1 **UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103**  **DATE:** 4/12/12 **SUBJECT:** Technical Support Document for Maryland’s Reasonable Available Control

Technology f

or the 1997 8
- hour Ozone National Ambient Air Quality Standard **FROM:** Jacqueline Lewis, Environmental Engineer /s/

Office of Air Program Planning (3AP30) **TO:** S tate Implementation P lan (SIP) Docket File **THRU:** Cristina Fernandez, Associate Director /s/

Office of Air Program Planning (3AP30)
**I. Affected Regulation**  On October 17, 2011, Maryland submitted a revision to its SIP that meets the requirements of Reasonable Available Control Technology (RACT) set forth by

the Clean Air Act (CAA) for the 1997 8
- hour O zone National Ambient Air Quality Standards (NAAQS ). The entire state of Maryland is located within the Ozone Transport Region (OTR). Therefore , the entire state is subject to the CAA’s RACT requirements. Three areas were classified as moderate and one as m arginal. Maryland also had an Early Action Compact area. All other remaining counties are part of the OTR. The three moderate 1997 8 hour ozone nonattainment areas are Baltimore, Washington, D.C. , and Cecil County (part of the Philadelphia nonattainment area). The one marginal 1997 8
- hour ozone nonattainment area consists of Kent and Queen Anne’s Counties. Washington County was part of the Earl y Action Compact program
. **II**
. **Background** Ozone is formed in the atmosphere b y photochemical re actions between volatile organic compounds (VOC), oxides of nitrogen (NO x ) , and carbon monoxide (CO) in the presence of sunlight. In order to reduce ozone concentrations in the ambient air, the CAA requires all nonattainment areas to apply control on VOC/

NO x emission sources to achieve emission reductions. Among effective control measures, RACT controls are a major group for reducing VOC and NO x emissions from stationary sources. Since the 1970' s EPA has consistently interpreted RACT to mean the lowest emission limit that a particular source is capable of meeting b y the application of the control technology that is reasonabl y available considering technological and economic feasibility
. See 72 F R 20586 at 20610 , April 25, 2007. Section 182 of the CAA sets forth two separate RACT requirements for an ozone nonattainment area. The first requirement, contained in section 182(a)(2)(A) of the2

CAA, and referred to as RACT fix

- up, requires the correcti on of RACT rules for which the Environmental Protection Agency (EPA) identified deficiencies before the CAA was amended in 1990
. The second requirement, referred to as RACT c atch

- u p set forth in section 182(b)(2) of the CAA, requires that moderate (or wor se) ozone nonattainment areas, as well as marginal and attainment areas in OTR established pursuant to section 184 of the CAA, implement RACT controls on all major VOC and NO x emission sources and on all sources and source categories covered b y a control t echnique guideline (CTG) issued by EPA. All Maryland counties we re subject to RACT requirements under the 1

- hour ozone standard. The Baltimore, Washington D.C. , and Cecil County , Maryland nonattainment areas were designated as severe 1
- hour ozone nonatta inment areas. Kent and Queen Anne’s C ounties were designated as a marginal 1

- hour ozone nonattainment area. All remaining Maryland counties were identified as part of the OTR. Since the early 1990s, Maryland has implemented numerous RACT controls throughout the State to meet the CAA’s RACT requirements. Maryland also implemented controls necessary to meet the requirements of the NO x SIP Call (40 CFR 51.121). **A. RACT Fix -**  **Up** The first RACT requirement for ozone nonattainment areas, contained in sectio n 182(a)(2)(A) of the CAA, required Maryland to submit a SIP revision correcting RACT rules prior to the CAA amendment in 1990. On April 5, 1991, September 20, 1991, April 2, 1992, January 18, 1993, June 8, 1993 , and July

19, 1993, the Maryland Department of the Environment submitted several SIP revisions consisting of revised VOC emission regulations applicable in the State of Maryland. Portions of Maryland’s June 8, 1993 and July 19, 1993 submittals also address the RACT c atch

- up requirements. EPA prop osed to approve the revisions to Maryland’s SIP as meeting the RACT fix

