### Technical Support Document

**for New Jersey’s Regional Haze State Implementation Plan**

**Air Programs Branch, EPA Region 2**

**July 2011**
**INTRODUCTION Three Technical Support Documents**  Technical Support Documents (TSD) describe EPA’s supporting documentation for its proposed approval of New Jersey ’s Regional Haze State Implementation Plan (SIP), and provide m ore detailed evaluations of the SIP submitted by New Jersey
. In addition, EPA should propose approval of New Jersey ’s sulfur in fuel regulation, which, by re ducing sulfur emissions, has the multiple purpose of improving visibility and reducing particulate matter. There are three Technical Support Documents that evaluate New Jersey ’s Regional Haze SIP. First, this document evaluates the approvability of th e SIP overall, focusing on the reasonable progress portion of the SIP. A second document , attached, evaluates New Jersey ’s application of Best Available Retrofit Technologies. A third document , also attached, evaluates New Jersey ’s development and use of emission inventories. **Overview of New Jersey’s State Implementation Plan** New Jersey ’s SIP includes emission controls measures that will reduce pollutants that impair the view at certain National Parks and wilderness areas, particularl y the Brigantine Wi lderness Area of the Edwin B. Fors ythe National Wildlife Refuge, located in coastal New Jersey
. New Jersey adopted some of these controls specificall y as part of its Regional Haze SIP. There are other controls listed in the SIP that were recently adopted (separatel y from this SIP) or were alread y existing; those also reduce haze. This portion of the TSD evaluates how well those emission measures reduce impairments to visibility at Brigantine and other areas. Additional documents evaluate the emission inventories New Jersey used and the emission controls on sources eligible for control using Best Available Retrofit Technologies (BART)
. **Material Submitted by New Jersey** New Jersey ’s Department of Environmental Protection (DEP) p repared the Regional Haze SIP, which the Commissioner submitted for the State of New Jersey . The main submittal was on July 28, 2009, containing the main document and Appendices A through O. The submittal was automatically

declared complete six months after New Jersey ’s submittal date . New Jersey submitted additional information about BART sources on March 2, 2011 ; and its sulfur in fuel rule was adopted on September 20, 2010 and submitted to EPA on December 9, 2010.2

**Background Information on the Nature of Regional Haze**  Region al haze is visibility impairment that is produced by a multitude of sources and activities which are located across a broad geographic area and emit fine particles (PM 2.5 ) (e.g., sulfates, nitrates, organic carbon, elemental carbon, and soil dust) and thei r precursors (e.g., sulfur oxide s (SO x ), nitrogen oxides (NO x ), and in some cases, ammonia (NH 3 ) and volatile organic compounds (VOC)). Fine particle precursors react in the atmosphere to form fine particulate matter which impairs visibility by scattering and absorbing light. Visibility impairment reduces the clarit y, color, and visible distance that one can see. PM 2.5 can also cause serious health effects and mortalit y in humans and contributes to environmental effects such as acid deposition and eutrop hication. The average visual range 1 in many Class I areas (i.e., national parks and memorial parks, wilderness areas, and international parks meeting certain size criteria) in the eastern United States, is less than 30 kilometers or about one

- fifth of th e visual range that would exist under estimated natural conditions (64 FR 35714, July 1, 1999). In section 169A of the 1977 Amendments to the Clean Air Act (CAA), Congress created a program for protecting visibility in the nation’s national parks and wild erness areas. This section of the CAA establishes as a national goal the “prevention of any future, and the remed yi ng of any existing, impairment of visibility in mandatory

Class IFederal areas 2 which impairment results from manmade air pollution.” On D ecember 2, 1980, the Environmental Protection Agency (EPA) promulgated regulations to address visibility impairment in Class Iareas that is “reasonably attributable” to a single source or small group of sources, i.e., “reasonably attributable visibility

i mpairment” (45 FR 80084). These regulations represented the first phase in addressing visibility impairment. The requirement to submit a regional haze SIP applies to all 50 states, the District of Columbia, and the Virgin Islands. 3 Section 51.308(b) r equire d states to submit the first implementation plan addressing regional haze visibility impairment no later than December 17, 2007. Regional haze SIPs must assure reasonable progress towards the national goal of achieving natural visibility conditions in Class Iareas. Section 169A of the CAA and EPA’s implementing regulations require states to establish long

- term strategies for making reasonable progress toward meeting this goal. Implementation plans must also give specific attention to certain stati onary sources that were in existence on August 7, 1977, but were not in operation before August 7, 1962, and require these sources, where appropriate, to install Best Available Retrofit Technology (BART) controls for the purpose of eliminating or reducing visibility impairment.

1 Visual range is the greatest distance, in kilometers or miles, at which a dark object can be viewed against the sky
. 2 Areas designated as mandatory Class I Federal areas consist of national parks exceeding 6000 acres, wilderness areas and national memorial parks exceeding 5000 acres, and all international parks that were in ex istence on August 7, 1977. 42 U.S.C. 7472(a). In accordance with section 169A of the CAA, EPA, in consultation with the Department of Interior, promulgated a list of 156 areas where visibility is identified as an important value ( 44 FR 69122 , November 30 , 1979). The extent of a mandatory Class I area includes subsequent changes in boundaries, such as park expansions. 42 U.S.C. 7472(a). Although states and tribes may designate as Class I additional areas which they consider to have visibility as an impo rtant value, the requirements of the visibility program set forth in section 169A of the CAA apply only to ‘‘mandatory Class I Federal areas.” Each mandatory Class I Federal area is the responsibility of a ‘‘Federal Land Manager.’’ 42 U.S.C. 7602(i). Wh en we use the term “Class I area” in this action, w e mean a “mandatory Class I Federal area.” 3 Albuquerque/Bernalillo County in Ne w Mexico must also submit a regional haze SIP to completely satisfy the requirements of section 110(a)(2)(D) of the CAA for th e entire State of New Mexico under the New Mexico Air Quality Control Act (section 74

- 2
- 4).3

**STATE’S SUBMITTAL** The SIP revision addresses regional haze for the first implementation period. New Jersey has a Class Iareas within its borders, the Brigantine National Wildlife Refuge Class I area, and so is responsible for ca lculation of baseline and natural visibility conditions, establishment of reasonable progress goals, monitoring requirements, and meeting RAVI requirements. Also, New Jersey is responsible for developing a regional haze SIP that addresses this Class Iare a, that describes its long

- term emission strategy , its role in the consultation processes, and how the SIP meets the other requirements in EPA’s regional haze regulations. **Measures Adopted to Address Long**  **- Term Strategy**  The LTS is a compilation of stat e - specific control measures relied on by the state to obtain its share of emission reductions to support the RPGs established by New Jersey and other Class I states
. New Jersey ’s LTS for the first implementation period addresses the emissions reductions f rom federal, state, and local controls that take effect in the State from the baseline period starting in 2002 until 2018. The LTS was developed by New Jersey in coordination with other states working together as the Mid

- Atlantic NorthEast Visibility Union ( MANE
- VU ) , as they i dentified emission controls that were reasonable and addressed the goal of meeting the RPG for the Brigantine National Wildlife Refuge Class I area
. On June 20, 2007, the MANE

- VU states agreed to adopt emission control strategie s that MANE

VU modeled to determine the amount of progress that the MANE

- VU states would make toward improving visibility

by the end of the first control period, ending in 2018. By adopting all the measures identified in the MANE

- VU anal ys is and applyin g BART to eligible sources, New Jersey ’s LTS achieve s its share of emissions reductions that are reasonable and which modeling shows will achieve the reasonable progress goals for the Brigantine National Wildlife Refuge Class Iarea. The following chart c ompares measures adopted b y New Jersey with the measures agreed to b y the MANE

- VU states (often referred to as the MANE

- VU ‘ask’).4

**MANE -**  **VU Measures Measures Adopted or Action Taken by New Jersey**  Timely implementation of BART on all sources identifie d as BART

– eligible Implementing BART on all eligible sources, except those that have emission limits less than the 250 ton s per ye ar BART eligibility thresholds in their permits
. Low sulfur fuel oil strategy : for NJ distillate oil to 0.05% sulfur b y 201 2 and to 15ppm by

2016, #4 residual oil to 0.25% sulfur no later than 2012, #6 residual oil to 0.3 to 0.5% by 2012 No. 2 & lighter: 0.05 percent by 2014; 0.0015 percent (15 ppm) by 2016 No. 4: 0.25 percent by

2014 No. 5, No. 6 & h eavier: 0.5 percent b y 20 14 All lower sulfur targets met well before 2018. 90% or more reduction in SO2 emissions from 167 stacks or alternative measures 90% or greater reductions of sulfur emissions at the f our stacks located in New Jersey at: BL England, PSEG (2)

- Hudson, and PSEG

– Mercer. Plus nearly 90% reduction of other pollutants responsible for haze. Continued evaluation of other measures, including energy efficiency , alternative clean fuels, reduce SO2 and NOx from coal units by 2018 and NSPS for wood combustion if re asonable and cost

- effective Energy Master Plan and Greenhouse Gas Plan Smoke Management Plan and Construction Activities Residential Wood Burning Strategies Measures to Reduce Organic Carbon Emissions These measures were agreed

- to by MANE
- VU states and tr ibes on June 20, 2007. **New Jersey Adoption of M easures** 
**• BART Controls**  A more detailed review of New Jersey ’s implementation of BART is found in the companion Technical Support Document: Review of Application of Best Available Retrofit Technology in New Jersey ’s Regional Haze State Implementation Plan, July 29, 2011 , which is attached to this TSD. In summary , New Jersey initially identified eleven sources that could be subject to BART (l etter to EPA, September 8, 2005 )
. Of these, the five sources li sted in EPA’s Notice of Proposed Rulemaking were determined to be potentially subject to BART controls. From the five sources, two had

