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

DATE:

August 19, 2020 
SUBJECT:
REVISED - 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); 19 Sources

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

TO:
File for Docket ID Number EPA-R03-OAR-2019-0686

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

                                       
A.  INTRODUCTION

The Environmental Protection Agency (EPA) is taking action on several submittals 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).  These submissions were also required pursuant to a conditional approval and were 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 ozone NAAQS and the 2008 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 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 multiple dates, the Commonwealth of Pennsylvania submitted, through PADEP, revisions to its SIP to address the RACT requirements under sections 182 and 184 of the CAA for the 1997 and the 2008 ozone NAAQS.  Table 1 below lists each submittal date, the facilities included, and the permit number and permit effective date.

Although submitted in multiple submissions by PADEP, 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 Name (County)
                      1-Hour Ozone RACT Source? (RACT I)
                    Major Source Pollutant (NOx and/or VOC)
                    RACT II Permit Number (Effective Date)





                                   8/14/2017
                 Exelon Generation  -  Fairless Hills (Bucks)
                                      Yes
                                      NOx
                              09-00066 (01/27/17)





                                  11/21/2017
                           The Boeing Co. (Delaware)
                                      Yes
                                  NOx and VOC
                             23-00009 (01/03/17) 






                Cherokee Pharmaceuticals, LLC (Northumberland)
                                      Yes
                                      VOC
                              49-00007 (04/24/17)






           Dominion Transmission  -  Finnefrock Station (Clinton)[a]
                                ...............
                                ...............
                                ...............

                      First Quality Tissue, LLC (Clinton)
                                      No
                                      VOC
                              18-00030 (09/18/17)






                        JW Aluminum Company (Lycoming)
                                      No
                                      VOC
                              41-00013 (03/01/17)






              Transco  -  Salladasburg Station 520 (Lycoming)[b]
                                ...............
                                ...............
                                ...............






                        Ward Manufacturing, LLC (Tioga)
                                      No
                                      VOC
                              59-00004 (01/10/17)






                            Wood-Mode Inc. (Snyder)
                                      No
                                      VOC
                              55-00005 (07/12/17)





                                   4/26/2018
                       Foam Fabricators Inc. (Columbia)
                                      No
                                      VOC
                              19-00002 (12/20/17)






                              Novipax (Berks)[c]
                                ...............
                                ...............
                                ...............






                Resilite Sports Products Inc. (Northumberland)
                                      Yes
                                      VOC
                              49-00004 (08/25/17)






            Sunoco Partners Marketing & Terminals (Delaware)[d]
                                ...............
                                ...............
                                ...............






                      Texas Eastern  -  Bernville (Berks)
                                      Yes
                                      NOx
                              06-05033 (03/16/18)






                  Truck Accessories Group (Northumberland)[e]
                               ................
                               ................
                               ................





                                   6/26/2018
                    Texas Eastern  -  Shermans Dale (Perry)
                                      Yes
                                      NOx
                              50-05001 (03/26/18)






                     Texas Eastern  -  Perulack (Juniata)
                                      Yes
                                  NOx and VOC
                              34-05002 (03/27/18)






                    Texas Eastern  -  Grantville (Dauphin)
                                      Yes
                                      NOx
                              22-05010 (03/16/18)






                    NRG Energy Center Paxton, LLC (Dauphin)
                                      Yes
                                      NOx
                              22-05005 (03/16/18)






                    Texas Eastern  -  Bechtelsville (Berks)
                                      Yes
                                      NOx
                              06-05034 (04/19/18)






             Merck, Sharp & Dohme Corporation (Montgomery)[f]
                                ...............
                                ...............
                                ...............





                                  10/29/2018
              Containment Solutions/Mt. Union Plant (Huntingdon)
                                      Yes
                                      VOC
                              31-05005 (07/10/18)






            Armstrong World Ind./Marietta Ceiling Plant (Lancaster)
                                      Yes
                                      VOC
                              36-05001 (06/28/18)






                   Jeraco Enterprises Inc. (Northumberland)
                                      Yes
                                      VOC
                              49-00014 (01/26/18)






               Global Advanced Metals USA, Inc. (Montgomery)[g]
                              ...................
                              ...................
                              ...................






                    Blommer Chocolate Company (Montgomery)
                                      No
                                      VOC
                              46-00198 (01/26/17)





[a]  -  Dominion Transmission  -  Finnefrock Station was withdrawn from EPA consideration on August 27, 2018.  PADEP determined this source was no longer subject to source-specific RACT requirements for the 1997 and 2008 8-hour ozone NAAQS. 
[b]  -  Transco  -  Salladasburg Station 520 will be acted on in a future rulemaking action.
[c]  -  Novipax will be acted on in a future rulemaking action. 
[d]  -  Sunoco Partners Marketing & Terminals will be acted on in a future rulemaking action.
[e]  -  Truck Accessories Group was withdrawn from EPA consideration on July 11, 2019.  EPA will be taking action on this source in a future rulemaking action, once resubmitted by PADEP for approval into the PA SIP.
[f] - Merck, Sharp & Dohme Corporation was withdrawn from EPA consideration on July 11, 2019.  EPA will be taking action on this source in a future rulemaking action, once resubmitted by PADEP for approval into the PA SIP.
[g] - Global Advanced Metals USA Inc. will be acted on in a future rulemaking action.

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, 6) EPA's Conclusions and Recommendations, and 7) Incorporation by Reference.

Contents
Acronyms and Abbreviations	11
Chapter 1:  Exelon-Fairless Hills Generating Station (#09-00066)	13
Chapter 2:  Boeing Company (#23-00009)	15
Chapter 3:  Cherokee Pharmaceuticals LLC (#49-00007)	20
Chapter 4:  First Quality Tissue LLC (#18-00030)	24
Chapter 5:  JW Aluminum Company (#41-00013)	29
Chapter 6:  Ward Manufacturing LLC (#59-00004)	32
Chapter 7:  Wood-Mode (#55-00005)	36
Chapter 8:  Foam Fabricators, Inc (#19-00002)	40
Chapter 9:  Resilite Sports Products Inc. (#49-00004)	42
Chapter 10:  Texas Eastern  -  Bernville Station; (#06-05033)	46
Chapter 11:  Texas Eastern Transmission, L.P. - Shermans Dale Station (#50-05001)	49
Chapter 12:  Texas Eastern Transmission, L.P., Perulack Station (#34-05002)	52
Chapter 13:  Texas Eastern Transmission, L.P., Grantville Station (#22-05010)	55
Chapter 14:  NRG Energy Center Paxton, LLC (#22-05005)	58
Chapter 15:  Texas Eastern Transmission, L.P., Bechtelsville Station (#06-05034)	61
Chapter 16:  Containment Solutions, Inc./Mount Union Plant (#31-05005)	64
Chapter 17:  Armstrong World Industries, Inc./Marietta Ceiling Plant (#36-05001)	67
Chapter 18:  Jeraco Enterprises, Inc. (#49-00014)	70
Chapter 19:  Blommer Chocolate Company (#46-00198)	76



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 
hp			-	horsepower
hr			-	hour	
ICI			- 	Industrial, Commercial, and Institutional 
lbs			-	pounds
LAER			-	lowest achievable emission rate
LNB			-	low NOx burners
MMBtu 		-	million British thermal units
mmHg			-	millimeter of mercury
MMScf		-	million standard cubic feet
NAAQS		-	National Ambient Air Quality Standards
NESHAP		-	National Emission Standards for Hazardous Air Pollutants
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:  Exelon-Fairless Hills Generating Station (#09-00066) 

Facility Description and Processes
Exelon  -  Fairless Hills, formerly known as PECO Energy Company  -  Fairless (Exelon), is a power generation station located in Bucks County, Pennsylvania.  Exelon consists of two 468.5 MMBtu/hr boilers and a degreaser. 
      
Units Subject to Case by Case RACT II
Exelon is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  CbC NOx RACT II is being determined for Exelon's two boilers (Source IDs 044 and 045) when they burn landfill gas (LFG).  Both of these boilers can currently burn LFG, natural gas, and No. 4 residual oil.  
      
When burning natural gas, both of these boilers will comply with the presumptive RACT II requirement at 25 Pa. Code §129.97(g)(1)(i), which is 0.10 lbs NOx/MMBtu.  When burning No. 4 Residual Oil, both of these boilers will comply with the presumptive RACT II requirement at 25 Pa. Code §129.97(g)(1)(ii), which is 0.20 lbs NOx/MMBtu.  

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-09-0066, issued December 31, 1998 and revised April 6, 1999.  This permit was approved by EPA into the SIP on December 15, 2000.  See 40 CFR Part 52.2020(c)(143)(i)(B)(15).  

Under OP-09-0066, there were three boilers.  Only two of these boilers remain in service.  The RACT I emission limits for Source IDs 044 and 045 when burning natural gas or No. 4 Residual Oil are less stringent than the presumptive RACT II requirements at 25 Pa. Code §129.97(g)(1)(i) and (ii), respectively.  Therefore, the presumptive RACT II requirements apply for these two boilers when burning natural gas or No. 4 Residual Oil.  

Technical and Economic Feasibility
A RACT II technical and economic feasibility analysis is only required for the evaluation of Source IDs 044 and 045 when burning LFG.  Of the NOx control technologies evaluated, LNB are already in use; FGR, Water Injection, and SNCR are infeasible because of the lower temperatures caused by burning LFG.  Furthermore, EPA has not identified any applications of FGR, Water Injection or SNCR to boilers burning LFG.  SCR was evaluated and at a cost of more than $21,000/ton of NOx reduced, was determined to be infeasible due to cost.  With the LNB in use for Source IDs 044 and 045, the proposed 0.10 lbs NOx/MMBtu emission limit for the burning of LFG is based on CEMS data.  This proposed NOx emission limit is equivalent to the 0.10 lbs NOx/MMBtu presumptive emission limit under 25 Pa. Code §129.97(g)(1) for combustion units burning natural gas.  
      
When Source IDs 044 and 045 burn either natural gas or No. 4 Residual Oil, the presumptive RACT II requirements at 25 Pa. Code §129.97(g)(1)(i) and (ii), respectively, apply.



PADEP's Conclusions
PADEP has determined that NOx RACT II for Source IDs 044 and 045 boilers when burning LFG, is 0.10 lb NOx/MMBtu on a 30-day rolling average basis because of the economic infeasibility of add-on controls.  A CEMS is required for monitoring NOx emissions at these boilers (per 25 Pa. Code §127.441).  Appropriate monitoring, recordkeeping and reporting related to RACT II compliance for these two boilers when burning LFG is required pursuant to 25 Pa. Code §127.441 and §129.95.  

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 Exelon.  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.    

Incorporation By Reference
Exelon Generation  -  Fairless Hills - Incorporating by reference Permit No. 09-00066, issued January 27, 2017, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. OP-09-0066, issued December 31, 1998 and amended April 6, 1999, except for Conditions 10, 11.A, 11.C, 11.D, 12, 13, 14, and 15, which remain as RACT requirements for the two remaining Boilers No. 4, Serial 2818 (now Source ID 044) and No. 5, Serial 2819 (now Source ID 045).























Chapter 2:  Boeing Company (#23-00009) 

Facility Description and Processes 
Boeing Company (Boeing) is an aerospace manufacturing facility located in Delaware County, Pennsylvania.  The emission units at Boeing consist of many combustion sources (grouped under 18 Source IDs) and a variety of spray painting and degreasing operations.  With the exception of the Composite Manufacturing Operations (Source ID 251), Boeing's other emission units are subject to existing CTG, NESHAP, or presumptive RACT II requirements.

Units Subject to Case-by-Case RACT II
Boeing is classified as a major NOx and VOC emitting facility, thus required to meet NOx and VOC RACT II requirements.  Boeing is seeking approval of CbC VOC RACT II requirements for its existing Composite Manufacturing Operations (Source ID 251). 
      
RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. CP-23-0009, issued September 3, 1997.  This permit was approved by EPA into the SIP on December 15, 2000.  See 40 CFR 52.2020(c)(143)(i)(B)(1).  

All NOx units subject to CbC RACT I are either exempt or subject to the presumptive RACT II requirements due to a small volume of emissions.  Therefore, no technical or economic feasibility analysis is required for these units for RACT II.   

Under CP-23-0009, CbC VOC RACT I covered the Composite Manufacturing Operations (now Source ID 251) and established VOC emission limits for the materials used.  Source ID 251 had previously been approved as a CbC VOC RACT I source and VOC content emission limits were specified.  Other CbC RACT I units included the Nital Etch (6 process tanks are now permanently shutdown), Paint Gun Cleaning (now Source ID 216), Solvent Bath Cleaning, and Degreasing Operations (Ultrasonic Cleaner Model CTR 750A is now shutdown and the remainder are subject to CTG RACT degreasing operations).  In addition, a variety of Combustion Sources (4 boilers firing #6 fuel oil or natural gas, 3 boilers firing #6 fuel oil, plus space heaters, hot water heaters and emergency generators) were subject to RACT I requirements but are now subject to the presumptive RACT II requirements under 25 Pa. Code §129.97(b)(1), 129.97(c)(8), or 129.97(g)(2).  These units are listed in Table 2.2 below.  

All the VOC sources subject to CbC RACT I are either subject to CTG RACT or have been re-evaluated with a technical and economic feasibility analysis for RACT II.  
      
The VOC limits for Source ID 251 granted under CbC VOC RACT I are the same as those now being proposed for CbC VOC RACT II.  To meet the RACT II obligation, Boeing is required to re-evaluate the RACT I requirements via a technical and economic feasibility analysis, which was completed as follows.  

Technical and Economic Feasibility
The emission limitations for Source ID 251 were approved as RACT I in 2000.  However, under the RACT II requirements, a new technical and economic feasibility analysis is required.  For the VOC RACT II analysis for Source ID 251 (Composite Manufacturing Operations), Thermal Oxidation, Catalytic Oxidation and Carbon Adsorption were considered as potential add-on VOC controls for the autoclaves to Source ID 251.  Because of the high temperatures of the gases exiting the Source ID 251 autoclaves, both Thermal Oxidation and Carbon Adsorption were determined to be technically infeasible.  Based on the economic analysis, costs for Catalytic Oxidation were estimated at over $59,000/ton VOC removed and, therefore, determined to be economically infeasible.  The following emission rate limitations on materials used under Source ID 251 are RACT II, which are the same emission limitations previously approved under RACT I.  These activities and the corresponding VOC RACT II emission limitations are shown in the Table 2.1. 

           Table 2.1: VOC RACT II Emission Limits for Source ID 251
Source ID 251 Materials
VOC RACT II Emission Limit
Prepregs
0.65 lbs VOC/gal (78 grams per liter, g/l)
Tooling Fill and Fairing
3.5 lbs VOC/gal (420 g/l)
Tooling Resin and Hardeners
1.0 lb VOC/gal (120 g/l)
Core Stabilizing and Tacking Resin
5.70 lbs VOC/gal (684 g/l)
Engineering Foams
2.5 lbs VOC/gal (300 g/l)

The Table 2.2 summarizes all the current RACT II requirements for the units at Boeing.

