1 Appendix C : Contingency Measure Calculations

Chapter 6 outlines the State’s contingency plans, needed in the event that either New Jersey associated nonattainment area is unable to attain the 1997 annual PM 2.5 health standard by its required attainment date. These plans require the implementation of the following measures (nine State measures and one Federal):

1) Diesel idling rule changes, 2) Municipal Waste Combus tor (Incinerator) NO x Rule, 3) Onroad Motor Vehicle Control Programs (State and Federal) (Fleet turnover 2010), 4) Nonroad Motor Vehicle Control Programs (Fleet turnover 2010), 5) Industrial/Commercial/Institutional (I CI) Boiler Rule 2009 (portion not modeled), 6) NO x RACT Rule 2006 (portion not modeled), 7) Asphalt production plants rule, and 8) Controls from EGU Consent Decree (PSE&G Hudson SO 2 ), and 9) Refinery Consent Decrees (Sunoco and Valero)

A detailed description of all these measures is included in Chapter 4 (a brief description is also provided in this appendix as well) and th e estimated benefits from these measures are included in Chapter 6. The remainder of this appendix provides the de tailed calculations used to determine the emission benefits from these measures. Since some of the measures are already implemented and it is the State and Federal governme nt’s intention to implement the remainder of these measures as soon as practical, regardless of their need in the contingency plans, these additional benefits provide further confidence that New Jersey will attain the PM 2.5 National Ambient Air Quality Sta ndard (NAAQS) by 2009. By following the USEPA’s guidance that encourages early implementation of contingency measures and relying on measures already impl emented or under development, New Jersey is ensuring that no additional contingency measures will need to be developed and implemented beyond those identified. 1

1. New Jersey Diesel Idling Rule Changes Calculations

Emission reductions will be realized through im plementation of rule ch anges to Subchapter 14, Control and Prohibition of Ai r Pollution from Diesel-Powered Motor Vehicles, adopted in May 2007. These changes included clar ifying the language on some exemptions; eliminating other exemptions, such as “sun set ting” the sleeper berth exemption in 2010; and other associated changes such as enforcement, education, outreach, and legislative changes.

Emission Reduction Calculation Methodology: The following emission reduction estimates are calc ulated for use as credits for contingency measure purposes only. They are based on the amount of idling emissions implicit in the

1 72 Fed. Reg. 20642-43 (April 25, 2007).2 MOBILE6 model. This methodolog y differs from that used for estimating emission benefits during the rulemaking process.

Emission benefits were estimated by: 1. Starting with the MOBILE6 based value 2 for the percent of heavy duty truck emissions that result from idling: Idli ng emissions from onroad (class 8) heavy duty highway trucks represent approxim ately 3.4 percent of total emissions; 2. Applying an idling reduction percent assumption: Assuming that New Jersey’s actions will reduce idling by 50 percent; and 3. Applying this to the New Jersey 2009 i nventory emissions for class 8 heavy duty highway trucks.

The 50 percent reduction in idling from class 8 ve hicles is estimated to be achieved from the following sources:

o Subchapter 14 rule revision (which includes eliminating / tightening many exemptions, the phasing-in of idling a lternates such as auxiliary power units and sun setting the sleeper berth exemption in 2010);

o Increased enforcement through a legi slative language change (N.J.S.A. 39:3-70.2), which allows State and local police to clearly en force this rule;

o Education and outreach;

o Idling sweeps by the Compliance and Enforcement group; and

o Sales of “No Idling” signs, yielding in creased awareness of the regulation.

The 2009 Emission Inventory for class 8 onroad di esel heavy duty vehicles attributable to long duration truck id ling is 8 tpy of PM 2.5 and 435 tons per year (tpy) of NO x for the New Jersey portion of the Northe rn New Jersey/New York/Connecticut nonattainment area and 4 tpy of PM 2.5 and 223 tpy of NO x for the New Jersey portion of the Southern New Jersey/Philadelphia nonattainme nt area. A 50 percent reduction yields approximately 4 tpy of PM 2.5 and 218 tpy of NO x for the New Jersey portion of the Northern New Jersey/New York/Connecticut nonattainment area and 2 tpy of PM 2.5 and 112 tpy of NO x for the New Jersey portion of the Southern New Jers ey/Philadelphia nona ttainment area.

2. Municipal Waste Combustors (Incinerators) NO x Rule

The NJDEP proposed a NO x standard of 150 ppm for municipal solid waste combustors (MSW), based upon the capability of existing selective non-catalytic reduction (SNCR) emission controls to reduce emissions more th an are now being achieved. New Jersey has four resource recovery faciliti es located in the following coun ties: Essex, Union, (both in the Northern New Jersey/New York/Connecticut nonattainment area), Camden, and Gloucester (both in the Southern New Jersey/Philadelphia nonattainment area). There are 11 municipal waste combustors (MWC) at these four facilities. There is one facility in Warren County that would be subjected to this rule but Warren County is not part of the 1997 PM 2.5

2 USEPA. Guidance for Quantifying and Using Long Duration Truck Idling Emission Reductions in State Implementation Plans and Transportation Conformity. United States Environmental Protection Agency, Office of Transportation and Air Quality, EPA420-B-04-001, January 2004.3 nonattainment area so those bene fits are not included for the contingency measure in this proposed SIP revision. The NJDEP anticipates a NO x emission reduction of 240 tons per year in the Southern New Jersey /Philadelphia nonattainment area.