- or are in the process of taking

- permit limits that reduce their BART

- eligible emissions to less than the 250 ton per year BART eligibility limit. New Jersey evaluated three sources for controls under the BART rules. EPA, in a separate review, found two sources that might meet BART

- eligibility requirements. N ew Jersey had not evaluated these two sources, since they were to be shutdown or controlled under other programs . One source had additional controls under New Jersey ’s EGU strategy described in Section 9

- 2 of New Jersey ’s SIP. As described in companion Technical Support Document on BART, New J ersey has since ev aluated these two sources with respect to BART controls and is documenting the appropriate level of control for these two sources in permit modifications to be submitted to EPA.5

While BART controls were included in the modeling that forecasted visibility in the reasonable progress goal ye ar of 2018 , emission reductions due to New Jersey ’s BART controls were not included in the 2018 modeling. (See Figure 5

- 3 in MANE
- VU Modeling for Reasonable Progress Goals , submitted by New Jersey

as Appendix N

- 2 in its SIP and at http://www.nescaum.org/documents/modeling

- for

- reasonable

- progress - final

- 021208.pdf .) Thus, emission reductions from New Jersey ’s application of BART will result in additional improvements in visibility beyond that predicted by the modeling and will provide additional likelihood that the Brigantine Class I area will meet or exceed the P rogress G oal for 2018.
**• Electric Generating Units**  New Jer sey

is home to four of the 167 EGU stacks identified in the setting of the 2018 reasonable progress goal s for Brigantine and five other Class I areas in MANE

- VU. New Jersey has addressed emissions from these stacks through A dvanced Consent Orders or Consent Decrees that require all four facilities to meet performance standards for sulfur, nitrogen and particulate emissions
. EPA proposed that states could use their involvement under the Clean Air Interstate Rule to fulfill their commitment to implementing controls on EGUs. However, New Jersey chose to implement control on each of its EGUs, outside of EPA’s CAI R. Thus the court remand of CAIR , and EPA’s development of an improved transport rule to replace CAIR, does not affect the amount of control that Ne w Jersey implemented on its sources and has no negative impact on New Jersey ’s efforts to meet the visibility Progress Goals. The f our EGU stacks are located in the following facilities: BL England, PSEG

- Hudson, and PSEG

– Mercer. These facilities all have coal

- fired EGU boilers. The BL England facility is under an Administrative Consent Order (ACO) [ New Jersey Department of Environmental Protection Administrative Consent Order (ACO) NEA 040002

- 73001 , e ffective January 24, 2006 ] to meet performance standards for SO 2 , NO x , and PM. The Hudson and Mercer facilities are under a Consent Decree to also meet performance standards for SO 2 , NO x and PM [http://www.epa.gov/compliance/resources/decrees/amended/psegfossil

- amended

- cd.pdf ] These orders/decrees will require more than a 90 % SO 2 emission reduction by 12/15/2012, in addition to about 90% reduction of NO x and PM. New Jersey has also adopted a mercury rule that sets performance standards for coal

- fired boilers, for companies which choose the multi

pollutant strategy

in that rule. The four of the167 EGU stacks located in New Jersey are committed to multi

- pollutant controls, as part of their mercury rule compliance plan. For the other electric generating units not specifically identified, New Jersey

adopt ed new rules (April 20, 2009 New Jersey

Register) to implement a multi

- pollutant control strategy to reduce allowable NO x , SO 2 , and particulate emissions from all coal

- fired boilers. Details regarding this rule proposal are available at NJDEP’s website, http://www.state.nj.us/dep/aqm/index.html.
**• Sulfur in Fuel Oil**  **- Proposed**  **Approval of Subchapter 9**

**– Sulfur in Fuels**  NJDEP proposed revisions to Subchapter 9 on November 16, 2009 at 41 N.J.R. 4156(a) which established a comment period running until Janu ary 15, 2010. A public hearing was held on6

January 5, 2010. The public comment period was extended to March 15, 2010 and New Jersey held an informal stakeholder meeting on March 8, 2010. New Jersey evaluated all the comments received throughout this period and adopted the revisions on September 20, 2010 at 42 N.J.R. 2244 with an operative date of October 25, 2010. New Jersey ’s responses to the public comments and stakeholder recommendations are posted at http://www.nj.gov/dep/aqm/1997adop.html under ‘Sulfur in Fuels’. New Jersey propos ed these amendments to help the State attain and maintain the Federal health

based National Ambient Air Quality Standards (NAAQS) for fine particles (particles smaller than 2.5 microns in diameter (PM2.5)), SO 2 and ozone, and to reduce haze in New Jersey and the region. Th e rulemaking is part of a regional effort to reduce regional haze and fine particles through the implementation of a low sulfur fuel strategy
. New Je rsey committed to propose this course of action as a member of MANE

- VU. New Jersey

included the MANE

- VU states ’ long term strategy for reducing the sulfur content in fuel in the 1997 fine Particulate Matter (PM 2.5 ) SIP that was submitted to EPA on April 1 , 2009. New Jersey

had specifically

noted that NJDEP planned to propose t o amend NJAC 7:27

- 9, Sulfur in F uels, specifically section 9.2, anticipating lowering the maximum allowable sulfur content in fuel and the maximum allowable SO2 emissions from fuel combustion in order to reduce the emissions of SO2 and other pollutants from the combustion of fuel in New Jersey
. Under the MANE

- VU agreement on the proposed standards, phase one establishes limits of 0.05 percent sulfur b y weight (500 ppm) for distil late oil (No. 2 and lighter); 0.25 percent sulfur by weight (2,500 ppm) for No. 4 residual oil; and between 0.3 and 0.5 percent sulfur by weight (3,000 to 5,000 ppm) for No. 6 residual oil. Under the MANE

- VU strategy , these standards are to go into effect no later than 2012. New Jersey propose d additional time, until July 1, 2014, to achieve these standards to ensure sufficient time for production and distribution of lower sulfur fuel oil. In addition, the MANE

- VU strategy provides for a phase two reduct ion by 2016 for distillate oil (No. 2 and lighter) to 15 ppm. The proposed new standards for maximum allowable SO2 emissions at N.J.A.C. 7:27

- 9.2 Table 2B represent, as do the existing standards, the emissions level for each grade of fuel oil under combus tion scenarios without add

- on SO2 air pollution control equipment. The amendments to N.J.A.C. 7:27
- 9.2 include the addition of Tables 1B and 2B, which contain the new maximum allowable sulfur

- in

- fuel and maximum allowable SO2 emission standards, effective July

1, 2014 and July

1, 2016 . The new standards at Table 1B are given in parts per million by

weight (ppm), rather than percent sulfur by weight, as the existing standards are described. In addition, the existing standards in Table 1 have been converted to e quivalents in parts per million (now Table 1A) for greater ease in comparing the existing standards to th e new standards in effect in 2014 and 2016 . For sources that chose to control their emissions by use of control equipment, Table 2B contains the n ew maximum allowable sulfur dioxide emissions that are release to the atmosphere in pounds per million BTU.7

These new standards in Tables 1B and 2B are consistent with the MANE

- VU emission management strategy

for new standards for maximum allowable sulfur in fuel, which would reduce sulfur content in the inner zone states (including New Jersey). New Jersey

has repealed section 9.5 which allowed the limited use of higher content sulfur fuel for units that were converting to coal. This provision was counte r to the new sulfur standards. New Jersey

i nclude d a “sell

- through” provision, which allows the storage, sale, distribution, delivery or use of newl y - noncompliant fuel that is alread y in tanks in New Jersey as of July

1, 2014 and July

1, 2016. It should be noted that EPA’s current SIP approved version of Subchapter 9 has a condition that sulfur dioxide “bubble” permits issued by the State pursuant to section 9.2 and not waived under the provisions of section 9.4 become applicable parts of the SIP onl y aft er receiving EPA approval as a SIP revision. See 7/8/83, 48 FR 31400. This is necessary because detailed air quality simulation modeling involves many factors that can impact the results, such as, source location, stack height, distance between stacks and local topograph y and EPA review is required to insure replicable results. This provision has not changed in the latest revision and EPA is continuing its previous finding as it appears in 40 CFR 52.1605, under Subchapter 9 in the comment column. New Je rsey

asked for a longer period of time than agreed to in the MANE

- VU ‘ask’ to implement these rules that reduce sulfur in fuels. EPA notes that New Jersey has provided a reasonable justification for the new effective dates and that they will be in place w ell before the end of the first planning period in 2018. With the limitation that sulfur dioxide bubbles must continue to be approved on a case

- by

- case basis as SIP revisions, EPA is proposing to approve the revisions to Subchapter 9 as part of the Regi onal Haze SIP and the PM2.5 SIP.
**• Additional Measures**  The following additional measures also are part of New Jersey ’s Regional Haze Plan, but were not adopted specifically

for the Plan. The following summaries are excerpted from New Jersey ’s Regional Haze Plan, July 2009:
• Energy Master Plan and Greenhouse Gas Plan New Jersey

developed an Energy

Master Plan2 (EMP) to address New Jersey ’s electricity and heating challenges. The draft plan was released on April 17, 2008, and finalized on October 22, 2 008. One component of the Energy Master Plan addresses way s to increase energy efficiency

in the State. New Jersey

is also developing a Greenhouse Gas Reduction Plan pursuant to the Global Warming Response Act. Measures which will be implemented as a resul t of these plans will reduce multiple air contaminants and improve visibility
. • Smoke Management Plan and Construction Activities Since New Jersey

is home to the federall y protected visibility area, the Brigantine Wilderness Area, New Jersey

is require d by

the USEPA rules to: D evelop and implement a smoke management plan and a ddress emissions from construction activities
.8