                    Table 2.2: Current RACT II Requirements
Source ID
Source Description
RACT I Requirement (Yes/No)
Applicable RACT II Requirement
033
Cleaver Brooks 1 (Bldg 3-05)
Yes
25 Pa. Code §129.97(b)(1)
039
Cleaver Brooks 2 (Bldg 3-05)
Yes
25 Pa. Code §129.97(b)(1)
050A
Emergency Generators (4)
Yes
25 Pa. Code §129.97(c)(8)
053
Nebraska Boiler (Bldg 3-05)
No
25 Pa. Code §129.97(g)(1)
054
Cleaver Brooks 4 (Bldg 3-05)
No
25 Pa. Code §129.97(b)(1)
055
Cleaver Brooks 5 (Bldg 4-14)
No
25 Pa. Code §129.97(b)(1)
056
Cleaver Brooks 6 (Bldg 4-14)
No
25 Pa. Code §129.97(b)(1)
057
Cleaver Brooks 7 (Bldg 4-14)
No
25 Pa. Code §129.97(b)(1)
041
Emergency Generator (Bldg 3-10)
Yes
25 Pa. Code §129.97(c)(8)
042
(4) Turbine Generators (Bldg 3-52), formerly Source ID 040
No
25 Pa. Code §129.97(g)(2)(iii) (stack test required) 

050
(18) Natural Gas Emergency Generators
No
25 Pa. Code §129.97(c)(8)
050A
<500 hp Generators 
No
25 Pa. Code §129.97(c)(8)
050B
>500 hp Generators
No
25 Pa. Code §129.97(c)(8)
050C
New <500 hp Generators
No
25 Pa. Code §129.97(c)(8)
051
CI Emergency Generators and Diesel Fire Pump (Bldg 3-52, 3-19)
No
25 Pa. Code §129.97(c)(8)
051A
<500 hp CI Generators
No
25 Pa. Code §129.97(c)(8)
051B
>500 hp CI Generators
No
25 Pa. Code §129.97(c)(8)
051C
New <500 hp CI Generators
No
25 Pa. Code §129.97(c)(8)
110
Paint Stripper (Facility wide)
Yes
VOC 25 Pa. Code §129.97(c)(2) (Exempt)
171
Touch and Repair Booth (Bldg 3-06)
Yes/CTG
VOC: 25 Pa. Code §129.73
194
3-12 Degreaser 34217
Yes/CTG
VOC 25 Pa. Code §129.63
201
Gasoline Tank (TK043A)
Yes/CTG
VOC 25 Pa. Code §129.61
202
Gasoline Tank (TK043B)
Yes/CTG
VOC 25 Pa. Code §129.61
213
3-12 Degreaser 11-088308
Yes/CTG
VOC 25 Pa. Code §129.63
216
Cleaning Solvent Emission
Yes/CTG
VOC 25 Pa. Code §129.73(7)
218
Misc. Cold Degreasers
Yes/CTG
VOC 25 Pa. Code §129.63
228
Frekote Exhaust Booth #1 (Bldg 3-07)
Yes/CTG
VOC 25 Pa. Code §129.73
229
Frekote Exhaust Booth #2 (Bldg 3-07)
Yes/CTG
VOC 25 Pa. Code §129.73
251
Composite Manufacturing
Yes/CbC
CbC VOC emission limits for each of 5 materials used at Source ID 251
300A
Bldg 3-80 Bay 3-Spray Booth
Yes/CTG
VOC 25 Pa. Code §129.73
300B
Bldg 3-80 Bay 4-Spray Booth
Yes/CTG
VOC 25 Pa. Code §129.73
301
Bldg 3-B3 and 4-04 Spray Booths
Yes/CTG
VOC 25 Pa. Code §129.73
302
Bldg 3-12 Spray Booths
Yes/CTG
VOC 25 Pa. Code §129.73
303
Two Spray Booths (Bldg 3-73)
Yes/CTG
VOC 25 Pa. Code §129.73
304
Bldg 3-07 Spray Booths
Yes/CTG
VOC 25 Pa. Code §129.73
305
Fugitive Specialty Coating Operations
Yes/CTG
VOC 25 Pa. Code §129.73
307
Tooling Primers and Topcoats
Yes/CTG
VOC 25 Pa. Code §129.73
308
Bldg 3-25 Spray Booth
Yes/CTG
VOC 25 Pa. Code §129.73
309
Bldg 3-80 Bay 2 Spray Booth
Yes/CTG
VOC 25 Pa. Code §129.73
Title V permit, Section G, (A)(1)
Hot water heater (Natural gas), Building 3-01
Yes
25 Pa. Code §129.97(c)(3) (Exempt)

Title V permit, Section G, (A)(6)
2 Autoclaves (Natural gas); (#3) Building 3-07 and Building 3-31B
No
25 Pa. Code §129.97(c)(3) (Exempt) 
Title V permit, Section G, (A)(20)
2 Heat and Vent Units
Yes
25 Pa. Code §129.97(c)(3) (Exempt) 
Title V permit, Section G, (A)(19)
26 Gas Unit Heaters (Natural gas); Building 3-25
Yes
25 Pa. Code §129.97(c)(3) (Exempt) 
Title V permit, Section G, (A)(21)
6 Air Handlers (Natural gas); Building 3-25
Yes
25 Pa. Code §129.97(c)(3) (Exempt)
Title V permit, Section G, (A)(5)
33 Infra-red Heaters (Natural gas); Building 3-32
Yes
25 Pa. Code §129.97(c)(3) (Exempt)

PADEP's Conclusions
PADEP has determined that the VOC content for the materials used at Source ID 251, Composite Manufacturing Operations, is RACT II because limiting the VOC content and usage is demonstrated to be the most technically and economically feasible option producing the lowest emissions.  In addition, VOC emissions from Source ID 251 are not to exceed 8.5 tpy on a 12-month rolling basis.  The annual emission cap provides an additional level of compliance assurance and is calculated based on the short term emission limits applicable to this unit. Appropriate monitoring and recordkeeping requirements necessary to determine compliance are required pursuant to 25 Pa. Code §127.441 and §129.95.

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 Boeing.  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.      

Incorporation By Reference
The Boeing Co.  -  Incorporating by reference Permit No. 23-00009, issued August, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. CP-23-0009, issued September 3, 1997, except for Conditions 5.A, 5.C.1-3, and 5.D.2 and 4 (applicable to Source ID 251,Composite Manufacturing Operations); Conditions 7.A, 7.B.1-4, 7.D.1 and 7.E (applicable to Source ID 216, Paint Gun Cleaning); Condition 11. A, 11.C-E and 11.G (applicable to all solvent wiping and cleaning facility-wide); Condition 12 (applicable to listed de minimis VOC emission sources facility-wide); Condition 14.A (applicable to Source IDs 041, 050 and 051, Emergency Generators and Diesel Fire Pump); Conditions 15.B and 16.B (applicable to Source IDs 033 and 039, Cleaver Brooks Boilers 1 and 2); Condition 15.D (applicable to Source ID 042, 4 combustion turbines); Condition 16.C (applicable to Source IDs 041, 050, 050A, 051, 051A, and 051B, Emergency Generators); and Condition 16.D (applicable to Source ID 039, Cleaver Brooks Boiler 2), which remain as RACT requirements.
Chapter 3:  Cherokee Pharmaceuticals LLC (#49-00007)

Facility Description and Processes 
Cherokee Pharmaceuticals, formerly known as Merck (Cherokee), is a manufacturer of pharmaceuticals located in Northumberland County, Pennsylvania.  Permitted emission sources at this facility include pharmaceutical process equipment, bulk storage tanks, and wastewater treatment plant (with associated basins and tanks).  

Units Subject to Case-by-Case RACT II
Cherokee is classified as a major NOx and VOC emitting facility, thus required to meet VOC and NOx RACT II requirements.  Cherokee is seeking approval of a CbC VOC RACT II determination for its wastewater treatment facility (Source ID 101).  

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-49-0007B, issued May 16, 2001.  This permit was approved by EPA into the SIP on March 4, 2008.  See 40 CFR 52.2020 (d)(1)(v).  

Under OP-49-0007B, the units covered by this 2008 CbC VOC RACT I determination are 8 tanks: TA-870, TA-871, TA-886, TA-887, TA-888, TA-889, TA-811, and TA-806.  Currently, 4 tanks (TA-870, TA-886, TA-887, and TA-888) are identified under Source ID 131 in Cherokee's current Title V permit.  TA-871 has been shutdown and is no longer in service.  TA-889 and TA-811 are identified with Source ID 140 and TA-806 is identified with Source ID 155.

Technical and Economic Feasibility
Cherokee's wastewater treatment plant (Source ID 101) consists of multiple components that collect, remove, and treat organic compounds from the water used in the manufacture of pharmaceuticals at this location.  This source is also subject to 40 CFR Part 63, Subpart GGG  -  NESHAP for the Pharmaceutical Manufacturing Industry, which requires 95% reduction in total HAPs using biotreatment.  The NESHAP requirements have reduced Cherokee's VOC potential emissions from Source ID 101 from 146 tpy to 15 tpy, which is a federally enforceable VOC emissions cap applicable to all components of Source ID 101.  For Cherokee, the VOCs with the highest volatility are also HAPs.  The components of Source ID 101 are listed in the Table 3.1 below with its current potential emissions and emission controls (tank lid).
      
                        Table 3.1:  Source ID 101 Components
Source ID 101 Tank Name 
ID number
Tank Covered? (Yes/No)
VOC Potential Emissions (tpy)
                               Influent Wet Well
                                    TA-100
                                      Yes
                                      6.3
                              Equalization Basin
                                    TA-110
                                      Yes
                                      2.1
                             Neutralization Basin
                                    TA-120
                                      Yes
                                      0.2
                             Primary Lift Station
                                    TA-140
                                      Yes
                                      0.1
                              (6) Aeration Basins
               TA-180, TA-181, TA-182, TA-183W, TA-183C, TA-183E
                                      No
                                4.2 (0.7 each)
                              (3) Aeration Tanks
                           TA-184W, TA-184C, TA-184E
                                      No
                                2.1 (0.7 each)
                               Flocculation Tank
                                    TA-196
                                      No
                                       0
                           (3) Secondary Clarifiers
                            CF-190, CF-191, CF-192
                                      No
                                       0
                             Aeration Lift Station
                                    TA-601
                                      Yes
                                       0
                              (3) Heat Exchangers
                           HE-140A, HE-140B, HE-140C
                                      N/A
                                       0
                               Distribution Tank
                                    TA-160
                                      Yes
                                       0
 
The VOC emissions from Source ID 101 are due to the agitation and residence time required for biotreatment/biodegradation of the wastewater.  The RACT II control technologies evaluated for Source ID 101 tanks without current tank covers that have VOC emissions (Aeration Basins and Aeration Tanks), are Covers (Floating Roof or Floating Membrane Covers), Fixed Roof Tank with Add-on Control devices, Steam Strippers and Biodegradation.  For some of the units under Source ID 101 TA-100, TA-110, TA-120, and TA-140, covers to minimize VOC emissions are feasible and determined to be RACT. For the other units at Source ID 101, covers are determined to be technically infeasible because the Cherokee wastewater treatment process requires surface mixing and aeration, which cannot happen if the covers float on the surface of the tank liquids.  Steam Strippers are determined to be technically infeasible because of the dilute VOC concentrations in the waste stream.  Biodegradation is currently being implemented at Cherokee.  Fixed Roof tanks were also evaluated and determined to be technically feasible but economically infeasible at over $23,000/ton VOC removed.  The VOC RACT II requirements for the uncovered tanks under Source ID 101 are good operating practices.  The VOC RACT II requirements for the currently covered tanks under Source ID 101 are to retain their covers and together with the emissions from the uncovered tanks, all of Source ID 101's VOC emissions are not to exceed 15 tpy, which is the sum of the individual unit emission caps in Table 3.1.  In addition, CbC RACT II for these sources include all the necessary monitoring, recording and reporting for compliance with the applicable requirements pursuant to 25 Pa. Code §127.441 and §129.95.  

PADEP's Conclusions
PADEP has evaluated the options for RACT II for Source ID 101 and determined that tank covers for units other than TA-100, TA-110, TA-120 and TA-140 are infeasible because the Cherokee process requires tank access for mixing and aeration.  Add-on controls and alternative tank designs are economically infeasible because of dilute waste streams.  Therefore, PADEP determined that VOC RACT II for Cherokee consists of the 95% reductions obtained by complying with 40 CFR Part 63, Subpart GGG  -  NESHAP for the Pharmaceutical Manufacturing Industry, which requires 95% reduction in total HAPs using biotreatment.  RACT II for Source ID 101 also includes the emissions cap of 15 tpy.  
      
Cherokee is also currently subject to existing RACT requirements previously approved into the Pennsylvania SIP.  For Source IDs 140, 155, and 162, which are meeting CTG requirements, these requirements fulfill the RACT II obligations.  For Source ID 145, the only NOx/VOC emitting units are C500 (IN-2050) and C150 (IN-226), which are both subject to the presumptive RACT II requirements based on their emissions.  The VOC RACT II requirements for Cherokee are listed in Table 3.2.  

                      Table 3.2: VOC RACT II Requirements
Source ID
Source Description
VOC RACT II Requirement
101
Wastewater Treatment Plant consisting of the following units: TA-100, TA-110, TA-120, TA-140, TA-180, TA-181, TA-182, TA-183W, TA-183C, TA-183E, TA-196, CF-190, CF-191, CF-192, TA-601, TA600A, TA-600B, TA-184W, TA-184C, TA-184E, HE-140A, HE-140B, HE-140C, TA-160, plus 1 sulfur dioxide dechlorination system.
CbC RACT II:  < 15 tpy (in any 12-month consecutive period) VOC cap and 40 CFR Part 63, Subpart GGG (NESHAP). Plus, for units TA-100, TA-110, TA-120, and TA-140, installation of covers is required. 
131
300 Pad Wastewater System (formerly, Avermectin Wastewater Detox System. Avermectin is no longer manufactured at this facility but this wastewater systems is still used and therefore is renamed here.). Consists of units: TA-870, TA-886, TA-887, TA-888, RE-351.
25 Pa. Code §129.97(c)(6) and (presumptive, <2.7 tpy VOC) plus retention of more stringent RACT I conditions (for TA-870, TA-886, TA-887, TA-888) pertaining to submerged tank fill lines, sealed overflow lines and small diameter manway vents.
140
Pharmaceutical/Chemical Manufacturing; including TA-889 and TA-881
25 Pa. Code §129.68
145
TO and Scrubber Units
For C500 (IN-2050) T-Thermal LPV-14M and C150 (IN-226) T-Thermal Sub-X: 25 Pa. Code §129.97(c) (presumptive, <2.7 tpy VOC)
155
Bulk Storage Tanks consisting of TA-100, TA-101, TA-102, TA-104, TA-106, TA-107, TA-108, TA-109, TA-110, TA-111, TA-112, TA-113, TA-114, TA-115, TA-116, TA-118, TA-601, TA-606, TA-607, TA-610, TA-119, TA-672, TA-681, TA-690, TA-801, TA-806, TA-812, TA-814, TA-824, TA-854, TA-858, TA-860, TA-866, TA-868, TA-876, TA-878, TA-372, TA-373, TA-862, TA-931, TA-932, TA-934, TA-935, TA-900.
25 Pa. Code §129.57
162
Fuel Storage Tanks consisting of TA-201, TA-300, TA-301, TA-304-1, TA-410, TA-699, TA-802.
25 Pa. Code §129.57
180
Loading Operations
25 Pa. Code §129.97(c)(2) (presumptive, <2.7 tpy VOC)
250
Drum Sampling and Handling Area
25 Pa. Code §129.97(c)(2) (presumptive, <2.7 tpy VOC) plus existing RACT I condition that continues to apply: < 3lbs VOC/hr, and < 15 lbs/day.

EPA 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 Cherokee.  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.    
 
Incorporation By Reference
Cherokee Pharmaceuticals, LLC  -  Incorporating by reference Permit No. 49-00007, issued April 24, 2017, as redacted by Pennsylvania.  All permit conditions in the prior RACT Permit No. OP-49-0007B, issued May 16, 2001 remain as RACT requirements.
























Chapter 4:  First Quality Tissue LLC (#18-00030)

Facility Description and Processes
First Quality Tissue is a paper manufacturing facility located in Clinton County, Pennsylvania.  The emission sources at First Quality Tissue consists of paper making, printing, gluing and combustion units.  

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

First Quality Tissue is seeking a CbC VOC RACT II determination for the following sources: 
 Source ID P101, #1 Paper Machine Wet-End; 
 Source ID P201, #2 Paper Machine Wet-End;  
 Source IDs P102 and P103, #1 Paper Machine Dryer and #1 Paper Machine Glue Containment Area; 
 Source IDs P202 and P203, #2 Paper Machine Dryer and #2 Paper Machine Glue Containment Area; 
 Source ID P108, Adhesive Operation; 
 Source ID P110, Wastewater Treatment Operation; and
 Source IDs P202 and P203 #2 Paper Machine Dryers and #2 Paper Machine Glue Containment Area.

RACT I Considerations
There are no RACT I considerations for First Quality Tissue.  

Technical and Economic Feasibility
PADEP evaluated the above-identified units for case by case RACT II.  For all of these units (P101, P201, P102, P103, P202, P203, P108, P110, P202, P203), the VOC flow rates through the stacks are very low (from less than 1 to 4 ppmvd, measured as propane, as verified by stack testing) or estimated based on the VOC content of the material (20 g VOC/liter in the case of Source ID P108), making it technically infeasible to consider requiring an add-on emission control device.  In addition, Source ID P102 is the dryer section of Source ID P103 (#1 Paper Machine Glue Containment Area) and Source ID P202 is the dryer section of Source ID P203 (#2 Paper Machine Glue Containment Area).  Therefore, Source IDs P102/P103 and Source IDs P202/P203 are grouped together.  In addition to other specified requirements for Source IDs P102, 103, 108, 110, 202, and 203 described in Table 4.1 below, the site-wide VOC RACT II for all sources (Source IDs P101, 102, 103, 108, 110, 201, 202 and 203) are the following VOC content and usage limits, which are determined to be the lowest reasonable emission limits based on available materials and usage because add-on controls have been determined to be technically infeasible.  





                      Table 4.1: VOC RACT II Requirements
Site-wide Material Used
VOC RACT II Content, as applied, (Vapor Pressure) Limitations 
Material Usage Limitation (based on calendar month average)
VOC RACT II Usage Limitation
Wet Strength #1
0.124 lbs/gal (18.000 mmHg)
 25.0 lbs Wet Strength/ton paper towel; 0.00 lbs Wet Strength/ton tissue paper
For all adhesives, total combined VOC added as paper additives may not exceed 3.13 lbs/ton paper towel manufactured and 0.58 lbs/ton tissue paper manufactured, as calculated on a calendar month basis.  
Wet Strength #2
0.005 lbs/gal (18.000 mmHg)


Dry Strength
0.080 lbs/gal (0.001 mmHg)
                                      N/A

Softener/Debonder
0.009 lbs/gal (0.001 mmHg)
                                      N/A

Formation Aid
0.001 lbs/gal (18.000 mmHg)
                                      N/A

Defoamer
0.010 lbs/gal (0.010 mmHg)
                                      N/A

Crepe Adhesive
0.002 lbs/gal (0.010 mmHg)
                                      N/A

Release Aid
0.092 lbs/gal (0.001 mmHg)
 0.562 lbs Release Aid/ton paper towel; 1.172 lbs Release Aid/ton tissue paper

Fabric Release
2.319 lbs/gal (1.000 mmHg)
20.0 lbs Fabric Release/ton paper towel; 20.0 lbs Fabric Release/ton tissue paper

Biocide 
0.001 lbs/gal (0.500 mmHg)
                                      N/A

Drainage Aid
2.285 lbs/gal (18.000 mmHg)
 0.96 lbs Drainage Aid/ton paper towel; 0.96 lbs Drainage Aid/ton tissue paper


Additionally, for Source ID P108 (Adhesive Operation), VOC RACT II is determined to be an emissions cap of 6.83 tons in any 12-month consecutive period and VOC emission limits on glue content and usage.  Because add-on controls have been determined to be infeasible, VOC emission limits are being applied.  These emission limits for Source ID P108 are listed in Table 4.2.  

