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

DATE:

May 31, 2020
SUBJECT:
Technical Support Document for the Pennsylvania State Implementation Plan Revisions Related to Reasonably Available Control Technology (RACT) Determinations for Case-by-Case Sources under the 1997 and 2008 8-Hour Ozone National Ambient Air Quality Standards (NAAQS); 4 Sources

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

TO:
File for Docket ID Number EPA-R03-OAR-2020-0189

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").  See 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, the permit number and permit effective date, and the status of EPA's approval for each source.

Specific to this rulemaking action, EPA is proposing to approve case-by-case RACT determinations for the following facilities:  

 Transco  -  Salladasburg Station 520;
 Novipax;
 Sunoco Partners Marketing & Terminals; and 
 Global Advanced Metals USA, Inc.

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)
                            Status of EPA Approval 
                                   8/14/2017
                 Exelon Generation  -  Fairless Hills (Bucks)
                                      Yes
                                      NOx
                              09-00066 (01/27/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                  11/21/2017
                           The Boeing Co. (Delaware)
                                      Yes
                                  NOx and VOC
                              23-00009 (01/03/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                Cherokee Pharmaceuticals, LLC (Northumberland)
                                      Yes
                                      VOC
                              49-00007 (04/24/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
           Dominion Transmission  -  Finnefrock Station (Clinton)[a]
                                ...............
                                ...............
                                ...............
                   No longer subject to source-specific RACT
                                       
                      First Quality Tissue, LLC (Clinton)
                                      No
                                      VOC
                              18-00030 (09/18/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                        JW Aluminum Company (Lycoming)
                                      No
                                      VOC
                              41-00013 (03/01/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                Transco  -  Salladasburg Station 520 (Lycoming)
                                      Yes
                                  NOx and VOC
                              41-00001 (06/06/17)
                 Proposing approval in this rulemaking action
                                       
                        Ward Manufacturing, LLC (Tioga)
                                      No
                                      VOC
                              59-00004 (01/10/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                            Wood-Mode Inc. (Snyder)
                                      No
                                      VOC
                              55-00005 (07/12/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                   4/26/2018
                       Foam Fabricators Inc. (Columbia)
                                      No
                                      VOC
                              19-00002 (12/20/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                                Novipax (Berks)
                                      Yes
                                      VOC
                             06-05036 (12/19/2017)
                 Proposing approval in this rulemaking action
                                       
                Resilite Sports Products Inc. (Northumberland)
                                      Yes
                                      VOC
                              49-00004 (08/25/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
             Sunoco Partners Marketing & Terminals (Delaware)
                                      Yes
                                  NOx and VOC
                              23-00119 (01/20/17)
                 Proposing approval in this rulemaking action
                                       
                      Texas Eastern  -  Bernville (Berks)
                                      Yes
                                      VOC
                              06-05033 (03/16/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                  Truck Accessories Group (Northumberland)[b]
                               ................
                               ................
                               ................
                              Withdrawn by PADEP
                                   6/26/2018
                    Texas Eastern  -  Shermans Dale (Perry)
                                      Yes
                                      NOx
                              50-05001 (03/26/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                     Texas Eastern  -  Perulack (Juniata)
                                      Yes
                                  NOx and VOC
                              34-05002 (03/27/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                    Texas Eastern  -  Grantville (Dauphin)
                                      Yes
                                      NOx
                              22-05010 (03/16/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                    NRG Energy Center Paxton, LLC (Dauphin)
                                      Yes
                                      NOx
                              22-05005 (03/16/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                    Texas Eastern  -  Bechtelsville (Berks)
                                      Yes
                                      NOx
                              06-05034 (04/19/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
             Merck, Sharp & Dohme Corporation (Montgomery)[c]
                                ...............
                                ...............
                                ...............
                              Withdrawn by PADEP
                                  10/29/2018
              Containment Solutions/Mt. Union Plant (Huntingdon)
                                      Yes
                                      VOC
                              31-05005 (07/10/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
            Armstrong World Ind./Marietta Ceiling Plant (Lancaster)
                                      Yes
                                      VOC
                              36-05001 (06/28/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                   Jeraco Enterprises Inc. (Northumberland)
                                      Yes
                                      VOC
                              49-00014 (01/26/18)
         EPA proposed approval on 03/20/20               (85 FR 16021)
                                       
                 Global Advanced Metals USA, Inc. (Montgomery)
                                      Yes
                                      VOC
                             46-00037   (03/10/17)
                 Proposing approval in this rulemaking action
                                       
                    Blommer Chocolate Company (Montgomery)
                                      No
                                      VOC
                              46-00198 (01/26/17)
         EPA proposed approval on 03/20/20               (85 FR 16021)
[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]  -  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.
[c] - 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.

D.  ORGANIZATION OF THIS DOCUMENT

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


Contents
Acronyms and Abbreviations	10
Chapter 1:  Transcontinental Gas Pipe Line Company - Station 520 (#41-00001)	12
Chapter 2:  Novipax (#06-05036)	15
Chapter 3:  Sunoco Partners Marketing and Terminals LP  -  Marcus Hook (#23-00119)	20
Chapter 4:  Global Advanced Metals USA, Inc. (#46-00037)	27



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 
KBBL			-	thousand barrels of oil
lbs			-	pounds
LAER			-	lowest achievable emission rate
LNB			-	low NOx burners
MBBL			-	million barrels of oil
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:  Transcontinental Gas Pipe Line Company - Station 520 (#41-00001)

Facility Description and Processes
Transcontinental Gas Pipe Line Company  -  Station 520 (Transco) is the owner and operator of an interstate natural gas pipeline transmission systems. Transco is located in Lycoming County, Pennsylvania.  Transco consists of internal combustion engines, gas turbines and a parts washer and storage tanks.  The parts washer and storage tanks are subject to existing CTG requirements. 
   
Units Subject to Case-by-Case RACT II
Transco is classified as a major VOC and NOx emitting facility, thus required to meet VOC and NOx RACT II requirements.  Transco is seeking approval of CbC NOx RACT II for two of its units at Station 520.  These units are Source ID P106, Solar Mars Turbine 1 (12,600 hp) and Source ID P107, Solar Mars Turbine 2 (12,600 hp); both simple cycle gas turbines.  Source ID P106 is currently prohibited from operating in excess of 2,400 hours in any 12-month consecutive period.  This equates to a NOx emissions cap on P106 of 95.2 tpy.  Source ID P107 is currently prohibited from operating in excess of 3,360 hours or emitting more than 133.2 tons of NOx in any 12-month consecutive period. 

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. PA-41-0005A, issued August 9, 1995.  This permit was approved by EPA into the SIP on August 24, 2005.  See 40 CFR 52.2020(d)(1)(i).  