- up requirements of the amended CAA through numerous notices . These revisions included amendments to the Code of Maryland Regulations (COMAR), specifically revisions to Title 26, subtitles11, chapters 1, 2, 4, 6, 8, 10, 13,14, 19, and T est M ethod 91
- 01( See 58 FR 34392, June 25, 1993 ; 58 FR 50307, September 27, 1993 ; and 58 FR 51028, September 30, 1993). On March 31, 1994, September 7, 1994, and November 29, 1994, EPA published fin al rulemaking notices approving the State of Maryland’s SIP revisions ( See 59 FR 15117, March 31, 1994 ; 58 FR 50307 , September 27, 1993 ; 59 FR 46180, September 7, 1994 ; and 59 FR 60908, November 29, 1994 ). **B. RACT Catch -**  **Up** The second RACT requirement f or ozone nonattainment areas, set forth in section 182(b)(2) of the CAA, requires Maryland to implement RACT for each category of VOC sources covered by a CTG document issued between the date of the 1990 Amendments and the date of attainment, for VOC sourc es covered by an y CTG issued before the 1990 Amendments, and for all other major stationary

sources of VOCs. Because Maryland is in the OTR, the entire State is subject to the RACT c atch

- up provisions of the section 182(b)(2) of the CAA . The Baltimore an d Philadelphia nonattainment areas were classified as severe. Therefore , a major source in these areas is a source having the potential to emit 25 tons per year ( TP Y) of VOC or more. In the remainder of the State, a major source was defined as a source h aving the potential to emit 50 TPY of VOC or more. As mentioned above portions of Maryland’s June 8, 1993 and July 19,3

1993 submittals address the RACT c atch

- up requirements. These submittals included amendments to chapters 11, 13, and 19 under Title 26, subtitle 11. EPA approved these amendments through Direct Final Rulemaking on January 6, 1995 (60 FR 2018). On July 12, 1995, Maryland submitted additional amendments to satisfy the RACT c atch

- up provisions. This submittal contained amendments to the d efinition of the term “major stationary source of VOC” and Maryland’s major source VOC RACT regulations COMAR 26.11.19.01B(4) and 26.11.19.02G, respectively . On May 13, 1998, EPA published a direct final notice to approve COMAR 26.11.19.01B(4) of Maryland ’s SIP as meeting the RACT “ c atch

- up” provisions of the CAA (63 FR 26462)
. **C .**  **Conditional Limited Approval** On March 1, 1996, EPA proposed conditional approval of Maryland’s April 5, 1991 and June 8, 1993 revision submittals pertaining to COMAR 26.11.19.02G and COMAR 26.11.06.06 (61 FR 8009). Approval was conditioned on the State of Maryland certifying that it has determined and imposed RACT for all the major VOC sources covered b y the VOC RACT regulation and submitted those enforceable RACT determinations to EPA as SIP revisions. That certification was to be made b y M aryl and no later than one year from the dat e EPA promulgated final conditional approval of the SIP revision. Because proposed conditional approval does not comply with EPA’s generic RACT policy , EPA withdrew its March 1, 1996, proposed conditional approval on September 4, 1998 (63 FR 47174) and at the same time also conditionally

and limitedly

approved th e April 5, 1991, June 8, 1993 , and July 12, 1995 submittals
. This September 4, 1998, direct final notice withdrew the March 1, 1996 , proposed conditional approval and conditionally and limitedl y approved the Maryland major source VOC RACT regulation and minor source VOC regulations, COMAR 26.11.19.02G and COMAR 26.11.06.06 respectivel y. On February 7, 1996, Maryland submitted a letter to EPA committing to: (1) complete submission of the SIP revi sions required by COMAR 26.11.19.02G containing RACT determinations for the major VOC sources in the State that are subject to the RACT rule ; and (2) provide a written statement to EPA that, to the best of its knowledge, it has completed submission of the SIP revisions described above within one year of the effective date (November 3, 1998) of the final conditional limited approval of the Maryland generic major source VOC RACT regulation. On December 19, 2008, Maryland submitted a letter certifying that it has imposed RACT for all major category

