UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: March 22, 2016

SUBJECT: Technical Support Document for Maryland’s Approval and Promulgation of Air 

Quality Implementation Plans for the Control of Emissions from Various 

Processes and Fuel-Burning Equipment from Kraft Pulp Mills

FROM: Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND: 

This technical support document (TSD) provides the Environmental Protection Agency’s 

(EPA’s) rationale for proposing a conditional approval of a revision to the State of Maryland’s 

state implementation plan (SIP) concerning the regulations and requirements for Kraft pulp mills. 

On October 15, 2014, EPA received a revision to the State of Maryland’s SIP submitted by 

Maryland Department of the Environment (MDE). The SIP revision adds and amends 

regulations in order to control emissions from various processes and fuel-burning equipment at 

Kraft pulp mills. The SIP revision amends regulation .01 under Code of Maryland Regulations 

(COMAR) 26.11.01 – “General Administrative Provisions,” in order to add a definition for “NOx

Ozone Season Allowance.” The SIP revision also adopts a new regulation .07 under COMAR 

26.11.14 – “Control of Emissions from Kraft pulp mills,” in order to establish a nitrogen oxides 

(NOx) limitation for fuel-burning equipment located at Kraft pulp mills. The SIP revision amends 

regulation .08 under COMAR 26.11.09 – “Control of Fuel-Burning Equipment, Stationary 

Internal Combustion Engines and Certain Fuel-Burning Installations,” in order to incorporate and 

include existing NOx reasonably available control technology (RACT) requirements under 

COMAR 26.11.14.07 – “Control of NOx Emissions from Fuel Burning Equipment,” into 

COMAR 26.11.09.08. The SIP revision also amends COMAR 26.11.14.06 – “Control of 

Volatile Organic Compounds,” in order to clarify the volatile organic compound (VOC) control 

system and requirements for several process installations at Kraft pulp mills. 

In the October 15, 2014 SIP revision, MDE’s submittal: (1) included references to the Clean Air 

Interstate Rule (CAIR) within the definition of “NOx Ozone Season Allowance,” under COMAR 

26.11.01.01; and (2) discussed a reference to COMAR 26.11.01.11E(2), which is not included in 

the Maryland SIP. EPA discussed with MDE the need to remove all references to CAIR within 
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the definition of “NOx Ozone Season Allowance,” and submit COMAR 26.11.01.11E(2) as a SIP 

revision, in order to approve the October 15, 2014 SIP revision. On September 29, 2015, EPA 

received a supplemental letter from MDE committing to remove all references to CAIR within 

the definition of “NOx Ozone Season Allowance,” and submit COMAR 26.11.01.11E(2) as a SIP 

revision, no later than September 2016. 

On December 22, 2015, EPA received a SIP revision from MDE concerning Maryland’s opacity 

regulations. The SIP revision includes adoption of COMAR 26.11.01.11E(2) into Maryland’s 

SIP, which satisfies one of the requisites for final approval and will be addressed in a separate 

rulemaking action. MDE still has to submit a SIP revision removing all references to CAIR 

within the definition of “NOx Ozone Season Allowance.” Because this has not been submitted, 

EPA is doing a conditional approval. Upon timely meeting of this commitment, a conditional 

approval of the SIP revision will become a final approval. If the MDE fails to do so, the 

commitment to address these provisions will become a disapproval a year from EPA finalizing

our conditional approval. EPA will notify the State by letter that this action has occurred. At 

that time, this commitment will no longer be a part of the approved Maryland SIP. EPA 

subsequently will publish a notice in the Federal Register notifying the public that the conditional 

approval automatically converted to disapproval. If the Maryland meets its commitment, within 

the applicable time frame, the conditionally approved submission will remain a part of the SIP 

until EPA takes final action approving the State's SIP submittal of the regulations and 

requirements for Kraft pulp mills. 

B. STATE SUBMITTAL:

MDE’s SIP revision amends and adds regulations in order to control emissions from various 

processes and fuel-burning equipment at a non-electric generating facility, specifically at a Kraft 

Pulp Mill. The following provisions are affected by this revision: 

I. Amendment to Regulation COMAR 26.11.01 – General Administrative Provisions

The SIP revision amends COMAR 26.11.01.01 in order to add a definition for “NOx Ozone 

Season Allowance.” “NOx Ozone Season Allowance” means a CAIR NOx ozone season 

allowance as defined in 40 Code of Federal Regulations (CFR) 96.302 and does not substitute a 

security or other form of property. This definition makes references to CAIR which is no longer 

applicable. In the letter dated September 19, 2015, MDE has committed to remove all references 

to CAIR in a separate SIP revision in order to meet the commitment for conditional approval. 

