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

DATE:

April 10, 2020
SUBJECT:
Technical Support Document for the Pennsylvania State Implementation Plan Revisions Related to Reasonably Available Control Technology (RACT) Determinations for Case-by-Case Sources under the 1997 and 2008 8-Hour Ozone National Ambient Air Quality Standards (NAAQS); 9 Sources

FROM:
Emily Bertram, Physical Scientist /s/
Permits Branch 

TO:
File for Docket ID Number EPA-R03-OAR-2019-0657

THRU:
Mary Cate Opila, P.E., Ph.D., Branch Chief /s/
Permits Branch


A.  INTRODUCTION

The Environmental Protection Agency (EPA) is taking action on a submittal made by the Commonwealth of Pennsylvania to satisfy the reasonably available control technology (RACT) requirements under sections 182 and 184 of the Clean Air Act (CAA) for the 1997 and 2008 8-hour ozone national ambient air quality standards (NAAQS).  This submission was also required pursuant to a conditional approval and was submitted in order to satisfy the conditional nature of that action.  See 84 FR 20274 (May 9, 2019).  


B.  BACKGROUND

1997 and 2008 8-Hour Ozone NAAQS

Ground level ozone is not emitted directly into the air but is created by chemical reaction between NOx and VOC in the presence of sunlight.  Emissions from industrial facilities, electric utilities, motor vehicle exhaust, gasoline vapors, and chemical solvents are some of the major sources of NOx and VOC.  Breathing ozone can trigger a variety of health problems, particularly for children, the elderly, and people of all ages who have lung diseases such as asthma.  Ground level ozone can also have harmful effects on sensitive vegetation and ecosystems.

On July 18, 1997, EPA promulgated a standard for ground level ozone based on 8-hour average concentrations.  62 FR 38856.  The 8-hour averaging period replaced the previous 1-hour averaging period, and the level of the NAAQS was changed from 0.12 parts per million (ppm) to 0.08 ppm.  EPA has designated two moderate nonattainment areas in Pennsylvania under the 1997 8-hour ozone NAAQS, namely Philadelphia-Wilmington-Atlantic City, PA-NJ-MD-DE (the Philadelphia Area) and Pittsburgh-Beaver Valley (the Pittsburgh Area).  See 40 CFR 81.339.  

On March 12, 2008, EPA strengthened the 8-hour ozone standards, by revising its level to 0.075 ppm averaged over an 8-hour period (2008 8-hour ozone NAAQS).  On May 21, 2012, EPA designated five marginal nonattainment areas in Pennsylvania for the 2008 8-hour ozone NAAQS:  Allentown-Bethlehem-Easton, Lancaster, Reading, the Philadelphia Area, and the Pittsburgh Area.  77 FR 30088; see also 40 CFR 81.339.  
    
On March 6, 2015, EPA announced its revocation of the 1997 8-hour ozone NAAQS for all purposes and for all areas in the country, effective on April 6, 2015.  80 FR 12264.  EPA has determined that certain nonattainment planning requirements continue to be in effect under the revoked standard for nonattainment areas under the 1997 8-hour ozone NAAQS, including RACT.

RACT Requirements for Ozone

The CAA regulates emissions of NOx and VOC to prevent photochemical reactions that result in ozone formation.  RACT is an important strategy for reducing NOx and VOC emissions from major stationary sources within areas not meeting the ozone NAAQS.  

Areas designated nonattainment for the ozone NAAQS are subject to the general nonattainment planning requirements of CAA section 172.  Section 172(c)(1) of the CAA provides that SIPs for nonattainment areas must include reasonably available control measures (RACM) for demonstrating attainment of all NAAQS, including emissions reductions from existing sources through the adoption of RACT.  Further, section 182(b)(2) of the CAA sets forth additional RACT requirements for ozone nonattainment areas classified as moderate or higher.   

Section 182(b)(2) of the CAA sets forth requirements regarding RACT for the ozone NAAQS for VOC sources.  Section 182(f) subjects major stationary sources of NOx to the same RACT requirements applicable to major stationary sources of VOC.    

Section 184(b)(1)(B) of the CAA applies the RACT requirements in section 182(b)(2) to nonattainment areas classified as marginal and to attainment areas located within ozone transport regions established pursuant to section 184 of the CAA.  Section 184(a) of the CAA established by law the current Ozone Transport Region (OTR) comprised of 12 eastern states, including Pennsylvania.  This requirement is referred to as OTR RACT.  As noted previously, a "major source" is defined based on the source's PTE of NOx, VOC, or both pollutants, and the applicable thresholds differ based on the classification of the nonattainment area in which the source is located.  See sections 182(c)-(f) and 302 of the CAA.  
Since the 1970's, EPA has consistently defined "RACT" as 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.  

EPA has provided more substantive RACT requirements through implementation rules for each ozone NAAQS as well as through guidance.  In 2004 and 2005, EPA promulgated an implementation rule for the 1997 8-hour ozone NAAQS in two phases ("Phase 1 of the 1997 Ozone Implementation Rule" and "Phase 2 of the 1997 Ozone Implementation Rule").  69 FR 23951 (April 30, 2004) and 70 FR 71612 (November 29, 2005), respectively.  Particularly, the Phase 2 Ozone Implementation Rule addressed RACT statutory requirements under the 1997 8-hour ozone NAAQS.  See 70 FR 71652  

On March 6, 2015, EPA issued its final rule for implementing the 2008 8-hour ozone NAAQS ("the 2008 Ozone SIP Requirements Rule").  80 FR 12264.  At the same time, EPA revoked the 1997 8-hour ozone NAAQS, effective on April 6, 2015.  The 2008 Ozone SIP Requirements Rule provided comprehensive requirements to transition from the revoked 1997 8-hour ozone NAAQS to the 2008 8-hour ozone NAAQS, as codified in 40 CFR part 51, subpart AA, following revocation.  Consistent with previous policy, EPA determined that areas designated nonattainment for both the 1997 and 2008 8-hour ozone NAAQS at the time of revocation, must retain implementation of certain nonattainment area requirements (i.e., anti-backsliding requirements) for the 1997 8-hour ozone NAAQS as specified under section 182 of the CAA, including RACT.  See 40 CFR 51.1100(o).  An area remains subject to the anti-backsliding requirements for a revoked NAAQS until EPA approves a redesignation to attainment for the area for the 2008 8-hour ozone NAAQS.  There are no effects on applicable requirements for areas within the OTR, as a result of the revocation of the 1997 8-hour ozone NAAQS.  Thus, Pennsylvania, as a state within the OTR, remains subject to RACT requirements for both the 1997 8-hour ozone NAAQS and the 2008 8-hour ozone NAAQS. 

In addressing RACT, the 2008 Ozone SIP Requirements Rule is consistent with existing policy and Phase 2 of the 1997 Ozone Implementation Rule.  In the 2008 Ozone SIP Requirements Rule, EPA requires RACT measures to be implemented by January 1, 2017 for areas classified as moderate nonattainment or above and all areas of the OTR.  EPA also provided in the 2008 Ozone SIP Requirements Rule that RACT SIPs must contain adopted RACT regulations, certifications where appropriate that existing provisions are RACT, and/or negative declarations stating that there are no sources in the nonattainment area covered by a specific control technique guidelines (CTG) source category.  In the preamble to the 2008 Ozone SIP Requirements Rule, EPA clarified that states must provide notice and opportunity for public comment on their RACT SIP submissions, even when submitting a certification that the existing provisions remain RACT or a negative declaration.  States must submit appropriate supporting information for their RACT submissions, in accordance with the Phase 2 of the 1997 Ozone Implementation Rule.  Adequate documentation must support that states have considered control technology that is economically and technologically feasible in determining RACT, based on information that is current as of the time of development of the RACT SIP.

In addition, in the 2008 Ozone SIP Requirements Rule, EPA clarified that states can use weighted average NOx emissions rates from sources in the nonattainment area for meeting the major NOx RACT requirement under the CAA, as consistent with existing policy.  EPA also recognized that states may conclude in some cases that sources already addressed by RACT determinations for the 1-hour and/or 1997 8-hour ozone NAAQS may not need to implement additional controls to meet the 2008 8-hour ozone NAAQS RACT requirement.  See 80 FR 12278-12279.

Applicability of RACT Requirements in Pennsylvania

As indicated earlier, RACT requirements apply to any ozone nonattainment areas classified as moderate or higher (serious, severe or extreme) under CAA sections 182(b)(2) and 182(f).  Pennsylvania has outstanding ozone RACT requirements for both the 1997 and 2008 8-hour ozone NAAQS.  The entire Commonwealth of Pennsylvania is part of the OTR established under section 184 of the CAA and thus is subject statewide to the RACT requirements of CAA sections 182(b)(2) and 182(f), pursuant to section 184(b).

At the time of revocation of the 1997 8-hour ozone NAAQS (effective April 6, 2015), only two moderate nonattainment areas remained in the Commonwealth of Pennsylvania for this standard, the Philadelphia and the Pittsburgh Areas.  As required under EPA's anti-backsliding provisions, these two moderate nonattainment areas continue to be subject to RACT under the 1997 8-hour ozone NAAQS.  Given its location in the OTR, the remainder of the Commonwealth is also treated as moderate nonattainment area under the 1997 8-hour ozone NAAQS for any planning requirements under the revoked standard, including RACT.  The OTR RACT requirement is also in effect under the 2008 8-hour ozone NAAQS throughout the Commonwealth, since EPA did not designate any nonattainment areas above marginal for this standard in Pennsylvania.  Thus, in practice, the same RACT requirements continue to be applicable in Pennsylvania for both the 1997 and 2008 8-hour ozone NAAQS.  RACT must be evaluated and satisfied as separate requirements under each applicable standard.

RACT applies to major sources of NOx and VOC under each ozone NAAQS or any VOC sources subject to CTG RACT.  Which NOx and VOC sources in Pennsylvania are considered "major" and are therefore subject to RACT is dependent on the location of each source within the Commonwealth.  Sources located in nonattainment areas would be subject to the "major source" definitions established under the CAA.  In the case of Pennsylvania, sources located in any areas outside of moderate or above nonattainment areas, as part of the OTR, shall be treated as if these areas were moderate.

