**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103** 
**- 2029** 

**DATE:** February

12, 2013

**SUBJECT:** Technical Support Document for the Allegheny County , Pennsylvania Reasonably Available Control Technolo gy Under the 8

- hour Ozone National Ambient Air Quality Standard **FROM:** Melissa L inden , Li fe Scientist

Office of Air Program Planning (3AP30 ) **TO:**

**REVIEWED BY:**  SI P Docket File

**/s/** Cristina Fernandez, Associate Director Office of Air Program Planning (3AP30 )

**I .**  **Affected Regulation** Th e revision to the Allegheny County section of the Pennsylvania State Implementation Plan (SI P) , submitted on May

5 , 2009 , applies to the demonstration that the area meets the requirements of reasonably

available control technology (RACT) for nitrogen oxides (NOx) and volatile organic compounds (VOCs) set forth by the Clean Air Act (CAA) for the 1997 8

- H our Ozone National Ambient Air Quality

Standard (NAAQS)

. **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. Inorder to reduce ozone concentrations in the ambient air, the CAA requ ires 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 h as 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, Ap ril 25, 2007

. Section 182 of the CAA sets forth two separate RACT requirements for ozone nonattainmentarea s . The first requirement, contained in section 182(a)(2)(A) of the CAA, and referred to as RACT

fix

- up, requires the correction of RAC T rules for which the Environmental Protection Agency (EPA) identified deficiencies before the CAA was amended in 1990. The second requirement, 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 ozone transport regions (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 guid eline (CTG) issued by EPA.
The first RACT requirement for ozone nonattainment areas, contained in section 182(a) (2)(A) of the CAA, required Allegheny County to submit a SI P revision correcting RACT rules prior to the CAA amendment in 1990. The second RACT requirement for ozone nonattainment areas, set forth in section 182(b)(2) of the CAA, requires the Commonwealth of Pennsylvania 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. On July 18, 1997 (62 FR 38856) , EPA promulgated the new 8

- hour NAAQS for ozone . Under the 8

- hour ozon e NAAQS, Allegheny County was designated nonattainment for the 8

- h our ozone standard and is required to submit to EPA a SI P revision that demonstrates how the County meets the RACT requirements under the 8

- hour ozone standard. EPA requires under the 8

- h our ozone NAAQS that states meet the CAA RACT requirements, either through a certification that previously adopted RACT controls in their SI P approved by EPA under the 1

- hour ozone NAAQS represent adequate RACT control levels for 8

- hour attainment purposes , or through the adoption of new or more stringent regulations that represent RACT control levels. See , Final Rule To Implement the 8

-Hour Ozone National Ambient Air Quality Standard

-- Phase 2; Final Rule To Implement Certain Aspects of the 1990 Amendments Relating to New Source Review and Prevention of Significant Deterioration as They Apply in Carbon Monoxide, Particulate Matter and Ozone NAAQS; Final Rule for Reformulated Gasoline (Phase 2 Rule) 70 FR 7161 2, 71655, November 29, 2005. Sections 172(c)(1) and 182(b)(2) of the CAA require that all SI Ps satisfy the NOx and VOCs RACT requirements that apply in areas that have not attained the NAAQS for ozone. See , 42 U.S.C. 7502(c)(1), 42 U.S.C. 7511a(b)(2), and 42 U.S.C. 7511a(f). EPA has determined that St ates that have RACT provisions approved in their SI Ps for 1

- hour ozone nonattainment areas have several options for fulfilling the RACT requirements for the 8

- hour ozone NAAQS. I f a State meets certain conditions, it may certify that previously

adopted 1

- hour ozone RACT controls in the SI P continue to represent RACT control levels for purposes of fulfilling 8

- hour ozone RACT requirements. Alternatively , a State may adopt new or more stringent regulations that represent RACT control levels, either in lieu of or in conjunction with a certification. As set forth in the preamble to the Phase 2 Rule, a certification must be accompanied by appropriate supporting information such as consideration of information received during the public comment period and con s ideration of new data (70 FR 71655). This information may supplement existing RACT guidance documents that were developed for the 1

- hour standard, such that the State’s SI P accurately

reflects RACT for the 8

- hour ozone standard based on the current avail ability of technically

and economically

feasible controls. Adoption of new RACT regulations will occur when states have new stationary sources not covered by

existing RACT regulations, or when new data or technical information indicates that a previously adopted RACT measure does not represent a newlyavailable RACT control level. Another 8