Under PA-41-0005A, VOC and NOx RACT I for five internal combustion engines was established.  These five engines are now identified in the Title V permit as Source IDs P101, P102, P103, P104, and P105.  As required, these 5 units were re-evaluated for RACT II.  

Technical and Economic Feasibility
PADEP evaluated the technical and economic feasibility of NOx control technologies for Source IDs P106 and P107 are: Dry Low NOx (DLN) Combustors, Water and Steam Injection, SCR, SNCR, Rich/Quench/Lean (RQL) Combustion, Catalytic Combustion, Catalytic Absorption, and Alternate Lower Fuel-Bound Nitrogen (FBN) Fuels. Water and Steam Injection (rarely used for simple cycle gas turbines), SNCR (required operating temperatures not compatible with P106 and P107's operating temperatures), RQL Combustion (not commercially available for P106/P107 type turbines), Catalytic Combustion (not commercially available), Catalytic Absorption (not used for simple cycle gas turbines), and Alternate FBN Fuels (coal or methanol are not feasible fuel alternatives for P106/P107) were not feasible technologies for the reasons noted.  Therefore, DLN Combustors and SCR were evaluated for economic feasibility.  The cost effectiveness for these technologies was between $11,000 and $17,000/ton NOx removed, using the federally enforceable emission caps applicable to these two gas turbines.  Consequently, there are no technically and economically feasible NOx control technologies available for P106 and P107.  
   
PADEP also evaluated the existing VOC and NOx RACT I requirements currently applicable to three of the IC engines, now Source IDs 101, 102, and 103.  These requirements include the following NOx and VOC emission limits for each engine: 13.55 lbs NOx/hr at full load/speed, 27.1 lbs NOx/hr at any time, and 2.5 lbs VOC/hr.  In addition, the RACT I requirements include semi-annual portable analyzer testing, which are not required in the presumptive RACT II regulations.  The presumptive RACT II requirements at 25 Pa. Code §129.97(g)(3)(i)(A) are less stringent than the existing and applicable RACT I requirements; therefore, the RACT I requirements are retained as meeting RACT II.  
   
Source IDs 104 and 105 are similar to Source IDs 101, 102 and 103 but received different RACT I emission limits.  PADEP evaluated the existing RACT I requirements for these 2 units and compared them with the presumptive RACT II requirements at 25 Pa. Code §129.97(g)(3)(i)(A).  Source IDs 104 and 105 are currently required to meet 13.2 lbs NOx/hr and 2.5 lbs VOC/hr emission limits as well as conduct semi-annual portable analyzer testing.  For the combustion sources (IDs 101-105), which would otherwise be required to meet the presumptive RACT II requirements in the PA Code, the existing and applicable RACT I requirements are also more stringent than the presumptive RACT II requirements.  Therefore, the RACT I requirements are retained as meeting RACT II.  

PADEP's Conclusions
Because add-on controls are determined to be technically and/or economically infeasible for the gas turbines (Source IDs 106 and 107), PADEP has determined that the NOx RACT II requirements for both of these gas turbines is a NOx emission limit of 79.3 lbs/hr and a NOx emissions cap.  The NOx emissions cap for P106 is 95.2 tons in any 12-month consecutive period.  The NOx emissions cap for P107 is 133.2 tons in any 12-month consecutive period.  The NOx emission limits and annual emission caps, which reflect a restriction in operating hours for Source IDs 106 and 107, are approved as Best Available Technology (BAT) requirements by PADEP.  Additionally, stack testing per 25 Pa. Code §127.441 at least once every five years for NOx (as NO2), CO, VOC, and non-methane hydrocarbons is required.  Appropriate recordkeeping provisions pursuant to 25 Pa. Code §127.441 and §129.95 to determine compliance with the RACT II requirements is also required.  
   
The NOx RACT II requirements for the units at Transco are shown in Table 1.1.  

             Table 1.1: Units Subject to NOx RACT II Requirements
Source ID
Source Description
NOx RACT II Requirement
P101
I-R Engine 1 412-KVS 2050 hp LEC RETRO
13.55 lbs NOx/hr at full load/speed, 27.1 lbs NOx/hr at any time, and 2.5 lbs VOC/hr and semi-annual portable analyzer testing
P102
I-R Engine 2 412-KVS 2050 hp LEC RETRO
13.55 lbs NOx/hr at full load/speed, 27.1 lbs NOx/hr at any time, and 2.5 lbs VOC/hr and semi-annual portable analyzer testing
P103
I-R Engine 3 412-KVS 2050 hp LEC RETRO
13.55 lbs NOx/hr at full load/speed, 27.1 lbs NOx/hr at any time, and 2.5 lbs VOC/hr and semi-annual portable analyzer testing
P104
I-R Engine 4 CLN BRN/LEC 412-KVS
13.2 lbs NOx/hr and 2.5 lbs VOC/hr and semi-annual portable analyzer testing
P105
I-R Engine 5 CLN BRN/LEC 412-KVS
13.2 lbs NOx/hr and 2.5 lbs VOC/hr and semi-annual portable analyzer testing
P106
Solar Mars Turbine 1 (12,600 hp)
79.3 lbs NOx/hr, 95.6 tpy in any 12-month consecutive period, no more than 2,400 hrs of operation in any 12-consecutive month period
P107
Solar Mars Turbine 2 (12,600 hp)
79.3 lbs NOx/hr, 133.2 tpy in any 12-month consecutive period, no more than 3,360 hrs of operation in any 12-consecutive month period
P109
Pipeline Valves and Flanges
25 Pa. Code §129.96(c)
P110
Generator Waukesha 2895GL (607 hp)
25 Pa. Code §129.97(c)(8)
P112
Parts Washer (35 gal)
25 Pa. Code §129.63
P114
4 Storage Tanks > 2000 gal
 Plus 1- 10,000 gal Methanol tank 
For 4 storage tanks: 25 Pa. Code §129.96(c)
For methanol tank: 25 Pa. Code §129.57

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 Transco.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional VOC and NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.      

Chapter 2:  Novipax (#06-05036)

Facility Description and Processes 
Novipax LLC, formerly W.R. Grace & Company, is a polystyrene foam product manufacturing facility located in Berks County, PA.  The emission sources at Novipax consist of foam extruders and pentane storage tanks. 
 
Units Subject to Case-by-Case RACT II
Novipax is a major source of VOC emissions, thus required to meet VOC RACT II requirements, which can be met by a CbC RACT determination.  

Novipax is seeking a CbC VOC RACT II determinations for Source IDs 102 (Extrusion, consisting of 7 units), 103 (Outside Storage), 104 (Thermoform), 105 (Product Storage/Shipping), 106 (Scrap & Spoilage Grind/Conveying), 106B (Spoilage Grinding-Conveying), 106C (Trim Grinding-Conveying), 107 (Reclaim Extrusion), and 108 (Fluff Storage-Conveying).  Collectively, these Source IDs are also identified in the RACT II Plan Approval 06-05036C as Group Name, SG05.  

