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 for the 1997 8-hour Ozone National Ambient Air Quality Standard

FROM: Jacqueline Lewis, Environmental Engineer /s/

Office of Air Program Planning (3AP30)

TO: State Implementation Plan (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 Ozone 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 

marginal. 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 Early Action Compact program. 

II. Background

Ozone is formed in the atmosphere by photochemical reactions between volatile organic 

compounds (VOC), oxides of nitrogen (NOx), 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/NOx emission sources to achieve emission 

reductions. Among effective control measures, RACT controls are a major group for reducing 

VOC and NOx 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 by the application of the control technology that is 

reasonably available considering technological and economic feasibility. See 72 FR 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 the 
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CAA, and referred to as RACT fix-up, requires the correction 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 catch-up set forth in section 182(b)(2) of 

the CAA, requires that moderate (or worse) 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 NOx emission sources and on all sources and source categories 

covered by a control technique guideline (CTG) issued by EPA.

All Maryland counties were 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 nonattainment areas. Kent and Queen Anne’s Counties 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 NOx SIP Call (40 CFR 51.121). 

A. RACT Fix-Up

The first RACT requirement for ozone nonattainment areas, contained in section 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 catch-up requirements. EPA proposed 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 Test Method 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 

final 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 for 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 sources covered by any 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 catch-up provisions of the section 182(b)(2) of the CAA. The Baltimore and 

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 (TPY) of VOC or more. In the 

remainder of the State, a major source was defined as a source having the potential to emit 50 

TPY of VOC or more. As mentioned above portions of Maryland’s June 8, 1993 and July 19, 
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1993 submittals address the RACT catch-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 catch-up provisions. 

This submittal contained amendments to the definition 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 “catch-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 by the VOC RACT regulation and 

submitted those enforceable RACT determinations to EPA as SIP revisions. That certification 

was to be made by Maryland no later than one year from the date 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 the 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 limitedly approved the Maryland major source VOC RACT 

regulation and minor source VOC regulations, COMAR 26.11.19.02G and COMAR 26.11.06.06 

respectively. On February 7, 1996, Maryland submitted a letter to EPA committing to: (1) 

complete submission of the SIP revisions 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 by EPA and a list of all major 

sources of VOC and NOx 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 status of COMAR 26.11.19.02G and COMAR 26.11.06.06 to full approval. See

63 FR 47174.
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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 section 111(d) 

plan in 40 CFR part 62 and not as a part 52 SIP revision. Thus this rule is federally enforceable, 

but under a different requirement of the CAA. However, in November 2008, EPA published a 

guidance document titled, “Guidance For Estimating VOC and NOx 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 the 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 determined that this rule approved under 40 

CFR part 62 also serves to satisfy the requirements under 40 CFR part 52. 

III. VOC RACT Controls

Most of Maryland’s Regulations and Statues, under COMAR 26.11.06, 26.11.10, 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 SIP under the 1-hour ozone NAAQS. However, 

COMAR 26.11.19.20 (“Control of Landfill Gas Emissions from Municipal Solid Waste 

Landfill”) which was approved by EPA on September 18,1999, contain the VOC RACT controls 

that were implemented and approved in Maryland’s SIP under section 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) are 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 requirements 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 Based 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 70667
5

Storage and Handling – Loading 

Operations

26.11.13.05 Control of Gasoline 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 Light 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, Vinyl, 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 Synthesized 

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 analysis 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 2. Maryland’s VOC RACT Controls Based on Maryland RACT Analysis

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

10/18/07 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 32415
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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 10/18/11 76 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 Polystyrene Operations

10/2/00 5/7/01 66 FR 22924

26.11.19.20 Control of Landfill 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

8/11/97 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 Production and 

Polytetrafluoroethylene Installations

4/21/08 10/18/11 76 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

4/15/02 5/7/03 68 FR 24363

Table 3 lists Maryland’s negative declaration for VOC CTG categories which no facilities exist 

in the state.
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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 Synthetic 

Organic Chemical Manufacturing Industry

Control of Volatile Organic Compound Emission from Synthetic Organic Chemical Polymer and 