New Jersey

addresses smoke management through its Open Burning rules at N.J.A.C. 7:27

- 2. New Jersey

addresses “fugitive dust” emiss ions from construction activities through its “Soil Erosion and Sediment Control Standards: Standards for Dust C ontrol.” The USEPA has promulgated several regulations which limit exhaust emissions from non

- road vehicles, such as those used at construction sites. Inaddition, New Jersey has existing rules to limit the idling of vehicles and equipment. New Jersey will consider additional mitigating measures for construction activities on a case

- by

- case basis depending on the size and nature of the construct ion work, and the review of the potential emissions on the property in relation to any potential off

- site impacts. New Jersey is considering amendments to its Open Burning Rule.
• Residential Wood Burning Strategies Residential wood burning from woodst oves and fireplaces is one of the largest sources of direct fine particulate matter, PM 2.5 , emissions in New Jersey. New Jersey is considering strategies to reduce the emissions of wood smoke. Implementation of these strategies will reduce fine particle em issions and improve visibility . One strategy under consideration is a Home Wood Heating Advisory Program, similar to those in Oregon and Washington states. In general, these programs request wood burning be limited during times when unhealthy air qualit y i s forecast or monitored. Other control measures under investigation include woodstove and fireplace change

out programs.
• Measures to Reduce Organic Carbon Emissions Even though the focus of the Reasonable Progress Goal is to reduce emissions of sulfur dioxide, the largest contributor to regional haze, for the 2018 reasonable progress plan, New Jersey is taking actions to reduce emissions of organic carbon, the second largest contributor to visibility impairment at Brigantine Wilderness Area. Some of Ne w Jersey ’s existing and proposed rules which reduce emissions from organic carbon include: • Existing Diesel Idling Rule N.J.A.C 7:27
- 14.3 r emoves or further limits the exemptions to the State’s idling restrictions , r emoves sleeper berth exemption from v ehicles effective May 1, 2010 , and i ncludes additional idling restrictions for gasoline vehicles
. • Existing Open Burning Rule N.J.A.C 7:27
- 2 limits open burning. • Existing Industrial, Commercial and Institutional (I CI ) Boilers N.J.A.C. 7:27
- 16.8,
- 1 9.7 s ets performance standards for NO x , CO and VO C which ensure good combustion, and requires annual tune up s to reduce NO x emission and may also help reduce fuel consumption. • Existing Heav y Duty

Diesel Trucks Rule N.J.A.C 7:27
- 14 s ets tighter opacit y standards for the Inspection and Maintenance (I/M) program.9

**Emissions Inventory for 2018 with Federal and State Control Requirements** The emissions inventory

used in the regional haze technical analy ses was developed by Mid

Atlantic Regional Air Managem ent Association ( MARAMA ) for MANE

- VU with assistance from the MANE

- VU states. The 2018 emissions inventory was developed by

projecting 2002 emissions, and assuming emissions growth due to projected increases in economic activity as well as appl yi ng reduct ions expected from federal and state regulations affecting the emissions of VOC and the visibility

- impairing pollutants NO x , PM 10 , PM 2.5 , and SO 2 . The BART guidelines direct states to exercise judgment in deciding whether VOC and NH 3 impair visibi lity in their Class Iarea(s). MANE
- VU demonstrated that anthropogenic emissions of sulfates are the major contributor to PM 2.5 mass and visibility impairment at Class I

areas in the Northeast and Mid

- Atlantic region. It was also determined that the total ammoni a emissions in the MANE

VU region are extremel y small. In addition, since VOC emissions are aggressively controlled through New Jersey ’s ozone SIP s , the pollutants New Jersey considered under BART are NO x , PM 10 , PM 2.5 , and SO 2 . Additional information on the emission inventory used in the Regional Haze SIP, see the companion Technical Support D ocument , attached : **Review of New Jersey State -**  **wide 2002 and 2018 Projection Modeling Inventories and Reasonable Progress Goal Inventory**  **D emonstration**  **for the Reg ional Haze SIP, December 7, 2010**  **. M**  **odeling to Support the LTS and Determine Visibility Improvement for Uniform Rate**  **of Progress**  MANE
- VU performed modeling for the regional haze LTS for the 11 Mid

- Atlantic and Northeast states and the District of Columbia
. The modeling anal ys is is a complex technical evaluation that began with selection of the modeling sy stem. M ANE
- VU used the following modeling s ys tem:  Meteorological Model: The Fifth

- Generation Pennsylvania State University /National Center for Atmospheric Research (NCAR) Mesoscale Meteorological Model (MM5) version 3.6 is a nonh ydrostatic, prognostic meteorological model routinel y used for urban

- and regional

- scale photochemical, PM 2.5 , and regional haze regulatory modeling studies.  Emissions Model: Th e Sparse Matrix Operator Kernel Emissions (SMOKE) version 2.1 modeling s ys tem is an emissions modeling sy stem that generates hourly gridded speciated emission inputs of mobile, non

- road mobile, area, point, fire and biogenic emission sources for photochemi cal grid models.  Air Quality

Model: The EPA’s Models

- 3/Community Multiscale Air Quality (CMAQ) version 4.5.1 and REMSAD modeling s ys tem is a photochemical grid model capable of addressing ozone, PM, visibility and acid deposition at a regional scale.  Ai r Quality

Model: The Regional Model for Aerosols and Deposition ( REMSAD), version 8 is a Eulerian grid model used for a source apportionment anal ys is.  Air Quality

Model: The California Puff Model (CALPUFF), version 5 is a non

- stead y state Lagrangian puff model used to access the contribution of individual states’ emissions to sulfate levels at selected Class I receptor sites.10

The MANE

- VU was tasked with the assignment of preparing a PM 2.5 modeling platform that all member states could use to model their L TSs to demonstrate reasonable progress by 2018 in meeting the ultimate goal of natural visibility conditions by

2064. The New York State Department of Environmental Conservation (NYSDEC) was the lead agency for coordinating and running the m odeling platfo rm used b y the MAN E
- VU RPO. Modeling centers responsible for running the platform included the NYSDEC, the Universit y of Maryland at College Park (UMD), the Northeast States for Coordinated Air Use Management (NESCAUM), the New Jersey Department of Enviro nmental Protection (NJ DEP), and the Virginia Department of Environmental Quality

(VA DEQ). Each modeling center was responsible for installing the modeling platform, conducting diagnostic tests and completing a benchmark run to ensure accurate results. MANE
- VU used the CMAQ version 4.5.1 as its photochemical grid model. The model uses simulations of chemical reactions, emissi on of PM 2.5 and PM 2.5 precursors and a sophisticated meteorological model (The Pennsylvania State University /National Center for Atmospheric Research Mesoscale Meteorological Model) to produce speciated PM 2.5 concentrations over the eastern United States . The meteorological data used in the meteorological model was for the 2002 base year. The photochemical grid model was run with the base ye ar meteorology and base ye ar emissions to determine if the model performance was satisfactory . Once the model per formance was determined to be adequate, PM 2.5 concentrations were modeled b y running the model with projected emissions for 2018 and the original 2002 meteorology . The meteorology was held constant so that the results of changing the emissions would not b e influenced b y changing meteorology
. **Conceptual Description of the Problem** A conceptual model describes how weather patterns affect the formation and transport of PM 2.5 , accounting for emissions and photochemistry
. New Jersey ’s SIP includes, in Chapter 7, numerous methods that provide information about how haze occurs in New Jersey and the sources of haze. The methods include emissions information (and the distance to sources), trajectory analy ses, and impacts predicted by dispersion and various grid m odels. Monitoring data is used to show that sulfates are the predominate species that reduce visibility

at the Brigantine Class I area. The various models support the hy pothesis that many sources across a wide range of states in the eastern United States contribute to haze in New Jersey
. **Modeling Platforms** Two regional

- scale air quality models were evaluated and used by NESCAUM to perform air quality simulations. These are the Community Multi

- scale Air Qualit y modeling s ys tem (CMAQ; By

un and Ching, 19 99) and the Regional Modeling Sy stem for Aerosols and Deposition (REMSAD; SAI, 2002). CMAQ was developed b y EPA, while REMSAD was developed b y IC F Consulting/Sy stems Applications International (ICF/SAI) with EPA support. CMAQ has undergone extensive community development and peer review (Amar et al., 2005) and has been successfully used in a number of regional air quality studies (Bell and Ellis, 2003;11

Hogrefe et al., 2004; Jimenez and Baldasano, 2004; Mao and Talbot, 2003; Mebust et al., 2003). REMSAD has also has been peer reviewed (Seigneur et al., 1999) and used by EPA for regulatory

applications ( www.epa.gov/otaq/regs/hd2007/frm/r00028.pdf and www.epa.gov/clearskies/air_quality _tech.html ) to study

ambient concentrations and deposition of sulfate and other PM species. Five modeling centers, worked collectivel y to maximize efficiency of computing resources in MANE
- VU for SIP modeling. These centers include NY DEC, NJ DEP/Rutgers, VA DEQ, UMD, and NESCAUM. **Use of Air Quality Models: Contribution Assessment**  The 1999 Regional Haze Rule requires State Implementation Plans to include a “contribution assessment” to identify

those states or regions that may be influencing specially

protected federal lands known as Federal Class Iareas. 4 These states or regions would then be subject to the consultation provisions of the Haze Rule. The Haze Rule also requires a “pollution apportionment” anal ys is as part of the long

- term emissions management strategy for each site. As described in the Conceptual Description portion of this TSD, sulfate alone accounts for any where from one

- half to two

- thirds of total fine particle mass on the 20 percent haziest day s at MANE
- VU Class I sites. As a result of the d ominant role of sulfate in the formation of regional haze in the Northeast and Mid