                 Table 4.2: Emission Limits for Source ID P108
Source ID P108 Materials
VOC RACT II Emission Limit (lbs VOC/gallon)
Usage Limit (gallons/day)
Laminating Glue 
0.0005
4000
Tail Tie 
0.008
1100
Transfer Glue
0.010
300
Core Glue
0.008
700
Case Glue
0.000
No usage limit

Additionally, for Source ID 110 (Wastewater Treatment Operation), the large surface area over which the VOCs are generated make add-on control technology infeasible.  Therefore, for Source ID P110, VOC RACT II for the treatment of paper additives is a VOC emissions cap of 8.81 tons in any 12-month consecutive period and a limitation on the VOC content of the flocculant and clarifier used at Source ID 110 is limited to 2.34 lbs/gal and 2.18 lbs/gal, respectively.  In addition, for Source ID 110, the VOC RACT II requirements for the treatment of boiler and cooling tower additives are limited to less than 0.12 tons in any 12-month consecutive period. 

The remaining units at First Quality Tissue are subject to the presumptive RACT II requirements.  The units at First Quality Tissue with the applicable RACT II requirements are listed in Table 4.3 below:  

             Table 4.3: Units Subject to VOC RACT II Requirements
Source ID
Source Description
VOC RACT II Requirement
032
Unit Heaters and Air Make-up Units
25 Pa. Code §129.97(g)(1)(i)
033
#1 Paper Machine Boiler
25 Pa. Code §129.97(g)(1)(i)
034
#2 Paper Machine Boiler
25 Pa. Code §129.97(g)(1)(i)
P101
#1 Paper Machine Wet-End
CbC (see next section)
P102
#1 Paper Machine Dryers
CbC (see next section)
P103
#1 Paper Machine Glue Containment Area
CbC (see next section)
P105
#1 Paper Machine Dry End
25 Pa. Code §129.96(c) (Exempt)
P106
#1 Paper Machine DAF Clarifier
25 Pa. Code §129.96(c) (Exempt)
P108
Adhesive Operation
CbC (see next section)
P109
Printing Operation (2 flexographic printing presses, now shutdown; 1 ink jet printer)
(For the ink jet printer) 25 Pa. Code §129.96(c) (Exempt)
P110
Wastewater Treatment Operation
CbC (see next section)
P111
12 Storage Tanks
25 Pa. Code §129.96(c) (Exempt)
P112
Diesel Fire Pump (300hp)
25 Pa. Code §129.97(c)(5) and 40 CFR 63.6640 Subpart ZZZZ
P201
#2 Paper Machine Wet-End
CbC (see next section)
P202
#2 Paper Machine Dryers
CbC (see next section)
P203
#2 Paper Machine Glue Containment Area
CbC (see next section)
P205
#2 Paper Machine Dry End
25 Pa. Code §129.96(c) (Exempt)
P206
#2 Paper Machine DAF Clarifier
25 Pa. Code §129.96(c) (Exempt)

PADEP's Conclusions
PADEP's determinations for CbC VOC RACT II requirements for First Quality Tissue are listed in Table 4.4.  PADEP has determined that VOC usage rates and content limits rather than add-on controls are RACT II because low flow rates in these units make add-on controls technically infeasible.  To determine compliance with the RACT II requirements, appropriate monitoring and recordkeeping pursuant to 25 Pa. Code §127.441 and §129.95, is also required.   

            Table 4.4: Case-by-Case (CbC) VOC RACT II Requirements
Source ID
Source Description
VOC RACT II Requirement
P101
#1 Paper Machine Wet-End
See Site-wide Materials Content and Usage Limitations
P102
#1 Paper Machine Dryers
(combined with Source ID P103) 12.38 lbs/hr when manufacturing paper towels and 6.55 lbs/hr when manufacturing tissue paper; Site-wide Materials Content and Usage Limitations
P103
#1 Paper Machine Glue Containment Area
(combined with Source ID P102) 12.38 lbs/hr when manufacturing paper towels and 6.55 lbs/hr when manufacturing tissue paper; Site-wide Materials Content and Usage Limitations
P108
Adhesive Operation
6.83 tpy plus VOC emission limits by type of glue; Site-wide Materials Content and Usage Limitations
P110
Wastewater Treatment Operation
8.81 tpy plus VOC emission limits 2.34 lbs/gal for flocculant and 2.18 lbs/gal clarifier; 0.12 tons VOC from boiler and cooling tower additives in any 12-month consecutive period; Site-wide Materials Content and Usage Limitations
P201
#2 Paper Machine Wet-End
See Site-wide Materials Content and Usage Limitations
P202
#2 Paper Machine Dryers
(combined with Source ID P203) 12.38 lbs/hr when manufacturing paper towels and 6.55 lbs/hr when manufacturing tissue paper; Site-wide Materials Content and Usage Limitations
P203
#2 Paper Machine Glue Containment Area
(combined with Source ID P202) 12.38 lbs/hr when manufacturing paper towels and 6.55 lbs/hr when manufacturing tissue paper; Site-wide Materials Content and Usage Limitations

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 First Quality Tissue.  

Incorporation By Reference 
First Quality Tissue  -  Incorporating by reference Permit No. 18-00030, issued September 18, 2017, as redacted by Pennsylvania. 



























Chapter 5:  JW Aluminum Company (#41-00013)

Facility Description and Processes
JW Aluminum, located in Lycoming County, Pennsylvania.  JW Aluminum rolls aluminum to final thicknesses of between 0.001 to 0.006 inches.  The emissions sources at JW Aluminum consist of rolling mills, coating lines, degreasers and combustion units. 
      
Units Subject to Case-by-Case RACT II
JW Aluminum is classified as a major VOC emitting facility, thus required to meet VOC RACT II requirements.  This facility is not classified as a major NOx emitting facility.  JW Aluminum is seeking approval for a CbC VOC RACT II determination for four rolling mills (Source IDs P101, P102, P103, and P104).   

RACT I Considerations
There are no RACT I considerations for JW Aluminum.  

Technical and Economic Feasibility
The VOC RACT II requirements for the four rolling mills were evaluated as follows.  The VOC control technologies, Thermal Oxidation with and without heat recovery, Adsorber, and RTO were determined to be technically feasible.  The economic costs were evaluated and ranged from $10,800 to more than $290,000/ton VOC removed.  Consequently, none of these control technologies are deemed technically and economically feasible for these rolling mills.  
      
PADEP's Conclusions
PADEP's determinations for CbC VOC RACT II requirements for JW Aluminum's four rolling mills are listed in Table 5.1.  PADEP is applying emission limits on each rolling mill, because add-on controls have been determined to be economically infeasible.      

             Table 5.1: VOC RACT II Requirements for Rolling Mills
Source ID/Description
RACT II VOC Emission Limit 
RACT II VOC Emissions Cap
P101, Cold Roll Mill 1
30.5 pounds per hour (lbs/hr)
Mills 1 and 2 combined VOC cap of 225 ton/12-month consecutive period
P102, Cold Roll Mill 2
30.5 lbs/hr
Mills 1 and 2 combined VOC cap of 225 ton/12-month consecutive period
P103, Cold Roll Mill 3
2.0 lbs/hr
No more than 8,000 operating hrs/12-month consecutive period
P104, Cold Roll Mill 4
6.0 lbs/hr
None

In addition, all sources are required to conduct appropriate monitoring and recordkeeping to determine compliance with the RACT II requirements pursuant to 25 Pa. Code §127.441 and §129.95.  Other units at JW Aluminum are subject to CTG requirements or have small enough emissions for exemption and hence, meet the RACT II requirements.  These units are listed in Table 5.2.

        Table 5.2: Additional Units Subject to VOC RACT II Requirements
Source ID
Source Description
VOC RACT II Requirement
031
Small RACT Boilers and Heaters
(existing permit requirements) < 3 lbs VOC/hr and 15 lbs/day and annual VOC emissions cap from 25 Pa. Code §129.97(c)(2)
032
Large RACT Heaters
(existing permit requirements) < 3 lbs VOC/hr and 15 lbs/day and annual VOC emissions cap from 25 Pa. Code §129.97(c)(2)
033
Small Heater 
25 Pa. Code §129.96(c)
034
Large Heater and Boiler
25 Pa. Code §129.96(c)
P106
Cold Cleaning Degreasers
25 Pa. Code §129.63 
P107
Animal Fat and Vegetable Oil Application Area
Shutdown
P108
Quality Control Laboratory Operations
VOC emission cap of 1.0 tpy (in any 12-month consecutive period) to comply with 25 Pa. Code §129.96(c) (Exempt)
P109
>2000 gallon Storage Tanks
25 Pa. Code §129.57 
P110
>2000 gallon Storage Tanks
25 Pa. Code §129.57 
P111
Storage Tanks
25 Pa. Code §129.57 
P113
Oven #4
25 Pa. Code §129.96(c) (Exempt)
P114
Oven #3
25 Pa. Code §129.96(c) (Exempt)
P201
Coil Coating Line 1
25 Pa. Code §129.52 
P202
Coil Coating Line 2
25 Pa. Code §129.52 
P203
Coil Coating Line 3
25 Pa. Code §129.52 
P204
Coil Coating Line 4
25 Pa. Code §129.52 
P204A
Coil Coating Line 4B and Cleanup
25 Pa. Code §129.52 
P205
Coil Coating Line 5
25 Pa. Code §129.52 
P206
Coil Coating Line 6
25 Pa. Code §129.52 
P207
Coating Solutions Mixing Area
25 Pa. Code §129.97(c)(2)
P208
Coating Solutions Storage Area
25 Pa. Code §129.97(c)(2)
P209
Process Heaters and Ovens
(existing permit requirements) < 3 lbs VOC/hr and 15 lbs/day and annual VOC emissions cap from 25 Pa. Code §129.97(c)(2)
P210
Coil Coating Line and Cleanup
25 Pa. Code §129.52
P211
Distillation Unit
VOC emission cap of 1.0 tpy (in any 12-month consecutive period) to comply with 25 Pa. Code §129.96(c)

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 JW Aluminum.  

Incorporation By Reference
JW Aluminum Company  -  Incorporating by reference Permit No. 41-00013, issued March 1, 2017, as redacted by Pennsylvania.
































Chapter 6:  Ward Manufacturing LLC (#59-00004)

Facility Description and Processes
Ward Manufacturing (Ward) is an iron casting, molding and finishing operation that includes metal coating and degreasing operations.  Ward is located in Tioga County, Pennsylvania.  The emission sources at Ward consist of molding, casting and glue operations including degreasing and combustion units.  
      
Units Subject to Case-by-Case RACT II
Ward is classified as a major VOC emitting facility, thus required to meet VOC RACT II requirements.  Ward is seeking CbC VOC RACT II approval for Source IDs 173 (Molding and Casting Operations) and 199 (Molding Lines, SP01, SP02, SP03), which share the same stack, 101 (Cupola), 149 (Core Room Operations), and 149W (Furan Warm Box Core Machine).  

RACT I Considerations
There are no CbC RACT I considerations for Ward.

Technical and Economic Feasibility
For the VOC RACT II analysis, TOs were determined to be technically feasible for Source IDs 101, 149, 149W, 173 and 199.  For the combined VOC emissions from Source IDs 173 and 199, Ward agreed to abide by the 40 CFR 63 Subpart EEEE (NESHAP for Iron and Steel Foundries) requirements to ignite VOC coming from the mold vents to reduce the VOC emissions from the molding process.  In addition, Ward agreed to completely remove the SP02 pouring and cooling line.  These combined actions reduce the PTE from Source IDs 173 and 199 from 165.9 tpy to 109.5 tpy.  The cost of adding a TO to remove the 109.5 tpy VOC are determined to be infeasible (in excess of $130,000/ton VOC removed).  Therefore, VOC RACT II requirement for Source IDs 173 and 199 is a VOC emissions limit of 55.3 lbs/hr and 109.5 tpy (determined on a 12-month rolling basis), based on the available materials and usage that would allow these Source IDs to comply with the NESHAP.  

Source ID 101's (Cupola) potential VOC emissions is about 1 tpy, making use of a TO economically infeasible.  VOC RACT II requirements for Source ID 101 (Cupola) are both throughput restrictions and a VOC emission limit of < 20 ppmvd, corrected to 10% O2, which is taken from the NESHAP requirements at 40 CFR 63.7680, Subpart EEEE.  The throughput restrictions are 37.78 tons per hour of malleable and gray iron and no more than 225,680 tons/12-month consecutive period.  The low VOC emissions would allow Source ID 101 to meet the presumptive RACT II requirements under 25 Pa. Code §129.97(c)(2) and the application of 40 CFR 63.7680, Subpart EEEE, satisfy the RACT II requirements for this unit and PADEP has identified these as CbC RACT II requirements.  

For Source ID 149 (Core Room Operations), Ward agreed to use a new core binder that reduces the potential VOC emissions at this source from 145.32 tpy to 72.66 tpy, a reduction of 50% from pre-RACT II levels.  The use of a TO, while technically feasible, is determined to be economically infeasible at over $135,000/ton VOC removed.  
      
The two emission units that comprise Source ID 149A meet the minimum VOC emissions (< 2.7 tpy VOC per unit) for exemption from the PA RACT II regulations at 25 Pa. Code §129.97(c)(2).  

For Source ID 149W (Furan Warm Box Core Machine), Ward will use the same lower VOC core binder used in Source ID 149 and 149A, which reduces the potential VOC emissions from Source ID 149W from 15.57 tpy to 8.00 tpy.  The addition of a TO on Source ID 149W is estimated to cost $39,000/ton VOC and therefore deemed economically infeasible. VOC RACT II requirement for Source ID 149W (Furan Warm Box Core Machine) is the continued use of the lower VOC core binder and a VOC emissions cap of 8.00 tpy (a reduction of 48.6% from pre-RACT II levels).  
      
For Source ID 173 (Molding and Casting Operations) and 199 (Molding Lines, SP01, SP02, and SP03), there are existing PADEP emissions limits and an emission cap that apply.  Together, both of these units are required to meet a 55.3 lbs VOC/hr and 165.7 tpy VOC emissions cap.  Source ID 173 has low VOC emissions, which are venting as part of Source ID 199's VOC emissions.  Source ID 199 is subject to the mold vent ignition requirements of 40 CFR 63.7610 Subpart EEEEE based on previously approved PADEP requirements.  TOs were evaluated for use on Source ID 199.  While technically feasible, the economic costs of TO is estimated at more than $130,000/ton VOC removed, making this economically infeasible.  Therefore, for the RACT II evaluation, PADEP determines that the VOC emissions cap is reduced to 109.5 tpy (due to the shutdown of Molding Line SP02) and continued use of the mold vent ignitors per 40 CFR 63.7610 Subpart EEEEE.  

PADEP's Conclusions
PADEP has determined that VOC RACT II for Source ID 149 (Core Room Operations) is the use of the lower VOC core binder, restriction to the use of only natural gas or propane (an additional requirement imposed by PADEP to minimize emissions), and the 72.66 tpy emission cap (determined on a 12-month rolling basis).  
      
PADEP has determined that VOC RACT II for Source ID 149W (Furan Warm Box Core Machine) is the continued use of the lower VOC core binder and a VOC emissions cap of 8.00 tpy.  In addition, CbC RACT II for the Ward sources includes the appropriate monitoring, recording and reporting for compliance with the applicable requirements pursuant to 25 Pa. Code §127.441 and §129.95.  
      
PADEP has determined that the VOC RACT II requirements for Source IDs 173 and 199 are 55.3. lbs VOC/hr and 109.5 tpy (and shutdown of Molding Line SP02) plus the requirement to use the mold vent ignitors per 40 CFR 63.7610 Subpart EEEEE.  

The following VOC RACT II requirements listed in Table 6.1 apply to the sources at Ward.