- specific and generic VOC sources and submitted those enforceable RACT determinations to EPA as SIP revisions for approval. In addition to this letter, Maryland also provided a list of VOC RACT regulations submitted and approved b y EPA and a list of all major sources of VOC and NO x and the applicable RACT regulations. EPA Region 3 has determined that this letter satisfies all requirements , and on March 25, 2009 , EPA converted the conditional limited approval stat

us of COMAR 26.11.19.02G and COMAR 26.11.06.06 to full approval
. See 63 FR 47174
.4

**D. Maximum Achievable Control Technology**  ( **MACT )**  **Standards** On September 8, 1999 (69 FR 48714), EPA published approval of COMAR 26.11.19.20, “Control of Landfill Gas Emissions from Municipal Solid Waste Landfill , ” as a s ection 111(d) plan in 40 CFR p art 62 and not as a p art 52 SIP revision. Thus this rule is federall y enforceable, but under a different requirement of the CAA. However, in November 2008, EPA published a guidance document titled, “Guidance For Estimating VOC and NO x Emission Changes From MACT Rules
. ” This document was develop in part because EPA recognized that nonattainment areas should be able to take credit for MACT standards under section 112 of th e CAA in meeting the above

- mentioned requirements for the attainment demonstration, RACT and reasonable further progress ( RFP ) . This guidance document estimates a national VOC reduction of 75% for this source category . Therefore, EPA Region 3 has determi ned that this rule approved under 40 CFR p art 62 also serves to satisfy the requirements under 40 CF R p art 52. **III. VOC**  **RACT Controls** Most of Maryland’ s Regulations and Statues, under COMAR 26.11. 06, 26.11.1 0 , 26.11.11, 26.11.13, 26.11.14, 26.11.19 and 26.11. 24 contain the VOC RACT controls that were implemented and approved in Maryland’s SI P under the 1

- hour ozone NAAQS. However, COMAR 26.11.19.20 ( “Control of L andfill Gas Emissions from Municipal Solid Waste Landfill”) which was approved b y EPA on Sep tember 18 , 1999, contain the VOC RACT controls that were implemented and approved in Maryland’s SIP under s ection 111(d) using EPA’s MACT standards under 40 CFR 60.752 and 40 CFR 60.755 as the RACT basis
. Although Alternative Control Technology ( ACTs ) ar e not regulatory documents and have no legal effect on state regulations, EPA requires that states verify that ACTs have been considered in the RACT program development process. Therefore, Maryland included ACTs in their review of applicable RACT requirem ents in this submittal. Table 1 lists Maryland’s VOC RACT controls using EPA’s CTGs as the RACT basis
. This list also includes the date the rule became affective in the state of Maryland and the Federal Register publication date and citation.
**Table 1**  **. Maryland’s VOC RACT Controls**  **B ased on EPA’s CTGs**  **Regulation COMAR**  **Existing Stationary Sources**

**Title of Regulation State**  **Effective Date**  **Federal**

**Register Date**  **Citation**
26.11.11 Control of Petroleum Products

Installation, including Asphalt Paving and Asphalt Concrete Plants 8/1/88 & 4/26/93 11/3/92

& 1/6/95 57 FR 49651

& 60 FR 2018 26.11.13.03 Control of Gasoline and VOC

Storage and Handling

- Large Storage Tanks 8/1/88 11/3/92 57 FR 49651
26.11.13.04 Control of Gasoline and VOC 8/11/97 12/22/98 63 FR 706675 Storage and Handling

– Loading Operations 26.11.13.05 Control of Gasoli ne and VOC

Storage and Handling

– Loading Operations

- Gasoline Leaks from Tank Trucks 2/15/93 1/6/95 60 FR 2018

26.11.19.03 Automotive L ight Duty Truck Coating 9/22/97 11/5/98 63 FR 59720 26.11.19.04 Can Coating 8/1/88 11/3/92 57 FR 49651 26.11.19.05 Coil Coating 8/1/88 11/3/92 57 FR 49651 26.11.19.06 Large Appliance Coating 10/1/10 5/12/11 76 FR 27610 26.11.19.07 Paper, Fabric, Vin yl , and Other