In Pennsylvania, the SIP program is implemented primarily by the PADEP, but also by local air agencies in Philadelphia County (the City of Philadelphia's Air Management Services [AMS]) and Allegheny County, (the Allegheny County Health Department [ACHD]).  These agencies have implemented numerous RACT regulations and source-specific measures in Pennsylvania to meet the applicable ozone RACT requirements.  Historically, statewide RACT controls have been promulgated by PADEP in Pennsylvania Code Title 25- Environmental Resources, Part I- Department of Environmental Protection, Subpart C- Protection of Natural Resources, Article III- Air Resources, (25 Pa. Code) Chapter 129.  AMS and ACHD have incorporated by reference Pennsylvania regulations, but have also promulgated regulations adopting RACT controls for their own jurisdictions.  In addition, AMS and ACHD have submitted separate source-specific RACT determinations as SIP revisions for sources within their respective jurisdictions, which have been approved by EPA.  See 40 CFR 52.2020(d)(1).

States were required to make RACT SIP submissions for the 1997 8-hour ozone NAAQS by September 15, 2006.  PADEP submitted a SIP revision on September 25, 2006, certifying that a number of previously approved VOC RACT rules continued to satisfy RACT under the 1997 8-hour ozone NAAQS for the remainder of Pennsylvania.  PADEP has met its obligations under the 1997 8-hour ozone NAAQS for its CTG and non-CTG VOC sources.  See 82 FR 31464 (July 7, 2017).  RACT control measures addressing all applicable CAA RACT requirements under the 1997 8-hour ozone NAAQS have been implemented and fully approved in the jurisdictions of ACHD and AMS.  See 78 FR 34584 (June 10, 2013) and 81 FR 69687 (October 7, 2016).  For the 2008 8-hour ozone NAAQS, states were required to submit RACT SIP revisions by July 20, 2014.  On May 16, 2016, PADEP submitted a SIP revision addressing RACT under both the 1997 and 2008 8-hour ozone NAAQS in Pennsylvania.  Specifically, the May 16, 2016 SIP submittal intends to satisfy sections 182(b)(2)(C), 182(f), and 184 of the CAA for both the 1997 and 2008 8-hour ozone NAAQS for Pennsylvania's major NOx and VOC non-CTG sources, except ethylene production plants, surface active agents manufacturing, and mobile equipment repair and refinishing.

Pennsylvania's RACT II SIP and EPA's Conditional Approval

On May 16, 2016, PADEP submitted a SIP revision addressing RACT under both the 1997 and 2008 8-hour ozone NAAQS in Pennsylvania.  PADEP's May 16, 2016 SIP revision intended to address certain outstanding non-CTG VOC RACT, VOC CTG RACT, and major NOx RACT requirements under the CAA for both standards.  The SIP revision requested approval of Pennsylvania's 25 Pa. Code 129.96-100, Additional RACT Requirements for Major Sources of NOx and VOCs (the RACT II rule).  Prior to the adoption of the RACT II rule, Pennsylvania relied on the NOx and VOC control measures in 25 Pa. Code 129.92-95, Stationary Sources of NOx and VOCs, (the RACT I rule) to meet RACT for non-CTG major VOC sources and major NOx sources.  The requirements of the RACT I rule remain in effect and continue to be implemented as RACT.  On September 26, 2017, PADEP submitted a supplemental SIP revision which committed to address various deficiencies identified by EPA in their May 16, 2016 RACT II rule SIP revision.  

On May 9, 2019, EPA conditionally approved the RACT II rule based on PADEP's September 26, 2017 commitment letter.  See 84 FR 20274.  In EPA's final conditional approval, EPA noted that PADEP would be required to submit, for EPA's approval, SIP revisions to address any facility-wide or system-wide averaging plan approved under 25 Pa. Code 129.98 and any source-specific RACT determinations under 25 Pa. Code 129.99.  PADEP committed to submitting these additional SIP revisions within 12 months of EPA's final conditional approval, specifically May 9, 2020.

Therefore, as authorized in CAA section 110(k)(3) and (k)(4), Pennsylvania shall submit the following as source-specific SIP revisions, by May 9, 2020, for EPA's approval as a condition of approval of 25 Pa. Code 128 and 129 in the May 16, 2016 SIP revision: (1) All facility-wide or system-wide averaging plans approved by PADEP under 25 Pa. Code 129.98 including, but not limited to, any terms and conditions that ensure the enforceability of the averaging plan as a practical matter (i.e., any monitoring, reporting, recordkeeping, or testing requirements); and (2) all source-specific RACT determinations approved by PADEP under 25 Pa. Code 129.99, including any alternative compliance schedules approved under 25 Pa. Code 129.97(k) and 129.99(i); the source-specific RACT determinations submitted to EPA for approval into the SIP should include any terms and conditions that ensure the enforceability of the source-specific RACT emission limitation as a practical matter (i.e., any monitoring, reporting, recordkeeping, or testing requirements).  See May 9, 2019 (84 FR 20274).  

In general, under the RACT II rule, there are two main source-specific concepts  - an "alternative RACT" and a "case-by-case RACT".  An "alternative RACT" submission is one that is made because a unit at the facility is unable to comply with the presumptive RACT emission limit under 25 Pa. Code 129.97, whereas a "case-by-case RACT" is a submission made because there is no presumptive RACT emission limit in 25 Pa. Code 129.97 that applies to that unit (i.e., VOC emissions from paint striping operations).  In both cases the owner or operator must do a source-specific, top-down RACT evaluation.  Throughout this document the term "case-by-case RACT" or "CbC RACT" will be used for both "alternative RACT" and "case-by-case RACT" evaluations.  


C.  SUMMARY OF PENNSYLVANIA'S SIP REVISIONS

On April 11, 2019, the Commonwealth of Pennsylvania submitted, through PADEP, a revision to its SIP to address the RACT requirements under sections 182 and 184 of the CAA for the 1997 and the 2008 8-hour ozone NAAQS for ten major facilities.  Table 1 below lists the state submittal date, the facilities included, and the permit number and permit effective date.
EPA views each facility as a separable SIP revision, and thus, should EPA receive comment on one facility but not others, EPA will treat the comment as only pertaining to that specific facility and may take separate, final action on the remaining facilities.  

Table 1  -  Pennsylvania SIP Submittals for Major NOx and/or VOC Sources Subject to RACT under 1997 and 2008 8-Hour Ozone NAAQS
                              SIP Submittal Date
                             Major Source (County)
                      1-Hour Ozone RACT Source? (RACT I)
                    Major Source Pollutant (NOx and/or VOC)
                        RACT II Permit (Effective Date)
                                   4/11/2019
                            Carpenter Co. (Lehigh)
                                      No
                                      VOC
                            39-00040    (9/5/2018)
                                       
            East Penn Manufacturing Co. Inc, Smelter Plant (Berks)
                                      No
                                  NOx and VOC
                             06-05040D (1/3/2019)
                                       
                     Ellwood Quality Steel Co. (Lawrence)
                                      Yes
                                  NOx and VOC
                             37-00264 (10/13/2017)
                                       
                    GE Transportation  -  Erie Plant (Erie)
                                      Yes
                                  NOx and VOC
                             25-00025  (2/21/2018)
                                       
                        Graymont Pleasant Gap (Centre)
                                      Yes
                                      NOx
                            14-00002    (2/5/2018)
                                       
                         Hazleton Generation (Luzerne)
                                      Yes
                                      NOx
                             40-00021  (6/19/2018)
                                       
                Helix Ironwood (formerly TC Ironwood) (Lebanon)
                                      No
                                      NOx
                            38-05019   (9/24/2018)
                                       
                         Magnesita Refractories (York)
                                      Yes
                                      NOx
                             67-05001 (11/27/2018)
                                       
                        Penn State University (Centre)
                                      Yes
                                      NOx
                             14-00003 (12/13/2017)
                                       
                    American Craft Brewery, LLC (Lehigh)[a]
                                   ---------
                                   ---------
                                   ---------
[a]  -  American Craft Brewery, LLC was withdrawn from EPA consideration on October 21, 2019.  EPA will be taking action on this source in a future rulemaking action, once resubmitted by PADEP for approval into the PA SIP

D.  ORGANIZATION OF THIS DOCUMENT

This technical support document (TSD) is organized in chapters where each chapter is dedicated to an individual facility.  EPA evaluated each facility independently to determine whether PADEP adequately identified RACT for each facility's sources and the following layout is used for consistency:  1) Facility Description and Processes, 2) Units Subject to Case-by-Case RACT II, 3) RACT I Considerations (if applicable), 4) Technical and Economic Feasibility, 5) PADEP's Conclusions, and 6) EPA's Conclusions and Recommendations.  


Contents
Acronyms and Abbreviations	10
Chapter 1:  Helix Ironwood, LLC (#38-05019)	12
Chapter 2:  GE Transportation  -  Erie (#25-00025)	14
Chapter 3:  Carpenter Co. (#39-00040)	18
Chapter 4:  Pennsylvania State University (#14-00003)	20
Chapter 5:  Ellwood Quality Steels (#37-00264)	23
Chapter 6:  East Penn Manufacturing Company, Inc.  -  Smelter Plant (#06-05040D)	25
Chapter 7:  Magnesita Refractories (#67-05001)	29
Chapter 8:  Hazleton Generation LLC (#40-00021)	34
Chapter 9:  Graymont PA, Inc. (#14-00002)	37