Table C1 : Estimated Reductions from Municipal Waste Combustors (Incinerators) Calculated for the 1997 PM 2.5 Nonattainment Areas

Municipal Solid Waste Plant Air Flow Rates in Actual Cubic Feet per Minute (ACFM) Air Flow Rates in

Dry Standard Cubic Feet per Minute (DSCFM) Pounds per hour using 100 ppm NO x limit Pounds per hour using 130 ppm NO x limit Pounds per hour using 150 ppm NO x limit 1997 PM 2.5 NNJ/NY/CT NAA 1997 PM 2.5 SNJ/PA NAA

Essex 237,900 60867 44 57 65 x

Essex 220,000 56287 40 52 60 x

Essex 229,000 58590 42 55 63 x Average ACFM 228,967 58581

Camden 97,409 24922 18 23 27 x Camden 99,064 25346 18 24 27 x Camden 101,495 25967 19 24 28 x Average ACFM 99,323 25412

Union 128,029 32756 23 30 35 x Union 131,191 33565 24 31 36 x Union 130,767 33457 24 31 36 x Average ACFM 129,996 33259

Warren 50,005 12794 9 12 14

Warren 55,702 14251 10 13 15

Average ACFM 52,854 13523

Gloucester 62,820 16072 12 15 17 x Gloucester 72,130 18454 13 17 20 x Average ACFM 67,475 17263

Total pounds per hour = 296 385 444

NNJ/NY/CT NAA 197 256 296

SNJ/PA NAA 79 103 1194 Warren 19 25 29

Total tons per year = 1296 1685 1944

NNJ/NY/CT NAA 864 1123 1296

SNJ/PA NAA 347 452 521

Warren 85 110 127

Assumption: 15% oxygen in the stack and 300 degrees F stack temperature

Actual 2002 NO x in

tons per year = 1,803 Expected reductions

= 507 118 -141

NNJ/NY/CT NAA 787 None None None

SNJ/PA NAA 761 414 309 240

Warren 255 170 145 128

Permitted NO x = 3,541

Emission Reduction Calculation Methodology:

The NJDEP calculated the estimated emission re ductions for this measure, assuming a 150 ppm NO x limit, by:

• Estimating emissions from each municipa l solid waste plant in pounds per hour.

• Converting the pounds per hour estimate to tons per year estimate: (lbs/hr)(8760 hours/year)/ 2000 lbs/ton = tons/year (444 lbs/hr)(8760 hours/year)/2000 lbs/ton = 1944 tons/year

• Calculating estimated emission reductions: Expected reductions in emissions from MSW plants in tons/year = (Actual 2002 NO x emissions from MSW plants in tons/year) – (Estimated emissions from the MSW plants in tons/year) = (1803 tons/year) – (1944 tons/year) = -141 tons/year statewide

• Reductions by nonattainment area:

NNJ/NY/CT NAA – Emissions for Essex and Union counties are s howing an increase because these numbers are based on permitted air flow rates and do not reflect actual emissions. As shown in Table C1, actu al emissions in 2002 (1,803 tpy) are lower than the calculated ones (1,944 tpy).

SNJ/PA NAA: Actual NO x Emissions (2002) – Calculated NO x Emissions using the 150 ppm limit5 761 tpy – 521 tpy = 240 tpy

The NJDEP estimated these benefits based upon permitted airflow rates at each facility. These emissions are higher than the actual emissions reported by the facility because, in general, the facilities op erate at air flow rates below the permitted level. For this reason, there are no additional reducti on benefits in the 1997 PM 2.5 New Jersey portion of the Northern New Jersey/New York/C onnecticut nonattainment area.

When New Jersey set an emission limit in th e proposed rules at 150 ppm, actual emissions were estimated to be maintained around 130 pp m. Also, the NJDEP anticipates that the facilities will decrease their emission s due to optimizing their existing NO x control systems (i.e., either injecting more ammonia or addi ng more nozzles). Finally, the NJDEP expects that the Camden County Resource Recovery facility will need to install a new NO x control to comply with the proposed rules. Therefore, the NJDEP expects that the estimated benefits will be even greater than those calculated.

3. Onroad Motor Vehicle Control Programs (S tate and Federal) (Fleet turnover 2010)

The turnover of the onroad fleet of cars, truc ks, and buses (i.e., the rate a which newer vehicles replace older ones in the overall fleet population) will result in additional direct PM 2.5 and NO x emission benefits in 2009 and beyond because the new vehicles have significantly lower emission standards than the ve hicles they are replacing, due to existing Federal regulations. Onroad fl eet turnover will result in a PM 2.5 decrease of 76 tpy (51 tpy in the New Jersey portion of the Northern Ne w Jersey/New York/Connecticut nonattainment area and 25 tpy in the New Jersey portion of the Southern New Jersey/Philadelphia nonattainment area); it will result in a NO x decrease of 7,421 tpy (5,613 tpy in the New Jersey portion of the Northern New Jersey /New York/Connecticut nonattainment area and 1,808 tpy in the New Jersey portion of the Sout hern New Jersey/Philadelphia nonattainment area).