Plastic Parts Coating 5/16/11 10/17/11 76 FR 64022 26.11.19.08 Metal Furniture Coating 8/1/88 11/3/92 57 FR 49651 26.11.19.09 Cold and Vapor Degreasing 6/5/95 8/4/97 62 FR 41853 26.11.19.10 Flexographic and Rotogravure 4/19/10 9/27/10 75 FR 59086 26.11.19.11 Lithographic Printing 6/5/95 9/2/97 62 FR 46199 26.11.19.12 Dry

Cleaning Installations 9/22/97 9/2/98 63 FR 46662 26.11.19.13 Miscellaneous Metal Coating 5/16/11 10/17/11 76 FR 64017 26.11.19.13
- 1 Aerospace Coating Operations 10/2/00 11/7/01 66 FR 56220 26.11.19.14 Manufacture of S ynthesized

Pharmaceutical Products 5/8/91 11/29/94 59 FR 60908 26.11.19.23 Control of VOC Emissions from

Vehicle Refinishing 5/22/95 8/4/97 62 FR 41853

Table 2 lists Maryland’s VOC RACT controls using Maryland’s RACT analy sis as the RACT basis
. This list also includes the date the rule became affective in the S tate of Maryland and the Federal Register publication date and citation. **Table 2.**  **Maryland’s VOC RACT Controls B**  **ased on Maryland RACT A nalysis**  **Regulation COMAR**  **Existing Stationary Sources**

**Title of Regulation State**  **Effective Date**  **Federal**

**Register Date**  **Citation**
26.11.10 01,.06 and .07 Control of VOCs from Iron and Steel

Production Installations 12/5/00 11/7/01 66 FR 56222 26.11.13.08 Control of VOC Emissions from

Marine Vessel Loading 10 /1 8 /07 7/18/08 73 FR 41268 26.11.14.01 and .06 Control of VOC Emissions from

Kraft Pulp Mills 1/ 8 / 01 11/7/01 66 FR 56220 26.11.19 .01B(4) and .02G Control of Major Stationary Sources of Volatile Organic Compounds 12/10/01 3/25/09 74 FR 12556
26.11.19.07
- 1 Solid Resin Decorative Surface

Manufacturing 6/15/98 6/17/99 64 FR 324156

26.11.19.09 Control of VOC Emissions from

Cold Vapor Degreasing 6/5/95 8/4/ 97 62 FR 41853 26.11.19.10 Flexographic and Rotogravure 4/19/10 9/27/10 75 FR 59086 26.11.19.13
- 2 Brake Shoe Coating Operations 8/24/98 6/17/99 64 FR 32415 26.11.19.13
- 3 Control of VOC from Structural Steel

Coating Operations 6/29/98 6/17/99 64 FR 32415 26.11.19.15 Paint, Resin and Adhesive and

Adhesive Application 4/19/10 10/ 1 8/1 1 7 6 FR 64237 26.11.19.16 Control of VOC Equipment Leaks 8/19/91 9/7/94 59 FR 46180 26.11.19.17 Control of VOC Emissions from

Yeast Manufacturing 9/12/05 3/31/06 71 FR 16237 26.11.19.18 Control of VOC Emissions from

Screen Printing and Digital Imaging 6/10/02 1/15/ 03 68 FR 1972 26.11.19.19 Control of VOC Emissions from

Expandable Poly st yr ene Operations 10/2/00 5/7/ 01 66 FR 22924 26.11.19.20 Control of L andfill Gas Emissions

from Municipal Solid Waste Landfill 2/5/98 and 3/21/99 9/8/99 69 FR 48714 26.11.19.21 Control of VOC from Bakery Ovens 7/3/95 10/15/ 97 62 FR 53544 26.11.19.22 Control of VOC from Vinegar

Generators 8/11/97 9/23/ 99 64 FR 41445 26.11.19.24 Control of VOC Emissions from