                      Table 6.1: VOC RACT II Requirements
Source ID
Source Description
VOC RACT II Requirement
034
18 Air Make-up Units
25 Pa. Code §129.97(c)(2)
035
Combustion Units
25 Pa. Code §129.97(c)(2)
101
Cupola
CbC: < 20 ppmv, corrected to 10% O2 (40 CFR 63.7680, Subpart EEEEE NESHAP), control with afterburners and maintain afterburner temperature > 1,300°F, and throughput restriction of 37.78 tons/hour of malleable and gray iron and no more than 225,680 tons per 12-month consecutive period.
105
Anneal Ovens
25 Pa. Code §129.97(c)(2)
107
3 Tumblast Machines
No VOC emissions
109
23 Grinders and Sanders
No VOC emissions
149
Core Room Operations
CbC: Use of low VOC core binder to meet tpy VOC caps as described above.
149A
New Core Machines
25 Pa. Code §129.97(c)(2)
149W
Furan Warmbox Core Machine
CbC: Use of low VOC core binder to meet tpy VOC caps as described above.
161
Dip Tank and Parts Spinner
No VOC emissions
163
5 Tumblast Machines
No VOC emissions
173
Molding and Casting Operations
CbC (together with Source ID 199, shared emission limit and annual emission cap): 55.3. lbs VOC/hr and 109.5 tpy (and shutdown of Molding Line SP02) and compliance of mold igniters with 40 CFR 63.7610 Subpart EEEEE
181
Plant 1 Evaporator
25 Pa. Code §129.97(c)(2)
181A
Wastewater Evaporator
25 Pa. Code §129.97(c)(2)
183
Scrap and Charge Handling Operations
No VOC generated by itself but existing requirement to ensure that scraps going to Source ID 101 have minimum VOC in accordance with 40 CFR 63.7700 Subpart EEEEE remains because it affects Source ID 101.
185
Bond Silo
No VOC emissions
189
Existing Emergency Generators
25 Pa. Code §129.97(c)(8)
189A
New Emergency Generator
25 Pa. Code §129.97(c)(8)
191
14 Parts Washers
25 Pa. Code §129.63
199
Molding Lines (SP01, SP02, SP03)
CbC (together with Source ID 173, shared emission limit and annual emission cap): 55.3. lbs VOC/hr and 109.5 tpy (and shutdown of Molding Line SP02) and compliance of mold igniters with 40 CFR 63.7610 Subpart EEEEE


EPA's Conclusions and Recommendations
EPA finds 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 Ward.  

Incorporation By Reference
Ward Manufacturing, LLC  -  Incorporating by reference Permit No. 59-00004, issued January 10, 2017, as redacted by Pennsylvania. 





























Chapter 7:  Wood-Mode (#55-00005)

Facility Description and Processes 
Wood-Mode  -  Kreamer Plant (Wood-Mode) is a custom wood kitchen cabinetry manufacturer located in Snyder County, Pennsylvania.  The emissions sources at Wood-Mode consist of staining, veneering, gluing, and combustion units.

Units Subject to Case by Case RACT II
Wood-Mode is classified as a major VOC emitting facility, thus required to meet VOC RACT II requirements.  Wood-Mode is seeking approval for a CbC VOC RACT II determination for Source IDs 143 and 146, Hand Wipe Stain Application Stations, only when stains are used.  

RACT I Considerations
There are no CbC RACT I considerations for Wood-Mode.  

Technical and Economic Feasibility
The non-stain coatings used at Source IDs 143 and 146 are subject to 25 Pa. Code §§129.52 and 129.101-129.107 requirements, which meet RACT II.  Therefore, the non-stain coatings are not being evaluated for CbC RACT II.  In PADEP's evaluation of the hand-wiped stains used in Source IDs 143 and 146 for the CbC RACT II analysis, the following VOC control options were considered:  TO, Flare, Condenser, Adsorption, Concentrator with TO, and Absorption (Scrubbing).  

Source IDs 143 and 146 use the same stains.  Current PADEP permit conditions for the stains used in Source IDs 143 and 146 require hand-wiping or brush application only and a VOC content limit of 6.4 lbs/gal.  The trial of using lower VOC content for stains was not acceptable to Wood-Mode's customers because of the graying effect of these stains.  Therefore, Wood-Mode returned to the use of oil-based stains.  The low VOC concentrations (< 100 ppm) in the exhaust systems for the subject sources makes flares, condensers, adsorption, and scrubbers infeasible control options.  Therefore, only TOs (expected 98% control efficiency) and concentrators with TOs (expected 95% control efficiency) are considered technically feasible options.  The economic analyses for these two technically feasible options were evaluated.  For each of the two (stain operations at Source IDs 143 and 146) CbC RACT II sources, the cost per VOC ton removed are found to range from $11,000/ton to more than $32,000/ton.  These are determined to be economically infeasible options for Source IDs 143 and 146 when stains are applied.  
      
The work practice standards for minimizing VOC emissions by sealing them in containers when not in actual use and not allowing VOC evaporation from rags or other cloths is determined to be part of the CbC RACT II determination for Source IDs 143 and 146.  The combination of VOC content limits for the stains with an emissions cap, which ensures limited stain usage (42.5 tpy for Source ID 143 and 15 tpy for Source ID 146), and good work practices is determined to be RACT II for these units. 



PADEP's Conclusions
PADEP has determined that the VOC RACT II requirements for Source IDs 143 and 146 is a VOC content restriction, an emissions cap, and work practice standards.  PADEP has determined that these are appropriate RACT II requirements because of the economic infeasibility of add-on controls for these operations.  In addition, CbC RACT II for these sources include all the appropriate monitoring, recordkeeping, and reporting for compliance with the applicable requirements pursuant to 25 Pa. Code §127.441 and §129.95.  The RACT II requirements for the units at Wood-Mode are listed in Table 7.1.

                      Table 7.1: VOC RACT II Requirements
Source ID
Source Description
VOC RACT II Requirements
031
Boiler 1
Existing PADEP requirements are more stringent than presumptive RACT II, so they are retained:  2.45 tpy, for any 12-month consecutive period with an annual tune-up requirement (25 Pa. Code §129.91-129.95 RACT I requirements)
032
Boiler 2
25 Pa. Code §129.96(c) (Exempt)
033
Boiler 3
25 Pa. Code §129.96(c) (Exempt)
101
Wood Waste Handling and Silos 1 and 2
No VOC emissions
102
Woodworking Operation Building C
No VOC emissions
103
Woodworking Operations A-1 and A-2
No VOC emissions
104
Woodworking Operations B-1 and B-2
No VOC emissions
105
Woodworking Operations B-4
No VOC emissions
106
Woodworking Operations B-5 and B-6
No VOC emissions
110
3 Storage Tanks
25 Pa. Code §129.57
140
Clean up and Wash off Operations
25 Pa. Code §§129.101-129.107
142
20 Spray Booths
25 Pa. Code §129.52, §§129.101-107
143
Hand Wipe Stain Application Station (Stain application only)
CbC:
 VOC content of any water-based stain or finishing material not to exceed 6.4 lbs VOC/gal (including water) unless more stringent limit applies in 25 Pa. Code §129.52.
 Hand application only permitted.
 VOC content of any stain or finishing material not to exceed 6.4 lbs VOC/gal, minus water unless more stringent limit applies in 25 Pa. Code §129.52.
 VOC emissions cap of 42.5 tons in any consecutive 12-month period.
 Work practice standards for stain handling and associated cleanup operations.
143
Hand Wipe Stain Application Station (Non-Stain applications only)
25 Pa. Code §129.52 and §129.101-107
144
20 Spray Booths
25 Pa. Code §129.52 and §129.101-107
146
Hand Wipe Stain Application Stations (Stain application only)
CbC:
 VOC content of any water-based stain or finishing material not to exceed 6.4 lbs VOC/gal (including water) unless more stringent limit applies in 25 Pa. Code §129.52
 Hand application only permitted
 VOC content of any stain or finishing material not to exceed 6.4 lbs VOC/gal, minus water unless more stringent limit applies in 25 Pa. Code §129.52
 VOC emissions cap of 15 tons in any consecutive 12-month period
 Work practice standards for stain handling and cleanup operations
146
Hand Wipe Stain Application Stations (Non-stain applications only)
25 Pa. Code §129.52 and §129.101-107
154
Lumber Drying Area
25 Pa. Code §129.97(c)(2) (Exempt)
155 
Veneering Operations
25 Pa. Code §129.52 and §129.101-107
156
Gluing Operations
25 Pa. Code §129.52 and §129.101-107
157
Ancillary Sources
 1 hot veneer machine
 1 glue/water evaporator
 1 UV roll coater
 Paint lab
 Paint lab booths
 25 Pa. Code §129.77
 25 Pa. Code §129.96(c) (Exempt)
 25 Pa. Code §129.96(c) (Exempt)
 25 Pa. Code §129.96(c) (Exempt)
 25 Pa. Code §129.96(c) (Exempt)
159
Inspection/Repair Area
25 Pa. Code §129.52 and §129.101-107
160
Pre-2006 Emergency Rice
40 CFR 63.6640 Subpart ZZZZ (NESHAP) and 25 Pa. Code §129.97(c)(8)
161
155 bhp Kohler Emergency Generator
40 CFR 60.4233 Subpart JJJJ (NSPS) and 25 Pa. Code §129.97(c)(8)

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 Wood-Mode.  

Incorporation By Reference
Wood-Mode Inc.  -  Incorporating by reference Permit No. 55-00005, issued July 12, 2017, as redacted by Pennsylvania.































Chapter 8:  Foam Fabricators, Inc (#19-00002)

Facility Description and Processes 
Foam Fabricators, Inc (FFI) is an expandable polystyrene (EPS) foam molding facility located in South Centre Township, Columbia County, Pennsylvania.  The facility manufactures custom-shape molded EPS foam into products for packing, material handling, and structural component uses.  Permitted emissions sources at this facility include a 14.29 MMBtu/hr natural gas-fired boiler, a 9.958 MMBtu/hr natural gas-fired boiler, thirteen natural gas-fired heat radiators (1.073 MMBtu/hr total combined heat input), a pre-expander, pre-puff storage, molding machines, a finish product warehouse, and a parts washer.

Units Subject to Case-by-Case RACT II
FFI is classified as a major VOC emitting facility, thus required to meet VOC RACT II requirements.  The facility is a minor source of NOx emissions and is not required to meet NOx RACT II requirements.

The following sources are exempt from VOC RACT II requirements because they emit less than 1 tpy VOCs (25 Pa. Code §129.96(a)):
 Source ID 032 (boiler 1)
 Source ID 034 (boiler 2)
 Source ID 033 (heat radiators)
 Source ID P109 (parts washer)

The following sources are subject to CbC RACT II because they each have a PTE greater than 2.7 tpy of VOC and no applicable presumptive RACT requirements exist (25 Pa. Code §129.99):
 Source P101 (pre-expander)
 Source P103 (pre-puff storage)
 Source P104 (molding machines)
 Source 105 (finished product warehouse)

RACT I Considerations
FFI was not subject to the VOC RACT I rule.

Technical and Economic Feasibility 
The following control technologies were deemed technically infeasible for Source ID P101, P103, P104, and 105:
 material substitution: the pentane content of the material used varies product to product (between 3.5% to 6.0% by weight)
 flaring: heat content of the exhaust stream would be less than 300 Btu per standard cubic foot, which is the lowest heat content recommended for air assisted flares (per 40 CFR 60.18); pentane emissions are not continuous and laden with steam
 carbon absorption: collecting pentane in an enclosed carbon container poses a potential explosion risk
 condensation: the airflow required to collect emissions from the facility would be too high
 wet scrubbing: controls are not effective in capturing pentane due to its low water solubility
 oxidizing using the facility's existing boiler: airflow needed to adequately collect pentane emissions would be too high for the facility's 350 hp boiler

The facility determined catalytic oxidation, RTO, and TO were technically feasible, and evaluated the economic feasibility of installing and operating each technology under three potential control scenarios.  The cost per ton of VOC controlled for every oxidation technology under each scenario were not economically feasible.

Table 8.1: Cost Per Ton of Pentane (VOC) Controlled by Control Technology and Control Scenario

                               Control Scenario

                        control pre-expansion operation
     control pre-expansion operation and 24-hour pre-puff aging operation
control pre-expansion operation, 24-hour pre-puff aging operation, and molding operation
Catalytic oxidation
                                    $12,535
                                    $16,942
                                    $15,702
RTO
                                    $13,835
                                    $17,691
                                    $18,463
Thermal oxidation
                                    $14,519
                                    $23,835
                                    $23,699

PADEP's Conclusions 
PADEP concurred that no technically and economically feasible control technologies were available to reduce VOC.  PADEP has determined that VOC CbC RACT II for FFI Source P101, Source P103, Source P104, and Source 105 is:
 use of polystyrene bead with the lowest pentane content possible, not to exceed 6% by weight
 a facility-wide VOC emissions limit of 85 tpy
The facility-wide VOC limit is an existing limit established in Plan Approval 19-00002A.

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 FFI.  

Incorporation by Reference
Foam Fabricators Inc.  -  Incorporating by reference Permit No. 19-00002, issued December 20, 2017, as redacted by Pennsylvania.

Chapter 9:  Resilite Sports Products Inc. (#49-00004)

Facility Description and Processes 
Resilite Sports Products Inc. (Resilite) is an athletic mat manufacturing facility located in Northumberland Borough, Northumberland County, Pennsylvania.  The facility manufactures new wrestling mats and reconditions used wrestling mats.  Emissions sources at this facility include a 16.8 MMBtu/hr natural gas-fired boiler, four spray bays with associated coating equipment, a spray booth with adhesive equipment, spray equipment cleanup operations, a 20,000-gallon solvent storage tank, and a 12.5 bhp propane-fired emergency generator.

Units Subject to Case-by-Case RACT II
Resilite is classified as a major VOC emitting facility, thus required to meet VOC RACT II requirements.  The facility is a minor source of NOx emissions and is not required to meet NOx RACT II requirements.

The following sources are exempt from RACT II VOC requirements: 
 Source ID 032 (Hurst Boiler) (25 Pa. Code §129.96(c))
 Source ID 203 (storage tank) and Source ID 2014 (emergency generator) (25 Pa. Code §129.96(a))
 Source ID 107 (adhesive application operation & assembly, reconditioning preparation) (25 Pa. Code §129.77 and 25 Pa. Code §129.96(a))

The following sources are subject to CbC RACT II requirements for VOC because they each have a PTE greater than 2.7 tpy of VOC (25 Pa. Code §129.99):
 Source ID 106 (mat finish and cure operations -- 4 spray bays)
 Source ID 201 (mat reconditioning operations)
 Source ID 202 (spray equipment cleanup operations)

Note that for Source ID 106, RACT analysis is only required for VOCs attributable to the application of mat coating materials.  VOC attributable to the application of adhesives/sealants are exempt from RACT II VOC requirements based on 25 Pa. Code §129.96(a).

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-49-0003, issued December 3, 1996.  This permit was approved by EPA into the SIP on October 17, 2003.  See 40 CFR §52.2020(d)(1)(g).  

Under OP-49-0003, the adhesive application operations (Source ID 107), mat finish and cure operations (Source ID 106), mat reconditioning operations (Source ID 201), spray equipment cleanup operations (Source ID 202), air stripper (remediation of contaminated groundwater), and #2 fuel oil-fired Continental boiler are subject to the following requirements:

Emissions and operational limits
 Combined VOCs (other than air stripper and boiler): 425 tons during any 12-month period
 Adhesive VOC: 5.98 lb/gal of adhesive (minus water)
 Organic solvent-based mat coating material VOC: 6.83 lb/gal of coating (minus water)
 Water-based mat coating materials: 1.0 lb/gal of coating (minus water)
 No equipment cleaned with VOC-containing solvents other than the spray guns and spray gun components
 Cleaning of all spray guns and spray gun components shall require soaking in closed containers
 Solvents or cleaning materials containing VOC shall not be sprayed through a spray gun into the atmosphere
 All containers containing adhesives, mat coating materials, cleaning solvents, etc. shall be kept closed except when transferring material into or out of the containers
 VOC limits for air stripper and Continental boiler: 3 lb/hr, 15 lb/day, 2.7 tpy
 Boiler fired only on gas (natural or liquified petroleum) or #2 fuel oil with a sulfur content not to exceed 0.5% by weight at any time
 Implement the "Employee Training Program" and "Leak Detection and Maintenance Program" described in the 6/21/95 submittal made to Mr. Kirit Dalal of the Department of Environmental Protection by Ms. Cynthia Mathhews of Rettew Associates on behalf of Resilite Sports Products Inc. to address the requirements and the operating permit and requirements of any applicable state and federal regulations

Recordkeeping
 Maintain manufacturer's formulation or composition data sheets for all VOC-containing materials used within the previous 2 years
 Reconditioning/cleanup solvent logs (retained for 2 years, accessible to the Department)
 Accurate, comprehensive records sufficient to demonstrate compliance with the RACT requirements (submitted quarterly to the department, except for annual air stripper data)
 Provide fuel analyses, or fuel samples used in the boiler at the department request

Through its RACT II determination, PADEP has modified the RACT I requirements in the following areas.  PADEP has determined that the RACT I emissions limit that capped VOC emissions from Source IDs 106, 107, 201, and 202 to 425 tpy will be superseded by individual CbC RACT II determinations for Source IDs 106, 201, and 202.  Source ID 107 is now exempt from RACT II VOC requirements.  Additionally, the RACT I limit of 6.83 lb/gal of coating (minus water) for VOCs in the organic solvent-based mat coating material will be superseded by a new VOC limit of 4.97 lbs/gal.  

VOC emissions attributable to the application of adhesives at Sources 106 and 107 are subject to a limit of 2.1 lb/gal per the CTG at 25 Pa. Code §129.77.  This limit supersedes the previous case-by-case requirement of 5.98 lbs/gal.  The air stripper and continental boiler requirements are removed, because the sources are no longer in operation.  