Novipax had also sought an alternative compliance schedule under 25 Pa. Code §129.99(i) for Source ID 102 (Extruders 217, 222, 230, 250, 260, 270, and 290).  The original RACT II compliance date is January 1, 2017.  Novipax seeks an alternative compliance date of January 1, 2018 for Source ID 102 (Extruders 217, 222, 230, 250, 260, 270 and 290. However, since this compliance date has passed and the RACT II final emission limits now apply, EPA is not taking action on this alternative compliance schedule.

RACT I Considerations
Novipax has units subject that are subject to CbC RACT I requirements that are being re-evaluated under the RACT II requirements.  Case by case RACT I (Plan Approval 06-1036) was approved for W.R. Grace & Company  -  Formpac Division and Reading Plant (now Novipax) by EPA into the SIP on May 16, 1996 (40 CFR 52.2020(c)(108)(i)(B)(6)).  

Source IDs 101 and 101A received previous RACT approval in 1996.  Under the current RACT requirements found at 25 Pa. Code §129.97(c)(2), these emission units emit less than 1 tpy VOC and qualify for an exemption.  However, since the RACT I approval included more stringent requirements, these are retained for Source IDs 101 and 101A. 

Source ID 102 (Extrusion) consists of 7 foam extrusion lines.  Six of those foam extrusion lines were subject to both pentane foam content limits and emission caps under the approved VOC RACT I requirements (Extruders 217, 222, 230 (mis-labeled as 203), 250, and 260, which are older lines, plus Extruders 270).  Source ID 111, Cold Degreaser, is subject to the Pennsylvania regulations, 25 Pa Code §129.63 for degreasing operations, a CTG requirement and is, therefore, not subject to case by case RACT II requirements.  The remaining units at Novipax with VOC RACT I requirements are identified in the table below.  

Technical and Economic Feasibility 
Source IDs 102, 103, 104, 105, 106, 106B, 106C, 107, and 108 are each evaluated for control options under RACT II.  For Source ID 102 (7 extruders), the option to install a RTO on 6 of those extruders (Extruder 290 is located in a different area) was assessed via conducting a stack test to determine the amount of VOC that can be captured and destroyed.  The hooding system of the 6 extruders cannot be enclosed to increase the capture efficiency.  The 2016 stack test determined that the capture efficiency of the current hoods is 35% and the addition of a RTO to control 61.55 tpy is more than $8000/ton and determined to be infeasible.  

Extruder 290 was evaluated separately from the other 6 extruders for add-on controls.  Because Extruder 290 is separate from the other extruders, use of a TO to remove the VOC emissions from this single extruder is more than the $8700/ton cost, which is determined to be infeasible for the combined VOC emissions of the other 6 extruders in Source ID 102.  Extruder 290 uses a fluorinated blowing agent, 152a, which is subsequently oxidized to a HAP, hydrofluoric acid (HF).  To control HF emissions, PADEP evaluated the technical and economic feasibility of a wet scrubber.  While the wet scrubber is technically feasible, at more than $15,000/ton VOC removed, PADEP determined it to be economically infeasible.  

For VOC RACT II, the following control options were evaluated for each of sources identified above: RTO, Scrubbers, Rotor Concentrator Wheel (CW), and combinations of these controls for each of the exhausts, stacks, blowers, and buildings.  A RTO removes VOCs through burners that oxidize the VOC-laden air stream.  Scrubbers neutralize inorganic acids created when pollutants are oxidized.  The CW uses adsorbents to remove VOCs from dilute high-volume air streams and concentrate VOC for destruction by an oxidizer.  In addition, Novipax also considered the technical and economic feasibility of using a total enclosure (to gain 100% capture efficiency) with an RTO and/or CW/RTO combination but totally enclosing the individual emission units were deemed technically infeasible due to physical or product quality or safety constraints. For the control options that were determined to be technically feasible for Novipax, the estimated costs range from $8000/ton VOC removed to more than $26,000/ton VOC removed.  Therefore, no add-on controls were determined to be both technically and economically feasible.

PADEP also evaluated material substitution as a control option to reduce the use of pentane (VOC emissions) across the Novipax facility.  Both CO2 and 152a were evaluated as substitute blowing agents.  In addition to being a greenhouse gas with a global warming potential 124 times more potent than CO2 (hence, its use is not generally encouraged as an environmental mitigation strategy), 152a's costs are much higher than CO2.  As a result, increasing the use of CO2 (to decrease pentane usage) is the chosen RACT II strategy across the facility.  The VOC emission limitations on the extruders reflects the decreased pentane use due to the substitution of CO2 as the blowing agent. 

Since the RACT I requirements for the extruders were also content based, a comparison and evaluation under RACT II requirements is warranted.  The RACT I and RACT II requirements can be compared in the table below. Although Source IDs 101 and 101A (Pentane Storage tanks) would otherwise be exempt from the RACT II requirements per 25 Pa. Code §129.97(c)(2) because these units emit less than 1 tpy VOC, they have existing RACT I requirements, which are more stringent than the 25 Pa. Code §129.97(c)(2) exemption and therefore, the RACT I requirements will continue to apply to these units. 

           Table 2.1:  Applicable VOC RACT II Requirements by Source
Source ID
Source Description
Approved RACT I Requirements (Yes/No)
VOC RACT II Requirements 
101
Storage Tanks (One of 2 pentane storage tanks subject to RACT I)
Yes 
VOC RACT I (with Source ID 101A): 3.5 lbs/hr, 85 lbs/day, and 0.13 tpy plus maintain vapor balance system
Combined with 101A: RACT I requirements retained: 3.5 lbs VOC/hr, 85 lbs/day, 0.13 tpy; maintain vapor balance system and records of annual throughput.
101A
Pentane Storage/Handling  (Second of 2 pentane storage tanks subject to RACT I)
Yes
VOC RACT I (with Source ID 101): 3.5 lbs/hr, 85 lbs/day, and 0.13 tpy plus maintain vapor balance system
Combined with 101, RACT I requirements retained: 3.5 lbs VOC/hr, 85 lbs/day, 0.13 tpy; maintain vapor balance system and records of annual throughput.
102
Extrusion consisting of the following units:
 Formerly RACT I units: Extruders 217, 222, 230,250, 260.
 Extruder 290
 
Partial (except Extruder 290)
VOC RACT I for Extruders 217, 222, 230, 250, 260: Meat tray foam (5.0  -  6.0 grams/60 in[2]) < 4.76% pentane by weight over 24 hour period.