- Atlantic region, MANE

- VU concluded that an effective emissions management approach would rely heavil y on broad

- based regional SO 2 control efforts in the eastern United State s. **Use of Air Quality Models: Area of Influence for MANE**  **- VU Class I Areas**  States with Class Iareas calculat e the baseline and natural visibility for their Class Iareas, and the determination of reasonable progress goals. Class IStates calculate d b aseline visibility conditions for the period between 2002 and 2004. The average impairment for the most and least impaired day s were determined for each calendar ye ar and compiled into the average of three annual averages (40 CFR 51.308 (d)(2)(i)). The nat ural visibility conditions were determined for the same baseline period with the most and least impaired day s determined by available monitoring data or an appropriate data anal ys is technique (40 CFR 51.308 (d)(iii

- iv)). There are seven Class I areas loc ated in the Mid

- Atlantic and Northeast, of which Brigantine in New Jersey

is one. In order to identify states whose emissions are most likely to influence visibility in MANE

- VU Class Iareas, MANE
- VU prepared the Contributions to Regional Haze

4 The Class I designation applies to national parks exceeding 6,000 acres, wilderness areas and national memorial parks exceeding 5,000 acres, and all international parks that were in existence prior to 1977. In the MANE

- VU area, this includes: Acadia National Park, Maine; Brigantine Wilderness (within the Edwin Wilderness, Vermont; Moosehorn Wilderness (within the Moosehorn National Wildlife Refuge), Maine; B. Fors ythe National Wildlife Refuge), New

Jersey; Great Gulf Wilderness, New Hampshire; Lye Brook Presidential Range

– Dry River Wilderness, New Hampshire; and Roosevelt Campobello International Park, New Brunswick.12

in the Northeast and Mid

- Atlantic United States (Contribution Assessment). The full report can be found in Appendix H
- 1 of the New Jersey Regional Haze SIP. Based on that work, MANE

- VU concluded that it was appropriate to define an “Area of In fluence” (AOI) includi ng all of the states participating in MANE

- VU plus other states outside MANE
- VU for which modeling indicated they contributed at least two percent (2%) of the sulfate ion in MANE

- VU Class Iareas in 2002. The Visibility Improvement State and Tribal Association of the Southeast (VISTAS) 5 also conducted an AOI anal ys is, which used a level of one percent (1%) to assess whether an upwind state significantly contributed. The VISTAS AOI did not show New Jersey to be a contributor to any VI STAS Class I area. The primary

contribution assessment tool used in the New Jersey Regional Haze SIP was the Regional Modeling S ys tem for Aerosols and Deposition (REMSAD) (SAI , 2002). A significant feature of the REMSAD work used to evaluate regional contributions is that N ESCAUM reprocessed the SO 2 emission data from each state to take advantage of REMSAD’s tagging capabilities. Thus, all SO 2 emissions included in the model for the eastern half of the country were tagged according to state of origin, and emissions from Canada a nd the boundary conditions were also tagged. This allowed for a rough estimation of the total contribution from elevated point sources in each state to simulated sulfate concentrations at eastern receptor sites. Using identical emission and meteorological inputs to those prepared for the CMAQ SIP modeling platform, described earlier in this TSD, REMSAD was used to simulate the annual average impact of each state’s SO 2 emis s ion sources on the sulfate fraction of PM 2.5 over the northeastern United States. A more in

- depth description of the REMSAD modeling used for contribution assessment can be found in Appendix H
- 1 of New Jersey ’s SIP. The REMSAD contribution assessment modeling used by New Jersey ’s Regional Haze SIP conforms to EPA modeling requirements an d is acceptable to EPA. **Use of Air Quality Models: REMSAD Contribution Assessment Results**  New Jersey

determined that a number of states contributed to haze in the Brigantine Class I area , and notified these states via the letters included in Appendix I
- 1 of New Jersey ’s plan. Man y states responded (Appendix I

- 2)
. New Jersey also contributes to haze in a number of Class I areas in MANE

- VU. These impacts were determined using a variet y of methods as described below. MANE
- VU States decided that any state or region that contributed at least 2 percent of total sulfate observed on 20 percent worst visibility days in 2002 is contributing significantl y to the haze problem in that particular Class I area. With respect to sulfate, the Contribution Assessme nt estimated emissions from within MANE

- VU in 2002 were responsible for about 25

- 30 percent of the sulfate at Class Iareas located within and nearby to the MANE

- VU region. The

5 VISTAS is comprised of the following: the st ates of Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, West Virginia, and the Eastern Band of Cherokee Indians, and Knox County, TN13

contribution of sulfate at these Class I areas from other regions, Canada, and outside the modeling domain were also significant. **Use of Air Quality Models: CMAQ Modeling of**  **R elative**  **C ontributions**  **of P**  **ollutants to**  **V isibility**  **I mpairment**  An important step toward identifying reasonable progress measures is to identify the key pollutants contributing to visibility impairment at each Class I area. To understand the relative benefit of further reducing emissions from different pollutants, MANE

- VU developed emission sensitivity

model runs using CMAQ to evaluate visibility and air quali ty

impacts from various groups of emissions and pollutant scenarios in the Class Iareas on the 20 percent worst visibility day s. Regarding which pollutants are most significantly impacting visibility in the MANE

- VU region, MANE
- VU’s contribution assess ment, demonstrated that sulfate is the major contributor to PM 2.5 mass and visibility

impairment at Class Iareas in the Northeast and Mid

- Atlantic region. Sulfate particles commonly account for more than 50 percent of particle

- related light extinction at northeastern Class I areas on the clearest day s and for as much as or more than 80 percent on the haziest day s. In particular, for the Brigantine National Wildlife Refuge Class Iarea, on the 20 percent worst visibility

day s in 2000

– 2004, sulfate accounted for 66 percent of the particle extinction. After sulfate, organic carbon (OC) consistently accounts for the next largest f raction of light extinction. Organic carbon accounted for 13 percent of light extinction on the 20 percent worst visibility

day s for Brigantine, followed b y nitrate that accounts for 9 percent of light extinction. The emissions sensitivity anal ys es conducted b y MANE
- VU predict that reductions in SO 2 emissions from EGU and non

- EGU industrial point sources will result in the gre atest improvements in visibility in the Class I areas in the MANE

- VU region, more than any other visibility

- impairing pollutant. As a result of the dominant role of sulfate in the formation of regional haze in the Northeast and Mid

- Atlantic region, MANE

- VU concluded that an effective emissions management approach would rel y heavily on broad

- based regional SO 2 control efforts in the eastern United States. **Use of CMAQ Modeling to Develop 2018 Control Case Predictions: Meteorological Time Periods Used in**  **the Modeling** All of 2002, which represents the baseline period from 2000 to 2004, was included in CMAQ modeling. 2002 was divided into five periods. UMD is responsible for modeling the period from January 1 to February

28; NJ DEP/Rutgers are responsible f or the period from March 1 to May 14; NY DEC is responsible for the period from May 15 to September 30; VA DEQ is responsible for the period from October 1 to October 31; and NESCAUM is responsible for the period from November 1 to December 31. Each period uses a 15 day spin up run to minimize the impact of the default initial concentration fields. Each group performs CMAQ simulations on its period for a series of scenarios including 2002 Base Case, 2009 Base Case, 2018 Base Case, 2009 Control Case, and 201 8 Control Case. All scenarios adopt the same meteorological field (2002) and14

boundary conditions, varyingonl y emission inputs. To ensure consistency between modeling groups, a benchmark test was conducted b y each group. **Meteorological Data Used in the C**  **MAQ Air Quality Model**  The MANE

- VU states decided to use a prognostic meteorological model that provides life

- like meteorological inputs to the photochemical grid model. The Pennsylvania State University

/National Center for Atmospheric Research Mesoscale M eteorological Model version 3.6 was chosen for the modeling anal ys is. The MM5 model provides a reasonable representation of weather conditions at the surface and aloft. **Use of CMAQ Modeling to Develop 2018 Control Case Predictions: Domain of the Model**  **, Horizontal/Vertical Resolution and the Initial and Boundary Conditions**  MANE
- VU adopted the Inter

- RPO domain description for its modeling runs. This 36

- km domain covers the continental United States, southern Canada and northern Mexico. The dimensions of this domain are 145 and 102 cells in the east

- west and north

- south directions, r espectivel y. A 12
- km inner domain was selected to better characterize air quality in MANE

- VU and surrounding RPO regions. This domain covers the eastern region, which includes the northeastern, central, and southeastern U.S., as well as southeastern Canada. It extends from 66W
- 94W in longitude and 29N

- 50N in latitude with 172 × 172 grid cells
. Vertical resolution is the number of lay ers and the size of each lay er in the model. The lay ers in the photochemical grid model were set up to be compatible with the model that produced weather conditions f

or the photochemical grid model. The vertical resolution used in the modeling exercise followed EPA’s modeling guidance and therefore adequately represents the atmosphere where PM 2.5 is emitted, forms and is transported.
**Baseline and Future Year Emiss ion Inventories for**  **CMAQ Modeling**  Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires the States to identify the baseline emission inventory on which strategies are based. The baseline inventory is intended to be used to assess progress in maki ng emission reductions. Based on EPA guidance entitled, 2002 Base Year Emission Inventory SIP Planning: 8

- hour Ozone, PM 2.5, and Regional Haze Programs, which identifies 2002 as the anticipated baseline emission inventory y ear for regional haze, MANE

- VU and New Jersey are using 2002 as the baseline ye ar. Future y ear inventories were developed for the years 2009, 2012 and 2018 based on the 2002 base year. These future ye ar emission inventories include emissions growth due to projected increases in economic activity as well as the emissions reductions due to the implementation of control measures. The 2002 emissions were first generated b y the individual states in the MANE