- hour ozone NAAQS requirement for RACT is to submit a

negative declaration if there are no CTG major sources of VOC and NOx emissions in lieu of or in addition to a cer

tification. **A. VOC CTG RACT Controls**  Allegheny

County ’s Regulations codified at Article XXI , contain the County ’s CTG VOC RACT controls that were implemented and approved in the Allegheny County SI P under the 1

- hour ozone NAAQS. Table 1 lists Allegheny Coun ty ’s VOC RACT controls for which Allegheny County has provided the required evaluation and is certify ing as meeting the 8

- hour ozone NAAQS RACT requirements. Revisions to the CTG VOC RACT regulations were made after the May 6, 2009 submittal and were appr oved by EPA on December 28, 2010 (75 FR 81480) and supersede the current action being taken by

EPA.

**Table 1 .**  **Allegheny County’s CTG VOC RACT Controls Article XXI**  **Section Existing Stationary Sources** 

**– 40 CFR 52.2020 (c)** 

**CTG for RACT Basis State**  **Effec tive**  **Date Federal Register** 

**Date for SIP Approval**  **Citation**

2105.10 VOC Sources Surface Coating Processes Control of Volatile Organic

Emissions from Existing Stationary

Sources, Volume II: Surfact Coating of Cans, Coils, Paper, Fabrics, Automobiles, and L ig ht

Duty Trucks Control of Volatile Organic Emissions from Existing Stationary

Sources, Volume III: Surface Coating of Metal Furniture Control of Volatile Organic Emissions from Existing Stationary

Sources, Volume IV : Surface Coating for In sulation of Mag net Wire Control of Volatile Organic Emissions from Existing Stationary

Sources, Volume V: Surface Coating of Large Appliances Control of Volatile Organic Emissions from Existing 10/20/1995

07/10/03 11/14/2002

06/24/2005 67 FR 68935

70 FR 36511Stationary Sources, Volume VI : Surface Coating of Miscellaneous Metal Parts and Products 2105.11 VOC Sources Graphic Arts Sy stems Control of Volatile Organic

Emissions from Existing Stationary

Sources, Volume VI II: Graphic Arts

– Rotogravure and Flexography 10/20/1995 11/14/2002 67 FR 68935

2105.12 VOC Sources VOC Storage Tanks Control of Volatile Organic

Emissions from Petroleum Li quid Storage in External Floating Roof Tanks 10/20/1995 11/14/2002 67 FR 68935

2105.13 Gasoline Lo ading Facilities Control of Volatile Organic

Emissions from Bulk Gasoline Plants Design Criteria for Stage I Vapor Control Sy stems

– Gasoline Service Stations 10/20/1995 11/14/200 2 67 FR 68935

2105.15 Degreasing Operations Control of Volatile Organic

Emissions from Solvent Metal C leaning 10/20/1995 11/14/2002 67 FR 68935

2105.16 Cutback Asphalt Paving Control of Volatile Organic

Compounds from Use of Cutback Asphalt 10/20/1995 11/14/2002 67 FR 68935

2105.17 Ethylene Production Facilities 10/20/1995 11/14/2002 67 FR 68935

2105. 19 Sy nthetic Organic Chemical and Poly mer Manufacturing

– Fugitive Emissions Control of Volatile Organic

Compound Fugitive Emissions from Sy

nthetic Organic Chemical Poly

mer and Resin Manufacturing Equipment 10/20/1995 11/14/2002 67 FR 68935

2105.70 Petrol eum Refineries 10/20/1995 11/14/2002 67 FR 68935

2105.71 Pharmaceutical Products Control of Volatile Organic

Emissions from Manufacture of Sy

nthesized Pharmaceutical Products 10/20/1995 11/14/2002 67 FR 68935

2105.72 Manufacture of Control of Volatile Organic

Emissions from 10/20/1995 11/14/2002 67 FR 68935Pneumatic

Rubber Tire s Manufacture of Pneumatic

Rubber Tires 2105.74 Aerospace Manufacturing and Rework Aerospace 07/10/2003 06/24/2005 70 FR 36511

2105.75 Mobile Equipment Repair and Refinishing AC T: Automobile Body

refinishing 07/10/2003 06/24/2005 70 FR 36511

2105.76 Wood Furniture Manufacturing Operations Wood Furniture 07/10/2003 06/24/2005 70 FR 36511

Although alternative control technology ( ACTs ) are not regulatory documents and have no le gal effect on state regulations, EPA requires that states verify that ACTs have been considered in the RACT program development process. Therefore, Allegheny County included ACTs in their review of applicable RACT requirements in this submittal. Alleghe ny

County also submitted a negative declaration certifying that the following VOC CTG major sources do not exist in the county and therefore there is no need to adopt CTGs for these sources. Table 2 lists VOC CTG major sources in Allegheny County ’s negati ve declarat ion. A separate submittal was made by Allegheny

County submitting the negative declaration for Volatile Organic Emissions from L arge Petroleum Dry Cleaners on January

8, 2009.