Material Substitution: VOC limits for Meat foam trays produced at Extruders 217, 222, 230, 250, 260, and 290 are: 1) Foam trays (< 8.0 g/60 in[2] of product) < 4.5% pentane by weight over 24 hour period; 2) Foam trays (> 8.0 g/60 in[2] of product) < 4.0% pentane by weight over 24 hour period; 3) Extruder 290 limited to: 5 lbs/hr (24 hour average), 110 lbs/day (7 day running average), and 14.5 tpy during any consecutive 12-month period. 
102
Extruder 270 (formerly, RACT I Foam Extruder #6)
VOC RACT I for Extruder 270: A) Foam (< 7.9 gram/60 in[2]) < 4.259% pentane by weight over 24 hour period. B) Foam > 8.0 gram/60 in2) < 3.655% pentane by weight over 24 hour period. C) 5 lbs/hr (24 hour average), 110 lbs/day (7 day running average), and 18 tpy.
Material Substitution:
1) Foam trays (< 8.0 g/60 in[2] of product) < 4.5% pentane by weight over 24 hour period; 2) Foam trays (> 8.0 g/60 in[2] of product) < 4.0% pentane by weight over 24 hour period; 
3) Extruder 270 limited to: 5 lbs/hr (24 hour average), 110 lbs/day (7 day running average), and 14.5 tpy during any consecutive 12-month period.

103
Outside storage (Identified in RACT I as Polystyrene Foam Storage Area)
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC (i.e., pentane) emissions from this associated emission unit
104
Thermoform consisting of 15 existing thermoformers, all of which were subject to RACT I
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC emissions from this associated emission unit
105
Produce Storage/Shipping (Identified in RACT I as Final Product Storage Area)
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC emissions from this associated emission unit
106
Scrap & Spoilage/Grind Conveying
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC emissions from this associated emission unit
106B
Spoilage Grinding-Conveying
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC emissions from this associated emission unit
106C
Trim Grinding-Conveying
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC emissions from this associated emission unit
107
Reclaim Extrusion
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC emissions from this associated emission unit
108
Fluff Storage-Conveying
Yes, listed as emissions source where emissions are dependent on process/extruder emissions.
Material Substitution per Source ID 102, which reduces VOC emissions from this associated emission unit
110
1 Diesel Storage Tanks (280 and 300 gal)
No
25 Pa. Code §129.96(c) (less than 1 tpy VOC)
111
Cold Degreaser (Subject to RACT I)
Yes/CTG
25 Pa. Code §129.63
114
Propane Emergency Generator 1
No
25 Pa. Code §129.96(c) (less than 1 tpy VOC)
115
Propane Emergency Generator 2
No
25 Pa. Code §129.96(c) (less than 1 tpy VOC)

Under PADEP's RACT II determination, the pentane content of the materials used for Extruder 270 (Source ID 102) has increased over the RACT I limits (4.5% pentane for trays less than 8 gram/ 60 in[2] vs. 4.26 % pentane and 4.0% pentane for trays more than 8 grams/ 60 in[2] vs. 3.66% pentane). However, the short term hourly and daily emission limits remain the same (5 lbs/hr and 110 lbs/hr) while the annual VOC emissions cap is reduced from 18 tpy to 14.5 tpy for this source. 

Additional emission reductions are achieved through the RACT II determination for Extruders 217, 222, 230, 250, and 260 (Source ID 102).  Under RACT I, there were no restrictions on pentane content for materials used for foam trays <5 grams/60 in[2] or > 6 grams/60 in[2] at these extruders.  The only pentane content limit for materials used these extruders under RACT I was 4.76%, but it only applied when the meat trays produced were between 5.0 and 6.0 grams/60 in[2].  Therefore, under RACT I, meat trays less than 5.0 grams/ 60 in[2] and more than 6.0 grams/ 60 in2 were permitted to emit uncontrolled amounts of pentane.  Further, under RACT I, the pentane content for the materials used at Extruder 290 was uncontrolled.  In contrast, under RACT II, the pentane content for all trays at all extruders is controlled.  For trays < 8.0 grams/60 in[2], the pentane content is limited to 4.5% and for trays > 8.0 grams/60 in[2], pentane content is limited to 4.0%.  In addition to regulating all the materials used at these extruders (plus an additional extruder, Extruder 290), the RACT II pentane content is lower than those for RACT I.  Consequently, there is no backsliding of emission requirements under CAA Section 110(l) with the approval of CbC RACT II for the extruders represented by Source ID 102. 

Recordkeeping and reporting to determine compliance with the RACT II requirements include monitoring and recording the daily amount of pentane used, the amount and type of expanded polystyrene foam on each extruder used daily, the pentane content of each polystyrene foam produce on each extruder daily, the amount of trays shipped offsite (by type) daily, the monthly pentane content sampling, monthly VOC totals, and 12-month rolling VOC totals.  Records must include sufficient data and calculations to demonstrate compliance in the required time frames. 

PADEP's Conclusions
PADEP has determined that RACT for Source IDs 101, 101A and 102 are the VOC emission limits and emission caps listed in the above table.  PADEP has determined that the VOC content for the materials used at Novipax is RACT because limiting the VOC content and usage is demonstrated to be the most technically and economically feasible option producing the lowest emissions.  All monitoring and recordkeeping requirements necessary to determine compliance are required per 25 Pa. Code §127.441, §129.95 and §129.100.

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




















Chapter 3:  Sunoco Partners Marketing and Terminals LP  -  Marcus Hook (#23-00119)

Facility Description and Processes 
Sunoco Partners Marketing and Terminals, Marcus Hook Facility (SPMT) is located in Delaware County, Pennsylvania.  Emission sources at this facility include boilers and tanks.
      
Units Subject to Case-by-Case RACT II
SPMT is classified as a major NOx and VOC emitting facility, thus required to meet NOx and VOC RACT II requirements.  SPMT is seeking approval for CbC NOx RACT II requirements for Source IDs 031 (Auxiliary Boiler 1), 033 (Auxiliary Boiler 3), and 034 (Auxiliary Boiler 4). These auxiliary boilers are also subject to the NESHAP requirements at 40 CFR Part 63 Subpart DDDDD.  SPMT is seeking approval for CbC VOC RACT II requirements for Source IDs 139 (Cooling Towers, Tower 15-2B only), 402 (Blind Changing), and 801 (Fugitive Equipment; includes former Source ID 800).  

RACT I Considerations
Under the RACT I rule, the facility was subject to Operating Permit No. CP-23-0001, issued June 8, 1995.  This permit was approved by EPA into the SIP on October 31, 2001.  See 40 CFR 52.2020(c)(179)(i)(B)(6).  