Leather Coating 8/11/97 9/23/ 99 64 FR 41445 26.11.19.25 Control of VOC Emissions from

Explosives and Propellant Manufacturing 8/11/ 9 7 1/26/99 64 FR 3852
26.11.19.26 Control of VOC Emissions from

Reinforced Plastic Manufacturing 8/11/97 8/19/99 64 FR 45182 26.11.19.27 Control of VOC Emissions from

Marine Vessel Coating Operations 10/20/97 9/5/01 66 FR 46379 26.11.19.28 Control of VOC Emissions from

Bread and Snack Food Operations 10/2/00 5/7/2001 66 FR 22924 26.11.19.29 Control of VOC Emissions from

Distilled Spirits Facilities 10/2/00 10/15/01 11/7/2001 66 FR 56220 26.11.19.30 Control of VOC Emissions from

Chemical P roduction and Poly tetrafluoroethylene Installations 4/21/08 10 / 18 / 11 7 6 FR 64237
26.11.19.31 Control of VOC Emissions from

Medical Device Manufacturing 6/5/06 1/11/2007 72 FR 1289 26.11.24 Stage II Vapor Recovery at Gasoline Dispensing Facilities 4 /1 5 / 02 5 / 7 / 03 68 FR 24363

Table 3 lists Maryland ’s negative declaration for VOC CTG categories which no facilities exist in the state
.7

**Table 3 .**  **Documents for which no Applicable Facilities Exist in the State of Maryland Document Title**  Control of Volatile Organic Compound Emission from Air Oxidation Processes in Sy nthetic Organic Chemical Manufacturing Industry Control of Volatile Organic Compound Emission from Sy nthetic Organic Chemical Poly mer and Resin Manufacturing Equipment Control of Volatile Organic Compound Emissions from Manufacture of High

- Density Polyeth yl ene, Pol yprop yl ene, and Pol ys ty rene Resins Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires Control of Volatile Organic Compound L eaks from form Natural Gas/Gasoline Processing Plants Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations Control of Volatile Organic Compound L eaks from Petroleum Refinery Equipment Control of Refinery

Vacuum Producing S ys tems, Wastewater Separators, and Process Unit Turnaround Control of Volatile Organic Compound Emission from Reactor Processes and Distillation Operations in Sy

nthetic Organic Chemical Manufacturing Industry Control Techniques Guidelines for Shipbuilding and Ship Repair Operations Control of Volatile Organic Compound Emission from Existing Stationary Source s, Volume IV: Surface Coating of Insulation of Magnet Wire
**IV. N**  **O x**  **RACT Controls** T able 4 lists the NO x RACT Regulations under the 1997 8
- hour ozone NAAQS and includes the date the rule became affective in the state of Maryland and the Federal Register publication date and citation. **Table 4.**  **Maryland’s NO x**  **RACT Regulations Regulation**  **COMAR Existing Stationary Sources** 

**Title of Regulation State**  **Effective Date**  **Federal**

**Register Date**  **Citation**
26.11.09.08A&B Fuel

- Burning Equipment L ocated at

Major Sources

– General Requirements and Conditions 11/24/03 9/20/04 69 FR 56170
26.11.09.08C Fuel

- Burning Equipment with a Rated

Heat Input Capacity

of 250 million british thermal units per hour ( MMBtu/hr) or Greater 11/24/03 9/20/04 69 FR 56170

26.11.09.08D Fuel

- Burning Equipment with a Rated

Heat Input Capacity

of Less than 250MMBtu/hr and Greater than 100MMBtu/hr 11/24/03 9/20/04 69 FR 56170

26.11.09.08E Fuel Burning Equipment with an input

capacity of 100 MM B tu/hr or less 11/24/03 9/20/04 69 FR 56170 26.11.09.08F Space Heaters 11/24/03 9/20/04 69 FR 561708

26.11.09.08G (1) Fuel Burning Equipment with a

Capacity Factor of 15 % or Less 11/24/03 9/20/04 69 FR 56170 26.11.09.08G (2) Combustion Turbines with a Capacity