**Table 2. VOC CTG sources for which no Applicable Facilities Exist**  **in Allegheny County** Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners Control of Volatile Organic Emissions from Existing Stationary Sources, Volume I I: Factory Surface Coating of Flat Wood Paneling Control of Volatile O rganic Compound Equipment L eaks from Natural Gas/Gasoline Processing Plants Processing Plants Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Sy nthetic Organic Chemical Manufacturing Industry Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations Processes in the Sy nthetic Organic Chemical Manufacturing Industry Shipbuilding/ R epair

**B. Source**
**- S**  **pecific RACT Controls Table 3**  **. Source** 
**- S**  **pecific RACT Controls Facility Name**  **State Effective**  **Date Pollutant**  **Federal Register**  **Date Citation** 
Allegheny

Ludlum Corporation 12/19/1996 NOx/VOC 10/18/2001 66 FR 52857 Ashland Specialty Chemical Co. 12/30/1996 NOx/VOC 10/16/2001 66 FR 52506 Bay Valley Foods 06/09/2005 NOx 05/11/2006 71 FR 273 94

Bellefield Boiler Plant 12/19/1996 NOx 10/12/2001 66 FR 52044

Eastman Chemical Resins, In c. 11/01/1999 NOx/VOC 10/16/2001 66 FR 52506 GE Lighting LLC 12/19/1996 NOx 10/16/2001 66 FR 52527 Guardian Industries Corp. 08/27/1996 NOx 10/16/2001 66 FR 525 27 Koppers Industries, Inc. 08/27/1996 VOC 10/17/2001 66 FR 52700 Neville Chemical Co. 12/13/1996 NOx/VOC 10/16/2001 66 FR 52506 NRG Energy

Center 06/09/2005 NOx 05/11/2006 71 FR 27394 Orion Power Brunot I sland 08/27/1996 NOx/VOC 10/15/2001 66 FR 52327 Orion Power Cheswick 03/08/1996 NOx 10/18/2001 66 FR 52867 PACT

– Pennsylvania Allegheny

County Thermal 03/04/1996 NOx 10/12/2001 66 FR 52044 Port Glenshaw Glass, L LC 03/10/2000 NOx/VOC 10/16/2001 66 FR 52527 PPG Industries, Inc Springdale 12/19/1996 VOC 10/12/2001 66 FR 52050 Pressure Chemical Company 06/11/1997 VOC 10/17/2001 66 FR 52700 Shenango Inc. 12/30/1996 NOx/VOC 10/16/2001 66 FR 52511 US Steel Clairton 12/30/1996 NOx/VOC 10/16/2001 66 FR 52511 US Steel Edgar Thomas 12/30/1996 NOx/VOC 10/ 16/2001 66 FR 52511 US Steel Irvin 12/30/1996 NOx/VOC 10/16/2001 66 FR 52511The sources in Table 3, required a re - evaluation of the 1

- hour RACT determinations for 8

- hour

RACT and EPA’s summary of those is provided below. **Allegheny Ludlum** The facili ty

is a major source for VOC and NOx. The only change at the facility

affecting VOC and NOx emissions was the replacement of four electric arc furnaces by two larger capacity electric arc furnaces. The 1

- hour RACT determination was good engineering and air pollution control practices for electric arc furnaces and that remains the determination for 8

- hour RACT because the selective non

- cataly tic reduction (SNCR) and selective cataly tic reduction (SCR) have not been applied to control NOx emission from an ele ctric arc furnace before. For VOC emission the cataly

tic oxidizer is technically infeasible and the thermal oxidizer is economically infeasible. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **As hland Inc.**  The facility

shut down the Maleic Anhydride Plant in 2006 and with the facility closure the potential

- to
- emit (PTE) for VOCs is below the threshold for a major source. Ashland also agree d in the Title V process to limit the fuel use in two boi lers as well as a facility