Under CP-23-0001, the following units were subject to RACT I requirements and are now shutdown:
 No. 1 CO Boiler
 Boilers No. 2, 3, 4, and 5
 Boilers No. 6, 7 
 10-4 Catalytic Cracker Feed Heater
 17-2A BTX Reforming Heater
 17-1A Octane Reforming HTR H101
 17-1A Octane Reforming Heater HTR H-102
 17-1A Octane Reforming Heater HTR H-103
 17-1A Octane Reforming Heater HTR H-104
 12 Plant Flare
 10 Plant Flare
 (10) Cooling Towers (12 Plant South, 12 Plant North, 10 Plant A (West), 10 Plant A (East), 15-2S Old, 15-2S New, 15-2 POLY, 17-1A, 17-1P, 17-2, 17-2A)
 (2) Cooling Towers (15-6 MTBE and 17-1)
 15-5 TDP Unit HTR H-02
 15-5 TDP Unit HTR H-03
 17-2A BTX Reforming HTR-04
 17-2A BTX Reforming HTR-05
 12-3 Crude and Vacuum Distillation Desulfurization HTR H-102A
 12-3 Crude and Vacuum Distillation HTR-301
 12-3 Crude and Vacuum Distillation H3006
 15-1 Crude Distillation HTR-03
 Tank Truck Loading (xylene and toluene)
 Combustion Sources (all shutdown except for 6 diesel engines under Source ID 113)
Other remaining units subject to RACT I requirements, which are being retained for RACT II, are:
 2  -  1250 hp Diesel Stormwater Pumps (P-05A-06A and B) (now Source ID113)
 2  -  2250 hp Diesel Stormwater Pumps (P-05A-04A and B) (now Source ID113)
 2  -  1750 hp Diesel Stormwater Pumps (P-05A-02A and B) (now Source ID113)
 Marine Vessel Loading (now Source ID115)
  (1) Cooling Tower (15-2B) (now Source ID 139)
 Middle Creek Wastewater Conveyance (9 Units: 1A Separator, 1C Separator, 1D Separator, 16 Separator, 12 Separator Flume, 1F Separator Flume, 14 Separator Discharge Flume, 16 Separator Discharge Flume, Wastewater Conveyance Channel) (now Source ID 701)

Technical and Economic Feasibility 
PADEP evaluated the 3 auxiliary boilers (Source IDs 031, 033, and 034), which can use natural gas or process gas as fuel.  All of these boilers are currently controlled with LNB and a FGR system.  The current NOx emission rate for these boilers is 0.05 lbs/MMBtu.  NOx continuous emission monitoring system (CEMS) is required for each of these boilers. However, for the NOx RACT II analysis, additional NOx controls were evaluated.  These are SNCR, ULNB, and SCR.  

PADEP also evaluated Source ID 115 (Marine Vessel Loading) for VOC RACT II.  Applicable to Source ID 115, PADEP's regulation at 25 Pa. Code §129.81 requires the control of 90% VOC by weight.  The requirements of 40 CFR Part 63, Subpart Y, which is the NESHAP for marine vessel loading, also apply to Source ID 115.  Subpart Y requires a reduction of 98% of the VOC emissions (by weight percent) captured when using a combustion device or 95% weight percent when using a recovery device.  Therefore, the Subpart Y requirements are more stringent than the PADEP regulations and RACT II for Source ID 115 is determined to be 98% VOC emissions reduction by weight.  

PADEP evaluated Source ID 139, Existing Cooling Towers, which now has only 15-2B as the remaining tower, for VOC RACT II.  Given the fugitive nature of the VOC emissions at this unit, it is infeasible to pass these emissions through a stack or other equivalent opening.  Therefore, PADEP has determined that VOC RACT II is a 4.6 lbs VOC/year emission cap as well as the implementation of good work practices (Condition #003 in the Title V permit) to ensure that leaks are minimized and when found repaired promptly.    

PADEP evaluated Source ID 402, Blind Changing, and 801, Fugitive leaks, and determined that it is not technically feasible to pass these fugitive emissions through a stack, chimney, vent or other equivalent opening.  Emission limits for these kinds of emissions are also infeasible as these emissions are unpredictable and relatively small.  Therefore, PADEP determined that RACT II for these sources is the 40 CFR Part 60 Subpart VV (NSPS) (or Subpart Vva, as appropriate for sources constructed or modified after November 7, 2006) requirement for fugitive sources.  