F actor Greater than 15 % 11/24/03 9/20/04 69 FR 56170 26.11.09.08H(3) Municipal Waste Combustors 11/24/03 9/20/04 69 FR 56170 26.11.09.08H(4) Hospital, Medical and Infectious

Waste Incinerators 11/24/03 9/20/04 69 FR 56170 26.11.09.08I(1) & (2) Glass M elting Furnaces 11/24/03 9/20/04 69 FR 56170 26.11.09.08J Industrial Furnaces and Other

Miscellaneous Installations the Cause Emissions of NO x 11/24/03 9/20/04 69 FR 56170
26.11.14.07 Kraft Pulp Mills 7/26/10 26.11.29.03 Portland Cement Manufacturing Plants 5/1/00 1/10/01 66 FR 1866 26.11.29.05B&C Stationary Internal Combustions Engines at Natural Gas Compression Stations 5/1/00 1/10/01 66 FR 1866

COMAR 26.11.09 .08
- Control of NO x Emissions for Major Stationary Sources are Maryland’s NO x RACT controls that were implemented and approved into the Maryland SIP under the 1

- hour ozone NAAQS. The NO x RACT anal ys e s for these eleven regulations are summarized below and the full anal ys is can be found on pages 28 through 48 of Maryland’s SIP submittal. COMAR 26.11.09.08 A & B
- Fuel

- Burning Equipment located at Major Sources identifies the major source cut

- offs and sets standards for the oil, gas and coal fired equipment. The standards are 0.020 pounds ( lbs ) NO x per million Btu for gas, 0.025 lbs NO x per million Btu for oil and 0.038 lbs NO x per million Btu for coal fired dry bottom equipment
. COMAR 26.11.09.08 C
- Fuel

- Burning Equipment with a Rated Heat Input Capacity of 250 MMBtu/hr or greater identifies standards for various coal

- fired , oil and gas/oil units at electric generating stations , and standard fuel burning equipment stacks at non

- electric generating facilities. RACT requirements for some coal fired units are superseded by the more restrictive standards under COMAR 26.11.27 (Healthy Air Act) which is beyond RACT
. Two of the dual

fueled units in Maryland are required, through consent orders, to operate on natural gas. COMAR 26.11.09.08 D
- Fuel

- Burning Equipment with a Rated Heat Input Capacity of Less than 250 MMBtu/hr an d Greater than 100 MMBtu/hr requires coal fired units to meet the standard of 0.65 lbs NO x per Million Btu. COMAR 26.11.09.08 E
- Fuel Burning Equipment with an input capacity of 100 MMBtu/hr or less r equires combustion analy sis and optimization of combustion each year. Equipment operators are required to maintain records for a period of two years. Equipment ope rators are also required to undergo training every three years
. COMAR 26.11.09.08 F
- Space Heaters regulation applies to space heater units registered with a facility under the major source category. Since s pace heaters are small sources of NO x emission s at9

major sources , no emissions limits are set in this regulation . However, app lication of best management practices is required and sources are required to i mplement an operating and maintenance plan to minimize NO x emissions, and attend operator traini ng once every 3 years and maintain a record of the training attendance. COMAR 26.11.09.08 G(1)

- Fuel Burning Equipment with a Capacity Factor of 15 % or Less , requires combustion analysis and optimization for NO x from fuel burning equipment operating greater than 500 hours during a calendar year
. COMAR 26.11.09.08 G(2)

- Combustion Turbines with a Capacity F actor Greater than 15 % , requires g as fired turbines to meet a NO x emission rate of 42 ppm , and oil fired turbines are required to meet an emission rate of 65 ppm or meet applicable Prevention of Significant Deterioration limits found in the permit to construct. COMAR 26.11.09.08 H(3)

– Control of NO x Emissions for Major Emissions for Major St ationary

Sources , Municipal Waste Combustors , references control required under COMAR 26.11.08.08. This regulation applies to existing large MWCs with a capacity greater than 250 tons per day . The current NO x standard for large MWC is 205 ppmv 24