Once the condition is satisfied, EPA’s approval of MDE’s SIP revision removing all references 

to CAIR within the definition of “NOx Ozone Season Allowance,” the conditional approval of 

this SIP revision will become a final approval.

II. New Regulation COMAR 26.11.14.07 – Control of NOx Emissions from Fuel Burning 

Equipment
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On July 16, 2010, MDE published in the Maryland Register a notice of final action adopting new 

regulation .07 under COMAR 26.11.14 in order to establish a NOx limitation for fuel-burning 

equipment located at Kraft pulp mills. Fuel-burning equipment at a pulp mill discharges through 

a common stack and is subject to RACT requirements under COMAR 26.11.09.08 and COMAR 

26.11.14.07A(2)(b) respectively. EPA defines RACT as “the lowest emission limitation that a 

particular source is capable of meeting by the application of control technology that is reasonably 

available considering technological and economic feasibility.” 44 FR 53761 (September 17, 

1979). On February 08, 2001 (66 FR 9522), EPA approved Maryland's NOx RACT rule 

COMAR 26.11.09.08 for major sources of NOx in the State of Maryland. RACT requires that 

fuel-burning equipment units with a rated heat input capacity of 250 one million British Thermal 

Units (MMBtu) per hour or greater, reduce NOx emissions to meet an emissions rate of 0.70 

pounds per million Btu during the period May 1 to September 30 of each year and a rate of 0.99 

pounds per million Btu for the rest of the year. 

Although the coal-fired units at Kraft pulp mills are not electric generating units, they have the 

capacity to exceed the 250 million BTU per hour threshold and were therefore subject to the NOx

SIP Call. Under the NOx SIP Call, the units were allocated NOx allowances and participated in 

regional NOx trading program. Under the NOx SIP Call, at COMAR 26.11.29 and COMAR 

26.11.30, the pulp mill was allocated 947 allowances for the May 1 to September 30 period. 

Maryland's NOx Reduction and Trading Program under COMAR 26.11.29 and COMAR 

26.11.30 was approved by EPA as meeting the requirements of the NOx SIP Call on January 10, 

2001 (66 FR 1866). Since this emission cap of 947 tons is more restrictive than the ozone season 

0.70 pound/MMBtu RACT requirement, Maryland’s regulation for pulp mill required total NOx

ozone emissions from the stack to not exceed 947 tons for the May 1 to September 30 period. 

However, the pulp mill is required to continue to meet the RACT requirement of 0.99 pounds per 

million Btu during the rest of each year.

On February 21, 2014, MDE published in the Maryland Register a notice of final action 

amending regulation .07 under COMAR 26.11.14 in order to: (1) consolidate NOx RACT 

requirements into this unique chapter of COMAR pertaining to Kraft pulp mills; (2) include the 

requirement that Kraft pulp mills must meet an emission rate of 0.70 pounds of NOx per million 

Btu during the period May 1 through September 30 of each year; (3) change the words 

“allowance” or “NOx allowance” to “NOx ozone season allowance;” and (4) change reference to 

COMAR 26.11.01.10G(2)(d), regarding the submission of continuous emission monitor (CEM)

quarterly reports to MDE, to COMAR 26.11.01.11E(2). 

This SIP revision adds COMAR 26.11.14.07 in order to: (1) establish the applicability and NOx

emission standards to any fuel burning equipment with a maximum design heat input capacity of 

greater than 250 million British thermal unit (Btu) per hour located at any Kraft pulp mill; (2) 

establish the requirement limits that Kraft pulp mills must meet an emission rate of 0.70 pounds 

of NOx per million Btu in addition to an emission limit of 947 tons of NOx during the period May 

1 through September 30 of each year; and an emission rate of 0.99 pounds of NOx per million

Btu during the period of October 1 through April 30 of each year; (3) establish the requirements 
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for demonstrating compliance; (4) allow the pulp mill to secure up to 95 allowances for each 

period in which they exceed the 947 ton emission cap; (5) specify the process of achieving 

compliance through the use of allowances; and (6) establish monitoring and reporting 

requirements such that the owner or operator of a Kraft Pulp Mill subject to this regulation shall 

include emissions data obtained from a CEM in the CEM quarterly reports submitted to MDE 

pursuant to COMAR 26.11.01.11E(2). As previously mentioned, COMAR 26.11.01.11E(2) is 

currently not included in the Maryland SIP; however, was submitted to EPA for review on 

December 22, 2015 and will be addressed in a separate rulemaking action.