The New Jersey Low Emission Vehicle (NJLEV) pr ogram (which is more stringent than the Tier 2 Federal standards), also contributes to the fleet turnover emi ssion benefits. The new vehicle emission standards are also lower because of a number of Federal rules such as the 2007 Heavy Duty Diesel standards for large diesel highway trucks. In order to estimate the emission benefits for fleet turnover betw een mid-2009 and mid-2010, the NJDEP made a number of assumptions, because the activity da ta (vehicle miles traveled (VMT), speeds, etc.) obtained from the Metr opolitan Planning Orga nizations’ (MPOs’) travel demand models were not yet available for 2010. The 2010 emissions were estimated by performing MOBILE6 runs for 2010 using 2009 activity levels . The results from these runs were adjusted for VMT growth by assuming that the VMT growth rate between 2009 and 2010 was similar to the average annual VMT growth rate between 2002 and 2009. The emission benefits for fleet turnover were calculated as the difference between the 2009 emissions and the 2010 emissions based on the estimated 2010 VMT. Calculation details and the MOBILE6 runs are provided in Attachment 1.6 4. Nonroad Motor Vehicle Control Programs (Fleet turnover 2010)

The turnover of many of the nonroad equipm ent types included in the USEPA Nonroad Emission Equipment Model (NNEM), version 2005c, will also result in additional direct PM 2.5 , NO x , and SO 2 emission benefits in 2009 and beyond because the newer nonroad equipment has to meet significantly lower emi ssion standards than the equipment that they are replacing and the new nonroad diesel fuel standard begins in 2010. Nonroad fleet turnover will result in a PM 2.5 decrease of 41 tpy (34 tpy in the New Jersey portion of the Northern New Jersey/New York/Connecticut nona ttainment area and 7 tpy in the New Jersey portion of the Southern New Jersey/P hiladelphia nonattainment area), a NO x decrease of 1231 tpy (1065 tpy in the New Jersey por tion of the Northern New Jersey/New York/Connecticut nonattainment area and 166 tpy in the New Jersey portion of the Southern New Jersey/Philadelphia nonattainment area), and a SO 2 decrease of 217 tpy (185 tpy in the New Jersey portion of the Nort hern New Jersey/New York/C onnecticut nonattainment area and 32 tpy in the New Jersey portion of the S outhern New Jersey/Philadelphia nonattainment area).

The new nonroad equipment emission standards ar e lower primarily beca use of a number of Federal rules such as the 2004 Nonroad Diesel Rule and the benefits of the small gasoline engine standards through Phase 2. In order to estimate the emission benefits for nonroad equipment turnover it was necessary to run the NNEM model for 2009 and 2010. The emission benefits for nonroad equipment tur nover was then calculated as the difference between the 2009 and the 2010 emi ssions generated by these two model runs. Calculation details and the NNEM runs are provided in Attachment 2.

5. ICI Boiler Rule 2009 (portion not modeled)

The beyond on the way (BOTW) ICI boiler rule, discussed in detail in Chapter 4, was included in the 2009 BOTW modeling. However, New Jersey has determined that the implementation of this rule will result in additional emission reductions beyond the 0.1 tpd that was included for the modeling.

Currently, New Jersey ICI boilers are regulated according to size, fuel and boiler type. New Jersey’s existing NO x rules generally apply only to IC I boilers at least 50 MMBtu/hr located at major sources. New Jersey intends to propose amendments to its current ICI boiler rules at N.J.A.C. 7:27-19.7. New Jersey plans on reducing the NO x emission limits for ICI boilers between 25-100 MMBtu/hr. Under th e anticipated rule proposal, there are approximately 388 ICI boilers that are a ssumed to achieve a 50% reduction in NO x emissions due to the lowering of the emission rate. By 2009, NO x emission reduction benefits will total approximately 6.8 tons per day. New Jersey estimates additional NO x reductions beyond those included in the 2009 BOTW modeling – 681 tpy in th e Northern New Jersey/New York/Connecticut nonattainment area and 193 tpy in the Southern New Jersey/Philadelphia nonattainment area. The emission benefits were allocated to each nona ttainment area based on the percent of point source emi ssions in each nonattainment area.7 6. NO x RACT Rule 2006 (portion not modeled)

The 2006 RACT NO x rule, discussed in detail in Chap ter 4, was included in the 2009 BOTW modeling. However, New Jersey has determined that the implementation of this rule will result in additional emission reductions beyond the 0.1 tpd that was included for the modeling.

The estimated emission reductions from the New Jersey 2006 amendments to Subchapter 19 “Additional NO x controls” that were included in the attainment demonstration modeling were calculated in 2001 by E.H. Pechan. 3 However, as discussed in the New Jersey rule proposal dated September 20, 2004, additional reductions were estimated from annual tune-ups for boilers. Specifically, while the benefits of the NO x RACT rule (2006) included in the regional attainment modeling were 7 tons per summer day (tpsd) (point and area sources); 4 the benefits included in the New Je rsey 2006 rule proposal were 13.3 tpsd. 5 The additional emission reductions, for point sources, are approximately 4.7 tpsd statewide. Based upon location, 66 percent of the emissi ons are in the northern part of the State and 34 percent of the emissions are in the southern part of the State. For details on how the State calculated its benefits from the implementation of this rule, see New Jersey Register 36 N.J.R. 4228(a); September 20, 2004.

For the purposes of contingency for this proposed PM 2.5 SIP revision, the additional statewide emission reductions were estimated to tons per year (tpy) and reduced to the 1997 PM 2.5 nonattainment areas as follows:

1. Emission Benefits Statewide (all counties) = 4.7 tpsd

2. New Jersey Portion of the Northern New Jersey/New York/Connecticut nonattainment area :

a. 0.66 * 4.7 tpsd = 3.1 tpsd b. 3.1 tpsd * 0.48 = 1.5 tpsd * 365 days/year = 547.5 tpy (48% of New Jersey’s counties are in the 1997 PM 2.5 Northern New Jersey/New York/Connecticut nonattainment area)

3. New Jersey Portion of the Southern Ne w Jersey/Philadelphia nonattainment area:

a. 0.34 * 4.7 tpsd = 1.6 tpsd (also 4.7 tpsd – 3.1 tpsd = 1.6 tpsd) b. 1.6 tpsd * 0.14 = 0.22 tpsd * 365 days/year = 81.76 tpy (14% of New Jersey’s counties are in the 1997 PM 2.5 Southern New

3 E.H. Pechan. Control Measure Development Support Analysis of Ozone Transport Commission Model Rules. Prepared for the Ozone Transport Commission by E.H. Pechan & Associates, Springfield, VA, 01.02.001/9408.000, March 31, 2001.