Technical and Economic Feasibility 
The following control technologies were deemed technically infeasible for Source ID 106, 201, and 202:
 waterborne coatings: water-based solvents are not compatible with the sealants and adhesives used for the mat assembly
 high solids coatings: these coatings are unable to flow readily to provide an even finish of the surface coating
 radiation cured coatings: pigments in the coatings will interfere with the photocure
 biofiltration: the total volume to provide a few seconds of residence time necessary for effective destruction would be prohibitive for the 60,000 cfm air flow of the coating stations 
 catalytic oxidation: inlet flow conditions have some variation; off gas streams with high VOC concentrations can produce temperatures high enough to destroy the catalyst and lead to failure

RTO and a hybrid concentrator system were eliminated in the facility's analysis due to estimated pollutant removal costs of greater than $10,000/ton of VOC removed.

The facility determined use of alternative solvent blends is both technically and economically feasible.  In order to maintain the quality and durability of the product, a blend cannot contain less than 15% VOC by weight.  The pollutant removal costs with the proposed VOC content limit was estimated at $428/ton of VOC.

As explained in the August 9, 2017 RACT II Addendum Review Memo, the facility encountered product quality issues when using the originally proposed solvent blend on high humidity days.  An additional 1% (by weight) of VOC was added to create Resilite Blend 6520.  The revised calculations assume 25% of the coating material will be an existing, higher VOC-containing blend (Resilite NP Acetate Blend) and 75% of the coating material will be Resilite Blend 6520. The sum of the revised individual source VOC emissions limits with the revised calculations establish a total of 230 tpy VOC.  In addition to appropriate monitoring, recordkeeping, and reporting conditions pursuant to 25 Pa. Code §129.100.  VOC RACT II is established as the following limits:
 Solvent-based coating material: 4.97 lbs VOC per gallon of coating
 Source ID 106: 221.74 tons in any 12 consecutive month period
 Source ID 201: 1.55 tons in any 12 consecutive month period
 Source ID 202: 6.41 tons in any 12 consecutive month period

PADEP's Conclusions 
PADEP determined that VOC RACT II for Resilite is:
 Solvent-based coating material: 4.97 lbs VOC per gallon of coating
 Source ID 106: 221.74 tons in any 12 consecutive month period 
 Source ID 201: 1.55 tons in any 12 consecutive month period
 Source ID 202: 6.41 tons in any 12 consecutive month period
 Appropriate monitoring, recordkeeping, and reporting conditions
The annual emissions limits for each source are derived from the VOC content limit.

EPA's Conclusions and Recommendations
EPA finds that the CbC RACT 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 Resilite.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional 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.    

Incorporation by Reference
Resilite Sports Products Inc  -  Incorporating by reference Permit No. 49-00004, issued August 25, 2017, as redacted by Pennsylvania.  All permit conditions in the prior RACT Permit No. OP-49-0003 issued December 3, 1996, remain as RACT requirements except for Condition 5.c, which is superseded by the new permit.

Chapter 10:  Texas Eastern  -  Bernville Station; (#06-05033)

Facility Description and Processes 
Texas Eastern Transmission LP  -  Bernville Station (TE-Bernville) is a natural gas compressor station located in Berks County, Pennsylvania.  The emission sources at TE  -  Bernville consist of two natural gas turbines and an emergency internal combustion engine.  

Units Subject to Case-by-Case RACT II
TE-Bernville is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  TE-Bernville is seeking approval for a CbC NOx RACT II determination for two GE natural gas turbines (Source IDs 101 and 102).  

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-06-1033, issued January 31, 1997.  This permit was approved by EPA into the SIP on April 18, 1997.  See 40 CFR 52.2020(c)(120)(i)(B)(1).  

Under OP-06-1033, CbC RACT I NOx requirements were approved for TE  -  Bernville. 

Technical and Economic Feasibility 
The two GE Turbines (Source ID 101 and 102) are subject to the presumptive requirements at 25 Pa. Code §129.97(g)(2) of 42 ppmvd at 15% O2 but are unable to meet these limits.  Therefore, TE-Bernville is requesting a CbC RACT II determination instead.  For the NOx RACT II analysis for Source ID 101 (rated at 22,000 hp) and Source ID 102 (rated at 19,800 hp), Water Injection, Dry Low NOx Burners (DLNB), SCR, XONON system, EMx/SCONOx system, and SNCR were evaluated.  XONON, a flameless combustion system where a catalyst prevents NOx formation, is contained within a gas turbine.  XONON is determined to be infeasible because it would require redesign and replacement of the combustion chamber for the Bernville gas turbines.  EMx/SCONOx utilizes a platinum-based catalyst coated with potassium carbonate, which ultimately oxidizes NOx to CO2.  The catalyst operates at a temperature much lower than the temperatures of Source IDs 101 and 102 and therefore determined to be technically infeasible.  SNCR requires a temperature much higher than those operated in Source IDs 101 and 102 and therefore determined to be technically infeasible.  The effective temperature range (1,600ºF-2,000ºF) required by SNCR is higher than the current peak exhaust temperature (900ºF -1,000ºF).  

Water Injection, DLNB, and SCR are determined to be technically feasible and estimated to produce 65% NOx reduction, 79% NOx reduction, and 88% NOx reduction, respectively. Estimated costs for Water Injection for Source IDs 101 and 102 are more than $15,000/ton NOx removed.  For Source ID 101, the cost of SCR or DLNB is estimated at $6,900/ton NOx removed. For Source ID 102, the cost of SCR or DLNB is estimated at more than $7,100/ton NOx removed.  PADEP has determined that these control technologies are economically infeasible.  Texas Eastern will be undergoing a major modernization project to replace all the General Electric Frame 5 turbines along their pipeline, which will bring those sources into compliance with the presumptive RACT II limit by no later than January 1, 2024, including Source IDs 101 and 102 at TE  -  Bernville.  
PADEP's Conclusions
PADEP has determined that NOx RACT II requirements for Source IDs 101 and 102 are the same as the NOx RACT I emission limits, emission caps and operating hour caps.  The RACT II requirements are described in the table below.  Monitoring and recordkeeping provisions (per 25 Pa. Code §127.441 and §129.95) are used to determine compliance with RACT II requirements.  Stack testing for NOx emissions, in accordance with approved PADEP methods, is required for Source IDs 101 and 102 at least once per permit cycle (5 years).  PADEP has included a federally enforceable permit condition requiring mandatory shutdown of Source IDs 101 and 102 no later than January 1, 2024.  

                  Table 10.1: Applicable RACT II Requirements
Source ID 
Description
Approved RACT I Requirements (Yes/No)
NOx RACT II Requirements
101
Natural Gas Turbine (22,000 hp)
Yes
CbC:
1) 120 ppmvd at 15% O2
2,053.6 MMScf in any 12-month consecutive period 
2) 463 tons NOx on 12-month rolling average basis 
3) 8,000 hours during any 12-month consecutive period
4) Mandatory shutdown no later than January 1, 2014.
102
Natural Gas Turbine (19,800 hp)
Yes
CbC: 
1) 120 ppmvd at 15% O2
1956.8 MMScf in any 12-month consecutive period 
2) 441 tons NOx on 12-month rolling average basis 
3) 8,000 hours during any 12-month consecutive period
4) Mandatory shutdown no later than January 1, 2014.
 
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 source-specific RACT controls currently approve in the SIP for the remaining sources adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for TE  -  Bernville.  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.    


Incorporation by Reference
Texas Eastern Transmission, L.P.  -  Bernville - Incorporating by reference Permit No. 06-05033, issued March 16, 2018, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. OP-06-1033, issued January 31, 1997, except for Conditions 6, 7, 9, 10, 11, 12 and 13 which remain as RACT requirements.

























Chapter 11:  Texas Eastern Transmission, L.P. - Shermans Dale Station (#50-05001)

Facility Description and Processes
Texas Eastern Transmission, L.P. - Shermans Dale Station (TE-Shermans Dale) is a natural gas compressor station located in Shermans Dale, Perry County, Pennsylvania.  Permitted emission sources at this facility include two natural gas-fired turbines, an emergency generator, and area fugitive emission sources.

Units Subject to Case-by-Case RACT II
TE- Shermans Dale is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  The facility has taken a federally enforceable limit on facility-wide VOC emissions below 50 tpy, thus, it is a minor source of VOC emissions and not subject to VOC RACT II regulations.

Three sources have been identified as subject to NOx RACT II requirements.  One of the three sources (Source ID 033) will comply with presumptive NOx RACT II requirements.  The facility has proposed RACT II case-by-case, in accordance with 25 Pa. Code §129.99, for the remaining two sources (Source IDs 031 and 032).
 General Electric Frame 5 Turbine (Source ID 031)
 General Electric Frame 5 Turbine (Source ID 032)
 Leroi Emergency IC Engine (Source ID 033)  -  Presumptive RACT pursuant to 25 Pa. Code §129.97(c)(8)
RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-50-02001, issued April 12, 1999.  This permit was approved by EPA into the SIP on April 28, 2006.  See 40 CFR §52.2020(d)(1)(n).  

Under RACT OP-50-02001, issued on April 12, 1999, the two General Electric Frame 5 turbines (Source IDs 031 and 032) were subject to a NOx emission limit of 120 ppmdv corrected to 15% O2.  In a prior permit (RACT OP-50-02001, issued May 16, 1995) these two turbines were permitted with a lower NOx emission limit of 90 ppmdv corrected to 15% O2.  However, the limit was revised for both turbines with the facility's revised RACT application dated July 29, 1996 and subsequent April 12, 1999 permit action.  PADEP has determined that there was an error with the April 28, 2006 SIP action and has provided documentation of this error both in its technical review memo, as well as within its SIP submittal attachments.  PADEP has determined that while the April 28, 2006 SIP action appears to have incorporated the later permit (April 12, 1999) with the RACT NOx limit of 120 ppmdv corrected to 15% O2, in reality, pages 2 and 3 of that purported permit did not actually belong to the 1999 permit, but rather were erroneously spliced from the earlier 1995 permit.  PADEP has determined that the spliced pages 2 and 3 were never intended to be placed in the SIP and should not be deemed to be part of the SIP.  PADEP considers the correct RACT I NOx emission limit to be 120 ppmdv corrected to 15% O2 for the two turbines.
Technical and Economic Feasibility 
The two General Electric Frame 5 turbines (Source IDs 031 and 032) are rated at 22,000 hp and 19,800 hp respectively and are subject to the presumptive RACT II emission limit of 42 ppmvd at 15% O2.  Source IDs 031 and 032 are currently unable to meet the presumptive limit, thus the facility is proposing CbC RACT.  Of the potential NOx control technologies evaluated by the facility for the two turbines, XONON technology (a system that utilizes a flameless combustion system where fuel and air reacts on a catalyst surface, preventing the formation of NOx while achieving low CO and unburned hydrocarbon emission levels), EMx/SCONOx technology (a system consisting of a platinum-based catalyst coated with potassium carbonate to oxidize NOx and CO), and SNCR were determined to be infeasible.  XONON is infeasible because it would be necessary to redesign and replace the combustion chamber.  EMx/SCONOx is infeasible because it has not been demonstrated in a simple-cycle gas turbine in natural gas combustion service.  SNCR is infeasible because the effective temperature range (1,600ºF-2,000ºF) is higher than the current peak exhaust temperature (900ºF -1,000ºF).  The facility evaluated the economic feasibility of water/steam injection, dry low NOx combustion, and SCR, determining all three to be economically infeasible > $15,375, $6,935, and $6,931/ton of NOx removed, respectively, for Source ID 031 and > $15,375, $7,278, and $7,183/ton of NOx removed, respectively, for Source ID 032).  The facility is already required to maintain good combustion practices for these two sources.  PADEP has determined RACT II for Source IDs 031 and 032 to be the current RACT I NOx short term limit of 120 ppmvd at 15% O2 per turbine, as well as a 463 tpy rolling NOx limit for Source ID 031 and a 411 tpy rolling NOx limit for Source ID 032.  The tpy rolling limits are based on hours of operation.  Texas Eastern will be undergoing a major modernization project to replace all the General Electric Frame 5 turbines along their pipeline, which will bring those sources into compliance with the presumptive RACT II limit by no later than January 1, 2024, including Source IDs 031 and 032 at TE - Shermans Dale.  

PADEP's Conclusions 
PADEP has determined that NOx RACT II for the two General Electric Frame 5 turbines (Source IDs 031 and 032) is the continued implementation of good combustion practices.  The facility will maintain and operate the turbine in accordance with manufacturer's specifications and with good operating practices.  The proposed RACT II limit for NOx for the turbines is 120 ppmvd at 15% O2 per turbine at all times, including startup and shutdown periods, and annual limits of 463 tpy (12-month running total) for Source ID 031 and 411 tpy (12-month running total) for Source ID 032.  Compliance with the emission limits will be demonstrated by continuing to conduct NOx stack testing once per permit term.  Compliance with the annual limits will be demonstrated by continuing to monitor and record operating hours (limited to 8,000 hours/year) and fuel consumption (there are fuel-based permit limits of 2,053.6 MMScf/yr for Source ID 031 and 1,956.8 MMScf/yr for Source ID 032).  The hours of operation and the fuel consumption limits are the basis for the tpy rolling limits, and were established to reduce PTE.  PADEP has included a condition in the permit for TE - Shermans Dale stating that Source IDs 031 and 032 shall be permanently shut down by no later than January 1, 2024.

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 TE - Shermans Dale.  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.      

Incorporation by Reference
Texas Eastern Transmission, L.P. - Shermans Dale - Incorporating by reference Permit No. 50-05001, issued March 26, 2018, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. OP-50-02001, issued April 12, 1999.





































Chapter 12:  Texas Eastern Transmission, L.P., Perulack Station (#34-05002)

Facility Description and Processes
Texas Eastern Transmission, L.P. - Perulack Station (TE  -  Perulack) is a natural gas compressor station located in Perulack, Juniata County, Pennsylvania.  Permitted emission sources at this facility include three natural gas-fired engines, five natural gas-fired turbines, three emergency generators, and area fugitive emission sources.

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

The sources in Table 12.1 have been identified as subject to NOx and VOC RACT II requirements, a majority of which will comply with presumptive NOx and VOC RACT II requirements except for Source ID 037, which was evaluated for NOx CbC RACT II pursuant to 25 Pa. Code §129.99.  

   Table 12.1: Units Subject to Applicable NOx and VOC RACT II Requirements
Source ID
Source Description
RACT
031
Cooper Bessemer GMVA-8 engine
Presumptive RACT for NOx (by 1/1/2020; when retrofitted with clean burn technology) and VOC pursuant to 25 Pa. Code §129.97(g)(3)(i)
032
Cooper Bessemer GMVA-8c clean burn engine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §129.97(g)(3)(i)
033
Cooper Bessemer GMVA-8c clean burn engine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §129.97(g)(3)(i)
034
Dresser Clark DC 990 turbine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §§129.97(g)(2)(iii) and 129.97(g)(2)(iii) and (iv) respectively
035
Dresser Clark DC 990 turbine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §§129.97(g)(2)(iii) and 129.97(g)(2)(iii) and (iv) respectively
036
Dresser Clark DC 990 turbine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §§129.97(g)(2)(iii) and 129.97(g)(2)(iii) and (iv) respectively
037
General Electric Frame 5 turbine
CbC RACT for NOx and Presumptive RACT for VOC pursuant to 25 Pa. Code §129.97(g)(2)(iii) and (iv)
038
Solar Centaur H turbine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §§129.97(g)(2)(iii) and 129.97(g)(2)(iii) and (iv) respectively
039
Caterpillar Emergency IC engine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §129.97(c)(8)
040
Waukesha Emergency IC engine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §129.97(c)(8)
041
Leroi Emergency IC engine
Presumptive RACT for NOx and VOC pursuant to 25 Pa. Code §129.97(c)(8)
042
Area Fugitive Sources
Exempt- all sources less than 2.7 tpy VOC

PADEP approved TE - Perulack's petition for an alternative compliance schedule on February 21, 2017, in accordance with 25 Pa. Code §129.97, for Source ID 031.  The facility plans to bring the engine into compliance with presumptive RACT for NOx, pursuant to 25 Pa. Code §129.97(g)(3)(1), by no later than January 1, 2020, by retrofitting the engine with "clean burn" technology.  PADEP concurs with the company's assertion that they require the full three years (within three years of the RACT II compliance date of January 1, 2017) for this project due to the intensive engineering and design required for the control of the engine.  In the intervening period, Source ID 031 will be required to comply with the current RACT I NOx emission limit of 27.3 lb NOx/hr at all times.

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-34-2002, issued January 1, 1997.  This permit was approved by EPA into the SIP on July 11, 2006.  See 40 CFR §52.2020(d)(1)(r).  

Under OP-34-2002, the General Electric Frame 5 turbine (Source ID 037) was subject to a NOx emission limit of 120 ppmdv corrected to 15% O2.

