary fuel source and can burn No. 2
fuel oil in emergency situations.  It was determined that no additional
NOx controls were both technically and economically feasible.  For
details of this evaluation please see Allegheny County’s supplemental
information dated March 9, 2012.

Glenshaw Glass

	This facility was damaged in a flood and shutdown on November 24, 2004.
 In the process of restarting the facility, the furnace that was
repaired ceased operating again to apply for emission reduction credits,
thus triggering it to be subject as a new source and completing best
available control technology (BACT) review.  The operating furnace has
installed BACT and the remaining furnaces are currently deactivated and
will require BACT if they are reactivated.  For details of this
evaluation please see Allegheny County’s supplemental information
dated March 9, 2012.

PPG Industries, Inc.

	The facility is a major source of VOC.  The 1-hour RACT determination
included conditions for the resin plant, which is no longer in
operation.  The emissions from the Paint Plant and Development Center
are currently vented to the thermal oxidizer, which has a demonstrated
destruction efficiency of 94.5%.  For details of this evaluation please
see Allegheny County’s supplemental information dated March 9, 2012.

Pressure Chemical Company

	This facility is a major source of VOC.  Allegheny County evaluated the
use of regenerative thermal oxidizer, thermal incinerator, and catalytic
incinerator as VOC control technologies and determined that although
they were technically feasible they are not economically feasible.  For
details of this evaluation please see Allegheny County’s supplemental
information dated March 9, 2012.

Shenango Incorporated

	This facility is a major source of VOC and NOx.  The facility replaced
four boilers with more efficient Low NOx Burner boilers since the 1-hour
RACT determination.  The facility went through BACT determination of
using Low NOx Burner and FGR on the four new boilers with heat input
capacity limit of 265.2 MMBtu/hour.  Nitrogen blanketing system has been
installed on the majority of VOC sources associated with the by-product
plant.  For all other sources proper combustion technology/design,
operation and maintenance of all other emission units according to good
engineering and air pollution control practices at all times is
considered RACT for NOx and VOC.  For details of this evaluation please
see Allegheny County’s supplemental information dated March 9, 2012.

U.S. Steel Clairton Works

	This facility is a major source of VOC and NOx.  It was determined that
no additional VOC or NOx control equipment was technically and
economically feasible for this facility beyond the 1-hour RACT
determination.  For details of this evaluation please see Allegheny
County’s supplemental information dated March 9, 2012.

U.S. Steel Edgar Thomson Works

	This facility is a major source of VOC and NOx.  It was determined that
no additional VOC or NOx control equipment was technically and
economically feasible for this facility beyond the 1-hour RACT
determination.  For details of this evaluation please see Allegheny
County’s supplemental information dated March 9, 2012.

	

III.       Evaluation

Allegheny County’s SIP revision contains the requirements of RACT set
forth by the CAA under the 8-hour ozone NAAQS.  Allegheny County’s SIP
revision satisfies the 8-hour RACT requirements through (1)
certifications that previously adopted RACT controls in Allegheny
County’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 continues to represent RACT for the 8-hour
implementation purposes; (2) a negative declaration demonstrating that
no facilities exist in the area for the applicable CTG categories; and
(3) a new RACT determination for a single source.  Therefore, approval
of Allegheny County’s 8-hour RACT SIP is recommended.

IV.       Conclusion

This SIP revision request satisfies all requirements for an acceptable
SIP revision.

V.	    Recommended Agency Action

The SIP revision request should be approved.

	