                  Table 3.1: Applicable RACT II Requirements
Source ID
Source Description
Approved VOC and/or NOx RACT I Requirements (Yes/No/Type)
VOC and/or NOx RACT II RACT Requirements
T001
Storage Tank
Yes/CTG
25 Pa. Code §129.56 (Storage tanks greater than 40,000 gallons)
T002
Storage Tank
Yes/CTG
25 Pa. Code §129.56 (Storage tanks greater than 40,000 gallons)
031
Auxiliary Boiler 1
Yes
CbC: 0.05lbs NOx/MMBtu (30 day rolling average), 92.71 tpy NOx (12-month consecutive period, NOx CEMS. 
033
Auxiliary Boiler 3
Yes
CbC: 0.05lbs NOx/MMBtu (30 day rolling average), 92.71 tpy NOx (12-month consecutive period, NOx CEMS.
034
Auxiliary Boiler 4
Yes
CbC: 0.05lbs NOx/MMBtu (30 day rolling average), 92.71 tpy NOx (12-month consecutive period, NOx CEMS.
101
Cryogenic Ethane Tank (300K BBL)
No
Not subject to RACT II (constructed after July 20, 2012
102
Cryogenic Propane Tank (500K BBL)
No
Not subject to RACT II (constructed after July 20, 2012
103
Fugitive Equipment Leaks
No
Not subject to RACT II (constructed after July 20, 2012
105
Caverns (4 owned by SPMT; Cavern 4 owned by Braskem, which is not covered in this permit)
Cavern 1 capacity: 211, 592 barrels
Cavern 2 capacity: 363,824 barrels
Cavern 3 capacity: 221, 684 barrels
Cavern 4 (owned by Braskem) capacity: 65,000 barrels
Cavern 5 capacity: 1,035, 849 barrels
Yes/CTG
25 Pa. Code §129.58 (requirements for petroleum refinery leaks still apply although facility is no longer a petroleum refinery; Leak Detection and Repair (LDAR) program
106
Deethanizer
No
Not subject to RACT II (constructed after July 20, 2012
111
Natural Gasoline Loading Rack
No
Not subject to RACT II (constructed after July 20, 2012)
112
New Cooling Towers (2)
No
Not subject to RACT II (constructed after July 20, 2012)
113
(6) Diesel Engine Pumps (former RACT I units identified as 2  -  1250 hp Diesel Stormwater Pumps (P-05A-06A and B) 
2  -  2250 hp Diesel Stormwater Pumps (P-05A-04A and B)
2  -  1750 hp Diesel Stormwater Pumps (P-05A-02A and B)
Yes
25 Pa. Code §129.97(c)(8) (limit to 499 operating hr/yr) 
115
Marine Vessel Unloading
No
Cbc: 25 Pa. Code §129.81 and 40 CFR Part 63 Subpart Y (NESHAP)
116
Marine Vessel Ballasting
No
25 Pa. Code §129.81 and §129.96(c) (Less than 1 tpy VOC)
117
Cryogenic Ethane Tank (300K BBL)
No
Not subject to RACT II (constructed after July 20, 2012
118
Cryogenic Butane Tank (575K BBL)
No
Not subject to RACT II (constructed after July 20, 2012
119
Cryogenic Propane Tank (900K BBL)
No
Not subject to RACT II (constructed after July 20, 2012
120
Cryogenic Propane Tank (589K BBL)
No
Not subject to RACT II (constructed after July 20, 2012
121
Tank 139, Internal Floating Roof (6.5 MBBL)
Yes/CTG
25 Pa. Code §129.56 
122
Tank 130, External Floating Roof (208.5 MBBL)
Yes/CTG
25 Pa. Code §129.56 
123
Tank 131, External Floating Roof (208.5 MBBL)
Yes/CTG
25 Pa. Code §129.56 
128
Tank 234, Internal Floating Roof (70.1 MBBL)
Yes/CTG
25 Pa. Code §129.56 
130
Tank 132, Internal Floating Roof (14.6 MBBL)
Yes/CTG
25 Pa. Code §129.56 
132
Tank 242, Internal Floating Roof (69.2 MBBL)
Yes/CTG
25 Pa. Code §129.56 
133
Tank 246, Internal Floating Roof (54.4 MBBL)
Yes/CTG
25 Pa. Code §129.56 
134
Tank 248, Internal Floating Roof (52.4 MBBL)
Yes/CTG
25 Pa. Code §129.56 
135
Tank 249, External Floating Roof (53.8 MBBL)
Yes/CTG
25 Pa. Code §129.56 
136
Tank 250, Internal Floating Roof (80.4 MBBL)
Yes/CTG
25 Pa. Code §129.56 
137
Tank 137, Internal Floating Roof (5 MBBL)
Yes/CTG
25 Pa. Code §129.56
139
Existing Cooling Towers: 15-2B only remaining tower; 15-6 Plant and 17-1 Plant towers have been removed from service
Yes
Cbc, for 15-2B: 4.6 tpy emission limit and good work practice; 2 of 3 towers now permanently shutdown
146
Tank 344, Fixed Roof (190.3 MBBL)
Yes/CTG
25 Pa. Code §129.56 
147
Tank 351, Internal Floating Roof (179.7 MBBL)
Yes/CTG
25 Pa. Code §129.56 
148
Tank 352, Internal Floating Roof (179.7 MBBL)
Yes/CTG
25 Pa. Code §129.56 
149
Tank 353, Internal Floating Roof (189.7 MBBL)
Yes/CTG
25 Pa. Code §129.56 
150
Tank 354, Internal Floating Roof (182.2 MBBL)
Yes/CTG
25 Pa. Code §129.56 
151
Tank 355, Internal Floating Roof (189.7 MBBL)
Yes/CTG
25 Pa. Code §129.56 
158
Tank 390, Internal Floating Roof (76.53 MBBL)
Yes/CTG
25 Pa. Code §129.56 
175
Tank 522, External Floating Roof (81.3 MBBL)
Yes/CTG
25 Pa. Code §129.56 
177
Tank 524, Internal Floating Roof (75.7 MBBL)
Yes/CTG
25 Pa. Code §129.56 
178
Tank 527, Internal Floating Roof (69.7 MBBL)
Yes/CTG
25 Pa. Code §129.56 
179
Tank 528, External Floating Roof (149.2 MBBL)
Yes/CTG
25 Pa. Code §129.56 
180
Tank 529, External Floating Roof (149.2 MBBL)
Yes/CTG
25 Pa. Code §129.56 
182
Tank 594, External Floating Roof (81.3 MBBL)
Yes/CTG
25 Pa. Code §129.56 
184
Tank 596, External Floating Roof (81.3 MBBL)
Yes/CTG
25 Pa. Code §129.56 
186
Tank 598, Internal Floating Roof (49.6 MBBL)
Yes/CTG
25 Pa. Code §129.56 
188
Tank 607, Internal Floating Roof (100 MBBL)
Yes/CTG
25 Pa. Code §129.56 
190
Tank 609, Internal Floating Roof (98.17 MBBL)
Yes/CTG
25 Pa. Code §129.56 
192
Tank 611, Internal Floating Roof (87.8 MBBL)
Yes/CTG
25 Pa. Code §129.56 
 202
Tank 3, Internal Floating Roof (41.0 MBBL)
Yes/CTG
25 Pa. Code §129.56 
204
Tank 253, Internal Floating Roof (90.5 MBBL)
Yes/CTG
25 Pa. Code §129.56 
212
Tank 610, Internal Floating Roof (96.0 MBBL)
Yes/CTG
25 Pa. Code §129.56 
221
Tank 23, Internal Floating Roof (0.14 MBBL)
Yes/CTG
25 Pa. Code §129.56 
225
Tank 638, Internal Floating Roof (61.13 MBBL)
Yes/CTG
25 Pa. Code §129.56 
245
Tank 245, Fixed Roof (45 MBBL)
Yes/CTG
25 Pa. Code §129.56 
300
(21) Miscellaneous Tanks
Yes/CTG
25 Pa. Code §129.56 and 129.57 
302
Tank 2, Internal Floating Roof (59.5 MBBL)
Yes/CTG
25 Pa. Code §129.56 
340
Tank 340, Fixed Roof (198.8 MBBL)
Yes/CTG
25 Pa. Code §129.56 
347
Tank 347, Fixed Roof (190 MBBL)
Yes/CTG
25 Pa. Code §129.56 
357
Tank 357, Internal Floating Roof (182.9 MBBL)
Yes/CTG
25 Pa. Code §129.56 
358
Tank 358, Internal Floating Roof (182.9 MBBL)
Yes/CTG
25 Pa. Code §129.56 
367
Vehicle Refueling - Diesel
No
25 Pa. Code §129.96(c) (Less than 1.0 tpy VOC)
368
Vehicle Refueling - Gasoline
Yes/CTG
25 Pa. Code §§129.57 and 129.61
402
Blind Changing (Fugitive leaks whenever pipes are opened across the facility)
No
CbC: 40 CFR Part 60.485 (NSPS Subpart VV
606
Tank 244 Fixed Roof (68.4 MBBL)
Yes/CTG
25 Pa. Code §129.56 
607
Tank 243 Fixed Roof (54.4 MBBL)
Yes/CTG
25 Pa. Code §129.56 
701
Wastewater Treatment System
Yes
25 Pa. Code §129.96(c)
801
Fugitive Leaks (from valves, flanges, etc.; includes former Source ID 800)
No
CbC: 40 CFR 60.485 Subpart VV or Subpart VVa as appropriate (NSPS)