Resin Manufacturing Equipment

Control of Volatile Organic Compound Emissions from Manufacture of High-Density

Polyethylene, Polypropylene, and Polystyrene Resins

Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires

Control of Volatile Organic Compound Leaks from form Natural Gas/Gasoline Processing Plants

Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations

Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment

Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit 

Turnaround

Control of Volatile Organic Compound Emission from Reactor Processes and Distillation 

Operations in Synthetic Organic Chemical Manufacturing Industry

Control Techniques Guidelines for Shipbuilding and Ship Repair Operations 

Control of Volatile Organic Compound Emission from Existing Stationary Sources, Volume IV: 

Surface Coating of Insulation of Magnet Wire

IV. NOx RACT Controls

Table 4 lists the NOx 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 NOx 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 Located 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 MMBtu/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 56170
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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 

Factor 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 Melting Furnaces 11/24/03 9/20/04 69 FR 56170

26.11.09.08J Industrial Furnaces and Other 

Miscellaneous Installations the Cause 

Emissions of NOx

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 NOx Emissions for Major Stationary Sources are 

Maryland’s NOx RACT controls that were implemented and approved into the Maryland SIP 

under the 1-hour ozone NAAQS. The NOx RACT analyses for these eleven regulations are 

summarized below and the full analysis 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) NOx per million Btu for gas, 0.025 lbs NOx per million Btu 

for oil and 0.038 lbs NOx 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 dualfueled 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 and Greater than 100 MMBtu/hr requires coal fired units to meet the 

standard of 0.65 lbs NOx per Million Btu. 

COMAR 26.11.09.08 E - Fuel Burning Equipment with an input capacity of 100 MMBtu/hr 

or less requires combustion analysis and optimization of combustion each year. Equipment 

operators are required to maintain records for a period of two years. Equipment operators 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 space heaters are small sources of NOx emissions at 
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major sources, no emissions limits are set in this regulation. However, application of best 

management practices is required and sources are required to implement an operating and 

maintenance plan to minimize NOx emissions, and attend operator training 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 NOx 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 Factor Greater than 15 %, 

requires gas fired turbines to meet a NOx 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 NOx Emissions for Major Emissions for Major 

Stationary 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 NOx standard for large MWC is 205 ppmv 24-hr arithmetic average

which is based on the maximum achievable control technology (MACT) determination for NOx 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 NOx Emissions for Major Emissions for Major 

Stationary Sources Hospital, Medical and Infectious Waste Incinerators (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 current MACT standard.

COMAR 26.11.09.08 I(1) &(2) - Glass Melting Furnaces, currently only one source in 

Maryland is subject 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 NOx, 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 NOx 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 NOx during ozone season (May 1 – September 30), and the emissions rate of .99 

pounds of NOx per million Btu during the remainder of the year (October 1 – April 30). The 

annual trading of NOx allowances is limited to 95 tons of NOx. See pages 49 and 50 of 

Maryland’s SIP submittal for the full NOx RACT analysis. 

COMAR 26.11.29.03 – Portland Cement Manufacturing Plants requires cement kilns to 

install low NOx burners or mid-kiln firing. For long, dry kilns the maximum emissions of 5.1 

lbs per ton clinker is required and for pre-heater and pre-calciner kilns the maximum 

emissions of 2.8 lbs per NOx per ton clinker is required.
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COMAR 26.11.29.05 B & C- Stationary Internal Combustions Engines at Natural Gas 

Compression Stations. Sources subject to this regulation had two options for compliance: (1) 

on or before May 1, 2003, meet the applicable NOx emission standard listed in Table 5 below; 

or (2) on or before May 1, 2001, submit to Maryland for approval, a proposal to reduce NOx

emissions less than 90 percent from the 1995 base year emissions. 

Table 5. Maryland’s Emission Standards for Stationary Internal Combustions 

Engines at Natural Gas Compression Stations

Type Engine Size (brake horsepower 

(HP)) Standard (15 percent oxygen) 

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 NOx RACT analyses developed by Maryland and agrees that the 

analyses meet the RACT requirements for the 1997 8-hour ozone standard.

V. EPA Evaluation

Maryland’s SIP 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 adopted RACT controls in Maryland’s SIP that were approved by

EPA under the 1-hour ozone NAAQS are based on the currently available technically and 

economically feasible controls, and that they continue 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.

VI. 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.