4 NJDEP. State Implementation Plan (SIP) Revision fo r the Attainment and Maintenance of the Ozone National Ambient Air Quality Standard: 8-Hour Ozone Attainment Demonstration, Final. New Jersey Department of Environmental Protection, October 29, 2007.

5 New Jersey Register 36 N.J.R. 4228(a); September 20, 2004.8 Jersey/Philadelphia nonattainment area)

7. Asphalt Production Plants Rule

The NJDEP intends to propose amendments to its rules at N.J.A.C. 7:27-19.9 in order to lower NO x emissions from asphalt production facili ties. The proposed amendments, based on an OTC model rule, would pursu e control measures to achieve at least a 35% reduction of NO x emissions from asphalt production plants from current levels, with the inclusion of emission limits based on type of fuel combus ted and implementation of Best Management Practices (BMP) requirements.

NO x Emission Reduction Calculations Methodology :

Basis :

1. NJDEP had complied asphalt pavement production plant stack emission test data between 2001 and 2006 for 29 burners from 22 facilities. A total of 119 test re sults were reviewed from 38 test events. There are 51 asphalt pavement production plants in New Jersey consisting of 70 asphalt dryers. 2. Industry total, plant average, and monthly pr oduction information were obtained from the asphalt pavement production industry.

Limits

Anticipated proposed limits are the average of actu al stack test data less 35%. Basic statistics were reviewed in the calculation. The new limits are based on fuel type and will replace the current limit of 200 parts per million, volumetri c dry (ppmvd) at 7% oxygen for all plants. Table C2 presents the anticipated proposed new limits. These limits are 37.5%, 50%, and 62.5% lower than the current limit for natural gas, #2 and #4 fuel oil, and heavier fuel oil/onspecification used oil, respectively.

Table C2 : A Comparison of New Jersey Propos ed Limits to OTC Recommended Limits

NJ Proposed limits OTC Recommended Limits Natural Gas – 75ppmvd @7% Oxygen Na tural Gas (Batch and Drum) – 0.020 lb/Ton Fuel Oil (#2) – 100ppmvd @7% Oxygen Used Oil and Fuel Oil #4 and higher – 125ppmvd @7% Oxygen @7% Oxygen Fuel Oil/Waste Oil (Batch) – 0.090 lb/Ton Fuel Oil/Waste Oil (Drum) – 0.040 lb/Ton

The equivalent “lb NO x /ton” asphalt produced are: natura l gas- 0.025 lb/ton, #2 fuel oil – 0.040 lb/ton, #4 fuel oil or heavier fuel oils/on-specification used oil 0.050 lb/ton.

Tons per Year (tpy) Reduction

Stack test data (average fuel use and aver age emissions) and production information were9 used to calculate to tal annual emissions and annual em issions reduction for the State.

Total NO x emissions of 378 tpy and NO x emission reduction of 132 tpy were estimated for 2011. Average dryer emissions and emission reduc tions were calculated by county using the statewide number of dryers (i.e., 70). Count y numbers were totaled by nonattainment area for 2010 to derive the emission reductions for c ontingency purposes. Zero growth factor was adopted in the calculations.

Ozone Season Tons per Day (tpd) Reduction

Monthly production information av ailable for limited plants was used to calculate the percent monthly production, which in turn was used to calculate monthly emission reduction for the State. This information, along with the averag e production days per month (23), was used in calculating tons per day emission reducti on during ozone season. The estimated NO x reduction during ozone season was 0.64 tpd.

Compliance with the new limits is expected to be phased-in over a period of three years based on the asphalt production dryers with the highest maximum gross heat input rates coming into compliance first. Each year, approximately 1/3 of the sources will achieve compliance with the new standards.

1. For an asphalt pavement production dryer w ith a maximum gross heat input of at least 120 MMBtu/hr or greater shall comply by May 1, 2009. Total NO x reduction in 2009: 43 tpy; 0.21 tpd ozone season

2. For an asphalt pavement production dryer w ith a maximum gross heat input of at least 100 MMBtu/hr, but less than 120 MMBtu/hr, shall comply by May 1, 2010. Total NO x reduction in 2010: 86 tpy; 0.42 tpd ozone season

3. For an asphalt pavement production dryer w ith a maximum gross heat input rate of less than 100 MMBtu/hr, shall comply by May 12, 2011.

Total NO x reduction in 2011: 132 tpy; 0.64 tpd ozone season

Ozone Season NO x Reduction by County

Average production per plant and number of plants per county was the basis for the tpd per county calculations.

8. Controls from EGU Consent Decree (PSE&G Hudson SO 2 )

Emission reductions will be re alized between 2006 and 2011 from a settlement with Public Service Electric and Gas Compa ny (PSE&G) at its coal-fired power plants in Jersey City10 (Hudson) and Hamilton (Mercer), New Jersey. 6 , 7 The settlement required additional air pollution controls, lower sulfur coal, lower em issions, and environmental projects. These additional control measures are enforceable in an amended consent decree. The NO x control reductions were included in the attainme nt demonstration. A portion of the SO 2 reductions were not included in the m odeling and are being relied upon for contingency purposes.