Acronyms and Abbreviations

BACT			-	best available control technology
bhp			-	brake horsepower
Btu			- 	British thermal units
CAA			-	Clean Air Act
CbC			-	Case-by-Case RACT, 25 Pa. Code 129.99
CEMS			-	continuous emissions monitoring system
CI			-	compression ignition
CO			-	carbon monoxide
CO2			-	carbon dioxide
Cfm			- 	cubic feet per minute
CTG			- 	Control Technique Guideline
EPA			-	The U.S. Environmental Protection Agency
FGR			-	flue gas recirculation
gal			-	gallons
HAPs			-	hazardous air pollutants 
HHV			- 	higher heating value
hp			-	horsepower
hr			-	hour	
ICI			- 	Industrial, Commercial, and Institutional 
lbs			-	pounds
LAER			-	lowest achievable emission rate
LNB			-	low NOx burners
MAT			-	Mixing Air Technology
MKF			-	Mid-kiln firing
MMBtu 		-	million British thermal units
mmHg			-	millimeter of mercury
MMScf		-	million standard cubic feet
MW			-	megawatt
NAAQS		-	National Ambient Air Quality Standards
NESHAP		-	National Emission Standards for Hazardous Air Pollutants
NO2			-	nitrogen dioxide
NOx			- 	nitrogen oxides
NSPS			-	New Source Performance Standard
OAQPS		-	EPA's Office of Air Quality Planning and Standards
O2			-	oxygen
PADEP 		-	Pennsylvania Department of Environmental Protection
PJM			-	Pennsylvania, Jersey, Maryland (PJM) Interconnection regional 
            transmission organization
ppmvd			-	parts per million by volume, dry
PTE			-	potential to emit
RACT			-	reasonably available control technology
RACT I rule		-	Pennsylvania's 25 Pa. Code 129.91-95, Stationary Sources of NOx 
            and VOCs 
RACT I permit	-	a Permit issued under the RACT I rule and approved into the PA 
                        SIP for the 1-hour ozone NAAQS
RACT II rule		-	Pennsylvania's 25 Pa. Code 129.96-100, Additional RACT
            Requirements for Major Sources of NOx and VOCs
RBLC			-	EPA's RACT/BACT/LAER Clearinghouse database
RTO			-	regenerative thermal oxidizer
SCR 			-	selective catalytic reduction
SNCR			-	selective non-catalytic reduction
TO 			- 	thermal oxidizer
tpy			-	tons per year
ULNB			-	ultralow NOx burners
VOC			-	volatile organic compounds

Chapter 1:  Helix Ironwood, LLC (#38-05019)

Facility Description and Processes 
Helix Ironwood, LLC (Helix) is an electric generating facility in South Lebanon Township, Lebanon County, Pennsylvania.  The facility consists of two natural gas-fired combustion turbines, an emergency fire pump, and a parts washer.

Units Subject to Case-by-Case RACT II
Helix is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  The facility is a minor source of VOC emissions.

The following sources have a potential to emit greater than 2.7 tpy NOx and are subject to RACT:
 102 Emergency Fire Pump
 T001 No. 1 Combustion Turbine
 T002 No. 2 Combustion Turbine

Source 102 is subject to the presumptive requirements of 25 Pa. Code §129.97.

Due to the inability of SCR to control NOx emissions during start up and shutdown, Source T001 and T002 are unable to meet the applicable presumptive requirement of 25 Pa. Code §129.97(g)(2)(ii)(A) and are subject to CbC RACT requirements.

RACT I Considerations
The facility was not subject to RACT I.

Technical and Economic Feasibility
T001 and T002 NOx emissions are currently controlled by LNB and SCR.  A XONOX catalytic combustor systems was deemed technically infeasible because it not available for large combustion turbines.

The following controls were deemed technically feasible:
 SCR
 LNB
 SNCR
 SCONOx catalytic adsorption system
 Good combustion practices

SCR and LNB were selected as RACT because they are the top level of NOx controls established for the facility in a previous LAER determination. The LAER determination is source specific and tailored to the operation of the facility, allowing variability in unit use due to economic considerations and/or electric demand.  No enhancements to the existing controls would lower NOx emissions during startup and shutdown.  Existing LAER limits were proposed as RACT: short term limits for normal operation, annual limit for all operations, and startup and load change limits.

PADEP's Conclusions 
PADEP has determined that NOx RACT for Sources T001 and T002 is:
 LAER limits:
 Limit of 4.5 ppm dry volume NOx corrected to 15% oxygen, calculated as a 3-hour rolling bock average during normal operation
 Limit of 0.018 lb/mmBtu NOx, HHV, calculated as a 3-hour rolling bock average during normal operation
 Maximum total NOx emission per turbine for startup and load change events
 Cold startup: 731 lbs
 Warm startup: 543 lbs
 Hot startup: 295 lbs
 Load change: 295 lbs
 Annual limit of 442 tons of NOx per consecutive 12-month period, including startup and load change, as measured by the CEMS
 Definitions of cold start up, warm startup, hot startup, shutdown, and load changes
 Recordkeeping of operation intervals, maintenance records, SCR parameters, natural gas consumption, operating hours
 Use of a CEMS to determine compliance with RACT emissions limits

EPA's Conclusions and Recommendations
EPA finds that the CbC RACT II determinations provided by PADEP are reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for Helix.

  




















Chapter 2:  GE Transportation  -  Erie (#25-00025)

Facility Description and Processes
GE Transportation (GE) operates a diesel-electric locomotive assembly plant located in Lawrence Park Township, Erie County, Pennsylvania.  The facility manufactures locomotives, electric motors and alternators, off-highway vehicles, and replacement parts.  Permitted emission sources at this facility include an engine lab test facility (made up of 10 individual test cells), boilers and other combustion devices, and coating operations.

Units Subject to Case-by-Case RACT II
GE is classified as a major NOx and VOC emitting facility, thus is required to meet both NOx and VOC RACT II requirements.

Of the permitted sources at GE, seven are subject to CbC NOx and VOC RACT II.  They are Building 4E Test Cell #1 (Source ID 359) and Building 18E Test Cells B, C, D, E, F, and G (all six are part of Source ID 372).  These seven sources fall under 25 Pa. Code §129.99(b) and (c), as there is no applicable presumptive RACT II category under which they could comply.  The remaining permitted sources at the facility are either exempt or are complying with presumptive RACT II per 25 Pa. Code §129.97.  

RACT I Considerations
Under the RACT I rule, GE was subject to Operating Permit No. OP-25-025, issued December 21, 1994.  RACT requirements in this permit were approved by EPA into the SIP on August 8, 1995.  See 40 CFR §52.2020(c)(98)(i)(B)(5).  Subsequently, GE was issued a revised RACT I permit, Operating Permit No. OP-25-025A, issued August 26, 2002.  RACT requirements in the revised 2002 permit were subsequently approved by EPA into the SIP on April 7, 2003, superseding the previous RACT I requirements found in the 1994 permit.  See 40 CFR §52.2020(c)(198)(i)(B).

GE's 2003 SIP-approved RACT I determination consisted of NOx limits for four boilers- Boilers #1, #2, #5, and #9- which are no longer in existence at the facility.  The seven sources complying with CbC RACT II were not subject to any SIP-approved RACT I requirements.

Technical and Economic Feasibility 
Both Source IDs 359 and 372 were evaluated for CbC NOx RACT II.  Source ID 359, consisting of Test Cell #1 in Building 4E, is currently equipped with cloud chamber/SCR to control NOx emissions.  Test Cells B, C, D, E, F, and G, which are located in Building 18E and partially comprise Source ID 372, do not have existing NOx controls.  Two NOx controls were evaluated for CbC RACT: SCR and SNCR.  SCR was evaluated at a 70-90% efficiency and SNCR was evaluated at a 30-50% efficiency.  Of the two control technologies, SNCR was determined technically infeasible.  SNCR uses ammonia or urea to react with NOx to form N2 and H2O without the use of a catalyst.  This reaction occurs at a temperature of approximately 1600-2100ºF.  SNCR is not feasible for these sources because of the significant fluctuations in engine load.  The system would not be able to maintain the required operating temperature.  SCR was determined technically feasible for Source ID 372.  SCR is already being used on Source ID 359, thus, this control option was only further evaluated for Source ID 372.  SCR was determined to be anywhere between $8,058/ton for a single cylinder cell to $12,513/ton for a standard test cell.  Therefore, SCR was determined economically infeasible for Source ID 372.  

PADEP has determined that NOx RACT for Source ID 359 is the existing, combined fuel limitation of 11,000,000 gallons in a 12-month rolling period for all test cells in Source ID 359, as well as Source IDs 361 and 362.  The fuel limitation applies to gallons of diesel fuel oil by the test cells, as well as liquified natural gas (LNG)/compressed natural gas (CNG)/natural gas (NG) fuel use for these sources, which will be converted to gallon equivalents of No. 2 fuel oil on a BTU basis for purposes of demonstrating compliance with the fuel limitation.  PADEP has also determined that NOx RACT for Source ID 359 is a limit on test cell engine idling to the extent possible under a given research and development test plan.  Source ID 359 will continue to operate the existing cloud chamber/SCR.  

PADEP has determined that NOx RACT for Source ID 372 is 214 tpy of NOx for each full engine test cell and 214 tpy of NOx for the single cylinder test cell (based on source PTE), as well as the existing annual diesel fuel limitation of 1,100,000 gallons in a 12-month rolling period for all test cells in Source ID 372 and a limit on test cell engine idling to the extent possible under a given research and development test plan.

Both Source IDs 359 and 372 were evaluated for CbC VOC RACT II.  Source ID 359 is currently equipped with a catalytic oxidizer.  Source ID 372 does not have any existing VOC controls.  Four controls were evaluated for their efficiency as CbC VOC RACT: thermal oxidation (95-98%), catalytic oxidation (90-95%), adsorption (75-95%), and absorption (90-95%).  Source ID 359 is already employing catalytic oxidation, thus is was not evaluated for this source.  The three other control options (thermal oxidation, adsorption, and absorption) were determined to the technologically infeasible for Source ID 359.  All four control options were determined to be technologically infeasible for Source ID 372.  Thermal oxidation requires the VOC air stream to be heated to several hundred degrees above the auto-ignition temperature of the organic compounds being oxidized (typically around 1600ºF).  The high efficiency listed is due to high inlet loading concentrations.  As the inlet loading decreases, the efficiency also decreases.  Thus, thermal oxidation is not technically feasible for these two sources because of the low inlet VOC concentration, which would require supplemental fuel to raise exhaust gas temperatures to the required level.  This would result in an increase in NOx emissions.  Catalytic oxidation involves a catalyst being used to promote oxidation of the inlet gas stream at lower temperatures (600-1200ºF) than required in thermal oxidation.  Similar to thermal oxidation, the high efficiency listed is due to high inlet loading concentrations.  As the inlet loading decreases, the efficiency also decreases.  Supplemental fuel would also be required in this scenario, thus increases NOx emissions.  Adsorption is technically infeasible because, depending on the type of system, outlet concentrations are assumed to be 75 parts per million volume (ppmv) for continuous operations and 20 ppmv for a canister system.  During maximum operation of the test cell, the VOC concentration is expected to be less than 25 ppmv, therefore there would be minimal removal.  Absorption is also technically infeasible because most of the inlet VOC is non-oxidized hydrocarbons (not soluble or at best, only slightly soluble in water) and too low in concentration.  

