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 Technology 

Under the 8-hour Ozone National Ambient Air Quality

Standard

FROM: Melissa Linden, Life Scientist 

Office of Air Program Planning (3AP30)

TO:

REVIEWED 

BY:

SIP Docket File

 /s/ 

Cristina Fernandez, Associate Director 

Office of Air Program Planning (3AP30)

I. Affected Regulation

The revision to the Allegheny County section of the Pennsylvania State Implementation Plan

(SIP), 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-Hour 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. 

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 ozone nonattainment 
areas. The first requirement, contained in section 182(a)(2)(A) of the 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, 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 guideline (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 SIP 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 ozone NAAQS, Allegheny County was designated nonattainment for the 8-hour ozone 

standard and is required to submit to EPA a SIP revision that demonstrates how the County meets the 

RACT requirements under the 8-hour ozone standard. 

EPA requires under the 8-hour ozone NAAQS that states meet the CAA RACT requirements, 

either through a certification that previously adopted RACT controls in their SIP 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 71612, 

71655, November 29, 2005. Sections 172(c)(1) and 182(b)(2) of the CAA require that all SIPs 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 States that have RACT provisions approved in their SIPs for 1-hour ozone 

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

NAAQS. If a State meets certain conditions, it may certify that previously adopted 1-hour ozone 

RACT controls in the SIP 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 consideration 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 

SIP accurately reflects RACT for the 8-hour ozone standard based on the current availability 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 newly
available 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 certification.

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 SIP under the 1-hour ozone 

NAAQS. Table 1 lists Allegheny County’s VOC RACT controls for which Allegheny County has 

provided the required evaluation and is certifying 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 approved 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 

Effective 

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 LightDuty 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 

Insulation of Magnet 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 36511
Stationary Sources, Volume 

VI: Surface Coating of 

Miscellaneous Metal Parts

and Products

2105.11 VOC 

Sources 

Graphic Arts 

Systems

Control of Volatile Organic 

Emissions from Existing 

Stationary Sources, Volume 

VIII: 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 

Liquid Storage in External 

Floating Roof Tanks

10/20/1995 11/14/2002 67 FR 68935

2105.13

Gasoline 

Loading 

Facilities 

Control of Volatile Organic 

Emissions from Bulk 

Gasoline Plants

Design Criteria for Stage I

Vapor Control Systems –

Gasoline Service Stations

10/20/1995 11/14/2002 67 FR 68935

2105.15 

Degreasing 

Operations 

Control of Volatile Organic 

Emissions from Solvent 

Metal Cleaning

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 

Synthetic 

Organic 

Chemical and 

Polymer 

Manufacturing 

– Fugitive 

Emissions

Control of Volatile Organic 

Compound Fugitive 

Emissions from Synthetic 

Organic Chemical Polymer 

and Resin Manufacturing 

Equipment

10/20/1995 11/14/2002 67 FR 68935

2105.70 

Petroleum 

Refineries

10/20/1995 11/14/2002 67 FR 68935

2105.71 

Pharmaceutical 

Products

Control of Volatile Organic 

Emissions from 

Manufacture of Synthesized 

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 68935
Pneumatic 

Rubber Tires

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

ACT: 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 legal 

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.

Allegheny 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 negative declaration. A 

separate submittal was made by Allegheny County submitting the negative declaration for Volatile 

Organic Emissions from Large 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 II: Factory

Surface Coating of Flat Wood Paneling

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

Plants 

Processing Plants 

Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic 

Organic Chemical Manufacturing Industry

Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation 

Operations Processes in the Synthetic Organic Chemical Manufacturing Industry

Shipbuilding/Repair 

B. Source-Specific RACT Controls

Table 3. Source-Specific 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 27394

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

Eastman Chemical Resins, 

Inc.

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 52527

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 Island 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, LLC 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 52511
The 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 facility 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-catalytic reduction (SNCR) and selective catalytic reduction (SCR) 

have not been applied to control NOx emission from an electric arc furnace before. For VOC 

emission the catalytic 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. 