- VU area. MARAMA then coordinated and qualit y assured the 2002 inventory data. The 200 2 emissions from non

- MANE
- VU areas within the modeling domain were obtained from other Regional Planning Organizations for their corresponding areas. These Regional Planning Organizations15

included the Visibility

I mprovement State and Tribal Association of the Southeast (VISTAS), the Midwest Regional Planning Organization and the Central Regional Air Planning Association. Version 3 of the 2002 base y ear emission inventory was used in the regional modeling exercise. Technical support documentation for the M ANE
- VU 2002 base inventory is presented in Technical Support Document for 2002 MANE

- VU SIP Modeling Inventories, Version 3, which is Appendix F

- 1 of the New Jersey SIP. This document explains the data sources, methods, and results for preparing this versi on of the 2002 base y ear criteria air pollutant and ammonia emissions inventory . Documentation for the future y ear estimations of EGUs is presented in Appendix F
- 2 o f the SIP

– MARAMA’s Development of Emission Projections f or 2009, 2012, an d 2018 f

or Non
- E GU Point, Area, and Nonroad Source i n the MANE

- VU Region Final Report , February , 2007
. The emission inventory

submitted by

New Jersey

is evaluated in the attached technical support document: **Review of New Jersey State -**  **wide 2002 and 2018 Projection Model ing**  **Inventories and Reasonable Progress Goal Inventory D**  **emonstration for the Regional Haze**  **SIP, December 7, 2010 .**  **CMAQ Model Performance Evaluation**  The modeling is described in MANE
- VU Modeling for Reasonable Progress Goals , prepared b y NESCAUM , listed as Appendix N

- 2 of New Jersey’s SIP. NESCAUM evaluated the 2002 annual 12 km resolution meteorological fields generated b y MM5 using ENVIRON's METSTAT program. Model results of surface wind speed, wind direction, temperature, and humidity were paired with measurements from EPA’s Clean Air Status and Trends Network (CASTNET) and National Center for Atmospheric Research’s T echniques Data Laboratory (TDL) network by

hour and by

location and then statistically compared. Based on this statistical comparison between model prediction and data from the two networks for wind speed, wind direction, temperature, and humidity , MM5 performs well. An acceptable small bias, high index of agreement and strong correlation with CASTNET and TDL data are shown. Since MM5 us es TDL data for nudging, the model predictions are in better agreement with TDL data than with CASTNET data. MM5 performs better in Midwest and Northeast than Southeastern US. CMAQ modeling was conducted for ye ar 2002 b y cooperative modeling efforts from NYDEC, UMD, NJDEP, Rutgers, VADEP, and NESCAUM. CMAQ Performance for PM 2.5 species and visibility was examined based on this CMAQ run on a 12 km resolution domain. Measurements from IMPROVE and STN networks were paired with model predictions by location and time for evaluation. The goal and the criteria for PM 2.5 evaluation suggested b y Bo yl an and Baker (2004) were adopted b y every R PO for SIP modeling. The performance goals are: Mean Fractional Error (MFE) ≤ +50%, and Mean Fraction Bias (MFB) ≤ ±30%; while the criteria are proposed as: MFE ≤ +75%, and MFB ≤ ±60%. CMAQ prediction of PM 2.5 species from 40 STN sites and 17 IMPROVE sites within the MANE

- VU Region were paired with measurements and statistically

anal yz ed to generate MFE and MFB values. Considering CMAQ performance in terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and PM 2.5 all had the majority of data points within the goal curve, some were between the goal and acceptable criteria, and onl y a few16

were outside the criteria curve. Onl y fine soil has the majority of points outside the criteria curve, but there were some sites still within the goal. For the MANE

- VU region, CMAQ performs best for PM 2.5 sulfate, followed by PM 2.5 , EC, nitrate, OC, and then fine soil. Regional haze modeling also requires CMAQ performance evaluation for aerosol extinction coefficient (B ext ) and the haze index. Modeled daily aerosol extinction at each improve site was calculated following the IMPROVE formula with modeled daily PM 2.5 species concentration and relative humidity factors from IMPROVE. The approach used natural background visibility estimates and the haze index following EPA Guidance. The modeled B ext showed a near 1:1 linear relationship (slope of 0.78 and r2 of 0.46) with IMPROVE observed B ext . The regression excluded three points from July 7, 2002; the monitor s were directl y impacted by Canadian fires whose emissions were not modeled. **How to Calculate Uniform Rate of Progress Goals**  The key difference between SIPs from States with Class Iareas and those States without Class I areas, but may

have sources that impact visibility on Class Iareas, is the calculation of the baseline and natural visibility for their Class I areas and the determination of uniform rate of progress goals

- expressed in deciviews

- that provide for reasonable progress towards achieving natural visibility

by 2064. It is the Class I states ’ responsibility to assess these calculations. The Class IStates must also consult with those States which may reasonabl y be anticipated to cause or contribute to visibility

impairment in their Class I areas (40 CFR 51.308 (d)(1)(i

- vi)). The baseline visibility

conditions are calculated for the baseline period between 2002 and 2004. The average impairment for the 20 most and 20 least impaired day s are determined for each calendar year and compiled into the average of three annual averages (40 CFR 51.308 (d)(2)(i)). The natural visibility

conditions are determined for the same baseline period with the most and least impaired day s determined by available monitoring data or an appropriate data anal ys is tec hnique (40 CFR 51.308 (d)(iii

- iv)). The calculations used to determine the natural conditions used as the 2064 visibility goal are described at the MANE

- VU SIP Template document, June 10, 2004: NATURAL BACKGROUND VISIBILITY CONDITIONS CONSIDERATIONS AND PROPOSED APPROACH TO THE CAL CULATION OF NATURALBACKGROUND VI SI BILITY CONDITIONS AT MANE
- VU CLASS I AREAS , following EPA’s guidance at: U.S. EPA (2003). Guidance for Estimating Natural Visibility Conditions under the Regional Haze Rule. EPA
- 454/B

- 03
- 005. September 2003
. EPA released guidance on June 7, 2007 to use in setting reasonable progress goals. The goals must provide improvement in visibility for the most impaired day s, and ensure no degradation in visibility for the least impaired day s over the S I P period. The following f igure illustrates an example of how Uniform Rate of Progress is calculated.17 **Example C**  **alculation of Uniform Rate of Progress CMAQ**  **Modeled Visibility Pro jections for 2018**  The CMAQ air qualit y m odel was used to simulate base period emissions and future emissions. The modeling results for the base ye ar period (2002) and the ye ar representing the end of the first planning period (2018) are used to develop re lative response factors (RRF) for each component of particulate matter identified previously in this TSD. The relative response factors are multiplied by

the measured species concentration data during the base period (for the measured 20% best and worst d ay s). This results in daily future y ear species concentrations data. The projected concentrations are then used to derive daily visibility in deciviews and are averaged across all best and worst day s to create the projected future visibility . The results o f this procedure are plotted along with the uniform pr ogress glide slope below, and in Table 8.4 and Figure 8.1 in New Jersey’s SIP, taken from Figure 3

- 2, and 4

- 1B in 2018 Visibility Projections, Appendix J

- 1 in New Jersey ’s SIP.18 **Reasonable Progress Goa ls and Projected Future Visibility for the Brigantine**  **Wilderness Area** Baseline Visibility (2000

- 2004) Natural Background

Conditions for 2064 Reasonable Progress Goal for 2018 2018 CMAQ

Projections 20% Worst Day s 29.0 12.2 25.1 25.1
20% Best Day s 14.3 5.5 14.3 12.2 (A ll values expressed as deciviews

– lower deciviews means better visibility
. )

From: 2018 Visibility

Projections (NESCAUM for MANE

- VU States, May 2008), Appendix J

1 in New Jersey ’s SIP. By interpolating between the base y ear of 2004 and the natural background y ear of 2064, the Progress Goal for 2018 is 25.1 deciviews, 3.9 deciviews lower than the 29.0 deciviews starting point. State plans must adopt all reasonable controls, with the objective of improving visibility to equal to, or better than, the Progress Goal. MANE

- VU modeled the effects of reducing emissions on air quality

and visibility . Based on the emission controls agreed

- to by the MANE

VU states, visibility

at the Brigantine Class I area is forecast to improve t o 25.1 deciviews in 2018, meeting the Progress Goal. New Jersey evaluated the control measures agreed

- to by the MANE
- VU states and implemented all the agreed

- to measures and placed BART controls on its BART
- eligible sources. Thus, New Jersey has met the test of Reasonable Progress b y adopting all reasonable measures , as well as meeting the 2018 progress goal . Since NJ’s BART sources were not included in the modeled reductions and New Jersey achieved 90 percent or better19

control at its CAIR
- eligible sourc es, NJ is likely to have exceeded the modeled re ductions. If other states implemented the MANE

- VU measures, then visibility in the Brigantine area is likely to exceed the progress goal in 2018. The modeling results presented in 2018 Visibility Projections, Appendix J

- 1 in New Jersey ’s SIP, show all MANE

- VU sites are projected to meet or exceed the uniform rate of progress goals for 2018 on the 20 percent worst day s. In a ddition, no site anticipates increases in visibility impairment relative to the baseline on the 20 percent best day s. **Summary of Photochemical Grid Modeling Results** In summary , the photochemical grid modeling, documented in New Jersey ’s Regional Haze SIP , follow s EPA’s modeling guidance and is acceptable to EPA. All MANE