- wide limit of 98 tons per y ear (tpy

) of NOx, which makes it a sy nthetic minor source. **Bay Valley Foods** This facility

is a NOx RACT source. Allegheny County evaluated flue gas recirculation (FGR), combustion optimization which is already being done on all boilers, ultra

- low nitrogen fuels, SCR, SNCR, and f

uel switching for NOx controls. Itwas determined that all of these control options were either economically or technically

infeasible for this facility . For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Bellefield Boiler Plant** This facility

is a major source for NOx. The plant has 6 boilers which fire coal, natural gas, No.2 fuel oil or combinations of fuels. Alle gheny County evaluated SNCR, SCR, wet scrubbing, gas

- fired combustors/L ow NOx Burners/FGR, fuel switching and natural gas only . I t was determined that all of control options were either economically or technically

infeasible for this facility . For detail s of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Eastman Chemical Resins, Inc.** This facility

is a major source for VOC. It was determined for the poly merization processes, resin hydrogenation process, fi ve finishing processes and an emulsion process that there were no additional controls that were not cost prohibitive. For storage tanks in the facility about 40 are subject to section 2105.12 Article XXI , “VOC Storage Tanks” and the rest have been determi ned to have no additional control options that were reasonable for RACT. It would be cost prohibitive to install covers and a refrigerated condenser sy stem on the wastewater treatment plant so RACT is still proper operation and maintenance. For details o f this evaluation please see Allegheny

County ’s supplemental information dated March 9, 2012. **General Electric (GE) Lighting** This facility

is a major source for NOx. RACT for the glass melting furnaces are in Table 4 below. RACT for the miscellaneous combustion units shall be installation, maintenance, andoperation of the sources in accordance with manufacturer’s specifications at all times. For details

of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Ta ble 4.**  **Glass M**  **elting F**  **urnaces at GE with C**  **ontrols being U**  **tilized. NOx Emission Unit**  **Baseline Level of NOx Control** F2

- 8 Simplex Furnace Oxy

- firing Lo w Excess Air Electric Boost Use of Cullet in Batches Adherence to Manufacturer’s Specifications F3

- 4 Gas/Electric Furnace Oxy

- firing Lo w Excess Air Electric Boost Use of Cullet in Batches Adherence to Manufacturer’s Specifications F4

- 3 Frit Furnace Adherence to Manufacturer’s Specifications F6

- 3 Germicidal Furnace Lo w Excess Air Adher ence to Manufacturer’s Specifications F7

- 4 Special Furnace Oxy

- firing Lo w Excess Air Electric Boost Use of Cullet in Batches Adherence to Manufacturer’s Specifications F8

- 6 180 Furnace Lo w Excess Air Oxygen Enrichment Use of Cullet in Batches Adherence to Manufacturer’s Specifications **Guardian Industries Corporation** This facility

is a major source of NOx and the facility is already

utilizing all technically feasible control options and techniques for the melting furnace as listed in the T able 5 below. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Table 5. Glass**  **M elting**  **F urnace at Guardian Industries and**  **C ontrols being**  **U tilized.**  **NOx Emission Unit Baseline Level of NOx Control**  S001: Melting Furnace Oxy

- firing Lo w - NOx burners Minimize excess air Electric boost Maximize cullet in batches Minimize nitrates in batchesMinimize furnace temperatures Adherence to Manufacturer’s Specifications **Koppers ,**  **Inc.** This facility is a major source for VOC. Allegheny County evaluated thermal oxidation, cataly tic oxidation, flaring, carbon adsorption, condens ation, scrubbing, and submerged fill as control options and determined that no control options were both technically and econo mically feasible. RACT for 8

- hour ozone NAAQS is to extend the leak detection and repair program to equipment that was not subject under 1

- hour ozone RACT and for the product loading to be done in a submerged fill pipe. For details of this evaluation ple ase see Allegheny County ’s supplemental information dated March 9, 2012. **Neville Chemical Company** This facility

is a major source of NOx and VOC. For NOx the facility boilers are subject to presumptive RACT which is in Article XXI , section 2105.06(d)(2) . For VOC Allegheny County evaluated thermal oxidation, concentrator/oxidation, cataly tic oxidation, flaring, carbon adsorption, condensation and absorption as technically feasible options. None of the VOC controls were determined to be economically feas ible, so RACT will be the same as 1