III. Amendment to Regulation COMAR 26.11.09 – Control of Fuel-Burning Equipment, 

Stationary Internal Combustion Engines, and Certain Fuel-Burning Installations

The SIP revision amends COMAR 26.11.09.08 – “Control of NOx Emissions for Major 

Stationary Sources” in order to incorporate existing NOx RACT requirements into this chapter 

that requires the Fuel-Burning Equipment units, at a non-electric generating facility, to reduce 

NOx emissions to meet an emissions rate of 0.70 pounds per million Btu during the period May 1

to September 30 of each year and 0.99 during the period October 1 through April 30 of each year.

IV. Amendments to Regulation COMAR 26.11.14 – Control of Emissions from Kraft pulp 

mills

On November 07, 2001 (66 FR 56220), EPA approved COMAR 26.11.14.06 in order to establish 

RACT requirements to reduce emissions of VOCs from Kraft pulp mills. The regulation 

established RACT standards to control VOC emissions from Kraft pulp mill operations statewide 

that have actual emissions of 20 pounds or more of VOCs per day and the potential to emit total 

plant-wide VOC emissions of 25 tons or more per year. Requirements to control VOC emissions 

are as follows: (1) condensates from the digester blow tank system and evaporators are to be 

treated in a condensate steam stripper or other control system with a 90 percent control 

efficiency; (2) condensates from the steam stripper and non-condensable exhaust gases from the 

digester blow tank system and evaporator shall be collected and combusted in the boiler; (3) 

wash water for the brown stock washers and smelt dissolving tanks must use either fresh or clean

water and/or clean condensates; (4) a black liquor oxidation unit is required on the recovery 

boiler and at least 50 percent of the flue gas generated annually from the recovery boiler must be 

treated with a dry bottom precipitator with a salt cake mix tank; (5) fugitive VOC emissions from 

other miscellaneous processes at the installation will be controlled by processing pulp from the 

brown stock washers using clean condensates and fresh/clean wash water; and (6) annual tests 

are required to demonstrate the VOC removal efficiency of the condensate steam stripper using 

EPA Test Method 25D found in 40 CFR part 60. Other EPA approved VOC test methods 25, 

25A or 25B shall be used to test other VOC emission streams. Installations are required to 

submit a test protocol to MDE for approval. Test results must be submitted to MDE within 60 

days and retained for at least 5 years.
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This SIP revision amends COMAR 26.11.14.06 – “Control of Volatile Organic Compounds” in 

order to: (1) clarify that air emissions from brown stock washers are to be collected and 

combusted; (2) clarify that evaporators, digester blow tank systems, and brown stock wasters 

shall be controlled by removing 90 percent (90%) or more of the condensate VOC loading by 

demonstrating a VOC removal or destruction efficiency of the condensate stream stripper of 90% 

or greater or a system analysis of these units; and (3) in addition to using EPA Test Method 25D 

found in 40 Code of Federal Regulations (CFR) Part 60, allow the use of other approved methods 

by MDE as part of a SIP revision to demonstrate the collective VOC removal efficiency of the 

condensate steam stripper and other control systems as required.

C. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. The amendment of COMAR 

26.11.01 – “General Administrative Provisions,” the adoption of a new regulation .07 under 

COMAR 26.11.14 – “Control of Emissions from Kraft pulp mills,” the amendment of COMAR 

26.11.09.08 – “Control of NOx Emissions for Major Stationary Sources,” and the amendment of 

COMAR 26.11.14.06 – “Control of Volatile Organic Compounds” meet the applicable 

requirements of the Clean Air Act (CAA) and strengthens the SIP. Consequently, EPA is 

proposing to conditionally approve this SIP revision, concerning the regulations and 

requirements at a Kraft Pulp Mill facility, based upon MDE’s commitment to revise the 

definition of “NOx Ozone Season Allowance” at COMAR 26.11.01.01 to remove all references 

to CAIR a year from EPA finalizing our conditional approval.

Pursuant to section 110(k)(4) of the CAA, this conditional approval is based upon a letter from 

MDE dated September 29, 2015, committing to submit additional SIP revisions to address the 

deficiencies previously submitted in the October 15, 2014 SIP revision. Once EPA has 

determined that MDE has satisfied these condition, EPA shall remove the conditional nature of 

its approval and the SIP revision concerning the regulations and requirements at a Kraft Pulp 

Mill facility will, at that time, receive a full approval status. Should MDE fail to meet the 

conditions specified above, the final conditional approval of the October 15, 2014 SIP revision, 

concerning the regulations and requirements at a Kraft Pulp Mill facility, will convert to a 

disapproval.