PADEP has determined that VOC RACT for Source ID 359 is the existing, combined fuel limitation of 11,000,000 gallons in a 12-month rolling period for all test cells in Source ID 359, as well as Source IDs 361 and 362.  The fuel limitation applies to gallons of diesel fuel oil by the test cells, as well as LNG/CNG/NG fuel use for these sources, which will be converted to gallon equivalents of No. 2 fuel oil on a BTU basis for purposes of demonstrating compliance with the fuel limitation.  PADEP has also determined that NOx RACT for Source ID 359 is a limit on test cell engine idling to the extent possible under a given research and development test plan.  Source ID 359 will continue to operate the existing catalytic oxidation control technology.

PADEP has determined that VOC RACT for Source ID 372 is the existing annual diesel fuel limitation of 1,100,000 gallons in a 12-month rolling period for all test cells in Source ID 372 and a limit on test cell engine idling to the extent possible under a given research and development test plan.  

PADEP's Conclusions 
PADEP has determined that RACT for Source ID 359 (Building 4E Test Cell #1) is:
 Fuel limitation of 11,000,000 gallons in a 12-month rolling period combined fuel limitation for all test cells in Source ID 359, as well as Source IDs 361 and 362
 LNG/CNG/NG fuel use will be converted to gallon equivalents of No. 2 fuel oil on a BTU basis for purposes of demonstrating compliance with the above fuel limitation
 Limit all test cell engine idle to the extent possible under a given research and development test plan
 Appropriate monitoring, recordkeeping, and reporting requirements per 25 Pa. Code §129.100
PADEP has determined that RACT for Source ID 372 (Building 18E Test Cells B, C, D, E, F, and G) is:
 214 tpy of NOx for each full engine test cell and 214 tpy of NOx for the single cylinder test cell
 Annual diesel fuel limitation of 1,100,000 gallons in a 12-month rolling period combined for all test cells
 Limit all test cell engine idle to the extent possible under a given research and development test plan
 Appropriate monitoring, recordkeeping, and reporting requirements per 25 Pa. Code §129.100

EPA's Conclusions and Recommendations
EPA finds that the CbC RACT II determinations provided by PADEP are reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for GE.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional NOx or VOC emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.










































Chapter 3:  Carpenter Co. (#39-00040)

Facility Description and Processes
Carpenter Co. (Carpenter) operates a facility in Upper Macungie Township, Lehigh County, Pennsylvania, that manufactures foam products, including expanded polystyrene (ESP) and polyurethane products.  Permitted emission sources at this facility include the EPS manufacturing process, the polyurethane manufacturing process, and a boiler that operates on natural gas and pentane, which serves as a control device for pentane emissions from the EPS manufacturing process. 

Units Subject to Case-by-Case RACT II
Carpenter is classified as a major VOC emitting facility, thus is required to meet VOC RACT II requirements.  The facility is not a major NOx emitting source, thus is not subject to NOx RACT II requirements.  

Of the permitted sources at Carpenter, all but two are exempt from RACT II per 25 Pa. Code §129.96(c) because they have VOC emissions less than 1 tpy.  Carpenter has evaluated CbC RACT II for the EPS manufacturing process (Source ID 101) and the polyurethane manufacturing process (Source ID 102).  Neither Source ID 101 or 102 have applicable presumptive RACT II requirements, however, each emit greater than 2.7 tpy VOC.

RACT I Considerations
Carpenter was not issued a RACT I permit by PADEP.

Technical and Economic Feasibility 
Four different control technologies were identified as technically feasible for Source ID 101, the EPS manufacturing process: thermal oxidation, catalytic oxidation, carbon adsorption, and routing the pentane emissions to a boiler.  Carpenter is already routing pentane emissions from the EPS manufacturing process to a boiler, which achieves a 99% control efficiency.  This was determined to be the most effective technically feasible VOC control option for the process.  Thermal oxidation achieved a similar control efficiency, however the cost effectiveness of implementing this new control technology would be much higher than the cost effectiveness of continuing to operate the existing control technology currently in place.  Additionally, the current control technology offsets a portion of the fuel required to produce the steam needed for the EPS manufacturing process.  Implementation of a new control technology would result in an undesirable increase in fuel usage at the facility.  PADEP has determined VOC RACT for the EPS manufacturing process to be the existing control technology to route emissions to the existing boiler, which is required to operate within the parameters established in the facility's Compliance Assurance Monitoring (CAM) plan whenever the EPS manufacturing process is operational and must achieve at least 99% destruction efficiency for VOCs.  PADEP is also proposing the source's current VOC limit of 88.8 tpy be applied as RACT.

Four control options were evaluated for VOC RACT for Source ID 102, the polyurethane manufacturing process: thermal oxidation, catalytic oxidation, carbon adsorption, and good operating and management practices.  Catalytic oxidation and carbon adsorption were both determined to be technically infeasible.  Catalytic oxidation is infeasible due to the high volume of gas collected, which would require multiple oxidizers for each stack.  Additionally, the various ingredients and additives used in the process pose a potential problem of fouling the catalyst.  Carbon adsorption is infeasible due to the high gas flow rate with low VOC concentration.  Emissions from the operation would also have a tendency to poison the activated carbon.  The economic feasibility of thermal oxidation for VOC control in the polyurethane manufacturing process was determined to be over $292,000 per ton of VOC controlled from the stack emissions alone and over $40,000 per ton of VOC controlled from combined stack and fugitive emissions.  Therefore, thermal oxidation was determined to be economically infeasible.  The facility is already employing good operating and management practices, thus PADEP has determined this to be VOC RACT for the polyurethane manufacturing process.  These work practice standards include using non-VOC blowing agents.  PADEP is also proposing the source's current VOC limit of 20 tpy be applied as RACT.

PADEP's Conclusions 
PADEP has determined that VOC RACT for the EPS manufacturing process (Source ID 101) is:
 88.8 tpy VOC limit based on a 12-month rolling sum (25 Pa. Code §129.99(c))
 Throughput restrictions: only use EPS beads with pentane as a sole blowing agent and maximum hourly pentane throughput shall not exceed 4,000 lbs/hr, based on a daily average (25 Pa. Code §129.99)
 Achieve at least 99% VOC destruction efficiency in control device (Source ID C33, boiler) (25 Pa. Code §129.99(c))
 Appropriate monitoring, recordkeeping, and reporting requirements per 25 Pa. Code §129.100
 Ensure capture system and control device (Source ID C33, boiler) are operated at all times the source is in operation; boiler must be operating within the parameters established in the CAM plan whenever the EPS manufacturing process is operating (25 Pa. Code §129.100)
PADEP has determined that VOC RACT for the polyurethane manufacturing process (Source ID 102) is:
 20 tpy VOC limit based on a 12-month rolling sum (25 Pa. Code §129.99(c))
 Record chemical usage for the foam line on a daily and monthly basis for calculating VOC emissions (25 Pa. Code §129.100(d))
 Use only a non-traditional blowing agent (i.e. carbon dioxide) in polyurethane foam manufacturing process; VOC/HAP blowing agents are prohibited (25 Pa. Code §129.99)
EPA's Conclusions and Recommendations
EPA finds that the RACT determination provided by PADEP is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for Carpenter.



Chapter 4:  Pennsylvania State University (#14-00003)

Facility Description and Processes
The University Park Campus of Pennsylvania State University (PSU) is located in State College Borough, Centre County, Pennsylvania.  Permitted emission sources at this facility include steam generating units, a combustion turbine, an incinerator, emergency engines, and small heat units.  The steam generation sources are found at the West Campus Steam Plant (WCSP) and the East Campus Steam Plant (ECSP).  The ECSP also operates a combustion turbine with an associated heat recovery steam generator.

Units Subject to Case-by-Case RACT II
PSU is classified as a major NOx emitting facility, thus is required to meet NOx RACT II requirements.  The facility is not a major VOC emitting source, thus is not subject to VOC RACT II requirements.

Of the permitted sources at PSU, two are subject to CbC NOx RACT II.  Source IDs 036 and 037 (Boilers 1 and 2) are unable to comply with the applicable presumptive RACT II requirements when fired on natural gas, as found in 25 Pa. Code §129.97(g)(1)(i), thus a CbC analysis has been completed for these two sources.  Many of the facility's other permitted sources are complying with presumptive RACT II per 25 Pa. Code §129.97.  

RACT I Considerations
Under the RACT I rule, PSU was subject to Operating Permit No. OP-14-0006, issued December 30, 1998.  RACT requirements in this permit were approved by EPA into the SIP on March 30, 2005.  See 40 CFR §52.2020(d)(1)(c).

PSU's RACT I determination required:
 Annual tune-ups for WCSP Boilers 1, 2, 5, 6, and 8 and ECSP Boilers 1 and 2
 0.55 lb/MMBtu NOx (expressed as NO2) for WCSP Boilers 1, 2, 6, and 8 (in aggregation)
 0.15 lb/MMBtu NOx (expressed as NO2) for WCSP Boiler 5
 0.20 lb/MMBtu NOx (expressed as NO2) for ECSP Boilers 1 and 2 (individually)
 107.5 tpy NOx in any 12 consecutive month period for ECSP Boilers 1 and 2 (individually)
 Good air pollution practices for the E. Keeler DS-15 research boiler, small combustion units, space heaters, and emergency electric generators
 >500 hours of operation in any 12 consecutive month period for the emergency electric generators (individually)
 Appropriate monitoring, recordkeeping, and reporting requirements



Technical and Economic Feasibility 
ECSP Boilers 1 and 2 (Source IDs 036 and 037) are both Keller 130 MMBtu/hour natural gas fired boilers with No. 2 fuel oil only fired during emergency situations.  The following technologies were considered for CbC NOx control for the two boilers: SCR, SNCR, FGR, and LNB with FGR.  All but SNCR were determined technically feasible.  SNCR is technically infeasible due to the boilers' stack temperatures being well below the minimum temperature needed for this non-catalytic control technique (~1,600ºF).  The remaining three technologies were then ranked for removal efficiencies and subsequently determined to be economically infeasible: SCR (85% removal efficiency), FGR (60% removal efficiency), and LNB with FGR (75% removal efficiency) were determined to be $5,938/ton, $5,576/ton, and $8,715/ton respectively.  