Technical and Economic Feasibility 
The General Electric Frame 5 turbine (Source ID 037) is rated at 19,800 hp and is subject to the presumptive RACT II emission limit of 42 ppmvd at 15% O2.  Source ID 037 is currently unable to meet the presumptive limit, thus the facility is proposing CbC RACT.  Of the potential NOx control technologies evaluated by the facility for the turbine, XONON technology (a system that utilizes a flameless combustion system where fuel and air reacts on a catalyst surface, preventing the formation of NOx while achieving low CO and unburned hydrocarbon emission levels), EMx/SCONOx technology (a system consisting of a platinum-based catalyst coated with potassium carbonate to oxidize NOx and CO), and SNCR were determined to be infeasible.  XONON is infeasible because it would be necessary to redesign and replace the combustion chamber.  EMx/SCONOx is infeasible because it has not been demonstrated in a simple-cycle gas turbine in natural gas combustion service.  SNCR is infeasible because the effective temperature range (1,600ºF-2,000ºF) is higher than the current peak exhaust temperature (900ºF -1,000ºF).  The facility evaluated the economic feasibility of water/steam injection, dry low NOx combustion, and SCR, determining all three to be economically infeasible ($21,008, $10,677, and $9,898/ton of NOx removed, respectively).  The facility is already required to maintain good combustion practices for this source.
PADEP has determined RACT for Source ID 037 to be the current RACT I NOx short term limit of 120 ppmvd at 15% oxygen, as well as a 329 tpy rolling NOx limit.  The tpy rolling limit is based on the lowest of all General Electric Frame 5 units reported at Texas Eastern sites.  Texas Eastern will be undergoing a major modernization project to replace all the General Electric Frame 5 turbines along their pipeline, which will bring those sources into compliance with the presumptive RACT II limit by no later than January 1, 2024, including Source ID 037 at TE  -  Perulack. 

PADEP's Conclusions 
PADEP has determined that NOx RACT II for the General Electric Frame 5 turbine (Source ID 037) is the continued implementation of good combustion practices.  The facility will maintain and operate the turbine in accordance with manufacturer's specifications and with good operating practices.  The proposed RACT II limit for NOx for the turbine is 120 ppmvd at 15% O2 at all times, including startup and shutdown periods, and an annual limit of 329 tpy (12-month running total), pursuant to 25 Pa. Code §129.96.  Compliance with the emission limits will be demonstrated by continuing to conduct NOx stack testing once per permit term.  Compliance with the annual limits will be demonstrated by continuing to monitor and record operating hours and fuel consumption.  PADEP has included a condition in the permit for TE  -  Perulack stating that Source ID 037 shall be permanently shut down by no later than January 1, 2024.

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 TE - Perulack.  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.      

Incorporation by Reference
Texas Eastern Transmission, L.P.  -  Perulack - Incorporating by reference Permit No. 34-05002, issued March 16, 2018, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. OP-34-2002, issued January 31, 1997, except for Conditions 5.c, 6.a and 15 which remain as RACT requirements.

Chapter 13:  Texas Eastern Transmission, L.P., Grantville Station (#22-05010)

Facility Description and Processes
Texas Eastern Transmission, L.P. - Grantville Station (TE  -  Grantville) is a natural gas compressor station located in Grantville, Dauphin County, Pennsylvania.  Permitted emission sources at this facility include four natural gas-fired turbines, an emergency generator, and area fugitive emission sources.

Units Subject to Case-by-Case RACT II
TE  -  Grantville is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  The facility has taken a federally enforceable limit on facility-wide VOC emissions below 50 tpy, thus, it is a minor source of VOC emissions and not subject to VOC RACT II regulations.

Five sources have been identified as subject to NOx RACT II requirements.  Two of the five sources (Source IDs 032 and 035) will comply with presumptive NOx RACT II requirements.  The facility has proposed RACT II CbC, in accordance with 25 Pa. Code §129.99, for the remaining three sources (Source IDs 031, 033, and 034).
 General Electric Frame 5 Turbine (Source ID 031)
 Dresser Clark DC 990 Turbine (Source ID 032)  -  Presumptive RACT pursuant to 25 Pa. Code §§129.97(g)(2)(iii) and 129.97(g)(2)(iv)
 Westinghouse W52 Turbine (Source ID 033)
 Westinghouse W52 Turbine (Source ID 034)
 Leroi Emergency IC Engine (Source ID 035)  -  Presumptive RACT pursuant to 25 Pa. Code §129.97(c)(8)
RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-22-2010, issued January 31, 1997.  This permit was approved by EPA into the SIP on March 31, 2005.  See 40 CFR §52.2020(d)(1)(f).  

Under OP-22-2010, the General Electric Frame 5 turbine (Source ID 031) was subject to a NOx emission limit of 120 ppmdv corrected to 15% O2.  The two Westinghouse W52 turbines (Source IDs 033 and 034) were subject to a NOx emission limit of 116 ppmdv corrected to 15% O2.  

Technical and Economic Feasibility 
The General Electric Frame 5 turbine (Source ID 031) is rated at 18,500 hp and is subject to the presumptive RACT II emission limit of 42 ppmvd at 15% O2.  Source ID 031 is currently unable to meet the presumptive limit, thus the facility is proposing CbC RACT.  Of the potential NOx control technologies evaluated by the facility for this turbine, XONON technology (a system that utilizes a flameless combustion system where fuel and air reacts on a catalyst surface, preventing the formation of NOx while achieving low CO and unburned hydrocarbon emission levels), EMx/SCONOx technology (a system consisting of a platinum-based catalyst coated with potassium carbonate to oxidize NOx and CO), and SNCR were determined to be infeasible.  XONON is infeasible because it would be necessary to redesign and replace the combustion chamber.  EMx/SCONOx is infeasible because it has not been demonstrated in a simple-cycle gas turbine in natural gas combustion service.  SNCR is infeasible because the effective temperature range (1,600ºF-2,000ºF) is higher than the current peak exhaust temperature (900ºF -1,000ºF).  The facility evaluated the economic feasibility of water/steam injection, dry low NOx combustion, and SCR, determining all three to be economically infeasible ($15,304, $7,815, and $7,591/ton of NOx removed respectively).  The facility is already required to maintain good combustion practices for this source.  PADEP has determined RACT for Source ID 031 to be the current RACT I NOx short term limit of 120 ppmvd at 15% O2, as well as a 411 tpy rolling NOx limit.  The tpy rolling limit is based on hours of operation.  Texas Eastern will be undergoing a major modernization project to replace all the General Electric Frame 5 turbines along their pipeline, which will bring those sources into compliance with the presumptive RACT II limit by no later than January 1, 2024, including Source ID 031 at TE  -  Grantville. 

The two Westinghouse W52 turbines (Source IDs 033 and 034) are both rated at 6,040 hp and are also subject to the presumptive RACT II emission limit of 42 ppmvd at 15% O2.  Source IDs 033 and 034 are unable to meet the presumptive limit, thus the facility is proposing case-by-case RACT.  Of the potential NOx control technologies evaluated by the facility for these two turbines, water/steam injection, dry low NOx combustion, XONON technology, and SNCR were determined to be infeasible.  Water/steam injection is infeasible because of low flame temperature and flame destabilization.  Dry low NOx combustion is infeasible because it is integral to the design of the combustion chamber, thus, a cost estimate could not be obtained by the facility.  XONON is infeasible because it would be necessary to redesign and replace the combustion chamber.  SNCR is infeasible because the effective temperature range (1,600ºF-2,000ºF) is higher than the current peak exhaust temperature (500ºF -700ºF).  The facility evaluated the economic feasibility of EMx/SCONOx technology and SCR, determining them both to be economically infeasible ($16,484 and $8,242/ton of NOx removed, respectively).  The facility is already required to maintain good combustion practices for these two sources.  PADEP has determined RACT II for Source IDs 033 and 034 to be the current RACT I NOx short term limit of 116 ppmvd at 15% O2 per turbine, as well as a 107 tpy rolling NOx limit per turbine.  The tpy rolling limit is based on hours of operation.

PADEP's Conclusions 
PADEP has determined that NOx RACT II for the General Electric Frame 5 turbine (Source ID 031) is the continued implementation of good combustion practices.  The facility will maintain and operate the turbine in accordance with manufacturer's specifications and with good operating practices.  The proposed RACT II limit for NOx for the turbine is 120 ppmvd at 15% O2 at all times, including startup and shutdown periods, and an annual limit of 411 tpy (12-month running total).  Compliance with the emission limits will be demonstrated by continuing to conduct NOx stack testing once per permit term.  Compliance with the annual limit will be demonstrated by continuing to monitor and record operating hours (limited to 8,000 hours/year) and fuel consumption (there is a fuel-based permit limit of 1,822.5 MMScf/yr).  PADEP has included a condition in the permit for TE  -  Grantville stating that Source ID 031 shall be permanently shut down by no later than January 1, 2024.

PADEP has determined that NOx RACT for the two Westinghouse W52 turbines (Source IDs 033 and 034) is the continued implementation of good combustion practices.  The facility will maintain and operate the two turbines in accordance with manufacturer's specifications and with good operating practices.  The proposed RACT limit for NOx for the two turbines is 116 ppmvd at 15% O2 at all times per turbine, including startup and shutdown periods, and an annual limit of 107 tpy (12-month running total) per turbine.  Compliance with the emission limits will be demonstrated by continuing to conduct NOx stack testing once per permit term.  Compliance with the annual limit will be demonstrated by continuing to monitor and record operating hours (limited to 8,000 hours/year for each turbine) and fuel consumption (there is a fuel-based permit limit of 491.3 MMScf/yr per turbine).

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 TE  -  Grantville.  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.    

Incorporation by Reference  
Texas Eastern Transmission, L.P.  -  Grantville - Incorporating by reference Permit No. 22-05010, issued March 27, 2018, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. 22-2010, issued January 31, 1997.

Chapter 14:  NRG Energy Center Paxton, LLC (#22-05005)

Facility Description and Processes
NRG Energy Center Paxton, LLC (NRG) is a cogeneration plant located in the City of Harrisburg, Dauphin County, Pennsylvania.  Permitted emission sources at this facility include four boilers manufactured by Combustion Engineering.  Boilers No. 13 and No. 14 are duel-fuel units that use both natural gas and No. 6 fuel oil, while Boilers No. 12 and No. 15 use only No. 6 fuel oil.  The facility also operates two diesel-fired internal combustion engines, manufactured by Cooper.

Units Subject to Case-by-Case RACT II
NRG is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  Boilers No. 12 (Source ID 031) and No. 15 (Source ID 034), and the two engines (Source IDs 102 and 103), will follow presumptive NOx RACT II requirements pursuant to 25 Pa. Code §129.97(c).  

Boilers No. 13 (Source ID 032) and No. 14 (Source ID 033) have heat input capacities that exceed the thresholds which would allow compliance under the presumptive RACT II requirements available to smaller boilers.  The two boilers cannot meet the annual capacity factor of less than 5%, therefore, both of these boilers were evaluated by PADEP on a case-by-case basis for available control options to meet the RACT II requirements.

RACT I Considerations
Under the RACT I rule, the facility was subject to two operating permits: Operating Permit No. OP-22-02005, issued March 23, 1999 to Harrisburg Steam Works, and Operating Permit No. OP-22-02015, issued June 30, 1999 to Statoil Energy Power Paxton, LP.  OP-22-02005 was approved by EPA into the SIP on March 8, 2006.  See 40 CFR §52.2020(d)(1)(l).  OP-22-02015 was also approved by EPA into the SIP on March 8, 2006.  See CFR §52.2020(d)(1)(l).

Under OP-22-02005, the two boilers (Boilers No. 13 and 14; Source IDs 032 and 033) were subject to emission limits of 0.44 lb NOx/MMBtu each when combusting No. 6 fuel oil and 0.23 lb NOx/MMBtu each when combusting natural gas.  Boilers No. 13 and 14 were also subject to a limit of 214 MMBtu/hr each, No. 6 fuel oil and natural gas fired.  Boilers No. 12 and 15 (Source IDs 031 and 034) were each subject to an emission limit of 0.44 lb NOx/MMBtu.  Boiler No. 12 was subject to a limit of 105 MMBtu/hr, No. 6 fuel oil, and Boiler No. 15 was subject to a limit of 214 MMBtu/hr, No. 6 fuel oil.

Under OP-22-02015, the two engines (Source IDs 102 and 103) were subject to NO x emission limits of 4.5 g/hp-hr on dual fuel natural gas with No. 2 fuel oil as a pilot fuel and 3.5 g/hp-hr on dual fuel respectively.  Both engines were subject to a NOx emission limit of 11 g/hp-hr on No. 2 oil.

All sources were subject to monitoring, recordkeeping, and reporting requirements, as well as good operating and maintenance requirements.  While now complying with presumptive NOx RACT II requirements pursuant to 25 Pa. Code §129.97(c), Source IDs 031, 034, 102, and 103 will remain subject to several RACT I requirements (see the Incorporation by Reference section below).

Technical and Economic Feasibility 
Of the potential NOx control technologies evaluated by the facility for Boilers No. 13 and 14 (Source IDs 032 and 033), SCR, water/steam injection, and SNCR were determined to be infeasible.  SCR is not technically feasible due to flue gas temperatures being well below the effective range of control.  Water/steam injection is not technically feasible due to potential adverse effects on boiler performance.  SNCR is not feasible due to varying modulation in temperatures for these type boilers (urea needs a steady state temperature range of 1,400 ºF-1,600 ºF to be effective).  

Of the remaining technologies, FGR/forced draft (FD) fan/LNB, FGR/FD fan, and FGR were determined to be economically infeasible.  FGR/FD fan/LNB is determined to be $9,679 and $14,713/ton of NOx removed for natural gas and No. 6 fuel oil respectively, FGR/FD fan is determined to be $8,036 and $17,857/ton of NOx removed for natural gas and No. 6 fuel oil respectively, and FGR alone is determined to be $11,850 and $39,500/ton of NOx removed for natural gas and No. 6 fuel oil respectively.  

The two boilers are already subject to using an oxygen trim system within the performance specification for a low excess air firing system, thus no additional NOx emission reductions can be expected with a new low excess air firing system.

PADEP has determined RACT II for the two boilers to be the existing RACT I short-term NOx emission limitations on each, when combusting No. 6 fuel oil and when combusting natural gas.  

PADEP's Conclusions 
PADEP has determined that NOx RACT II for Boiler No. 13 (Source ID 032) and Boiler No. 14 (Source ID 033) is:
 214 MMBtu/hr each, No. 6 fuel oil and natural gas fired, which is the same as the RACT I limit
 0.44 lb NOx/MMBtu each when combusting No. 6 fuel oil, which is the same as the RACT I limit (with exception for when fuel borne nitrogen (FBN) in No. 6 fuel oil is greater than 0.49%, then formula is used to calculate lb NOx/MMBtu limits)
 0.23 lb NOx/MMBtu each when combusting natural gas, which is the same as the RACT I limit
 No. 6 fuel oil shall be limited to 1,533,300 gallons per year each based on a consecutive 12-month rolling period (there was no RACT I fuel consumption limit for No. 6 fuel oil)
 Natural gas shall be limited to 584,000,000 cubic feet per year each based on a consecutive 12-month rolling period (there was no RACT I fuel consumption limit for natural gas for Source ID 032; the previous RACT I fuel consumption limit for natural gas for Source ID 033 has been reduced from 787,000,000 cubic feet per year to 584,000,000 cubic feet per year)
 46 tpy NOx emission rate each based on a consecutive 12-month rolling period, which was the basis for the RACT II CbC cost analysis
 Appropriate testing, monitoring and recordkeeping requirements related to RACT II compliance pursuant to 25 Pa. Code §§129.100(d)(1) and (2), and 129.100(a)(4)
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 NRG.  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.    

Incorporation by Reference 
NRG Energy Center Paxton, LLC Permit No. 49-00004, issued March 16, 2018, as redacted by Pennsylvania, will supersede the prior RACT Permit Nos. OP-22-02005 and OP-22-02015, both issued March 23, 1999, for Source IDs 032 and 033, Boilers No. 13 and 14.  However, RACT Permit No. OP-22-02005 will remain in effect as to Source IDs 031 and 034, Boilers No. 12 and 15, except for Conditions 1(a), 7, 14, 16, 21; and RACT Permit No. OP-22-02015 will remain in effect as to Source IDs 102 and 103, Engines 1 and 2, except for Conditions 1(a), 7, 8, 9, 10, 12(c), 13, 14.

Chapter 15:  Texas Eastern Transmission, L.P., Bechtelsville Station (#06-05034)

Facility Description and Processes
Texas Eastern Transmission, L.P. - Bechtelsville Station (TE  -  Bechtelsville) is a natural gas compressor station located in Washington Township, Berks County, Pennsylvania.  Permitted emission sources at this facility include four natural gas-fired turbines, an emergency generator, and area fugitive emission sources.

Units Subject to Case-by-Case RACT II 
TE  -  Bechtelsville is classified as a major NOx emitting facility, thus required to meet NOx RACT II requirements.  The facility has taken a federally enforceable limit on facility-wide VOC emissions below 50 tpy, thus, it is a minor source of VOC emissions and not subject to VOC RACT II regulations.

Five sources have been identified as subject to NOx RACT II requirements.  Two of the 5 sources (Source IDs 101 and 105) will comply with presumptive NOx RACT II requirements.  The facility has proposed CbC RACT II, in accordance with 25 Pa. Code §129.99, for the remaining three sources (Source IDs 102, 103, and 104).
 Dresser Clark DC 990 Turbine (Source ID 101)  -  Presumptive RACT pursuant to 25 Pa. Code §§129.97(g)(2)(iii) and 129.97(g)(2)(iv)
 Westinghouse W52 Turbine (Source ID 102)
 Westinghouse W52 Turbine (Source ID 103)
 General Electric Frame 5 Turbine (Source ID 104)
 Leroi Emergency IC Engine (Source ID 105)  -  Presumptive RACT pursuant to 25 Pa. Code §129.97(c)(8)
RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-06-1034, issued January 31, 1997.  This permit was approved by EPA into the SIP on April 18, 1997.  See 40 CFR §52.2063(c)(120)(i)(B)(2).  