The additional measures include:

 Achieving an emission rate on its selectiv e catalytic reduction devices (SCRs) at Mercer Units 1 and 2 of 0.100 lbs/MMBtu on a 90 day rolling average, by January 1, 2007;

 Advanced installation and opera tion of an flue gas desulf urization (FGD) device (also known as a “scrubber”) FGD on Mercer Unit 2 starting in 2010, instead of 2012;

 Operating two new baghouses to control PM and mercury emissions from Mercer Units 1 and 2 by December 31, 2008;

 Limiting fuel to 100% ultra low-sulfur coal by May 1, 2007, comply with a lower interim SO 2 emission rate, and meet annual tonnage caps for SO 2 and NO x at Hudson Unit 2 until PSE&G installs a scrubber;

 Installing carbon injection systems to achie ve a 90% reduction in mercury emissions at Hudson Unit 2, Mercer Unit 1, and Mercer Unit 2;

 Shutting down Kearny Units 7 and 8 (two unc ontrolled oil-fired units), and surrender any SO 2 allowances allocated to those units in excess of the operational needs for PSE&G’s compliance; and

 Installing PM and Mercury Continuous Emission Monitoring Systems (CEMS). 8

Table C3 summarizes the polluti on controls in the amended consent decree compared to the 2002 consent decree.

6 USEPA. United States and New Jersey Announce Clean Air Act Settlement with PSE&G Fossil LLC for Violations of 2002 Consent Decree; Utility Require d to Pay Significantly Increased Penalties and Reduce Emissions. Accessed from: http://yosemite.epa.gov/opa/admpress.nsf/1ef7cd36224b565785257359003f533f/c59ece80a8a072d1852572360 065c298!OpenDocument. November 30, 2006.

7 State of New Jersey v. PSEG Fossil LLC , Amendment to Consent Decree, Newark Division, New Jersey, U.S. District Court (November 30, 2006). Accessible at http://www.epa.gov/compliance/resources/decr ees/amended/psegfossil-amended-cd.pdf.

8 USEPA. PSEG Fossil L.L.C. Civil Judicial Settlement, http://www.epa.gov/compliance/re sources/cases/civil/caa/psegllc.html. Fact sheets, press releases, and consent decrees are available on this site.11 Table C3 : Summary of Controls Required in th e 2002 Consent Decree Compared to the Amended Consent Decree

Hudson Unit 2 Mercer Unit 1 Mercer Unit 2 2002 Consent Decree Amendment 2002 Consent Decree Amendment 2002 Consent Decree Amendment

SO 2 Controls FGD Interim: use of ultra low sulfur coal until FGD FGD No change FGD No change

SO 2 Control Installation Date 12/31/06 12/31/2010 12/31/2010 No change 12/31/2012 12/31/2010

SO 2 Emission Rate 0.15 lbs/ MMBtu on 30-day avg; 0.25 lbs/MMBtu on 24-hr

avg. Interim: Overall annual SO 2 emissions cap and an SO 2 emissions rate (30 day average) based on the use of ultra low sulfur coal until the FGD is installed: ≤ 0.216 lbs/MMBtu - 30 day rolling average emission rate based on one calendar day block basis ≤ 0.310 lbs/MMBtu - 30 day rolling average emission rate based on one calendar day block basis, when PSEG is not able to get ultra low sulfur coal Adaro coal or coal from Indonesian mines.

Final: 0.150 lbs/MMBtu on 30-day average; 0.250 lbs/MMBtu on 24-hour average 0.15 lbs/ MMBtu on 30-day avg; 0.25 lbs/MMBtu on 24-hr

avg. Final: 0.150 lbs/MMBtu on 30-day

average; 0.250 lbs/MMBtu on 24-hour

average 0.15 lbs/ MMBtu on 30-day avg; 0.25 lbs/MMBtu on 24-hr

avg. Final: 0.150 lbs/MMBtu on 30-day

average; 0.250 lbs/MMBtu on 24- houraverage

NO x Controls SCR Interim: use of ultra low sulfur coal and SNCR year round SCR No change SCR No change

NO x Control Installation Date 5/1/07 SNCR operation by 1/1/2007; SCR installation and operation by 12/31/2010 5/1/05 No change 5/1/04 No change12 Hudson Unit 2 Mercer Unit 1 Mercer Unit 2 2002 Consent Decree Amendment 2002 Consent Decree Amendment 2002 Consent Decree Amendment

NO x Emission Rate 0.10 lbs/ MMBtu on 30-day avg; 0.15 lbs/MMBtu on 24-hr

avg. Interim: Overall interim annual NO x emissions cap and a NO x emission rate (30 day average) based upon the use of ultra low sulfur coal until SCR is installed. ≤ 0.300 lbs/MMBtu - 30 day rolling average emission rate based on one calendar day block basis

Final: SCR NO x rate of 0.100 lbs/ MMBtu on 30-day avg; 0.150 lbs/MMBtu on 24-hr

avg. 0.13 lbs/ MMBtu on 30-day avg; 0.15 lbs/MMBtu on 24-hr

avg. In addition to existing NO x emission rates, 0.100 lbs/MMBtu on 90-day avg. by 1/1/2007 0.13 lbs/ MMBtu on 30-day avg; 0.15 lbs/MMBtu on 24-hr

avg. In addition to existing NO x emission rates, 0.100 lbs/MMBtu on 90-day avg. by 1/1/2007