- hour requirements. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **NRG Energy Center** This facility

is a major source of NOx and four boilers and three generat ors. The 8

- hour RACT will keep the same limits for boilers 1

- 3 and add boiler 4 and the emergency generators because they

were installed after 1

- hour RACT determinations were made. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Orion Power MidWest, L.P.** This facility

is a major source of NOx and VOC. Allegheny County has determined that no NOx controls are technically or economically

feasible for the three turbines using the ACT document for c ombustion turbines. Allegheny County has also determined that no add

- on VOC controls would be cost effective for the turbines due to the low maximum potential of VOC emissions for those turbines. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Cheswick Power Station** This facility

is a major source of NOx. Since the 1

- hour RACT determination was made the facility ’s emissions are regulated during the ozone season by Pennsylvania Nitrogen Oxide Al lowance Program in permit # 02

- 0054 and SCR was installed to run during the ozone season for the main boiler. The auxiliary boiler will have a 12

- month rolling limit on British thermal units (Btu) input of 438,000 MMBtu. For details of this evaluation pl ease see Allegheny County ’s supplemental information dated March 9, 2012. **Pittsburgh Allegheny County Thermal, Ltd.** This facility

is a major source for NOx. The facility has four boilers that burn natural gas as their primary

fuel source and can burn N o. 2 fuel oil in emergency situations. I t wasdetermined that no additional NOx controls were both technically and economically

feasible. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Glenshaw Glass**  This facility

was damaged in a flood and shutdown on November 24, 2004. In the process of restarting the facility , the furnace that was repaired ceased operating again to apply for emission reduction credits, thus triggering it to be subject as a new source and completing best available control technology (BACT) review. The operating furnace has installed BACT and the remaining furnaces are currently deactivated and will require BACT if they are reactivated. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **PPG Industries, Inc.** The facility

is a major source of VOC. The 1

- hour RACT determination included conditions for the resin plant, which is no longer in operation. The emissions from the Paint Plant and Development Center are currently vented to the thermal oxidizer, which has a demonstrated destruction efficiency of 94.5%. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Pres sure Chemical Company**  This facility

is a major source of VOC. Allegheny County evaluated the use of regenerative thermal oxidizer, thermal incinerator, and cataly tic incinerator as VOC control technologies and determined that although they were technical ly

feasible they

are not economically

feasible. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **Shenango Incorporated** This facility

is a major source of VOC and NOx. The facility replaced four boilers with more efficient Low NOx Burner boilers since the 1

- hour RACT determination. The facility went through BACT determination of using Low NOx Burner and FGR on the four new boilers with heat input capacity

limit of 265.2 MMBtu/hour. Nitrogen blanketing sy stem has been installed on the majority

of VOC sources associated with the by

- product plant. For all other sources proper combustion technology /design, operation and maintenance of all other emission units according to good engineering and air po llution control practices at all times is considered RACT for NO x and VOC. For details of this evaluation please see Allegheny County ’s supplemental information dated March 9, 2012. **U.S. Steel Clairton Works** This facility

is a major source of VOC and NO x. I t was determined that no additional VOC or NOx control equipment was technically and economically

feasible for this facility bey ond the 1

- hour RACT determination. For details of this evaluation please see Allegheny County ’s supplemental information d ated March 9, 2012. **U.S. Steel Edgar Thomson Works** This facility

is a major source of VOC and NOx. I t was determined that no additional VOC or NOx control equipment was technically and economically

feasible for this facility bey ond the 1

- hour RACT deter mination. For details of this evaluation please see AlleghenyCounty ’s supplemental information dated March 9, 2012.

**III. Evaluation**  Allegheny

County ’s SI P revision contains the requirements of RACT set forth by the CAA under the 8

- hour ozone NA AQS. Allegheny County ’s SI P revision satisfies the 8

- hour RACT requirements through (1) certifications that previously adopted RACT controls in Allegheny County ’s SI P that were approved by

EPA under the 1

- hour ozone NAAQS are based on the currently availa ble technically and economically

feasible controls, and continues to represent RACT for the 8

- hour implementation purposes; (2) a negative declaration demonstrating that no facilities exist in th e area for the applicable CTG categories; and (3) a new RACT determination for a single source. Therefore, approval of Allegheny

County ’s 8

- hour RACT SI P is recommended.

**IV. Conclusion**  This SI P revision request satisfies all requirements for an acceptable SI P revision.

**V. Recommended Agency Action**  T he SI P revision request should be approved

.