Under OP-06-1034, the two Westinghouse W52 turbines (Source IDs 102 and 103) were subject to a NOx emission limit of 116 ppmdv corrected to 15% O2.  The General Electric Frame 5 turbine (Source ID 104) was subject to a NOx emission limit of 120 ppmdv corrected to 15% O2.

Technical and Economic Feasibility 
The two Westinghouse W52 turbines (Source IDs 102 and 103) are rated at 6,040 hp and are subject to the presumptive RACT II emission limit of 42 ppmvd at 15% O2.  Source IDs 102 and 103 are unable to meet the presumptive limit, thus the facility is proposing case-by-case RACT.  Of the potential NOx control technologies evaluated by the facility for these two turbines, water/steam injection, dry low NOx combustion, XONON technology (a system that utilizes a flameless combustion system where fuel and air react on a catalyst surface, preventing the formation of NOx while achieving low CO and unburned hydrocarbon emission levels), and SNCR were determined to be infeasible.  Water/steam injection is infeasible because of low flame temperature and flame destabilization.  Dry low NOx combustion is infeasible because it is integral to the design of the combustion chamber, thus, a cost estimate could not be obtained by the facility.  XONON is infeasible because it would be necessary to redesign and replace the combustion chamber.  SNCR is infeasible because the effective temperature range (1,600ºF-2,000ºF) is higher than the current peak exhaust temperature (500ºF -700ºF).  The facility evaluated the economic feasibility of EMx/SCONOx technology (a system consisting of a platinum-based catalyst coated with potassium carbonate to oxidize NOx and CO) and SCR, determining them both to be economically infeasible ($16,676 and $8,758/ton of NOx removed respectively).  The facility is already required to maintain good combustion practices for these two sources.  PADEP has determined RACT II for Source IDs 102 and 103 to be the current RACT I NOx short term limit of 116 ppmvd at 15% O2 per turbine, as well as a 101 tpy rolling NOx limit per turbine.  The tpy rolling limit is based on hours of operation.

The General Electric Frame 5 turbine (Source ID 104) is rated at 18,500 hp and is also subject to the presumptive RACT II emission limit of 42 ppmvd at 15% O2.  Source ID 104 is currently unable to meet the presumptive limit, thus the facility is proposing case-by-case RACT.  Of the potential NOx control technologies evaluated by the facility for this turbine, XONON technology, EMx/SCONOx technology, and SNCR were determined to be infeasible.  XONON is infeasible because it would be necessary to redesign and replace the combustion chamber.  EMx/SCONOx is infeasible because it has not been demonstrated in a simple-cycle gas turbine in natural gas combustion service.  SNCR is infeasible because the effective temperature range (1,600ºF-2,000ºF) is higher than the current peak exhaust temperature (900ºF -1,000ºF).  The facility evaluated the economic feasibility of water/steam injection, dry low NOx combustion, and SCR, determining all three to be economically infeasible ($15,279, $7,622, and $7,442/ton of NOx removed respectively).  The facility is already required to maintain good combustion practices for this source.  PADEP has determined RACT II for Source ID 104 to be the current RACT I NOx short term limit of 120 ppmvd at 15% O2, as well as a 421 tpy rolling NOx limit.  The tpy rolling limit is based on hours of operation.  Texas Eastern will be undergoing a major modernization project to replace all the General Electric Frame 5 turbines along their pipeline, which will bring those sources into compliance with the presumptive RACT II limit by no later than January 1, 2024, including Source ID 104 at TE  -  Bechtelsville. 

PADEP's Conclusions 
PADEP has determined that NOx RACT II for the two Westinghouse W52 turbines (Source IDs 102 and 103) is the continued implementation of good combustion practices.  The facility will maintain and operate the two turbines in accordance with manufacturer's specifications and with good operating practices.  The proposed RACT II limit for NOx for the two turbines is 116 ppmvd at 15% O2 at all times per turbine, including startup and shutdown periods, and an annual limit of 101 tpy (12-month running total) per turbine.  Compliance with the emission limits will be demonstrated by continuing to conduct NOx stack testing once per permit term.  Compliance with the annual limit will be demonstrated by continuing to monitor and record operating hours (limited to 8,000 hours/year for each turbine) and fuel consumption (there is a fuel-based permit limit of 461.4 MMScf/yr per turbine).

PADEP has determined that NOx RACT II for the General Electric Frame 5 turbine (Source ID 104) is the continued implementation of good combustion practices.  The facility will maintain and operate the turbine in accordance with manufacturer's specifications and with good operating practices.  The proposed RACT II limit for NOx for the turbine is 120 ppmvd at 15% O2 at all times, including startup and shutdown periods, and an annual limit of 421 tpy (12-month running total).  Compliance with the emission limits will be demonstrated by continuing to conduct NOx stack testing once per permit term.  Compliance with the annual limit will be demonstrated by continuing to monitor and record operating hours (limited to 8,000 hours/year) and fuel consumption (there is a fuel-based permit limit of 1,868.5 MMScf/yr).  PADEP has included a condition in the permit for TE  -  Bechtelsville stating that Source ID 104 shall be permanently shut down by no later than January 1, 2024.

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 TE  -  Bechtelsville.  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.    

Incorporation by Reference
Texas Eastern Transmission, L.P.  -  Bechtelsville  -  Incorporating by reference Permit No. 06-05034, issued April 19, 2018, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. OP-06-1034, issued January 31, 1997.

Chapter 16:  Containment Solutions, Inc./Mount Union Plant (#31-05005)

Facility Description and Processes
Containment Solutions, Inc.'s Mount Union Plant (Containment Solutions) is located in Huntingdon County, Pennsylvania.  Containment Solutions manufactures Fiberglass Reinforced Plastic (FRP) underground storage tanks for the petroleum distribution industry and various other industrial users.  This facility includes two boilers that operate on natural gas and No. 2 fuel oil, an emergency generator, a natural gas-fired cleaning furnace, and a layup area.

Units Subject to Case-by-Case RACT II
Containment Solutions 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.

All the VOC emitting sources at Containment Solutions, with the exception of the layup area (Source ID 101), are exempt from RACT II pursuant to 25 Pa. Code §129.96(c), because each source's PTE is less than 1 tpy.  Source ID 101, the layup area, has a PTE of 129.1 tpy VOC and was evaluated for CbC RACT II.  Source ID 101 encompasses the production of the storage tanks using an FRP open molding process, which includes six molding stations (rotating mandrels), as well as hand layup and resin spraying activities.  

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-31-02005, issued April 9, 1999.  This permit was approved by EPA into the SIP on August 6, 2001.  See 40 CFR §52.2020(c)(149)(i)(B)(11).  

Under OP-31-02005, RACT was determined to be the following:
 Good operating and maintenance practices
 Total facility resin use shall not exceed 12,910,000 lbs during any consecutive 12-month period
 The resin pouring layup method of tank fabrication shall be employed during the fabrication of the cylindrical tank shells while operating the five large production layup mandrels
 Solvent-based resin cleanup solutions shall not be used at this facility
 Production activities at this facility shall not exceed 8,736 hrs during any consecutive 12-month period
 Appropriate reporting and recordkeeping requirements
Technical and Economic Feasibility 
Of the potential VOC control technologies evaluated by the facility for the layup area (Source ID 101), a catalytic oxidizer, carbon adsorption, process changes, a refrigerated condenser, and a flare were determined infeasible.  Catalytic oxidation is infeasible because the high volume of gas collected by the exhaust vents would require multiple oxidizers for each stack and the particulate matter associated with the mandrel process creates the potential problem of fouling the catalyst with particulate, thus reducing efficiency.  Carbon adsorption is technically infeasible for similar reasons as catalytic oxidation.  Additionally, the styrene which evolves from the fiberglass tank manufacturing process potentially poses further technical challenges to the effectiveness of the carbon adsorption.  Process changes were evaluated; however, Containment Solutions is limited in what resins are available to manufacture the products produced at the Mount Union Plant.  Refrigerated condenser and flare technologies have not been commercially demonstrated on FRP processes similar to those that take place at the Mount Union Plant, thus determined to be infeasible.

Thermal oxidization was determined to be technically feasible, thus was evaluated for economic feasibility.  Traditional thermal oxidation systems were determined to require substantial supplemental fuel in order to maintain the required oxidation temperature at this facility.  Even without accounting for supplemental fuel costs, the estimated cost effectiveness of thermal oxidation was determined to be approximately $13,379/ton of VOC controlled.  Thus, thermal oxidation was determined to be economically infeasible.  

PADEP determined that the current RACT I VOC control technology and work practices, in addition to continued compliance with 40 CFR Part 63, Subpart WWWW (National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production), are appropriate to fulfill the CbC RACT II requirements for Source ID 101.

PADEP's Conclusions 
PADEP has determined that VOC RACT II for the layup area (Source ID 101) is:
 Total facility resin use shall not exceed 12,910,000 lbs during any consecutive 12-month period
 The resin pouring layup method of tank fabrication shall be employed during the fabrication of the cylindrical tank shells while operating the five large production layup machines
 Solvent-based resin cleanup solutions shall not be used at this facility
 Production activities at this facility shall not exceed 8,736 hrs during any consecutive 12-month period
 Appropriate recordkeeping and reporting requirements
 Source 101 shall comply with applicable provisions of 40 CFR Part 63, Subpart WWWW- NESHAP: Reinforced Plastic Composites Production
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 Containment Solutions.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional 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.    

Incorporation by Reference
Containment Solutions, Inc./Mt. Union Plant  -  Incorporating by reference Permit No. 31-05005, issued July 10, 2018, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. OP-31-02005, issued April 9, 1999.  












































Chapter 17:  Armstrong World Industries, Inc./Marietta Ceiling Plant (#36-05001)

Facility Description and Processes
Armstrong World Industries, Inc. (Armstrong) operates an acoustical ceiling tile manufacturing facility located in the East Donegal Township, Lancaster County, Pennsylvania.  This facility includes three direct perlite expanders and a natural gas-fired boardmill dryer consisting of eight zones, each equipped with its own burner assembly comprised of nine ribbon burners, and two reheat burners.  Armstrong also has surface coating operations, 134 natural gas-fired miscellaneous space heaters, four natural gas-fired emergency generators, and a 9.0 MMBtu/hr boiler.

Units Subject to Case-by-Case RACT II
Armstrong is classified as a major VOC emitting facility, thus is required to meet VOC RACT II requirements.  Armstrong is a major NOx emitting source; however, Armstrong has elected to take a 100 tpy (or less) cap on NOx emissions, thus it is not subject to NOx RACT II requirements.

A majority of the VOC emitting sources at Armstrong are exempt from RACT II either because the source's PTE is less than 1 tpy (pursuant to 25 Pa. Code §129.96(c)), the source is already subject to 25 Pa. Code §129.52 (pursuant to 25 Pa. Code §129.96(a)), or the source was installed after July 20, 2012 (also pursuant to 25 Pa. Code §129.96(a)).

Source ID 104, the boardmill line, is the only source at Armstrong evaluated for CbC VOC RACT II, pursuant to 25 Pa. Code §129.99(d).  Source ID 104 has a PTE of 139.5 tpy.

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. OP-36-2001, issued July 3, 1995.  This permit was approved by EPA into the SIP on November 2, 2005.  See 40 CFR §52.2020(d)(1)(b).  

Under OP-36-2001, RACT was determined to be the following:
 Condition 5: All air pollution sources and air pollution control devices shall be operated and maintained in accordance with good pollution control practices that minimize the emissions of NOx and VOC
 Condition 6: An annual report as per Section 129.95 containing, but not limited to, the following data for each fuel-burning unit covered by this RACT plan shall be submitted to the Lancaster District Supervisor:
 Identification of each source
 Hours of operation per quarter for each source
 Fuel combusted per quarter for each source
 Pounds of NOx emitted per quarter for each source
 Condition 7: An annual report containing, but not limited to, the following data for each surface coating shall be submitted to the Lancaster District Supervisor:
 Identification of each coating
 Coating quantity
 Lbs of VOC per gallon of coating (minus water)
 Solvent density
 % solvents by volume (minus EPA-exempted solvents)
 % solids by volume
 % water by volume
 Gallons per quarter of coating used (including water)
 Lbs per year of VOC emissions from surface coating
The reports required under Conditions 6 and 7 above for each January 1[st] through December 31[st] period are due no later than March 1[st] of the following year for each year authorized by the operating permit or its renewal.
Armstrong's RACT I requirements are retained as RACT in the facility's operating permit.

Technical and Economic Feasibility 
Of the potential VOC control technologies evaluated by the facility for the boardmill line (Source ID 104), all were determined to be technically infeasible and/or economically infeasible.  Tile reformation was determined to be infeasible because ceiling mix must remain fairly fixed due to rigid product specifications in order to meet consumer requirements.  Switching from a direct fired to indirect fired heating system and installing more efficient burners would require a complete redesign and replacement of the boardmill dryer, necessitating high capital investment and resulting in minimal reduction in VOC emissions.  Thus, this option was determined to be infeasible.  Activated carbon adsorption/zeolite adsorption was determined to be technically infeasible based on exhaust characteristics (temperatures are above 170ºF and adsorbents will not work if the gas stream is saturated and above 104ºF).  Oxidation without heat recovery (i.e., direct-fired thermal oxidation) was determined to be infeasible as this technology performs best at inlet concentrations of hydrocarbons around 1,500 to 3,000 ppmvd.  The boardmill's exhaust streams range from 25 to 60 ppmvd, thus the cost to utilize the device would be exorbitant due to the supplemental gas required to sustain a flame as compared to oxidation with heat recovery.  An RTO is technically feasible; however, the cost is approximately $18,510/ton of VOC removed, thus determined to be economically infeasible.  A catalytic oxidizer was determined to be technically infeasible because the boardmill's exhaust temperatures average around 338ºF and contain a high amount of moisture.  Recuperative oxidation was determined to be technically infeasible and economic infeasible also due to the exhaust characteristics of the boardmill and the increased consumption of fuel necessary to support combustion.  Finally, a zeolite concentrator with oxidation was determined to be technically infeasible again due to the exhaust characteristics of the boardmill.  

PADEP has determined that RACT II for the boardmill line is to maintain and operate the source in accordance with the manufacturer's specifications and with good operating practices for the control of VOC emissions. This determination is based on a search of the RBLC database which did not yield any results for ceiling board manufacturing.

PADEP's Conclusions 
PADEP has determined that VOC RACT II for the boardmill line (Source ID 104) is:
 Maintain an operations and maintenance (O&M) plan for the boardmill burners; maintain records of any maintenance or modifications performed on the boardmill burners
 Maintain written documentation of the current O&M plan for the boardmill burners and any maintenance or modifications performed on the boardmill burners for five years; records shall be made available to the Department upon written request pursuant to 25 Pa. Code §129.100(d) and (i)
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 Armstrong.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional 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.     

Incorporation by Reference
Armstrong World Industries, Inc.  -  Incorporating by reference Marietta Ceiling Plant - Permit No. 36-05001, issued June 28, 2018, as redacted by Pennsylvania, which supersedes the prior RACT Permit No. 36-2001, issued July 3, 1999.


























Chapter 18:  Jeraco Enterprises, Inc. (#49-00014)

Facility Description and Processes
Jeraco Enterprises, Inc. (Jeraco) operates a facility that manufactures truck caps and bed covers for all makes and models of truck, which is located in Milton Borough, Northumberland County, Pennsylvania.  The Milton Plant manufactures both fiber glass and aluminum caps and covers and builds a variety of sizes and capabilities from everyday use to heavy construction.  This facility includes several surface coating, cleaning, and spray layup booths and operations, and seven natural gas-fired space heaters and air make-up units.

Units Subject to Case-by-Case RACT II
Jeraco 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 Jeraco, the resin storage tank (Source ID 103B) and the miscellaneous sources are exempt from RACT II, pursuant to 25 Pa. Code §129.96(c), because the PTE for each source is less than 1 tpy VOC.  Jeraco has elected to take a less than 1 tpy VOC limit on Source IDs 031 (the seven natural gas-fired space heaters and air make-up units) and P104 (miscellaneous VOC sources) each, thus they are also exempt from RACT II pursuant to 25 Pa. Code §129.96(c). 

CbC RACT II was evaluated for Source IDs 101A (spray layup and cleanup operation), 102A (surface coating and cleanup operation), 203, 204, and 205 (the three surface coating booths).

RACT I Considerations
Under the RACT I rule, the facility, was subject to Operating Permit No. OP-49-0014, issued April 6, 1997.  This permit was approved by EPA into the SIP on March 29, 2005.  See 40 CFR §52.2020(d)(1)(h).  

Under OP-49-0014, Source ID 101A was subject to RACT I recordkeeping requirements for the amounts of each material used at the source each month, as well as monthly emissions calculations for VOC pursuant to 25 Pa. Code §129.95.  Source ID 101A is limited to 63 tpy VOC and 50.2 tpy styrene emissions pursuant to 25 Pa. Code §129.91.  Source ID 102A was subject to RACT I recordkeeping requirements for the amounts and VOC contents of each material and the amount of diluent used at the source each month, as well as monthly emissions calculations for VOC pursuant to 25 Pa. Code §129.95.  Source ID 102A is limited to 5.0 lb VOC/gallon of applied coating for clear coatings and 6.68 lb VOC/gallon of applied coating for all coatings other than clear coatings pursuant to 25 Pa. Code §129.91.  