Ashland 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 

agreed in the Title V process to limit the fuel use in two boilers as well as a facility-wide limit of 

98 tons per year (tpy) of NOx, which makes it a synthetic 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 fuel switching for NOx controls. It was 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. Allegheny County evaluated SNCR, SCR, wet 

scrubbing, gas-fired combustors/Low NOx Burners/FGR, fuel switching and natural gas only. It 

was determined that all of 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. 

Eastman Chemical Resins, Inc. 

This facility is a major source for VOC. It was determined for the polymerization 

processes, resin hydrogenation process, five 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 determined to have no additional control options that were reasonable for RACT. It would 

be cost prohibitive to install covers and a refrigerated condenser system on the wastewater 

treatment plant so RACT is still proper operation and maintenance. For details of 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, and 
operation 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.

Table 4. Glass Melting Furnaces at GE with Controls being Utilized. 

NOx Emission Unit Baseline Level of NOx Control 

F2-8 

Simplex Furnace 

Oxy-firing 

Low Excess Air 

Electric Boost 

Use of Cullet in Batches 

Adherence to Manufacturer’s 

Specifications 

F3-4 

Gas/Electric Furnace 

Oxy-firing 

Low 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 

Low Excess Air 

Adherence to Manufacturer’s 

Specifications 

F7-4 

Special Furnace 

Oxy-firing 

Low Excess Air 

Electric Boost 

Use of Cullet in Batches 

Adherence to Manufacturer’s 

Specifications 

F8-6 

180 Furnace 

Low 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 Table 5 below. 

For details of this evaluation please see Allegheny County’s supplemental information dated 

March 9, 2012.

Table 5. Glass Melting Furnace at Guardian Industries and Controls being Utilized.

NOx Emission Unit Baseline Level of NOx Control 

S001: Melting Furnace Oxy-firing 

Low-NOx burners 

Minimize excess air 

Electric boost 

Maximize cullet in batches 

Minimize nitrates in batches 
Minimize furnace temperatures 

Adherence to Manufacturer’s 

Specifications 

Koppers, Inc. 

This facility is a major source for VOC. Allegheny County evaluated thermal oxidation, 

catalytic oxidation, flaring, carbon adsorption, condensation, scrubbing, and submerged fill as 

control options and determined that no control options were both technically and economically

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 please 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, catalytic oxidation, flaring, carbon 

adsorption, condensation and absorption as technically feasible options. None of the VOC 

controls were determined to be economically feasible, 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 generators. 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 combustion 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 

Allowance 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 please 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 No. 2 fuel oil in emergency situations. It was 
determined 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.

Pressure Chemical Company

This facility is a major source of VOC. Allegheny County evaluated the use of 

regenerative thermal oxidizer, thermal incinerator, and catalytic incinerator as VOC control 

technologies and determined that although they were technically 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 system 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 pollution control practices at all times is considered RACT 

for NOx 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 NOx. It was determined that no additional 

VOC or NOx control equipment was technically and economically feasible for this facility

beyond the 1-hour RACT determination. For details of this evaluation please see Allegheny

County’s supplemental information dated March 9, 2012.

U.S. Steel Edgar Thomson Works

This facility is a major source of VOC and NOx. It was determined that no additional 

VOC or NOx control equipment was technically and economically feasible for this facility

beyond the 1-hour RACT determination. For details of this evaluation please see Allegheny
County’s supplemental information dated March 9, 2012.

III. Evaluation

Allegheny County’s SIP revision contains the requirements of RACT set forth by the CAA under the 

8-hour ozone NAAQS. Allegheny County’s SIP revision satisfies the 8-hour RACT requirements 

through (1) certifications that previously adopted RACT controls in Allegheny County’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 continues to represent RACT for the 8-hour implementation 

purposes; (2) a negative declaration demonstrating that no facilities exist in the 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 SIP is recommended.

IV. Conclusion

This SIP revision request satisfies all requirements for an acceptable SIP revision.

V. Recommended Agency Action

The SIP revision request should be approved.