After a statistical evaluation of PSU's historical test data for the two boilers, PADEP has determined NOx RACT II for Boilers 1 and 2 to be 0.18 lb/MMBtu for each boiler when fired on natural gas.  PSU will follow a NOx RACT emission limit of 0.12 lb/MMBtu for each boiler when fired on No. 2 fuel oil, which is the presumptive RACT II NOx emission limit for boilers of this size when fired on No. 2 fuel oil, per 25 Pa. Code §129.97(g)(1)(ii).  PADEP has determined that the RACT I 107.5 tpy NOx limit for each boiler is "out-of-date" due to the more recent natural gas usage restriction in the facility's permit, established as a result of NNSR.  The natural gas usage restriction, along with the NOx emission limits equates to a NOx limit of 53.7 tpy for each boiler.  PADEP has determined that the RACT I NOx limit of 107.5 tpy for each boiler be superseded with the new RACT II natural gas usage restriction of 520 million cubic feet/year and No. 2 fuel oil usage restriction of 743,000 gallons/year.  PADEP has also determined NOx RACT II for Boilers 1 and 2 to be the continued practice of annual tune-ups.

PADEP's Conclusions 
PADEP has determined that RACT for Boilers 1 and 2 (Source IDs 036 and 037) is:
 0.18 lb/MMBtu NOx (expressed as NO2) when fired on natural gas (per boiler)
 0.12 lb/MMBtu NOx (expressed as NO2) when fired on No. 2 fuel oil (per boiler)
 520 million cubic feet in any 12 consecutive month period natural gas restriction (per boiler)
 743,000 gal in any 12 consecutive month period No. 2 fuel oil restriction (per boiler)
 Annual tune-ups to minimize NOx emissions, which include, at a minimum: 1) inspection, adjustment, cleaning or replacement of fuel-burning equipment, including the burners and moving parts necessary for proper operation as specified by the manufacturer, 2) inspection of the flame pattern or characteristics and adjustments necessary to minimize total emissions of NOx, and to the extent practicable minimize emissions of CO, 3) inspection of the air-to-fuel ratio control system and adjustments necessary to ensure proper calibration and operation as specified by the manufacturer 
 Appropriate monitoring, recordkeeping, and reporting requirements per 25 Pa. Code §129.100



EPA's Conclusions and Recommendations
EPA finds that the CbC RACT II determinations provided by PADEP are reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for PSU.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.





































Chapter 5:  Ellwood Quality Steels (#37-00264)

Facility Description and Processes
Ellwood Quality Steels (EQS) is a small specialty steel mill located in New Castle City, Lawrence County, Pennsylvania.  Permitted emission sources at this facility include an electric arc furnace, two ladle refining furnaces, a vacuum degasser, two ingot teeming aisles, an internal scrap yard, six natural gas fired annealing furnace, miscellaneous steel cutting/grinding, and four process steam boilers.

Units Subject to Case-by-Case RACT II
EQS is classified as a major NOx and VOC emitting facility, thus is required to meet both NOx and VOC RACT II requirements.  

Of the permitted sources at EQS, only one is subject to CbC RACT II - Source ID 101, the electric arc furnace (EAF) - for both NOx and VOC emissions.  Many of the facility's sources are complying with presumptive RACT II per either 25 Pa. Code §129.97(b) or (c).  

RACT I Considerations
Under the RACT I rule, the facility, then called Ellwood Group Inc., was subject to Operating Permit No. OP-37-313, issued January 31, 2001.  RACT requirements in this permit were approved by EPA into the SIP on March 30, 2005.  See 40 CFR §52.2020(d)(1)(i)(d).  The original RACT I determination for Ellwood Group Inc. was an aggregated analysis for EQS, North American Forgemasters (NAF), and Ellwood City Forge-New Castle (ECFN).

Ellwood Group Inc.'s RACT I determination consisted mostly of sources subject to presumptive RACT I per 25 Pa. Code §129.93.  RACT I for the EAF at EQS was determined to be the continued operation of the direct evacuation control (DEC) and oxyfuel burners for NOx control and scrap management, and the DEC system combustion for VOC control.  EQS is required under RACT I to examine each shipment of scrap for excess insulation, rubber, non-metallics, heavy grease or oil.  Additionally, all three plants (EQS, NAF, and ECFN) had recordkeeping requirements under RACT I per 25 Pa. Code §129.95.

Technical and Economic Feasibility 
EQS' EAF (Source ID 101) is currently equipped with the following NOx control options: DEC; process control; oxy-fuel burners; LNB; and scrap management.  Three additional controls were evaluated and ranked, for control effectiveness, for NOx control for the EAF: SCR (70-90%), FGR (30-75%), and SNCR (30-50%).  All three were found to be technically infeasible.  SCR was determined to be technically infeasible because if the SCR is installed prior to the EAF's baghouse, the catalyst could be coated with particulate and SCR systems are sensitive to contamination and plugging.  If the SCR is installed after the baghouse, the temperature of the exhaust gas from the baghouse is 150ºF, which is well below the 600-700ºF required for the reaction.  FGR was determined to be technically infeasible because only a small portion of the NOx emissions result from the combustion of fuel in a burner.  Finally, SNCR was determined technically infeasible because of significant fluctuations in flow rates, NOx loading rates, and system temperatures inherent in the operation of batch steel production.  A review of EPA's RBLC resulted in 22 facilities with EAFs with BACT NOx limits ranging from 0.2 lbs/ton to 1.43 lbs/ton.  Therefore, PADEP has determined NOx RACT for the EAF to be existing NOx controls as well as the source's existing NOx emission limits of 0.1 lbs/ton steel produced and 22.5 tpy.

EQS' EAF is currently equipped with the following VOC control options: DEC, process control, and scrap management.  Three additional controls were evaluated and ranked, for control effectiveness, for VOC control for the EAF: thermal/catalytic oxidization (98%/95%), process flares (98%), and oxidation catalysts (90-95%).  All three were found to be technically infeasible because each would need to be placed after the baghouse to prevent contamination.  Due to the low VOC concentration, these control options would require supplemental fuel to raise the exhaust gas temperature to the required level, resulting in an increase in NOx emissions.  A review of EPA's RBLC resulted in 20 facilities with EAFs with BACT VOC limits ranging from 0.03 lbs/ton to 0.43 lbs/ton.  Therefore, PADEP has determined VOC RACT for the EAF to be existing VOC controls as well as the source's existing VOC emission limits of 0.3 lbs/ton steel produced and 67.5 tpy.

PADEP's Conclusions 
PADEP has determined that RACT for the EAF (Source ID 101) is:
 NOx emission limits: 0.1 lbs/ton steel produced and 22.5 tpy, 12 month rolling total
 VOC emission limits: 0.3 lbs/ton steel produced and 67.5 tpy, 12 month rolling total
 Appropriate monitoring, recordkeeping, and reporting requirements per 25 Pa. Code §129.100
EPA's Conclusions and Recommendations
EPA finds that the CbC RACT II determinations provided by PADEP are reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for EQS.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional NOx or VOC emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.









Chapter 6:  East Penn Manufacturing Company, Inc.  -  Smelter Plant (#06-05040D)

Facility Description and Processes
East Penn Manufacturing Company, Inc. (East Penn) operates a lead-acid battery manufacturing campus, made up of six lead-acid battery manufacturing facilities, located in Richmond Township, Berks County, Pennsylvania.  Permitted emission sources at this facility, a secondary lead smelting facility, include a blast furnace, a reverberatory furnace and tapping, six refining kettles, emergency generators, and miscellaneous chemical use.

Units Subject to Case-by-Case RACT II
East Penn is classified as a major NOx and VOC emitting facility, thus is required to meet both NOx and VOC RACT II requirements.  

Of the permitted sources at East Penn, three have been evaluated for CbC RACT II.  Source ID 101 (blast furnace) and Source ID 108 (reverberatory furnace) are subject to both NOx and VOC CbC RACT II and Source ID 115 (miscellaneous chemical use) is subject to VOC CbC RACT II.  None of the three sources have applicable presumptive RACT II requirements, however, they emit greater than 5 tpy NOx and/or 2.7 tpy VOC.  Many of the other sources at East Penn are complying with presumptive RACT II per 25 Pa. Code §129.97.  

RACT I Considerations
East Penn's smelter plant was not issued a RACT I permit by PADEP.  The facility underwent a RACT I review in 1996 and, at that time, the smelter plant's NOx and VOC PTE were evaluated.  The smelter plant's operating permit (06-1040, issued on September 10, 1996) imposed a 100 tpy NOx limit, thus memorializing its synthetic minor status for NOx RACT I.  It was a natural minor for VOC.  Therefore, East Penn has no existing RACT I SIP requirements to consider in the context of RACT II.

Technical and Economic Feasibility 
East Penn operates a secondary lead smelter that consists of a blast furnace (Source ID 101) and reverberatory furnace (Source ID 108), which share a common air pollution control system and historically reported combined emissions.  Therefore, a CbC RACT II analysis was performed for these two sources as a combined source.  

The following control options were evaluated for NOx control efficiency for Source IDs 101/108: low temperature oxidation system (90% efficiency); SCR (90% efficiency), SNCR (50% efficiency); combustion system modifications (15% efficiency); replacement of furnace system air/oxy fuel burners (15% efficiency); and good operating practices (already employed at the facility).  All control options were deemed technically feasible for NOx control.  Low temperature oxidation system ($16,726/ton), SCR ($10,802/ton), SNCR ($15,849/ton), and the replacement of fuel burners ($85,266) were ultimately determined economically infeasible for NOx control.  PADEP has determined NOx RACT for the blast furnace and reverberatory furnace to be combustion system modifications, which were determined economically feasible, and continued use of good operating practices.  PADEP has also determined NOx RACT to be the following emission limits: 0.6 lb/MMBtu and 71.42 tpy.

PADEP granted East Penn an alternative compliance schedule, per 25 Pa. Code §129.99, which allows the facility up to three years from the date of issuance of plan approval 06-05040D (issued on January 3, 2019) to demonstrate full compliance.  East Penn's petition for an alternative compliance schedule requested that additional time be allowed for planning, installation, and testing of the combustion system modifications.  PADEP approved the facility's existing NOx emission limits for Source IDs 101 and 108 as the interim emission limits (0.7 lb/MMBtu and 83.4 tpy).