- VU sites impacted b y New Jersey are projected to meet or exceed the uniform rate of progress goal for 2018 on the 20 percent worst day s. In addition, no site anticipates increases visibi lity impairment relative to the baseline on the 20 percent best day s. **Monitoring** In section 10.2.3 of its SIP, New Jersey commits to operate and maintain the monitoring site at the Brigantine Wilderness Area for the foreseeable future . New Jersey conten ds that this commitment is contingent upon continued Federal and State funding. SI P s cannot place obligations on EPA when the rules and guidance require states to be responsible for continued assessment of visibility

impairment. At present, visibility as sessment is based on IMPROVE network monitoring at the Class Iarea in Brigantine. We acknowledge and appreciate New Jersey ’s support for monitoring at this location. EPA agrees that monitoring to assess visibility impairment will be included in the annu al network review process between EPA and New Jersey
. **RAVI** EPA requires that states take responsibility for assessing and preventing visibility impairment reasonabl y attributable to a source or group of sources. This includes a commitment for New Jerse y to insure that new sources do not affect the achievement of reasonable progress goals and continued coordination with the Federal Land Manager on issues with reasonably attributable visibility impairment (RAVI). New Jersey , in section 10.2.1, commits to continue to review the impact of new sources on visibility under its prevention of significant deterioration program for all major new or modified sources in New Jersey

within 100km of the Brigantine Class Iarea, or further from Brigantine on a case - by

- case basis. This commitment is affirmed in the New Jersey ’s recently modified new source review delegation agreement. **P ublic Hearing and Response to Comments and Consultation with Federal Land Manager**  In Appendix O of the New Jersey Regional Haze SIP , New Jersey addressed the comments from the public, stakeholders, EPA and the Federal Land Manager. On May 10, 2006, the MANE

- VU State Air Directors adopted the Inter

- RPO State/Tribal and FLM Consultation Framework that documented the consultation proces s within the context of20

regional phase planning, and was intended to create greater certainty and understanding among RPOs. MANE
- VU states held ten consultation meetings and/or conference calls from March 1, 2007 through March 21, 2008. In addition to M ANE
- VU members attending these meetings conference calls participants from VI STAS, Midwest RPO and relevant Federal Land Managers were also in attendance at many of these meetings and conference call s . Inaddition to the conference calls and meeting , the FLMs were given the opportunity to review and comment on each of the technical documents developed b y M ANE
- VU. In addition to the conference calls and a meeting , the FLMs were given the opportunity to review and comment on each of the technical document s developed b y MANE
- VU and included as appendices in New Jersey ’s S IP submittal. New Jersey

consulted with the FLMs in person at a meeting that EPA Region 2 attended on October 20, 2009 during the development of the Regional Haze SIP. In addition, New Jersey submitted the draft plan for review b y the FLMs for the required ninet y - day review period before New Jersey

submitted the SIP to EPA. These actions fulfill EPA’s requirements in 40 CFR 51.308(i). New Jersey

held a public hearing on this propos ed SIP revision on October 27, 2008 at the New Jersey Department of Environmental Protection Public Hearing Room, Trenton, New Jersey
. Written comments relevant to the proposal were accepted through November 28, 2008. The onl y comments were submitted by USEPA, the Fish and Wildlife Service and one of the potential BART sources. New Jersey responded to the comments, as listed in Appendix O

- 3 of New Jersey ’s Regional Haze Plan. New Jersey commits in their SIP to ongoing consultation with the FLMs on Regio nal Haze issues throughout the implementation of the SIP as required in 40 CFR 51.308(i)(4). **P eriodic**  **SIP R evisions and**  **F ive**  **- Y**  **ear P**  **rogress R**  **eports** Consistent with the requirements of 40 CFR 51.308(g), New Jersey committed to submitting a report on rea sonable progress (in the form of a SIP revision) to the EPA every five ye ars following the initial submittal of its regional haze SIP. The reasonable progress report will evaluate the progress made towards the RPGs for the Brigantine National Wildlife Ref uge Class I area **.**

**CONCLUSIONS AND RECOMMENDED AGENCY ACTION** New Jersey ’s Regional H aze SIP establish es the reasonable progress goal for the Brigantine Wilderness Area Class I area in New Jersey . New Jersey ’s SIP adopts long

- term strategies assuring reasonable progress towards the national goal of achieving natural visibility conditions in Class Iareas affected by New Jersey
. The SIP includes al l measures necessary to obtain New Jersey ’s share of emissions reductions needed to meet the RPGs of the B rigantine Wildlife Refuge class I area. Furthermore, the submittal meets the requirements for New Jersey ’s contribution toward meeting the reasonable progress goals for other Class I areas in the northeastern United States
. This submittal also meets the a pplicable visibility

- related requirements of the CAA and EPA regulations. Inorder for EPA to give final approval to New21

Jersey ’s SIP, New Jersey needs to adopt its BART controls as described in its plan as SIP submittals . When that requirement is met , EPA can approve New Jersey ’s Regional Haze SIP, including its BART determinations.22 

### Attachm ent Review of Application of Best Available Retrofit Technology in New Jersey’s Regional Haze State Implementation Plan, July 29, 2011 **BART** Best Available Retrofit Technology (B ART) is an element of New Jersey ’s Long Term Strategy (L TS). The BART Regional Haze requirement consists of three components: (a) identification of all the BART eligible sources; (b) an assessment of whether the BART eligible source s are subject to BART; and (c) the determination of the BART controls. **BART Eligible Sources** The first component of a BART evaluation is to identify all the BART eligible sources. The BART eligible sources were identified utilizing the criteria in th e BART Guidelines (70 FR 39158
- 39161; July

6, 2005) as follows:  Determine whether one or more emissions units at the facility fit within one of the 26 categories listed in the BART Guidelines;  Determine whether the emission unit(s) was in existence on Augu st 7, 1977 and begun operation after August 6, 1962;  Determine whether potential emissions of SO 2 , NO x , and PM 10 from subject units are 250 tons or more per ye ar (tpy). The BART Guidelines recommend addressing SO 2 , NO x , and PM 10 as visibility

- impairment p ollutants and leave it up to the discretion of states to evaluate VOC or ammonia emissions. Because of the lack of tools available to estimate emissions and subsequently model VOC and ammonia effects on visibility , and because New Jersey is aggressivel y a ddressing VOCs through its ozone SIPs, New Jersey determined that SO 2 , NO x and PM 10/2.5 are the only reasonable contributing visibility

impairing pollutants to target under BART. New Jersey

identified five facilities as BART eligible in their July 2009 RH SIP but New Jersey later determined in its March 2011 supplement to the RH SIP that two of these facilities, namely Amerada Hess and Sunoco Eagle Point, had potential emissions of SO 2 , NO x , and PM 10 below the 250 tpy

threshold and therefore were not BAR T eligible. Of the remaining three facilities that are BART eligible, one is an electric generating facility and the other two are petroleum refineries, as described in Table 1 **.** Electric generating units and petroleum refineries fit within the 26 categories listed in the BART Guidelines. For additional details regarding New Jersey ’s identification of sources that are BART eligible, the reader is referred to pp 2

- 14 of New Jersey ’s technical support document (TSD) 6 located in the electronic docket for thi s rulemaking. On March 2, 2011, New Jersey submitted the TSD to EPA for approval as a supplement to the July 2009 RH SIP.

6 “Final BART Determinations for Affected BART

- eligible Sources in the State of New Jersey” March 2, 2011.23 **Table 1**  

### . **New Jersey’s BART Eligible Facilities Facility**  **Pollutants Facility**  **Category Location** 

**(County) Facility I.D.**  PSEG

– Hudson SO 2 , NO x , PM Electric Generating Hudson 12202 Chevron SO 2 , NO x , PM Petroleum Refinery Middlesex 18058 Conoco Phillips SO 2 , NO x , PM Petroleum Refinery Union 41805 Amerada Hess SO 2 , NO x Petroleum Refinery Middlesex 17996 Sunoco Eagle Point SO 2 , NO x , PM Petroleum Refinery Gloucester 55781 **Additional BART Eligible Sou r**  **ces** During EPA’s review of New Jersey ’s RH SIP, EPA discovered two other facilities in New Jersey that might be BART eligible , Vineland Municipal Electric Utility and BL England Ge nerating Station
. These facilities had planned to shut down several ye ars ago, b ut later each facility withdrew th eir request. New Jersey has updated its technical support document to determine BART for the two facilities. EPA evaluates New Jersey ’s BAR T determinations later in this document, following our review of the initial five BART eligible facilities. **BART Subject Sources** The second component of the BART evaluation is to identify those BART eligible sources that may reasonably

be anticipat ed to cause or contribute to visibility impairment at any

Class I area are subject to BART. As discussed in the BART Guidelines, a state may choose to consider all BART eligible sources to be subject to BART. (70 FR 39161) Consistent with the MANE

- VU Board’s decision in June 2004 that because of the collective importance of BART sources BART determination should be made by the MANE

- VU states for each BART eligible source. New Jersey identified each of its BART eligible sources as subject to BART, except, as explained in the previous paragraph, for Amerada Hess and Sunoco Eagle Point. **Determination of BART** The final component of a BART evaluation is making BART determinations for all BART subject sources. In making BART determinations, section 169A(g )(2) of the CAA requires that States consider the following five factors: (1) the costs of compliance; (2) the energy and non

- air quality environmental impacts of compliance; (3) any existing pollution control technology in use at the source; (4) the remai ning useful life of the source; and (5) the degree of improvement in visibility

which may

reasonabl y be anticipated to result from the use of such technology. Section 51.308(e)(2) of the Regional Haze Rule provides that a State may opt to implement an em issions trading program or other alternative measure rather than to require sources subject to BART to install, operate, and maintain BART. To do so, the State must demonstrate that the24

emissions trading program or other alternative measure will achieve greater reasonable progress than would be achieved through the installation and operation of BART. New Jersey did not opt to implement any

alternative measures or programs to BART. The following section reviews New Jersey ’s BART determinations for the rema ining three BART eligible facilities identified in Table 1 above and EPA’s evaluation of each determination. **PSEG -**  **Hudson Generating Station** New Jersey

identified four units that are subject to BART at the PSEG facility located in Hudson County . The four units include two boilers (E1 and E2) serving electric generating units (EGUs) and two coal handling s ystems (E22 and E23) that support the coal fired boiler (E2). The following summarizes New Jersey ’s determination of BART for each of the four units and EPA’s evaluation. For additional details concerning New Jersey ’s BART determination, the reader is referred to pp 29