PM Controls Optimize ESP and install polishing baghouse Install Full size baghouse to replace ESP Optimize and/or upgrade existing ESP Install new baghouse to replace ESP Optimize and/or upgrade existing ESP Install new baghouse to replace ESP

PM Control Installation Date Optimization by 12/31/02; Baghouse by 12/31/06 Operate existing ESP and fly ash conditioner by 1/7/2006; Install and operate baghouse by 12/31/2010 12/31/02 (est.) 12/31/2008 12/31/02 (est.) 12/31/2008

PM Emission Rate 0.015 lbs/MMBtu 0.0150 lbs/MMBtu 0.03 lbs/MMBtu 0.0150 lbs/MMBtu 0.03 lbs/MMBtu 0.0150 lbs/MMBtu

Continuous Emission Monitoring Systems (CEMS) Mercury or PM CEMS Mercury and PM CEMS Mercury or PM CEMS Mercury and PM CEMS Mercury or PM CEMS Mercury and PM CEMS

Mercer Controls None Carbon Injection by Dec 31, 2010 None Carbon Injection by Jan 1, 2007 None Carbon Injection by Jan 1, 200713 Paragraph 123 of the original Consent Decr ee required PSE&G Hudson (Unit 2) and Mercer (Units 1 and 2) to comply with the following annual NO x and SO 2 emission levels which were based on permitted levels at that time.

Total NO x emissions: 16,444 tpy in any calendar year after December 31, 2005 for Hudson Unit 2, Mercer Unit 1, and Mercer Unit 2.

Total SO 2 emissions: 29,948 tons of SO 2 in any calendar year after December 31, 2006 for Hudson Unit 2, Mercer Unit 1, and Mercer Unit 2.

Based upon the amended consent decree, Hudson (Unit 2) is required to meet the lower interim annual emission caps for NO x and SO 2 :

Table C4 : Interim Annual NO x and SO 2 Emission Limits for Hudson (Unit 2)

For contingency purposes, emission reductions from the interim SO 2 annual emission caps and the use of ultra-low sulfur coal for H udson (Unit 2) are used. The calculations are provided below:

SO 2 :

In order to determine emission reductions from the settlement caps, the consent decree interim annual emissions cap was subtracted from the previous permitted limit, which are listed.

o Hudson Permitted SO 2 emissions = 56,394 tpy

o Amended Consent Decree SO 2 emissions limit in 2010 = 5,270 tpy

o Total SO 2 emission benefits for Hudson: 56,394 tpy – 5,270 tpy = 51,124 tpy

The interim SO 2 control measures for Hudson 2 were not included in the photochemical modeling to demonstrate attainment (see Ch apter 5), and therefore can be used for contingency. The emission reductions are re lied upon for contingency in the final SIP revision.

Additional SO 2 and PM control measures in the 2002 consent decree and amendments that are required by 2010 will also prov ide future emission reductions (refer to Table C3). As part of the settlement, PSE&G will fund $3.25 million in diesel engine retrofit/replacement projects for New Jersey. These projects involve the upgrade of three CSX switcher Year SO 2 (tpy) NO x (tpy) 2007 5,547 3,486 2008 5,270 3,486 2009 5,270 3,486 2010 5,270 3,48614 locomotives from Tier 0 to Tier 3 nonroad engine s plus diesel particulate filters on all three. Thus, there will be more emission reductions achie ved in the future to ensure attainment of the 15 μg /m 3 annual NAAQS and to provide progress toward the New Jersey goal of 12

μg /m 3

.

9. Refinery Consent Decrees (Sunoco and Valero)

As discussed in Chapter 4, the USEPA and vari ous state and local agencies have negotiated Consent Decrees with major refineries to elic it emission reductions from five major refinery processes: Fluid Catalytic Cr acking Units (FCCUs) and Fluid Coking Units (FCUs), Process Heaters and Boilers, Flare Gas Recovery, Leak Detection and Repair (LDAR), and Benzene/Wastewater. The esti mated emission reductions for PM 2.5 , NO x , and SO 2 are shown in Table C5. The emission reduction cal culations are shown in Table 3.1 (Emission Inventory for Boilers/Heaters) and Appendi x A (Methodology from Estimating Emission Reductions from Model Rules) of the MARAMA Refinery report, 9 which can be found in Appendix A4 and at http://www.marama.org/Project s/. The consent decrees are included in Attachments 3-5 of Appendix C. Additional emission reductions from VOC are also anticipated that are not shown in Table C5.

Table C5 : Refinery Consent Decree Emission Reductions

Emission Reductions 2009 (tpy) Refinery Process Refinery County Nonattainment Area PM 2.5 NO x SO 2 Fluid Catalytic Cracking Units (FCCUs) Sunoco Gloucester SNJ/Phila. 34 56 86

Valero Gloucester SNJ/Phila. 0 0 3,425 ConocoPhillips Union NNJ/NY/CT 0 561 0 Flares Sunoco Gloucester SNJ/Phila. 0 0 0 Valero Gloucester SNJ/Phila. 0 0 0 ConocoPhillips Union NNJ/NY/CT 0 0 0 Boilers and Process Heaters Sunoco Gloucester SNJ/Phila. 0 407 25

Valero Gloucester SNJ/Phila. 0 275 0 ConocoPhillips Union NNJ/NY/CT 0 534 0 TOTAL 34 1,833 3,536 TOTAL SNJ/Phila. NAA 34 738 3,536

Notes: 1. Source of Emission Reductions: "Assessment of Control Technology Options for Petroleum Refineries in the Mid-Atlantic Region: Final Technical Support Document." Prepared for the Mid-Atlantic Regional Air Management Association (MARAMA) by MACTEC Federal Programs, Inc., January 31, 2007, Table 3.1 (Emission Inventory for Boilers/Heaters) and Appendix A (Methodology from Estimating Emission Reductions from Model Rules).