Good operating practices and the use of an afterburner were evaluated for case-by-case VOC RACT for Source IDs 101/108.  Both are currently being employed by the facility.  The reverbatory furnace exhaust gases are combined with the blast furnace exhaust gases prior to the afterburner.  The afterburner utilized to reduce VOC emissions from Source IDs 101/108 represents the highest level of control.  PADEP has determined that the afterburner, along with good operating practices, represent RACT for Source IDs 101/108.  PADEP has also determined VOC RACT to be the following emission limits, which are existing emission limits: 20 parts per million volume (ppmv) total hydrocarbons as propane at 4% carbon dioxide for both furnaces, 360 ppmv total hydrocarbons as propane at 4% carbon dioxide for the blast furnace only, 20 ppmv total hydrocarbons as propane at 4% carbon dioxide for the reverberatory furnace only, and 28.61 tpy VOC.  The facility is subject to 40 CFR Part 63, Subpart X, which addresses total hydrocarbons as a surrogate for VOC emissions and prescribes various work practice and monitoring requirements for total hydrocarbons, focused on the use of an afterburner, and continuous afterburner temperature monitoring.  PADEP has also determined VOC RACT to include requirements from 40 CFR Part 63 Subpart X. 

CbC VOC RACT II was evaluated for the miscellaneous chemical use at the facility (Source ID 115).  Due to the wide-spread use of miscellaneous chemicals throughout the facility and the resultant diffuse nature of the associated VOC emissions, the installation and operation of a VOC emissions reduction control device or other technology driven control strategy was determined technically infeasible to reduce VOC emissions from these activities.  The facility has an existing emission limit for Source ID 115 of 5 tpy VOC, which PADEP concludes is still appropriate after review of the source's reported VOC emissions for the last 5 calendar years.  The facility already employs the use of good operating practices to reduce VOC emissions from those activities that comprise Source ID 115.  PADEP has determined VOC RACT for the miscellaneous chemical use to be the existing emission limit of 5 tpy VOC and continued use of good operating practices.  PADEP has determined that using products, where possible, that are subject to 25 Pa. Code §130, be included as a good operating practice.  25 Pa. Code §130 outlines VOC content limits for various consumer products that may, in many instances, contribute to miscellaneous chemical use at the facility.

PADEP's Conclusions 
PADEP has determined that NOx and VOC RACT for the blast furnace (Source ID 101) and reverberatory furnace and tapping (Source ID 108) is:
 Combined exhaust of Source IDs 101 and 108 shall be limited to:
 0.6 lb NOx/mmBtu
 71.42 tpy NOx for any rolling consecutive 12-month period
 20 ppmv total hydrocarbons measured as propane at 4% carbon dioxide
 360 ppmv total hydrocarbons measured as propane at 4% carbon dioxide  -  blast furnace/Source ID 101 only
 20 ppmv total hydrocarbons measured as propane at 4% carbon dioxide  -  reverberatory furnace/Source ID 108 only
 28.61 tpy VOC in any consecutive 12-month period
 Exhaust from furnaces must pass through an afterburner
 7,680 hours of operation during any consecutive 12-month period (rolling basis)  -  combined Source IDs 101/108
 40 CFR Part 63, Subpart X requirements (National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting)
 Initial and subsequent source testing for NOx and VOC emissions
 Good combustion practices for Source IDs 101 and 108
 Appropriate recordkeeping per 25 Pa. Code §129.100(i)
PADEP has determined that VOC RACT for the miscellaneous chemical use (Source ID 115) is:
 Good operating practices, including methods such as proper employee training, standard operating procedures, periodic inspections, good housekeeping, monitoring and recordkeeping, and where possible, using products subject to 25 Pa. Code §130 (Standards for Products)
 5 tpy VOC in any 12-month rolling period
 Appropriate monitoring, recordkeeping, and reporting requirements


EPA's Conclusions and Recommendations
EPA finds that the RACT determination provided by PADEP is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for East Penn.








































Chapter 7:  Magnesita Refractories (#67-05001)

Facility Description and Processes 
Magnesita Refractories (formerly, J.E. Baker Company) is non-clay dolomite manufacturing facility located in York County, Pennsylvania.  The emission units at Magnesita consist of two lime kilns and associated ovens at the refractory and a pellet dryer and limestone dryer at an adjacent quarry. 

Units Subject to Case-by-Case RACT II
Magnesita is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  Magnesita is not subject to VOC RACT II requirements because its VOC emissions are limited by its existing operating permit to no more than 50 tpy.  Magnesita is seeking approval of CbC NOx RACT II requirements for five kilns and a curing oven (Source IDs 405, 415, 801 (process component), 810, 820, and 830). 
      
RACT I Considerations
Under the RACT I rule, the facility (as J.E. Baker Company) was subject to Operating Permit No. 67-2001, issued December 22, 1994.  The RACT I requirements in this permit, were approved by EPA into the SIP on August 8, 1995.  See 40 CFR 52.2020(c)(98)(i)(B)(6).  The emission units subject to RACT I requirements are cross-indexed with their RACT II descriptions and IDs in Table 7.1.  All the RACT I requirements are retained and CbC RACT II is evaluated for six emission units, IDs 405, 415, 801 (process component), 810, 820 and 830.  

Table 7.1: Cross-index of Emission unit identification numbers between 1995 and present
RACT I Emission Unit Name/ID
Current Emission Unit Name/ID
Current Status
No. 1 Rotary Kiln
No. 1 Rotary Kiln, ID 405 (formerly, ID 109)
Active
No. 2 Rotary Kiln
No. 2 Rotary Kiln, ID 415 (formerly, ID 110)
Active
Rotary Dryer
Rotary Dryer ID 8050 (formerly, ID 103)
(currently permitted under State Permit 67-05120; to be incorporated into next Title V permit)
Active
Well Block Oven and Incinerator
EC Well Block Oven ID 590 (formerly, ID 121)
Active
Pellet Dryer
Pellet Plant Dryer ID 7710 (formerly, ID 122)
(currently permitted under State Permit 67-05120; to be incorporated into next Title V permit)
Active
Despatch Oven and Incinerator
Curing Oven ID 801
Active
No. 5 Tunnel Kiln
Tunnel Kiln #5 ID 810
Active
No. 6 Tunnel Kiln
Tunnel Kiln #6 ID 820
Active
No. 7 Periodic Kiln and Incinerator
Bickley Periodic Kiln ID 830
Active
Electric Oven and Incinerator
Electric Oven and Incinerator, Eisenmann ID 620
Shutdown
Stationary I.C. Engines (eight)
Emergency Generators ID 110
Active

All the RACT I requirements for the currently operating emission units at Magnesita are retained. The RACT I requirements are retained in the Title V permit under Group 011 for Source IDs 110, 405, 415, 801, 810, 820 and 830. In addition, three emission units (ID 8050, Rotary Dryer, ID 7710, Pellet Dryer and ID 590, Wellblock Oven and Incinerator) were RACT I subject emission units and their RACT I requirements are also retained. Although these three emission units are not currently listed in the Title V Group 011 list of emission units, their RACT I requirements were already approved into the Pennsylvania SIP in 1995 and are being retained. Specifically, these requirements include compliance with 25 Pa. Code §129.93(c), the monitoring, recording and reporting of operating hours, fuel usage, fuel analysis per shipment, and lbs of NOx emitted per quarter.  In addition, the RACT II requirements for the RACT II subject emission units are described below.

Technical and Economic Feasibility
The two lime kilns (No. 1 and and No. 2 Rotary kilns, Source IDs 405 and 415) produce doloma sinter and not the typical quicklime produced by lime kilns at other lime manufacturing facilities. The doloma sinter production differs from quicklime production in that higher temperatures (peak temperature is 2100°C) are required in the process and there is no stone feed bin or related duct work to allow for the preheating of kiln gases. 

The emission limitations for Source IDs 405 and 415 were approved as RACT I in 1995.  However, under the RACT II requirements, a new technical and economic feasibility analysis is required.  The following control technologies were evaluated for technical feasibility on these two kilns: SNCR, SCR, good combustion practices, catalyst filters, LNB, Oxy-fuel combustion, Mid-kiln firing (MKF), Mixing Air Technology (MAT), and Fuel Switching.  SNCR, SCR, catalyst filters, MKF, MAT, and Fuel Switching are determined to be technically infeasible. SNCR is infeasible because the Magnesita rotary kilns must periodically be rigorously cleaned of the doloma sinter buildup using an industrial shotgun, which would damage any system designed to inject ammonia or urea, such as that needed for SNCR.  Magnesita evaluated the possibility of alternative locations for the SNCR such as outside the kiln shell but these alternative locations did not have the appropriate temperature window and auxiliary fuel would be needed to raise the gas stream temperature.  Therefore, SNCR in these alternative locations is deemed technically infeasible. 

SCR is not technically feasible because of the high operating temperature required in the doloma sinter process, which requires that a SCR catalyst be located prior to the baghouse.  However, the gas stream prior to the baghouse is laden with particulates, which would poison the catalyst. Catalyst filters are technically infeasible because it is used with SCR, which has been determined to be infeasible.  While MKF, a fuel injection system to add a second fuel source at the midpoint of the kiln, has been demonstrated to be effective in reducing NOx emissions in cement kilns, it is technically infeasible at Source IDs 405 and 415 because it reduces the flame temperature and has not be demonstrated in rotary kilns.  MAT creates staged combustion air by injecting high pressure air into the combustion zone to create more air mixing through the kiln.  MAT has primarily been used to control Carbon Monoxide (CO) emissions from cement kilns. Although commensurate reductions in NOx emissions can logically be expected, it has not been demonstrated and there are concerns that this technology requires kiln-specific burners and specific control of operating parameters with the potential for decrease product quality when these conditions are not met.  Fuel switching would lower fuel-bound NOx but since the NOx emissions at Magnesita are from thermal NOx, fuel switching is not an effective NOx reduction strategy for Magnesita. 

Good combustion practices to minimize excess air is technically feasible for the No. 1 and No. 2 rotary kilns (Source IDs 405 and 415) as this limits thermal NOx formation.  PADEP has determined that RACT for Source IDs 405 and 415 are good combustion practices, which include kiln feed controls and calibration, fuel feed controls and calibration, weekly kiln flame pattern inspections, and annual kiln burner inspections.  NOx emissions testing once every 5 years is required for Source IDs 405 and 415. 