Source IDs 203, 204, and 205 are identified in the facility's operating permit as their own distinct sources separate from Source ID 102A.  However, these three spray booths are a part of the surface coating operations covered by Source ID 102A.



Technical and Economic Feasibility 
Jeraco's spray layup and cleanup operations (Source ID 101A) did not qualify for the presumptive RACT II requirements found in 25 Pa. Code §129.97, therefore, it is subject to case-by-case.  Both a recuperative thermal oxidizer and an RTO were determined to be technically feasible control options for VOC emissions.  The RTO was determined to be $12,752/ton VOC removed (based on a 96% removal efficiency) and $12,492/ton VOC removed (based on a 98% removal efficiency).  The analysis concluded that the costs of an RTO are significantly less than those of a recuperative thermal oxidizer.  Therefore, as an RTO was determined to be cost prohibitive, a recuperative thermal oxidizer with similar control efficiencies was also determined to be economically infeasible.  Source ID 101A is currently subject to RACT I styrene content restrictions, annual VOC emission limitations, and recordkeeping and work practice requirements, which PADEP has determined to represent CbC RACT II for this source.  

The company's CbC RACT determination for Source ID 102A, the surface coating and cleanup operations, is similar to the analysis for Source 101A.  Source ID 102A also did not qualify for the presumptive RACT II requirements found in 25 Pa. Code §129.97.  The RTO was determined to be $27,831/ton VOC removed (based on a 96% removal efficiency) and $27,263/ton VOC removed (based on a 98% removal efficiency).  As with the case-by-case analysis for Source ID 101A, the costs of an RTO are significantly less than those of a recuperative thermal oxidizer.  Therefore, as an RTO was determined to be economically infeasible, a recuperative thermal oxidizer with similar control efficiencies was also determined to be economically infeasible.  Source ID 102A is currently in compliance with 25 Pa. Code §129.52(d), "Control of VOC emissions from miscellaneous metal parts surface coating processes, miscellaneous plastic parts surface coating processes and pleasure craft surface coatings," as well as subject to RACT I VOC content restrictions, material usage and recordkeeping requirements, monthly emission calculations criteria, and work practice requirements, which PADEP has determined to represent CbC RACT II for this source.  

The RTO system discussed above for Source ID 102A would also control VOC emissions from Source IDs 203, 204, and 205 (the three spray booths), as they are part of the surface coating operations covered under Source ID 102A.  Therefore, the case-by-case determination performed for Source ID 102A also applies to these spray booths since they are integral to the surface coating operations. 

PADEP's Conclusions 
PADEP has determined that VOC RACT II for the spray layup and cleanup operations (Source ID 101A) is:
 No gelcoat material used in Source 101A shall contain styrene in excess of 37%, by weight, and no resin material used in Source 101A shall contain styrene in excess of 36% by weight 
 63 tons VOC in any 12 consecutive month period 
 50.2 tons styrene in any 12 consecutive month period 
 Appropriate recordkeeping requirements pursuant to 25 Pa. Code §129.100
 All gelcoat and resin materials shall be applied using airless spray systems, or equivalent or better, as determined by the Department 
 All solvents used for spray line cleaning shall be flushed into closed containers; under no circumstances shall cleanup solvent be removed from spray lines by spraying through a spray gun.  All containers of solvent and waste solvent shall be kept closed when not in actual use and all solvent-wet rags shall be stored in closed containers when not in actual use.  Under no circumstances shall waste solvent be disposed of or solvent-wet rags, etc. be treated or pre-treated prior to disposal or reuse by subjecting them to air drying or any other means of solvent removal which would cause solvent to be evaporated into the air.  
 The only cleanup solvent to be used for spray line flushing and spray equipment cleanup activities associated with Source ID 101A shall be acetone, unless Department approval is granted for the use of an alternative cleanup solvent 
PADEP has determined that VOC RACT for the surface coating and cleanup operations (Source ID 102A) is:
 Low bake/air dried coatings-exterior parts: Primer: 4.8 lb VOC/gal coating; Basecoat: 5.0 lb VOC/gal coating; Clear coat: 4.5 lb VOC/gal coating; Non-basecoat/clean coat: 5.0 lb VOC/gal coating 
 Low bake/air dried coatings- interior parts: 5.0 lb VOC/gal coating 
 Touch-up and repair: 5.2 lb VOC/gal coating 
 For red, yellow and black automotive coatings, except touch-up and repair coatings, the limit is determined by multiplying the appropriate limit in this table (Table III, 25 Pa. Code §129.52(d)) by 1.15 
 Shall not cause or permit the emission into the outdoor atmosphere of VOC from Source IDs 102A, 203, 204, and 205 unless emissions of VOC are controlled in accordance with: VOC content of each miscellaneous metal part coating or each miscellaneous plastic part coating, as applied, excluding water and exempt compounds, is equal to or less than the VOC content limit for the applicable coating category specified in the applicable table of VOC content limits in Table III of 25 Pa. Code §129.52(d))
 Appropriate recordkeeping requirements pursuant to 25 Pa. Code §129.100
 All surface coatings shall be applied using a high volume, low pressure (HVLP) spray system, or equivalent or better spray system, as determined by the Department 
 All solvents used for spray line cleaning shall be flushed into closed containers; under no circumstances shall cleanup solvent be removed from spray lines by spraying through a spray gun.  All containers of solvent and waste solvent shall be kept closed when not in actual use and all solvent-wet rags shall be stored in closed containers when not in actual use.  Under no circumstances shall waste solvent be disposed of or solvent-wet rags, etc. be treated or pre-treated prior to disposal or reuse by subjecting them to air drying or any other means of solvent removal which would cause solvent to be evaporated into the air.  
 Shall not cause or permit the emission into the outdoor atmosphere of VOC from Source IDs 102A, 203, 204, and 205 unless the coatings are applied using one or more of the following coating application methods: HVLP spray coating 
 Comply with the following work practices for coating-related activities for Source IDs 102A, 203, 204, and 205: store all VOC-containing coatings, thinners or coating-related waste materials in closed containers; ensure that mixing and storage containers used for VOC-containing coatings, thinners or coating-related waste materials are kept closed at all times, except when depositing or removing those coatings, thinners or waste materials; minimize spills of VOC-containing coatings, thinners or coating-related waste materials and clean up spills immediately; convey VOC-containing coatings, thinners or coating-related waste materials from one location to another in closed containers or pipes 
 Comply with the following work practices for cleaning materials for Source IDs 102A, 203, 204, and 205: store all VOC-containing cleaning materials and used shop towels in closed containers; ensure that mixing vessels and storage containers used for VOC-containing cleaning materials are kept closed at all times except when depositing or removing these materials; minimize spills of VOC-containing cleaning materials and clean up spills immediately; convey VOC-containing cleaning materials from one location to another in closed containers or pipes; minimize VOC emissions from cleaning of application, storage, mixing or conveying equipment by ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent solvent is captured in closed containers 
 Regardless of the facility's VOC emissions, the permittee shall comply with 25 Pa. Code §129.52(d) as specified throughout §129.52(d) for Source IDs 102A, 203, 204, and 205 
PADEP has determined that VOC RACT II for each surface coating booth (booths 3, 4, and 5; Source IDs 203, 204, and 205) is:
 Total combined VOC emissions from Source IDs 203, 204, and 205 shall not exceed 18 tons in any 12 consecutive month period, including VOC emissions resulting from use of strippable booth coatings 
 Total combined HAPs from Source IDs 203, 204, and 205 shall not exceed 15 tons in any 12 consecutive month period 
 Total combined emission of any individual HAP from Source IDs 203, 204, and 205 combined shall not exceed 6 tons in any 12 consecutive month period 
 Low bake/air dried coatings-exterior parts: Primer: 4.8 lb VOC/gal coating; Basecoat: 5.0 lb VOC/gal coating; Clear coat: 4.5 lb VOC/gal coating; Non-basecoat/clean coat: 5.0 lb VOC/gal coating 
 Low bake/air dried coatings- interior parts: 5.0 lb VOC/gal coating 
 Touch-up and repair: 5.2 lb VOC/gal coating 
 For red, yellow and black automotive coatings, except touch-up and repair coatings, the limit is determined by multiplying the appropriate limit in this table (Table III, 25 Pa. Code §129.52(d)) by 1.15 
 Shall not cause or permit the emission into the outdoor atmosphere of VOC from Source IDs 102A, 203, 204, and 205 unless emissions of VOC are controlled in accordance with: VOC content of each miscellaneous metal part coating or each miscellaneous plastic part coating, as applied, excluding water and exempt compounds, is equal to or less than the VOC content limit for the applicable coating category specified in the applicable table of VOC content limits in Table III of 25 Pa. Code §129.52(d) 
 Appropriate recordkeeping requirements pursuant to 25 Pa. Code §129.100
 Shall only use HVLP spray guns to apply coatings 
 All solvents used for spray line cleaning shall be flushed into closed containers; under no circumstances shall cleanup solvent be removed from spray lines by spraying through a spray gun.  All containers of solvent and waste solvent shall be kept closed when not in actual use and all solvent-wet rags shall be stored in closed containers when not in actual use.  Under no circumstances shall waste solvent be disposed of or solvent-wet rags, etc. be treated or pre-treated prior to disposal or reuse by subjecting them to air drying or any other means of solvent removal which would cause solvent to be evaporated into the air.  
 Acetone shall be the only solvent used for cleanup 
 Water based strippable spray booth coating shall be used when possible to minimize the use of acetone for cleanup.  The water based strippable coating shall not contain VOC in excess of 0.24 lbs/gal of coating, as applied.  Furthermore, the strippable spray booth coating shall not contain HAPs. 
 Shall not cause or permit the emission into the outdoor atmosphere of VOC from Source IDs 102A, 203, 204, and 205 unless the coatings are applied using one or more of the following coating application methods: HVLP spray coating 
 Comply with the following work practices for coating-related activities for Source IDs 102A, 203, 204, and 205: store all VOC-containing coatings, thinners or coating-related waste materials in closed containers; ensure that mixing and storage containers used for VOC-containing coatings, thinners or coating-related waste materials are kept closed at all times, except when depositing or removing those coatings, thinners or waste materials; minimize spills of VOC-containing coatings, thinners or coating-related waste materials and clean up spills immediately; convey VOC-containing coatings, thinners or coating-related waste materials from one location to another in closed containers or pipes 
 Comply with the following work practices for cleaning materials for Source IDs 102A, 203, 204, and 205: store all VOC-containing cleaning materials and used shop towels in closed containers; ensure that mixing vessels and storage containers used for VOC-containing cleaning materials are kept closed at all times except when depositing or removing these materials; minimize spills of VOC-containing cleaning materials and clean up spills immediately; convey VOC-containing cleaning materials from one location to another in closed containers or pipes; minimize VOC emissions from cleaning of application, storage, mixing or conveying equipment by ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent solvent is captured in closed containers 
 Regardless of the facility's VOC emissions, the permittee shall comply with 25 Pa. Code §129.52(d) as specified throughout §129.52(d) for Source IDs 102A, 203, 204, and 205 
Source ID 101A is also subject to 40 CFR Part 63 Subpart WWWW, the NESHAP for Reinforced Plastic Composites Production.  Source IDs 102A, 203, 204, and 205 are also subject to 40 CFR Part 63 Subpart PPPP, the NESHAP for Surface Coating of Plastic, Parts, and Production.

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 Jeraco.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional 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.      

Incorporation by Reference 
Jeraco Enterprises Inc.  -  Incorporating by reference Permit No. 49-00014, issued January 26, 2018, as redacted by Pennsylvania.  All permit conditions in the prior RACT Permit No. OP-49-0014, issued April 6, 1997, remain as RACT requirements. 













Chapter 19:  Blommer Chocolate Company (#46-00198)

Facility Description and Processes
Blommer Chocolate Company (Bloomer) is a chocolate manufacturing company is located in Upper Hanover Township, Montgomery County, Pennsylvania.  This facility includes two natural gas/propane boilers, each 12.550 MMBtu/hr, and multiple cocoa bean roasting and grinding line operations.

Units Subject to Case-by-Case RACT II
Bloomer 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.  

The following nine sources were evaluated for CbC VOC RACT II:
 Line 2 Roaster (Source ID 105)
 Line 2 Grinder (Source ID 108)
 Line 1 Roaster (Source ID 109)
 Line 3 Grinder (Source ID 118A)
 Alkalization Processes (Source ID 124A)
 Line 3 Roaster (Source ID 125)
 Line 1 Grinder (Source ID 132A)
 Line 4 Micronizer (Source ID 143)
 Line 4 Cooler (Source ID 147)
Source IDs 107, 110A, 110B, 131A, 135, 142, 144, 033, 034, 109, 125, 131A, 142, 700, and C001 will comply with presumptive VOC RACT pursuant to 25 Pa Code §129.97(c)(2), 129.97(c)(3), 129.97(c)(5), and 129.97(c)(6).

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

Technical and Economic Feasibility 
The nature and speciation of process-related VOC emissions is similar for all sources at Blommer since each of the emission sources process essentially the same raw material (cocoa beans) in one form or another.  Due to the similarities in the VOC emissions profile, the case-by-case RACT analysis was conducted in general for all the affected sources.

Of the 10 VOC control technologies evaluated, six were determined to be technically infeasible.  Blommer already has a RTO in operation (Source ID C001) to control emissions from Line 4 Roaster (Source ID 145) and Line 4 Grinder (Source ID 148) operations.  The use of the existing RTO for additional sources was determined infeasible because the existing unit does not have the capacity to adequately handle and control additional air flows.  Catalytic oxidation was determined to be infeasible because the catalyst is incompatible with the exhaust constituents.  Adsorption is technically infeasible because the presence of fats and oils in the exhaust stream will foul, clog, and saturate the adsorption media.  Absorption is also infeasible because those same fats and oils will not easily be entrained in a water-based scrubbing medium.  Dry electrostatic precipitation (ESP) was determined to be infeasible because the tar buildup from the fats and oils on the electrodes would eventually lead to decreased efficiency of the unit.  Finally, mist elimination/fine fiber filtration is infeasible because, again, the nature of the exhaust stream makes it difficult to remove the fats and oils from the filter by the wash down spray system, resulting in a clogged filter bed.

Of the remaining four VOC control technologies- a new RTO, bio-filtration, wet ESP, and good operating practices- three were evaluated for economic feasibility.  Blommer currently uses good operating practices, thus, a control cost analysis was not conducted.  It was determined that the installation of a new RTO would not only abate more VOC emissions than the other technically feasible controls, but it would also yield the most cost-effective result (demonstrated in lowest dollar amount/ton of VOC controlled).  However, the installation of a new RTO was determined to be economically infeasible for all processes evaluated.  Line 1 (Source IDs 109 and 132A) was determined to be $25,964/ton VOC controlled, Line 2 (Source IDs 105 and 108) was determined to be $10,833/ton VOC controlled, Line 3 (Source IDs 118A and 125) was determined to be $8,358/ton VOC controlled, Line 4 (Source IDs 143 and 147) was determined to be $32,234/ton VOC controlled, and the Alkalization Processes (Source ID 124A) was determined to be $11,828/ton VOC controlled.

PADEP has determined RACT to be the installation, maintenance, and operation of the source in accordance with manufacturer's specifications and the use of good operating practices for the control of VOC emissions from the source, in addition to compliance with previously established permit emission limitations.  PADEP had determined that the emission limitations represented BAT at the time of permitting each source.

PADEP's Conclusions 
PADEP has determined that VOC RACT II for the Line 2 Roaster (Source ID 105) is:
 10.41 tpy VOC on a 12-month rolling sum basis 
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Line 2 Grinder (Source ID 108) is:
 4.68 tpy VOC on a 12-month rolling sum basis, combined emissions of VOC from Line 2 Grinder No. 1 and Line 2 Grinder No. 2 
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Line 1 Roaster (Source ID 109) is:
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Line 3 Grinder (Source ID 118A) is:
 7.78 tpy VOC on a 12-month rolling sum basis 
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Alkalization Processes (Source ID 124A) is:
 13.05 tpy VOC on a 12-month rolling sum basis, combined emissions of VOC from nauta mixers, red and black reactors, potassium carbonate storage and mix tank, and alkalization processes condenser (Line 3) pursuant to 25 Pa. Code §129.99(c)
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Line 3 Roaster (Source ID 125) is:
 21.31 tpy VOC on a 12-month rolling sum basis 
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Line 1 Grinder (Source ID 132A) is:
 5.5 tpy VOC on a 12-month rolling sum basis 
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §§129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Line 4 Micronizer (Source ID 143) is:
 3.29 tpy VOC on a 12-month rolling sum basis 
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §§129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
PADEP has determined that VOC RACT II for the Line 4 Cooler (Source ID 147) is:
 6.42 tpy VOC on a 12-month rolling sum basis 
 Appropriate recordkeeping and reporting pursuant to 25 Pa. Code §§129.100(d) and 129.100(i)
 Install, maintain, and operate each source in accordance with the manufacturer's specifications and with good operating practices
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 Blommer.  

Incorporation by Reference  
Blommer Chocolate Company  -  Incorporating by reference Permit No. 46-00198, issued January 26, 2017, as redacted by Pennsylvania.  