PADEP's Conclusions
PADEP has determined that the NOx and VOC RACT II requirements for the auxiliary boilers (Source IDs 031, 033 and 034) are the NESHAP requirements plus 0.05lbs NOx/MMBtu (30 day rolling average) and 92.71 tpy NOx (12-month consecutive period); 0.004 lbs VOC/MMBtu. VOC RACT II for Source ID 115 was evaluated and the 40 CFR Part 63, Subpart Y (NESHAP) requirements are determined to be RACT II for this source.  PADEP has determined that VOC RACT II for Source ID 402 (Blind Changing) and 801 (Fugitive Leaks) is 40 CFR Part 60, Subpart VV (or 40 CFR Part 60 Subpart VVa as appropriate for 801).  In addition, PADEP has determined that VOC RACT II for Source ID 139 is a 4.6 tpy VOC emissions cap and the implementation of good work practices to minimize fugitive leaks.  Appropriate monitoring and recordkeeping provisions pursuant to 25 Pa. Code §127.441 and §129.95 are required to determine compliance with RACT II requirements.

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 SPMT.  EPA also finds that the proposed SIP revisions to meet RACT will not result in additional VOC or NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.      
 







































Chapter 4:  Global Advanced Metals USA, Inc. (#46-00037)

Facility Description and Processes
Global Advanced Metals USA, Inc. (GAM) is a tantalum metal production facility, located in Douglass Township, Montgomery County, Pennsylvania.  GAM's Boyertown facility produces tantalum metal products for use in the manufacture of electronic capacitors, semiconductors, and specialty products for chemical, pharmaceutical, aerospace, energy, and ballistic industries.  Permitted emission sources at this facility include three boilers that operate on natural gas and No. 2 fuel oil, four emergency generators, process-related emissions, and a wastewater treatment plant. 

Units Subject to Case-by-Case RACT II
GAM 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 GAM, the following nine sources are complying with presumptive RACT II requirements, as specified in 25 Pa. Code §129.97(c) or (d), that is to install, maintain, and operate the source in accordance with manufacturer's specifications and with good operating practices:
 Superior Boiler 1 (Source ID 031)
 Superior Boiler 2 (Source ID 032)
 Johnston Boiler 3 (Source ID 034)
 Units Burn Gas 1 Subcategory (Source ID 050)
 Emergency Reciprocating Internal Combustion Engine (RICE)- Spark Ignition (SI) (Source ID 040)
 Emergency RICE- Compression Ignition (CI) (Source ID 041)
 Emergency RICE- CI (Source ID 042)
 Emergency RICE- SI (Source ID 044)
 Raffinate Solidification Process (Source ID 210)
GAM has evaluated CbC RACT II for the tantalum salts process (Source ID 102), extraction process (Source ID 124), wastewater treatment plant (Source ID 201), and fugitive emissions from ethanol transfer and storage (no source ID).

RACT I Considerations
Under the RACT I rule, the facility, then called Cabot Performance Materials- Boyertown, was subject to Operating Permit No. OP-46-0037, issued April 13, 1999.  RACT conditions found in this permit were approved by EPA into the SIP on December 15, 2000.  See 40 CFR §52.2020(c)(143)(i)(B)(20).  The conditions incorporated into the SIP per 65 FR 78418 as RACT included a general requirement for the facility to operate and maintain sources in a manner consistent with good operating and maintenance practices; requirements for specified sources to operate in association with their associated water scrubbers; and compliance with monitoring, recordkeeping, and reporting requirements found in 25 Pa. Code §129.95.

Technical and Economic Feasibility 
Of the available VOC control technologies for Source ID 102, the tantalum salts process found in Building 19, all but good air pollution control practices were determined to be technically infeasible.  GAM already employs good air pollution control practices at their facility for this source.  Thermal oxidation and catalytic oxidation were determined to be infeasible because the corrosive nature of hydrogen fluoride (HF) gases would attack the refractory of a thermal oxidizer or any known catalyst.  Likewise, carbon adsorption is infeasible due to the deteriorative properties of the HF gases on carbon.  The low water solubility of methyl isobutyl ketone (MIBK) makes the use of a scrubber (absorption) infeasible.  Biofiltration would be ineffective due to microbes being destroyed or limited by the presence of halogens.  Condensation is infeasible because the HF acid would deteriorate condensation equipment and piping.  There are currently no known material substitutes for MIBK in the tantalum extraction process, making material substitution infeasible.  Finally, MIBK is not needed as approximately 98% of the MIBK is recycled and recovered from this source before the tantalum salts process, resulting in minimal trace of VOC.  PADEP has determined RACT for Source ID 102 to be continued use of good air pollution control practices.  Additionally, existing lbs/hr and tpy emission restrictions for HF and hydrogen chloride (HCl), and restrictions on the heating tanks at this source will remain in the permit as RACT.

The same nine VOC control technologies were evaluated for Source ID 124, the extraction process found in Building 74, as were evaluated for Source ID 102.  Thermal oxidation, catalytic oxidation, carbon adsorption, absorption, biofiltration, condensation, and material substitution were all deemed technically infeasible due to the same reasoning found above for the Source ID 102 analysis.  GAM already employs good air pollution control practices at their facility for this source.  GAM also already employs MIBK recovery for Source ID 124 that achieves a 98% efficiency.  PADEP has determined RACT for Source ID 124 to be continued use of good air pollution control practices and MIBK recovery.

Source ID 201, the onsite wastewater treatment plant (WWTP), treats process water collected from various sources across the facility.  VOC emissions from Source ID 201 are released as fugitive emissions from the process wastewater source from the Building 74 MIBK stripper unit effluent, blowdown from the Building 74 and Building 19 scrubbers, and the process wastewater streams from Building 47.  Since the prior RACT I analysis, the relative emissions rate of the WWTP has decreased due to the addition of MIBK recovery to the process.  Several tanks have been removed from service, as well.  The following four different control scenarios were analyzed for RACT II case-by-case:
 Control Scenario 1: VOC removal from the wastewater prior to the lagoons, thereby reducing the VOC emitted from the lagoons
 Control Scenario 2: Installation of enclosure over the lagoons (expected to be the largest source of VOC emissions within the WWTP) and route collected gases to add-on control device
 Control Scenario 3: Capture and control VOC emissions from holding tanks (tanks E and EE; second largest source of VOC emissions within the WWTP) utilizing an add-on control device
 Control Scenario 4: Capture and control VOC emissions from work tanks (second largest source of VOC emissions, along with holding tanks, within the WWTP) utilizing an add-on control device
For Control Scenario 1, the following five control technologies were evaluated: liquid phase carbon adsorption, biodegradation, air stripping, steam stripping, and good operating practices.  For Control Scenarios 2, 3, and 4, the following eight control technologies were evaluated: thermal oxidation, catalytic oxidation, flare, vapor phase carbon adsorption, adsorption, condensation, biofiltration, and good operating practices.