- hr arithmetic average which is based on the maximum achievable control technology (MACT) determination for NO x in emission guidelines for MWC, 40 CFR 60 Subpart Cb, as revised, May 10, 2006 , or applicable PSD limits whichever is more restrictive . This standard can be achieved by combustion control and optimization. RACT for small MWCs are under 40 CFR 62 Subpart JJJ. COMAR 26.11.09.08 H(4)

– Control of NO x Emissions for Major Emissions for Major Stationary

Sources Hospital, Medical and Infectious Waste Incinerat ors (HMIWI ) , references control required under COMAR 26.11.08.08
- 1A(2)
. RACT for HMIWI is 250 ppm, 24 hour average which is also the c urrent MACT standard. COMAR 26.11.09.08 I(1 ) &(2)

- Glass M elting Furnaces , currently onl y one source in Maryland is sub

ject to this regulation. The source must perform daily oxygen tests and maintain excess oxygen at 4.5 % or less to assure compliance with this regulation. COMAR 26.11.09.08 J
- Industrial Furnaces and Other Miscellaneous Installations the Cause Emissions of NO x , requires that where possible the equipment be run on natural gas during ozone season, and it also requires good operating practices and operator training. COMAR 26 .11.14.07
- Kraft Pulp Mill is a NO x trading source that was recently adopted by Maryland , but has not been submitted to EPA. The emission limit for this regulation is 947 tons of NO x during ozone season (May 1

– September 30), and the emissions rate of . 99 pounds of NOx per million Btu during the remainder of the ye ar (October 1

– April 30). The annual trading of NO x allowances is limited to 95 tons of NO x . See pages 49 and 50 of Maryland’s SIP submittal for the full NO x RACT anal ys is. COMAR 26.11.2 9.03

– Portland Cement Manufacturing Plants requires cement kilns to install low NO x bur

ners or mid

- kiln firing. For lo ng, dry kilns the maximum emissions of 5.1 lbs per ton clinker is required and f or pre - heater and pre - calciner kilns the maximum emissions of 2.8 lbs per NO x per ton clinker is required
.10

COMAR 26.11.29.05 B & C
- Stationary Internal Combustions Engines at Natural Gas C ompression Stations . Sources subject to this regulation had two options for compliance: ( 1) o n or before May

1, 2003, meet the applicable NO x emission standard listed in Table 5 below; or ( 2) o n or before May

1, 2001, submit to Maryland for approval, a proposal to reduce NO x emissions less than 90 percent from the 1995 base year emissions.
**Tabl e 5**  **. Maryland’s Emission Standards for Stationary Internal Combustions**  **Engines at Natural Gas Compression Stations** Ty pe Engine Size (brake horsepower ( HP ) ) Standard (15 percent ox ygen) Spark ignited rich burn 2400 HP or greater 110 parts per million by volume (ppmv ) Spark ignited lean burn 2400 HP or greater 125 ppmv Diesel engines 3100 HP or greater 175 ppmv Dual fuel engines 4400 HP or greater 125 ppmv EPA has reviewed the NO x RACT anal ys es developed by Maryland and agrees that the anal ys es meet the RACT requirements for the 1997 8

- hour ozone standard.
**V. EPA**  **Evaluation** Maryland ’s SI P revision contains the requirements of RACT set forth by the CAA
. Maryland ’s SIP revision satisfies the 1997 8
- hour ozone NAAQS RACT requirements through (1) certification that previously a dopted RACT controls in Maryland’ s SIP that were approved by EPA under the 1
- hour ozone NAAQS are based on the currentl y available technicall y and economicall y feasible controls, and that they c ontinue to represent RACT for the 8
- hour implementation purposes; (2) a negative declaration demonstrating that no facilities exist in the state for the applicable CTG categories; and (3) adoption of new or more stringent RACT determinations. Therefore, this revision will help Maryland attain and maintain the NAAQS for ozone.
**V I**  **. Conclusion**  **and Recommended Agency Action** This SIP revision request satisfies all requirements for an acceptable SIP revision. EPA approval of Maryland ’s 1997 8
- hour Ozone RACT SIP revision is recommended
.