For the two tunnel kilns (Source ID 810 and 820), which are direct-fired sources, and the periodic kiln (Source ID 830), SNCR, SCR, LNB and good combustion practices were evaluated.  The tunnel kilns have a heat input of 31 MMBtu/hr each.  The periodic kiln has a heat input of 21 MMBtu/hr and annual potential NOx emissions of 10.2 tpy.  SNCR was determined to be technically infeasible because the temperatures in the exhaust stream of these kilns are insufficiently high and injection of the catalyst into the kiln would require the need to reheat the exhaust stream and addition of the catalyst also has an adverse effect on product quality.  LNB are determined to be technically infeasible because of very high temperatures in Source ID 810 and 820.  Source ID 830 has existing burners designed to meet emission rates equivalent to LNB.  Therefore, replacing the burners in Source ID 830 with LNB is not expected to further reduce emissions. 

The NOx emissions from the curing oven (Source ID 801) are generated from two sources:  the ammonia curing process (process) and the process' burners, which are less than 20 MMBtu/hr, making Source ID 801's burner emissions subject to the Pennsylvania presumptive RACT requirements at 25 Pa. Code §129.97(c)(1).  SNCR, SCR, LNB, and good combustion practices were also evaluated for Source ID 801's process emissions.  SNCR is deemed to be technically infeasible because the NOx emissions are generated primarily from TO, requiring any controls to be added on downstream of the TO.  The exhaust temperature of the TO is far below what is required for SNCR.  LNB is technically infeasible for Source ID 801's process because the process is not a burner.  LNB is unnecessary for Source ID's 801 burner because it is subject to the presumptive RACT requirements. 

Therefore, for Source IDs 801 (process), 810, 820 and 830, an economic feasibility analysis was performed for SCR, a technically feasible technology.  The cost analysis showed that the costs to reduce NOx emissions at each of these emission units through the use of SCR range from over $9500/ton NOx removed to over $48,000/ton NOx removed.  As a result, PADEP determined that good combustion practices are RACT for Source IDs 801 (process), 810, 820 and 830.  Among other things, these practices include minimum weekly and annual visual inspections of the kiln burners (Source ID 801, 810 and 820), adjustments to the air to fuel ratio as necessary to maintain good combustion (Source IDs 810 and 820), and monthly filter changes for the combustion air and diffusion air for Source 830.  

The two dryers at the adjacent quarry (Source IDs 8050 and 7710) have NOx emissions less than 5 tpy and therefore, are subject to the RACT II requirements via 25 Pa. Code §129.97(c)(1). PADEP has determined that these emission units at the adjacent quarry are part of the Magnesita refractory plant and at the next Title V permit renewal for Magnesita, these emission units and the corresponding requirements will be included in the Magnesita Title V permit. 

The remaining NOx units (Source IDs 110, 590 and 640) are also subject to subject to the presumptive RACT II requirements due to a small volume of emissions.   

The Table 7.2 summarizes all the current RACT requirements for the units at Magnesita.

              Table 7.2: Current RACT Requirements for Magnesita
Source ID
Source Description
Applicable RACT II Requirement
Applicable RACT I Requirement Retained
8050
Rotary Dryer, Simplicity
Presumptive RACT: 25 Pa. Code §129.97(c)(1)
Operating Permit No. 67-2001, issued December 22, 1994, approved into the Pennsylvania SIP on August 8, 1995.  See 40 CFR 52.2020(c)(98)(i)(B)(6).
110
Emergency Generators
Presumptive RACT: 25 Pa. Code §129.97(c)(5)
See Title V Permit No. 67-05001, Section E, Group 011
590
Well Block Oven and Incinerator
Presumptive RACT: 25 Pa. Code §129.97(c)(1)
Operating Permit No. 67-2001, issued December 22, 1994, approved into the Pennsylvania SIP on August 8, 1995.  See 40 CFR 52.2020(c)(98)(i)(B)(6).
405
No. 1 Rotary Kiln (with O2)
CbC: 34.0 lbs NOx/ton product plus calibration, weekly inspections, recordkeeping provisions
See Title V Permit No. 67-05001, Section E, Group 011(including annual emissions testing)
415
No. 2 Rotary Kiln (with O2)
CbC: 38.0 lbs NOx/ton product plus calibrations, weekly inspections, recordkeeping provisions
See Title V Permit No. 67-05001, Section E, Group 011 (including annual emissions testing)
640
EC Yorkaire Oven, 2.5 MMBtu/hr, firing natural gas
Presumptive RACT: 25 Pa. Code §129.97(c)(1)
none
801
Curing Oven (process)
CbC: Good operating and maintenance practices including annual inspection of burner, records of inspections.
See Title V Permit No. 67-05001, Section E, Group 011
801
Curing Oven (combustion)
Presumptive RACT: 25 Pa. Code §129.97(c)(6)
See Title V Permit No. 67-05001, Section E, Group 011
810
Tunnel Kiln #5
CbC: Good operating and maintenance practices, Weekly inspections and adjust air to fuel ratio as needed, records of inspections.
See Title V Permit No. 67-05001, Section E, Group 011
830
Tunnel Kiln #6
CbC: Good operating and maintenance practices, Monthly filter changes, Inspection after every 500 operating hours, records of inspections.
See Title V Permit No. 67-05001, Section E, Group 011
7710
Pellet Dryer
Presumptive RACT: 25 Pa. Code §129.97(c)(1)
Operating Permit No. 67-2001, issued December 22, 1994, approved into the Pennsylvania SIP on August 8, 1995.  See 40 CFR 52.2020(c)(98)(i)(B)(6).

PADEP's Conclusions
PADEP has determined that the NOx emission limits, good operating and maintenance practices and other specific provisions described in Table 7.2, is RACT II for Magnesita.  The 1995 RACT I requirements remain for those emission units that continue to operate today.  Appropriate monitoring and recordkeeping requirements necessary to determine compliance are required pursuant to 25 Pa. Code §127.441, §129.95 and §129.100.

EPA's Conclusions and Recommendations
EPA finds that the CbC RACT II determination provided by PADEP are reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for Magnesita.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional VOC and NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.      











Chapter 8:  Hazleton Generation LLC (#40-00021)

Facility Description and Processes 
Hazleton Generation LLC (Hazleton) (formerly, Williams Generation Company - Hazleton) is an electric generation facility located in Luzerne County, Pennsylvania.  The emission units at Hazleton consist of four simple cycle combustion turbines; three rated at 33 MW heat output (equivalent to 113 MMBtu/hr heat output and requiring 365.4 MMBtu/hr heat input) and one rated at 72.5 MW heat output (865.4 MMBtu/hr, heat input).  The current convention, and the applicability determination in the Pennsylvania regulations, is to describe combustion turbines by their heat input rather than by their heat output.  This convention will be maintained throughout this document.  

Units Subject to Case-by-Case RACT II
Hazleton is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  Hazleton is seeking approval of CbC NOx RACT II requirements for one 72.5 MW simple cycle combustion turbine (Source ID TURBN) when it is burning natural gas.  The Pennsylvania presumptive RACT regulations are based on heat input and TURBN is an 865.4 MMBtu/hr heat input unit.  TURBN will meet the presumptive RACT requirements at 25 Pa. Code §129.97(g)(2)(i)(B) when burning No. 2 fuel oil.  The three simple cycle combustion turbines rated at 365.4 MMBtu/hr (heat input) were not subject to RACT I (installed in 2001-2002) and will comply with the presumptive RACT II requirements at 25 Pa. Code §129.97(g)(2)(i)(A and B). 
      
RACT I Considerations
Under the RACT I rule, this facility was subject to Operating Permit No. 40-0031A, issued March 10, 2000.  This permit was approved by EPA into the Pennsylvania SIP on April 1, 2003.  See 40 CFR 52.2020(c)(196)(i)(B)(4).  The three combustion turbines rated at 365.4 MMBtu/hr were installed after the RACT I requirements and when they were installed, were required to meet Best Available Technology (BAT) requirements by Pennsylvania.  Hence, there were not RACT I requirements for those three combustion turbines.  All four combustion turbines have CEMs.

Operating Permit No. 40-0031A imposed RACT I requirements on Source ID TURBN.  However, there is some potential confusion regarding the simple cycle combustion turbine that received RACT approval in 2003 compared with the turbine seeking RACT II approval.  In 2003, this turbine was described as having 785 MMBtu/hr rated capacity Low Heating Value (LHV), which is equivalent to 865.4 MMBtu/hr High Heating Value (HHV).  The maximum heat input to this turbine has not changed since the original RACT approval.  The current CbC RACT proposal describes this turbine as rated at 72.5 MMBtu/hr, which is the output of the turbine.  This turbine requires 865.4 MMBtu/hr heat input to produce 72.5 MMBtu/hr heat output.  The heat rate is the ratio of the heat input to the heat output, which is about 12 for this turbine.  In comparison, newer simple cycle combustion turbines have a heat rate of 9.3 on an LHV basis.  Therefore, this is an old turbine that has only about 28% efficiency and, hence, runs infrequently in a competitive market. 

Technical and Economic Feasibility
The following NOx control technologies were evaluated for the combustion turbine, TURBN: SCR, SCONOX, Catalytic Combustion (XONON), Dry Low NOx Combustor and Water Injection.  All these control technologies were determined to be technically feasible except SCONOX and XONON.  SCONOX requires a catalyst with an adsorption range from 300°F to 700°F, with an optimal temperature of about 600°F.  The exhaust temperatures of TURBN are between 910°F and 950°F, which makes SCONOX technically infeasible. XONON is a catalyst based system to allow the combustion of very lean fuel mixtures but it has not been fully demonstrated and hence, is considered infeasible.  Hazleton is currently implementing water injection on TURBN.  In comparison to water injection, NOx emission controls would be 90% more effective using SCR and 67% more effective using Dry Low NOx Combustor controls. 

The economic analysis of SCR and Dry Low NOx Combustor controls indicates that both are economically infeasible.  SCR is able to control NOx emissions at TURBN to 7.5 ppm at a cost of over $8000/ton NOx removed.  Dry Low NOx Combustor controls reduce NOx emissions at TURBN to 25 ppm at a cost of over $11,000/ton NOx removed. 

