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

DATE: March 22, 2016

SUBJECT: T echnical Support Document for Maryland’s Approval and Promulgation of Air

Quality Implementation Plans for the Control of Em issions 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 revis ion to the State of M aryland’ s state implementation p lan (SIP) concerning the regulation s 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

- burnin g 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 “NO x Ozone Season Allowan ce.” 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 (NO x ) limitation for fuel

- burning equipment located at Kraft pulp mills

. The SIP revision a mends 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 NO x 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 a lso amends COMAR 26.11.14.06

– “Control of Volatile Organic Compounds,” in order to clarify the volatile organic compo und (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 “NO x Ozone S eason 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 within2

the definition of “NO x Ozone Season Allow ance,” 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 “NO x 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 s till has to submit a SIP revision removing all references to CAIR within the definition of “NO x Ozon e 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 revisi on 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 ac tion 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 m eets its commitment, within the applicable time frame, the conditi onally approved submission will remain a part of the SIP until EPA takes final action approving the State's SIP subm ittal of the regulations and requirements for Kraft pulp mills

.

B . STATE SUBMITTAL:

MDE’s SIP revision amends and adds regulations in order to contro l 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 Adminis trative Provisions

The SIP revision amends COMAR 26.11.01.01 in order to add a definition for “NO x Ozone Season Allowanc e.” “NO x Ozone Season Allowance” means a CAIR NO x ozone season allowance as defined in 40 Code of Fed eral Regulations (CFR) 96.302 and does not substitute a security or other form of property. This defini tion 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 or der 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 “NO x Ozone Season Allowance

, ” the conditional approval of this SIP revision will become a final approval.

I I. New Regulation COMAR 26.11.14.07

– Control of NO x Emissions from Fuel Burning Equipment3

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 NO x 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 (Sept ember 17, 1979). On February 08, 2001 ( 66 FR 9522 ), EPA approved Maryland's NO x RACT rule COMAR 26.11.09 .08 for major so urces of NO x in the State of Maryland . RACT requires that fuel

- burning equipment units with a rated heat input c apacity of 250 one mil lion British Thermal Units ( MMBtu ) per hour or g reater , 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 NO x SIP Call. Under the NO x SIP Call, the units were allocated NO x allowances and participated in regional NO x trading program

. Under the NO x 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 NO x Reduction and Trading Program under COMAR 26.11.29 and COMAR 26.11.30 was approved by EPA as meet ing the requirements of the NO x 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 NO x 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 d uring 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 NO x RACT requirements into this unique chapter of COMAR pertainin g to Kraft pulp mills; (2 ) include the requirement that Kraft pulp mills must meet an emission rate of 0.70 pounds of NO x per million Btu during the period May 1 through September 30 of each year; (3 ) change the words “allowance” or “NO x allowance” to “NO x 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 NO x 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 lim its that Kraft pulp mills must meet an emission rate of 0.70 pounds of NO x per million Btu in addition to an emission limit of 947 tons of NO x during the period May 1 through September 30 of each year ; and an emission rate of 0.99 pounds of NO x per million Btu during the period of October 1 through April 30 of each year; (3) establish the requirements4

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 monito ring 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.

I I I

. Amendment to Regulation COMAR 26.11.09

– Control of Fuel

- Burning Equipment, Stationary Internal Combustion Engines, and Certain Fuel

- Burning Installations

The SIP revision amend s COMAR 26.11.09.08

– “Control of NO x Emissions for Major Stationary Sources” in order to incorporate existing NO x RACT requirements into this chapter that requires t he Fuel

- Burning Equipment units, at a non

- ele ctric generating facility, to reduce NO x emissions to meet an emissions rate of 0. 70 pounds per million Btu during the period May 1 to September 30 of each ye ar and 0.99 during the period October 1 through April 30 of each year.

I V

. Amendments to Regulation COMAR 26.11.14

– Control of Emissions from Kraft pulp mills

On November 07, 2 001 ( 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 contr ol VOC emissions are as follows: (1) c ondensates 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) c ondensates 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)

w ash 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 precipit ator with a salt cake mix tank; (5) f ugitive VOC emissions from other miscellaneous processes at the installation will be controlled by processin g pulp from the brown stock washers using clean condens ates and fresh/clean wash water; and (6) a nnual tests are required to demonstrate the VOC removal efficiency of the condensate steam stripper using EPA Test Meth od 25D found in 40 CFR part 60. Other E PA approved VOC test methods 25, 25A or 25B shall be used to t est other VOC emission streams. Installations are required to submit a tes t protocol to MDE for approval. Test results must be submitted to MDE within 60 days and retained for at least 5 years

.5

This SIP revision amend s 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 b rown 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 analysi s 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 stripp er and other control systems as required.

C . CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requ irements for an acceptable SIP. The amendment of COMAR 26.11.01

– “General Administrative Provisions,” the adoption of a new re gulation .07 under COMAR 26.11.14

– “Control of Emissions from Kraft pulp mills ,” the amendment of COMAR 26.11.09.08

– “Control of NO x 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 strengthen s 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 co mmi t ment 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 th ese condition, EPA shall remo ve 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 condition s 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.