- 38 of New Jersey ’s March 2011 TSD located in EPA’s electronic docket for this rulemaking. In addition, the reader is referred to PSEG’s preliminary BART control plan, submitted to New Jersey on July 15, 2009, located in Appendix G8 of the State’s July 2009 RH SIP. New Jersey approved the Significant Modifications to PSEG’s title V permit for BART on March 8, 2011. (a) Boiler Unit 1 (E1) Thi s unit is a cyclone boiler generating electricity having a rating of 420 MWe and fires natural gas (onl y natural gas since 2005) but is also permitted to combust No. 6 Fuel Oil. Pre
- BART control measures do not include an y combustion technology or add

- on controls for limiting emissions of NO x , SO 2 or PM, however the use of either natural gas or low sulfur fuel oil limits emissions of SO 2 and PM. Unit 1 is primarily a standby

unit 7 and the area dispatcher (PJM Interconnection 8 ) requested PSEG to operate th is unit on an as needed basis to provide sy stem reliability through at least 2012, and perhaps longer, otherwise PSEG would have retired this unit around 2005. The following summarizes New Jersey ’s BART determinations for NO x , SO 2 and PM for this unit. NO x New Jersey

evaluated eight control measures as BART for control of NOx emissions and determined that SCR (or an equivalent control measure), although not cost effective, would be required to meet an emission limit of 1.00 pound per megawatt hour (lb/MWh) [equivalent to about 0.10 pounds per million BTU heat input (lb/MMBTU)], as measured on a 24
- hr average, when combusting natural gas by May 1, 2015, pursuant to the New Jersey Administrative Code, Title 7, Chapter 27, Subchapter 19 (N.J.A.C. 7:27

- 19). When Unit 1 combusts No. 6 Fuel Oil, Subchapter 19 requires compliance with an emission limit of 2.00 lb/MWh (equivalent to about 0.20 lb/MMBTU), as measured on a 24
- hr average, b y M ay

1, 2015. The aforementioned emission limits and compliance date for ga s and oil firing to meet Subchapter 19 requirements are also New Jersey ’s requirements for Unit 1’s implementation of BART. In addition to requiring the installation of SCR (or equivalent), for meeting BART, New Jersey is requiring PSEG to combust only

natural gas in the boiler unless there is a gas curtailment in which case No.

7 From 2007 to 2010, the annual capacity factor for Unit 1 ranged from 1.6% to 6.7% with an arithmetic mean of about 3.6%. 8 PJM Interconnection is a regional transmission organization (RTO) that coordinates the movement of wholesale electricity in all or parts of 13 states and the District of Columbia, including the State of New Jersey.25

6 Fuel Oil may

be combusted. Table 23 on p34 of New Jersey ’s March 2011 TSD summarizes the NO x control measures evaluated for BART and the cost effectiveness of each. SO 2 New Je rsey

determined that the combustion of natural gas and the restricted use of No. 6 Fuel Oil is BART for controlling emissions of SO 2 from Unit 1. The BART requirement to combust fuel oil only

during periods of gas curtailment is effective upon New Jersey ’ s approval of the permit modification (i.e., March 8, 2011) but no later than December 31, 2011. In addition, New Jersey restricts the sulfur content of No. 6 Fuel Oil to 0.30% (equivalent to approximately 0.33 lb SO 2 /MMBTU) b y weight which will further l imit emissions of SO 2 from Unit 1. The unit’s predominant use of natural gas and its low capacity factor minimize emissions of SO 2 (and PM). SO 2 emission limits when combusting natural gas and No. 6 Fuel Oil are summarized in Table 25 (p 37) of New Jerse y’s TSD. PM10 New Jersey

determined that the combustion of natural gas and the restricted use of No. 6 Fuel Oil is BART for controlling emissions of PM10 from Unit 1. The combustion of natural gas is inherently

low in PM emissions and the restricted use of low sulfur fuel oil also limits PM emissions. The State’s BART PM emission limits when combusting natural gas and No. 6 Fuel Oil are summarized in Table 25 (p 37) of New Jersey ’s TSD. (b) Boiler Unit 2 (E2) This unit is a dry

- bottom wall

- fired boiler gen erating electricit y having a rating of 660 MWe and fires low sulfur bituminous coal but is permitted to also fire natural gas or No. 6 Fuel Oil. Pre

- BART control measures include the use of the following: Selective non

catal yt ic reduction (SNCR) to contro l NOx emissions; Ultra low sulfur ( ≤ 0.25%) coal to control SO 2 emissions; and, optimization of an existing electrostatic precipitator (ESP) to control PM emissions. In July 2002, a Federal consent decree 9 (CD) required PSEG to install state

- of

- the

- art (SOTA) controls for NO x , SO 2 and PM on all coal

- fired boilers in the State of New Jersey , including the PSEG

- Hudson facility . An amended CD extended the compliance date to December 31, 2010. The CD is the basis for New Jersey ’s BART determination for reducing emissions of NO x , SO 2 and PM f rom this unit. NO x As a result of the July

2002 CD, PSEG is required to install selective cataly tic reduction (SCR) control technology using ammonia to reduce NO x emissions. This is in addition to the existing pre

- BART low NO x burner (LNB) control s installed in 2008. When combusting coal, Unit 2 must be in compliance, by December 31, 2010, with an emission limit of 0.15 lb NO x /MMBTU, measured on a 24

- hr average, and 0.10 lb NO x/MMBTU, as measured on a 30

- day

average. New Jersey

reports that init ial CEMS results for the first few months of operation have been approximately 0.09 lbs NO x /MMBTU on a 24

- hr average. This compares to EPA’s “presumptive” level of 0.39 lb/MMBTU (see Table 1 of EPA’s Appendix Y BART Guidelines) for the same t ype boiler a s Unit 2 (dry

bottom wall

- fired unit that combusts bituminous coal). Therefore, initial operating

9 http://www.epa.gov/compliance/resources/cases/civil/caa/psegfs.pdf26

results indicate that the BART controls for limiting NO x emissions are better than EPA’s presumptive level. SO 2 As a result of the July

2002 CD, PSEG is r equired to reduce SO 2 emissions by installing a spray dry er absorber with baghouse, using lime as the alkali, and to limit the sulfur content of the coal to ≤ 2.00%. When combusting coal, Unit 2 must be in compliance, b y December 31, 2010, with an emission limit of 0.25 lb SO 2 /MMBTU , measured on a 24

- hr average, and 0.15 lb/MMBTU, as measured on a 30

- day average . New Jersey

indicates that initial CEMS result s for the first few months of operation have been about 0.132 lb SO 2 /MMBTU on a 24

- hr average. PSEG indicates that initial results indicate SO 2 reductions of approximately 92%. EPA’s “presumptive” level for an EGU greater than 200 MW that is uncontrolled and located at a 750 MW power plant, is an SO 2 emission limit of either 0.15 lb/MMBTU or 95% reduction. Therefore, initial operating results indicate that the BART controls for reducing SO 2 emissions are slightl y better than EPA’s presumptive level. P M As a result of the July

2002 CD, PSEG is required to reduce PM emissions by installing a baghouse. This baghouse is installed in conjunction with the installation of the spray dry er absorber for controlling emissions of SO 2 . An existing electrostatic p recipitator removes fl y ash upstream of the spray dryer absorber/baghouse combination. When combusting coal, Unit 2 must be in compliance, by December 31, 2010, with a BART emission limit of 0.015 lb PM/MMBTU. PM emission limits for BART when combusting n atural gas and No. 6 Fuel Oil are summarized in Table 25 (p 38) of New Jersey ’s TSD. (c) Coal Handling S ys tem (E22 and E23) The coal receiving s ys tem (E22) and the coal reclaim sy stem (E23) are support sy stems for the Unit 2 (E2) coal fired boiler. The Coa l Handling Sy stem does not have any emissions of NO x or SO 2 but does emit PM when there are wind conditions at the facilit y. Since the potential to emit PM is low (2.7 tpy for E22 and 1.2 tpy

for E23), New Jersey has determined that BART for the Coal Hand ling Sy stem is the continued use of PSEG’s existing controls including a water dust suppression sy stem and covers on the conveying sy stems to minimize PM emissions. PM emission limits for BART are the existing title V permit conditions as summarized in Ta ble 25 (p 38) of New Jersey ’s TSD. (d) EPA’s Evaluation of New Jersey ’s BART Determination for PSEG EPA agrees with New Jersey ’s determinations for establishing BART requirements on the four units subject to BART at the PSEG

- Hudson facility . New Jersey di d not conduct a 5
- factor analy sis for determining BART for any of the units subject to BART since maximum control technology or control measures have alread y been implemented as BART on the two boilers and the PM emissions from the Coal Handling S ystems have very low potential to emits (PTEs) and have adequate existing PM control sy stems. Since EPA guidance 10 does not require a 5

- factor analy sis whenever maximum controls are determined to be BART, EPA agrees with New Jersey ’s BART determinations. New Jerse y has included the BART requirements in final title V permits and the State’s SIP

10 See EPA’s document “Additional Regional Haze Questions” August 24, 2006. See Q&A # 15.27

supplement will includes a summary of BART compliance requirements for monitoring, reporting and recordkeeping. New Jersey plans to submit this SIP supplement during Novembe r 2011. Since New Jersey has established BART requirements, including enforceable permit limits, in accordance with EPA guidance EPA recommends proposed approval of New Jersey ’s BART determination for the PSEG