Biodegredation was determined infeasible in several control scenarios because the presence of alcohol in the wastewater stream will inhibit the bacterial growth essential for effective VOC removal.  The use of an air stripper is dependent upon rate of transfer of a pollutant from the liquid into the air.  MIBK, methanol, and ethanol cannot be easily stripped from wastewater.  The presence of MIBK in the exhaust streams will result in poisoning or plugging of the oxidation catalyst, thus making catalytic oxidation infeasible.  The VOC concentrations in the WWTP exhaust streams are not high enough to achieve the minimum required heat content for the operation of a flare.  Vapor phase carbon adsorption is infeasible because the presence of particulate matter, acid gases, and polymerized substances in the WWTP exhaust gas streams can cause plugging of the adsorption media.  No reduction in VOC is expected from absorption because any VOC recovered by such a system would be transferred back into the liquid phase and would need to be re-treated by the WWTP.  Finally, the VOC concentrations in the WWTP exhaust streams are not high enough to achieve successful operation of a condensation system.

The remaining VOC control technologies were evaluated for cost effectiveness.  Thermal oxidation in control scenarios 2 and 3, and steam stripping (control scenario 1) were determined to be $18,148, $75,499, and $180,066 per ton of VOC removed respectively, making them cost prohibitive.  The relative cost effectiveness of liquid phase carbon adsorption is higher than the steam stripping system evaluated.  The relative cost effectiveness of biofiltration in control scenario 3 is higher than the thermal oxidation system evaluated.  Thus, those three control technologies were also deemed cost prohibitive.  GAM already employs good air pollution control practices at their facility for this source.  PADEP has determined RACT for Source ID 201 to be the continued use of good air pollution control practices.

Lastly, the fugitive emissions from ethanol transfer and storage, which are reported by the facility as a miscellaneous source and thus do not have an associated Source ID number in the operating permit, were evaluated for RACT II case-by-case.  Of the two available VOC control technologies, capture and control was determined infeasible due to the transient nature of storage and transfer of ethanol, making capture of these emissions inherently complex.  The other, good air pollution control practices, is already employed by GAM at their facility for this source.  PADEP has determined RACT for the fugitive emissions from ethanol transfer and storage as continued use of good air pollution control practices, and the continued use of the Building 47/101 vapor recovery unit (VRU).  RACT conditions were placed under Source ID 109 (Building 47/101). 

PADEP's Conclusions 
PADEP has determined that VOC RACT for the tantalum salts process in Building 19 (Source ID 102) is:
 HF emissions from the scrubber shall not exceed 0.73 lbs/hr and 3.2 tpy on a 12 month rolling sum (per 25 Pa. Code §129.99(c))
 HCl emissions shall not exceed 0.15 lbs/hr and 0.67 tpy on a 12 month rolling sum (per 25 Pa. Code §129.99(c))
 May operate heat tanks concurrently (per 25 Pa. Code §129.99(c))
 Number of batches per tank shall not exceed 364 batches per month (per 25 Pa. Code §129.99(c))
 Sources located in this building shall be operated and maintained in accordance with manufacturers' specifications and good air pollution control practices (per 25 Pa. Code §129.99(c))
PADEP has determined that VOC RACT for the extraction process in Building 74 (Source ID 124) is:
 MIBK recovery unit shall operate at an overall annual recovery efficiency of at least 75%, by weight, exclusive of downtime for required maintenance (per 25 Pa. Code §129.99(c))
 Maintenance downtime shall not exceed 250 hours on a 12 month rolling period (per 25 Pa. Code §129.99(c))
 Appropriate recordkeeping requirements pursuant to 25 Pa. Code §129.100(d)
 Sources located in this building shall be operated and maintained in accordance with manufacturers' specifications and good air pollution control practices (per 25 Pa. Code §129.99(c))
PADEP has determined that VOC RACT for the wastewater treatment plant (Source ID 201) is:
 Provide PADEP, upon request, copies of records required by the National Pollutant Discharge Elimination System (NPDES) permit (per 25 Pa. Code §129.100(d))
 Sources located in this building shall be operated and maintained in accordance with manufacturers' specifications and good air pollution control practices (per 25 Pa. Code §129.99(c))
PADEP has determined that VOC RACT for the fugitive emissions from ethanol transfer and storage is the following.  There is no source ID for the fugitive emissions, thus conditions were placed under Source ID 109, VRU, of the facility's operating permit.  Source ID 109 covers the tantalum acid leaching/drying in Building 47/101.
 High capacitance powder production shall not exceed 500,000 lbs per year in a 12 month rolling sum 
 Total combined powder production shall not exceed 1 million lbs per year in a 12 month rolling sum
 Requirements for the packed tower scrubber (Source ID C06): 
 The HF and HCl emissions shall be controlled by the scrubber
 The scrubber shall be operated to achieve a minimum removal efficiency of 90%
 The pressure drop across the packed tower shall be maintained at a minimum of 2 inches w.g.
 The recycle water flow rate to the scrubber shall be maintained at a minimum of 115 gal/min
 The blowdown flow rate of the scrubber shall be maintained at a minimum of 1 gal/min
 Requirements for the RotoClone wet dust collector (Source ID C109B):
 Particulate matter (PM) emissions from the blenders/screeners shall be controlled by the wet dust collector
 The wet dust collector shall be operated to achieve PM emissions not to exceed 0.02 grains per dry standard cubic foot
 The pressure drop between the inlet and outlet of the wet dust collector shall be maintained at a minimum of 3.0 inches w.g. and not to exceed a maximum of 7.0 inches w.g.
 The water level shall be maintained at the overflow weir in the control box
 Requirements for the VRU (Source ID C109):
 The vapor temperature at the VRU outlet shall not exceed 5ºF at all times when any of the Attritor mills are operating
 The VRU shall not be bypassed at any time when any of the Attritor mills are operating.
 Sources and APC units shall be operated and maintained in accordance with manufacturers' specifications and good air pollution control practices (per 25 Pa. Code §129.99(c))
EPA's Conclusions and Recommendations
EPA finds that the RACT determination provided by PADEP is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source-specific RACT controls adequately meet RACT under the 1997 and 2008 8-hour ozone NAAQS for GAM.  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.