9 MARAMA. Assessment of Control Technology Options for Petroleum Refineries in the Mid-Atlantic Region: Final Technical Support Document. Prepared for the Mid-Atlantic Regional Air Management Association (MARAMA) by MACTEC Federal Programs, Inc., January 31, 2007. Accessible at http://www.marama.org/Projects/.15 2. Additional reductions are attained that are not shown becaus e these numbers do not have emissions from growth removed.

The refinery consent decrees were included in the attainment demonstration photochemical modeling for PM 2.5 . For the purposes of satisfying the contingency requirements, New Jersey is allocating 738 tpy of the emission reductions provided by the refinery consent decrees in the Southern New Jersey/Philadelphi a nonattainment area. An analysis of how the attainment demonstration photochemical modeli ng indicates more emission reductions than needed to attain the PM 2.5 standard and why these modeled measures can also be used as contingency is presented in the following section.

Modeling Differential for Contingency

In addition to the eight measures listed in Table 6.1, to meet the contingency requirements for PM 2.5 , New Jersey is also usi ng emission reductions that ar e above and beyond what is needed for attainment (“modeled differential” ) for the New Jersey portion of the Southern New Jersey/Philadelphia nonattainment area. Some of the modeling differential can be assigned to the emission reductions achieved from the refinery consent decrees. The analysis of how New Jersey is meeting the contingency requirement usi ng this approach is outlined here.

STEP 1: Compare Modeling Concentrations and Emission Inventories at New Jersey Monitoring Sites

New Jersey monitors that were modeled for th e attainment demonstration in the New Jersey portion of the Northern New Jersey/New York/Connecticut and Southern New Jersey/Philadelphia nonattainment areas showed a decrease in the annual concentrations of PM 2.5 from 2002 to 2009. The associated emissions of direct PM 2.5 , NO x , and SO 2 within each New Jersey county that has a monitor fr om 2002 to 2009 demonstrate that significant emission reductions were achieved to produ ce an air quality benefit at the monitors.16Table C6:Modeling Concentrations and Emissions Inventory by County for 2002 and 2009 at the New Jersey Monitoring SitesSite IDMonitoring Site NameCountyModeling2002AverageAnnualBaselineConc.(μg/m3)Projected2009AnnualConc.(μg/m3)AirQualityChange(2002-2009Modeled)(μg/m3)2002 County Emissions (tpy)2009 County Emissions (tpy)DirectPM2.5NOxSO2DirectPM2.5NOxSO2340011006 Atlantic City Atlantic 11.5 9.9 -1.6 1,010 8,330 880 926 5,719 638340030003 Fort Lee Library Bergen 13.7 11.9 -1.8 1,801 26,840 1,739 1,698 16,862 1,064340070003 Camden Camden 14.3 12.3 -2.0 1,289 15,372 1,908 1,157 9,201 922340071007 Pennsauken Camden 14.3 12.4 -1.9340130015 Newark Cultural Center Essex 13.9 11.8 -2.1 1,520 24,594 4,316 1,246 14,123 3,331340130016 Newark Lab Essex 14.7 12.5 -2.1340155001 Clarksboro Gloucester 13.7 11.8 -1.8 1,303 14,515 7,169 1,462 9,494 3,476340171003 Jersey City Primary Hudson 14.9 13.0 -1.9 2,002 22,047 21,409 1,646 10,866 12,064340172002 Union City Hudson 16.2 14.1 -2.1340210008 Trenton Mercer 13.9 11.8 -2.1 1,236 25,520 15,508 1,653 9,957 4,270340218001 Washington Crossing Mercer 11.9 10.1 -1.8340230006 New Brunswick Middlesex 12.5 10.5 -2.0 1,977 26,835 2,115 1,811 16,704 1,239340270004 Morristown Morris 12.4 10.5 -1.9 1,663 15,708 1,234 1,536 9,586 894340273001 Chester Morris 11.1 9.4 -1.7340292002 Toms River Ocean 11.5 9.7 -1.8 2,256 10,421 1,074 2,0237,300 762340310005 Paterson Passaic 13.2 11.2 -2.0 1,021 9,836 760 930 6,019 533340390004 Elizabeth Union 15.7 13.3 -2.4 1,380 18,850 3,503 1,293 11,746 2,189340390006 Elizabeth Downtown Union 13.5 11.6 -2.0340392003 Rahway Union 13.1 11.2 -2.0340410006 Phillipsburg Warren 13.4 11.7 -1.7 1,031 5,250 565 958 3,065 46417 STEP 2: Calculate Average Modeling Concentr ations for the New Jers ey Portion of the Nonattainment Areas

The average 2002 and 2009 modeled PM 2.5 annual concentrations were calculated for the New Jersey portions of the No rthern New Jersey/New York/C onnecticut and Southern New Jersey/Philadelphia nonattainme nt areas, respectively. The modeling predicted an average 2.0 and 1.9 μ g/m 3 decrease in PM 2.5 at New Jersey monitors in the New Jersey portion of the Northern New Jersey/New York/Connecticut and Southern New Jersey/Philadelphia nonattainment areas, respectively. The 2002 modeling inventory a nd the projected 2009 modeling inventory (refer to Chapter 5 for a dditional information on the emission inventories used for this final SIP revision) for the Ne w Jersey counties in each nonattainment area demonstrates significant emi ssion reductions associated w ith the improved air quality benefits predicted.