Table 8.1 summarizes all the applicable RACT (RACT I and RACT II) requirements for the units at Hazleton. 
              Table 8.1:  Current RACT Requirements for Hazleton
Source ID
Source Description
Applicable RACT II Requirement
Applicable RACT I Requirement
TURBN
Natural Gas Turbine with water injection 
All RACT I requirements are determined to be RACT II.
Use of water injection is required.
75 ppmvd NOx at 15% O2, 1 hour average.
252.4 lbs NOx/hr at any time
Facility-wide emissions cap: 252.4 tons NOx/yr; 12 month rolling average.
Facility wide operating hours restriction: 2000 hrs/yr, rolling 12 month average.
NOx CEM
102A
Gas Turbine 2 Dual-fuel with water injection Winlet Fogging (365.4 MMBtu/hr)
25 Pa. Code §129.97(g)(2)(i)(A and B)
None
103A
Gas Turbine 2 Dual-fuel with water injection Winlet Fogging (365.4 MMBtu/hr)
25 Pa. Code §129.97(g)(2)(i)(A and B)
None
104A
Gas Turbine 2 Dual-fuel with water injection Winlet Fogging (365.4 MMBtu/hr)
25 Pa. Code §129.97(g)(2)(i)(A and B)
None
PADEP's Conclusions
PADEP has determined that the NOx emission limits, a facility-wide operating hours restriction, and good operating and maintenance practices described in Table 8.1 is RACT II for Hazleton.  The necessary monitoring and recordkeeping requirements to determine compliance are required pursuant to 25 Pa. Code §127.441, §129.95 and §129.100.

EPA's Conclusions and Recommendations
EPA finds that the CbC RACT II determination provided by PADEP is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for Hazleton.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.      
































Chapter 9:  Graymont PA, Inc. (#14-00002)

Facility Description and Processes 
Graymont PA, Inc. (formerly, three adjacent facilities: Graybec Lime, Inc., Bellefonte Lime Company, and Con-Lime Inc.) (Graymont) is a lime manufacturing facility located in Pleasant Gap, Spring Township, Centre County, Pennsylvania.  PADEP considers Graymont to be a single facility under common ownership.  The emission units at Graymont consist of three lime kilns and associated combustion units and miscellaneous emergency generators. 

Units Subject to Case-by-Case RACT II
Graymont is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  Graymont is not subject to VOC RACT II requirements because its VOC emissions are limited by its existing operating permit to no more than 50 tpy.  Graymont is seeking approval of CbC NOx RACT II requirements for two kilns (Source IDs 408 and 413). 
      
RACT I Considerations
Graymont now includes three lime manufacturing facilities that were each subject to the RACT I requirements under 25 Pa. Code 129.91.  These three lime manufacturing facilities were: Graybec Lime Inc., Bellefonte Lime Company, and Con-Lime Inc.  Under the RACT I rule, Graybec Lime Inc. was subject to Operating Permit No. 14-0004, issued April 16, 1999; Bellefonte Lime Company was subject to Operating Permit No. 14-0002, issued October 19, 1998; and Con-Lime Inc. was subject to Operating Permit No. 14-0001, issued January 7, 1998.  These permits were approved by EPA into the SIP on April 28, 2006 (see 40 CFR 52.2020(d)(1)(n)), on June 19, 2006 (see 40 CFR 52.2020(d)(1)(q)) and on March 9, 1998 (see 40 CFR 52.2020(c)(130)(i)(B)(3)), respectively.  Additionally, Con-Lime's RACT I requirements were approved into the Pennsylvania SIP on June 3, 1997 (see 40 CFR 52.2020(c)(122)(B)(5)).  The RACT I approval for Graybec Lime Inc. included 3 rotary lime kilns #1, 2, and 3 and 2 waste oil furnaces.  The RACT I approval for Bellefonte Lime Company included 2 rotary lime kilns #4 and 5, a stone dryer, 6 space heaters, and 1 waste oil heater.  The RACT I approval for Con-Lime Inc. included 2 lime kilns # 1 and #3, a stone dryer and six heaters.  Graymont purchased all three facilities prior to 2004, when it applied to install two new lime kilns (#6 and 7), which were to replace the old lime kilns.  The three lime kilns # 1, 2, and 3 at Graybec, two rotary lime kilns #4 and 5 at Bellefonte and the two lime kilns # 1 and 3 at Con-Lime Inc. were all shutdown and replaced in 2004 with lime kilns #6 (Source ID 408) and #7 (Source ID 413). 

The other NOx emission units in operation at the Graymont facility are subject to the presumptive RACT requirements at 25 Pa. Code §129.97 or are exempt because they were not in operation on July 20, 2012 (25 Pa. Code §129.96(b)).  Source ID P310, Pulverized Limestone System Rotary Dryer, is neither the Con-Lime nor Bellefonte dryer and therefore, there is no need to perform a comparison analysis between the stringency of RACT I and RACT II requirements. Source ID P310 is subject to the presumptive RACT requirements at 25 Pa. Code §129.97(c)(3).  These NOx emission units are listed in Table 9.1.

                                       
                                       
Table 9.1:  Graymont Emission Units Exempt or subject to Presumptive RACT II Requirements 
Source ID
Source Description
NOx PTE (tpy)
Presumptive RACT II requirement or Exempt
032
Combustion Units and Heaters
1.4
§129.97(c)(1)
P310
Pulverized Limestone System Rotary Dryer
8.8
Dryer rated at 10 MMBtu therefore, subject to 129.97(c)(3) work practice requirements and good combustion practices. 
P313
Lime Processing Project 
4.27
Exempt, constructed after 7/20/12
P320A

136 hp Diesel Generator
3.66
§129.97(c)(1)
P321
Miscellaneous Emergency Generators
2.4
§129.97(c)(1)
P328
65 kW Kiln and Emergency Generator
0.1
Exempt, constructed after 7/20/12 
P418
Kiln #8
34.6
Exempt, constructed after 7/20/12 


Technical and Economic Feasibility
The only emission units requiring a CbC determination for RACT II are the two rotary lime kilns.  Kiln #6 (P408) is a 1200 ton of lime per day rotary lime kiln with a preheater and a 240 MMBtu/hr coal/petroleum coke-fired burner.  Kiln #7 (P413) is a 1050 ton of lime per day rotary lime kiln with a 280 MMBtu/hr coal/petroleum coke-fired burner.  SCR, MFK, MAT, catalyst filters and oxy-fuel combustion were evaluated.  SCR was determined to be technically infeasible because the high particulate matter in the kiln exhaust precludes placement of the SCR prior to the fabric filter. However, placement of the SCR after the fabric filter is also not feasible because the exhaust stream is cooled to avoid damage to the fabric filters and the temperature requirements of the catalyst are not met.  MKF and MAT are technologies typically installed together to optimize combustion within the rotary kiln.  However, these have not been demonstrated for these types of lime kilns and hence, are technically infeasible.  Catalyst filters and oxy-fuel combustion combination have also not been demonstrated in these types of lime kilns and the costs are substantially higher than the cost of SCR.  Therefore, catalyst filters and oxy-fuel combination are not considered technically or economically feasible.

Both kilns have CEMs and proposed NOx emission limits for RACT are based on these data.  The proposed NOx RACT emission limit for Kiln #6 is 205 lbs NOx/hr over 30 day rolling average.  The proposed NOx RACT emission limit for Kiln #7 is 179 lbs NOx/hr over 30 day rolling average.  By way of comparison, even though these are not the same kilns subject to the RACT I requirements, it is possible to compare the NOx RACT II proposed limits with the average NOx RACT I emission limits.  The seven kilns that were subject to RACT I were required to meet different NOx RACT emission limits.  Using these seven kilns as representative of what is achievable, on average, the NOx RACT I emission limit for these now shutdown kilns was 8.26 lbs NOx/ton lime.  The proposed NOx RACT II emission limits for Kilns #6 and 7 can be converted to similar units for comparison.  Since the lime production capacity for Kiln #6 is 1200 tons of lime per day, dividing by 24 hours/day results in 50 tons of lime per hour.  Neither Kiln #6 nor Kiln #7 is restricted by operating hours.  Using the proposed Kiln #6 RACT II emission limit of 205 lbs NOx/hr and dividing by 50 tons of lime per hour, produces the equivalent NOx emission rate in lbs of NOx per ton of lime for Kiln #6 as 4.1 lbs/ton lime.  This calculated figure is less than the average NOx RACT I emission rate of 8.26 lbs NOx/ton lime.  Performing the same calculation for Kiln #7, which has a capacity of 1050 tons of lime produced per day and a proposed NOx RACT II emission rate of 179 lbs NOx/hr, produces 4.1 lbs NOx/ton of lime produced, which also compares favorably with the average NOx RACT I emission rate of 8.26 lbs NOx/hr. 

In addition to the NOx emission limits for Kilns #6 and 7, as part of its RACT determination, PADEP is requiring monitoring and recording of combustion parameters such as kiln temperature, oxygen levels, fuel usage, and gas flow.  Both kilns are required to operate and maintain their NOx CEMs in accordance with Pennsylvania requirements, which have previously been approved into the Pennsylvania SIP.  Annual tune-ups of the kiln preheat burner (Kiln #6) include, among other things, regular inspections of the burner (including cleaning and replacement of components as necessary to optimize performance) and inspection and optimization of the flame pattern.  For Kiln #6 (Source ID 408), these RACT II requirements are contained in Section D, Conditions # 009, 028, 034, and 042, in the Title V permit (14-00002).  For Kiln #7 (Source ID 413), these RACT II requirements are contained in Section D, Conditions #009, 034, 042, and 052 in the Title V permit (14-00002). 

                 Table 9.2:  Case By Case RACT II Requirements
Source ID
Source Description
Case by Case RACT II Requirement
408
Kiln #6, Rotary Lime Kiln with preheater. 1200 tons lime/day
205 lbs NOx/hr plus combustion practices and burner tune-ups
413
Kiln #7, Rotary Lime Kiln with semi-wet scrubber, 1050 tons lime/day
179 lbs NOx/hr plus combustion practices and burner tune-ups


PADEP's Conclusions
PADEP has determined that the NOx emission limits, NOx CEMs, and the requirements for monitoring and recording combustion parameters, and burner tune-ups for Kilns #6 (Source ID 408) and 7 (Source ID 413) are RACT.  Appropriate monitoring and recordkeeping requirements necessary to determine compliance are required pursuant to 25 Pa. Code §127.441, §129.95 and §129.100.

EPA's Conclusions and Recommendations
EPA finds that the CbC RACT II determination provided by PADEP are reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for Graymont PA, Inc.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.      