Table C7 : Average Modeling Concentrations for the Ne w Jersey Portion of the Nonattainment Areas

2002 NAA Emissions (tpy) 2009 NAA Emissions (tpy) New Jersey Portion of NAA Average Modeling 2002 Average Annual Baseline

Conc. ( μ g/m 3 ) Average Projected 2009 Annual Conc. ( μ g/m3) Model Predicted Change in DV from 2002 to 2009 ( μ g/m3) Direct PM 2.5 NO x SO 2 Direct PM 2.5 NO x SO 2

NNJ/NY/CT 13.6 11.6 -2.0 15,797 198,518 52,889 14,752 113,690 26,811 SNJ/Phila. 14.1 12.2 -1.9 4,485 48,409 12,506 4,336 30,928 5,712

STEP 3: Calculate an Average Ratio of Em ission Inventory Reductions to Modeling Design Values for the New Jersey Portion of the Nonattainment Areas (tpy/ μ g/m 3 )

In order to determine the modeled differential in tons per year using the predicted change in PM 2.5 concentration, a ratio of th e predicted change in emissions inventory from 2002 to 2009 to the predicted change in the modeled design values (DVs) was calculated for each PM 2.5 precursor using the following equation:

[2002 emissions (tpy)] - [2009 emi ssions (tpy)] / [2002 modeling DV ( μ g/ m 3 )] - [2009 modeling DV ( μ g/m 3 )] = Change in emissions inventory (tpy) / Predicted change in modeled DVs ( μ g/ m 3 )

Table C8 : Ratio of Emissions from New Jersey Port ion of Nonattainment Areas to Average Modeling Design Values (tpy/ μ g/m 3 )

New Jersey Portion of NAA PM 2.5 (tpy/ μ g/m 3 ) NO x (tpy/ μ g/m 3 ) SO 2 (tpy/ μ g/m 3 ) NNJ/NY/CT NAA 525 42,630 13,105 SNJ/Phila. NAA 77 9,053 3,51818 STEP 4: Apply Conversion Factor from Step 3 to Contingency Requirements

The conversion factors calculated from Step 3 we re applied to the air quality benefits in each New Jersey portion of the nonattainment ar eas that were achieved below the PM 2.5 annual standard of 15.0 μ g/m 3 . The process to calculate the m odeled differential is outlined here:

1. The modeled average PM 2.5 annual concentration for 2009 for New Jersey monitors in the Northern New Jersey/New York/Connectic ut and Southern New Jersey/Philadelphia nonattainment areas are 11.6 and 12.2 μ g/m 3 , respectively.

2. The PM 2.5 annual standard is 15.0 μ g/m 3

.

3. Therefore, the measures modeled for 2009 provi ded more reductions than needed to meet the annual standard.

4. The 2009 modeling scenario provided an addi tional air quality benefit of 3.4 and 2.8 μ g/

m 3 above the standard in the New Jersey portion of the Northern New Jersey/New York/Connecticut and Southern New Jers ey/Philadelphia nonattainment areas, respectively.

5. Applying the conversion factor from Step 3, the additional air quali ty benefit can be converted to tpy for each PM 2.5 precursor.

Table C9 : Modeled Differential New Jersey Portion of Nonattainment Areas

New Jersey Portion of NAA NNJ/NY/CT NAA SNJ/Phila. NAA

Direct PM 2.5 : 1,785 216 tpy modeled differential emission reductions

NO x : 144,943 25,348 tpy modeled differential emission reductions

SO 2 : 44,559 9,851 tpy modeled differential emission reductions

STEP 5: Compare Refinery Consent Decree Emission Reductions to Modeled Differential Emissions to Determine Compliance with Contingency Requirements

In order to meet the contingency requiremen t for the New Jersey portion of the Southern New Jersey/Philadelphia nonattainment area (ref er to Chapter 6 for complete details), 738 tpy of total emission reductions remain that were not achieved by the eight contingency measures listed in Table 6.1. The modeled differe ntial (calculated in Step 4) can be partly attributed to the emission reductions achieved by the refinery consen t decrees at Sunoco and Valero. New Jersey is relying upon 738 tpy of the emission reductions that are above and beyond what is needed for attainment from those refinery consent decrees to meet contingency requirements.19 Table C10 : Refinery Consent Decree Emission Reduc tions Compared to Modeled Differential Emissions to Determine Complian ce with Contingency Requirements

PM 2.5 NO x SO 2 TOTAL Contingency Requirement (1/7) (tpy) (for New Jersey portion of SNJ/Phila. NAA) (see Chapter 6) 21 2,497 971 3,489

Emission Reductions from Proposed Contingency Measures except for Refinery Consent Decrees (tpy) 34 2,685 32 2,751

Remaining Emission Reduct ions Needed to Meet Contingency Requirement (tpy) -13 -188 939 738

Modeled Differential Emission Reductions Available for New Jersey portion of SNJ/Phila. NAA (tpy) 216 25,348 9,851 35,415

Emission Reductions for New Jersey portion of SNJ/Phila. NAA from Refinery Consent Decrees (tpy) (Table C5) 34 738 3,536 4,308

Emission Reductions Allocated as Contingency from Refinery Consent Decrees (tpy) 0 0 738 738

Remaining Refinery Consent Decree Emission Reductions (tpy) (not needed for contingency) 34 738 2,798 3,570

Remaining Modeled Differential Emission Reductions for New portion of SNJ/Phila. NAA (tpy) 216 25,348 9,113 34,677