- Hudson Station. **Chevron Products Co.** 

**– Pert**  **h Amboy** New Jersey

identified two units that are subject to BART at the Chevron petroleum refinery located in the cit y of Perth Amboy, Middlesex County. The two units are both fuel gas

- fired furnaces (E1501 and E1502), also referred to as process heaters, serving the petroleum refinery
. The following summarizes New Jersey ’s determination of BART for the two units and EPA’s evaluation. For additional details concerning New Jersey ’s BART determination, the reader is referred to pp 8

- 10 and 17

- 18 of New Jer sey ’s March 2011 TSD located in EPA’s electronic docket for this rulemaking. New Jersey approved the Significant Modifications to PSEG’s title V permit for BART on March 4, 2011. (a) Gas
- Fired Furnaces (E1 501 and E1502 ) For the two BART

- subject units, the pre

- BART PTEs are as follows: 40.5 tpy SO 2 , 262.2 tpy NO x , and 32.7 tp y PM. In addition, the annual emissions for these two units have been low (see p 17 of New Jersey ’s TSD). From 2005

- 2008, the estimated annual emissions as a percentage of PTE for these two units are as follows: 55%

- 10.5% (35% average) for E1501; and 16.8%

- 2.5% (11.7% average) for E1502. In 2009, both units did not operate at all. Chevron submitted its BART proposal to New Jersey in March 2009 (see Appendix G8 of New Jersey ’s July 2009 RH SIP revision) but subsequently decided to ”cap

- out” the emissions of NO x to below the BART

eligible threshold of 250 tpy . Thus, each visibility impairing pollutant (SO 2 , NO x and PM) from the two furnaces were scheduled to be below the BART

- eligible PTE threshold of 250 tpy by the effective compliance date of March 4, 2011. Since the modification to the title V permit allowed the facility

to avoid becoming subject to a Federal rule, it was considered a “significant” modification and was subject to public notice and a 30

- day comment period. New Jersey reports that no comments were received during this 30

- day comment period. The title V permit requires Chevron to limit heat input to each furnace and to monitor and report annual emissions to limit the PTE of each pollutant to below 250 tpy . New Jersey requires Chevron to report the amount of fuel burned and actual emission rates in accordance with its Emissions Statements program adopted b y the State at Subchapter 21 (N.J.A.C. 7:27

- 21). (b) EPA’s Evalu ation of New Jersey ’s BART Determination for Chevron EPA agrees with New Jersey ’s BART determination for the two BART

- eligible units at the Chevron facilit y located in the city of Perth Amboy. Chevron has proposed and New Jersey has approved limiting the PTE of each visibility impairing pollutant from units E1501 and E1502 to below 250 tpy

thereby satisfying BART requirements. Since the two units at Chevron have approved and effective title V permits that will result in limiting the emissions of each visibility impairing pollutants to less than 250 tpy , the two units no longer meet the criteria for establishing a unit as being BART eligibility . Therefore the two units are not subject to BART and are not required to implement any BART requirements to furth er limit emissions of visibility impairing pollutants. It should be noted that should Chevron request to operate the two units such that the cumulative PTE of the two units equals or exceeds 250 tp y, then E1501 and E1502 shall be subject to BART and the f acility ’s title V permit would need to be revised to include new applicable requirements. New Jersey ’s BART anal ys is and determination meets the criteria28

in EPA’s BART Guidelines (70 FR 39158

- 39161; July 6, 2005) and is therefore acceptable to EPA. New J ersey

has included the BART requirements in final title V permits which will be submitted to EPA in a November 2011 SIP supplement along with a summary of BART compliance requirements for monitoring, reporting and recordkeeping. Since New Jersey has estab lished BART requirements, including enforceable permit limits, in accordance with EPA guidance and the CAA, EPA recommends proposed approval of New Jersey’s BART determination for the two process heaters located at the Chevron facility in the city of Perth Amboy
. **ConocoPhillips Bayway Refinery** New Jersey

identified eleven units that are subject to BART at the ConocoPhillips (CP) petroleum refinery

located in the city

of Linden, Union County . The eleven units are all refinery fuel gas

- fired process heater s. The list of process heaters, as well as equipment descriptions, determined b y the State to be subject to BART are listed in Table 16 on p 26 of New Jersey’s TSD. For additional details concerning New Jersey ’s BART determination, the reader is referre d to pp 10
- 13 and 19

- 29 of the State’s March 2011 TSD located in EPA’s electronic docket for this rulemaking. In addition, the reader is referred to CP’s proposal for BART submitted to New Jersey and located in Appendix G8 of the State’s July 2009 RH SIP. It should also be noted that, on January 27, 2005, the US Department of Justice (DOJ), EPA and New Jersey

Department of Environmental Protection (NJDEP) entered into a national enforceable consent decree 11 (CD) with CP, including its Bay way refinery . Th e CD identifies “boilers and heaters,” as well as other equipment categories, as affected units requiring reductions in NO x and SO 2 , precursors of fine PM. The eleven process heaters subject to BART are also subject to the requirements of the CD. On Janu ary 27, 2005, CP discontinued the use of fuel oil combustion in the eleven process heaters. In addition, the CD obliges CP to upgrade the refinery fuel gas s ys tem by

December 31, 2010 and to comply with the hydrogen sulfide (H 2 S) requirements of the NSPS for petroleum refineries (40 CFR Part 60,Subpart J) by June 30, 2011. Absorbers are used as control technology to reduce H 2 S emissions from the refinery fuel gas. Combustion of H 2 S in the process heaters results in the formation of SO 2 emissions. The NS PS Subpart J requires that the H 2 S concentration of refinery fuel gas to be combusted in process heaters is to be less than 0.10 grains/dry standard cubic feet (gr/dscf) which is equivalent to 162 parts per million dry

(ppmd). The SO 2 emission concentrati on resulting from the combustion of refinery fuel gas containing 162 ppmd H 2 S would also be 162 ppmd. CP submitted an application for Significant Modifications to its title V permit for the eleven units subject to BART and New Jersey has provided for a 30
- day public comment period that ends on July

30, 2011. New Jersey

is expected to approve and submit those elements of the title V permits to EPA, as a supplement to the July 2009 RH SIP, in November 2011. The following summarizes New Jersey ’s determin ation of BART for the eleven units and EPA’s evaluation. NO x New Jersey

considered seven control measures as potentially BART applicable for control of NO x emissions and determined that ultra low NO x burners (ULNB) with internal flue gas recirculation (FGR), the control measure currently being implemented on each of the eleven process heaters, is BART. For details, the reader is referred to Table 7 on p 16 of New Jersey ’s TSD and to CP’s analy sis found in Appendix G8 of the State’s July 2009 RH SIP. New Jersey determined that SCR was not cost effective and that SNCR was not feasible due to temperature

11 http://www.epa.gov/compliance/resources/cases/civil/caa/conocophillips.html29

variations in the process heaters. In addition, process heaters combusting refinery fuel gas with a heat input of 50 million BTU or greater, are subject to the State’s NO x regulation at N.J.A.C. 7:27
- 19.7(h) requiring NO x emissions of 0.20 lb/MM BTU. Also, New Jersey ’s State of the Art (SOTA) Manual for Petroleum Refineries requires process heaters with replacement burners to meet a NO x performance emission limit of not more than 0.07 lb/MM BTU. New Jersey reports that the process heaters at CP’s Bay way refinery have a measured average overall NO x emission rate of approximately

0.04 lb/MM BTU (see p 20 of New Jersey ’s TSD). New Jersey has established BART NO x emission limits, expressed in pounds per hour for any 60
- minute period, for the eleven process heaters and are summarized in Table 16 on p 26 of the State’s TSD. The BART requirements for the process heaters are alread y included in CP’s title V permit
. SO 2 New Jersey

considered three control measures as potentially BART applicable for control of SO 2 emissions and determined that CP’s compliance with the January 2005 CD is BART. The CD requires upgrading the existing gas s ys tem to comply with the NSPS Subpart J that requires limiting the H 2 S concentration in the refinery fuel gas combusted in the process heaters to less than 0.10 gr/dscf (162 ppmd). For details, the reader is referred to Table 7 on p 16 of New Jersey ’s TSD and to CP’s analy sis found in Appendix G8 of the State’s July 2009 RH SIP. In its BART analy sis, New Jersey determined that scrubbers were not technically feasible and fuel processing was not practically applicable to individual process heaters. As indicated above, CP is obligated b y the CD to upgrade the fuel gas s ys tem (that provides fuel to the process heaters) to comply

with the NSPS Subpart J that requires reducing the H 2 S concentration to not more than 162 ppmd. Section 60.104 of Subpart J provides the standards for SO 2 emissi ons at petroleum refineries. Subpart J also requires continuous monitoring of the H 2 S concentration and the State is requiring H 2 S concentration measurements on a 3

- hour rolling average. CP’s current title V permit alread y requires monitoring the H 2 S con centration of the refinery fuel gas. New Jersey

estimates that when CP’s refinery fuel gas s ys tem is full y upgraded, the SO 2 emissions from the process heaters will be approximately 0.033 lb/MM BTU (see Table 15 on p 25 of New Jersey ’s TSD). EPA’s RH gu idance does not have an y presumptive limits for petroleum refineries but, for comparative purposes, EPA’s presumptive SO 2 limit for a large (200 MW at a 750 MW facility) uncontrolled coal

- fired EGU is either 95% removal or 0.15 lb/MM BTU. EPA’s presumptiv e limit for oil

- fired boilers is that the sulfur content should be limited to 1% (equivalent to about 1.0 lb/MM BTU) or less. Therefore, CP’s SO 2 emission limit of 0.033 lb/MM BTU compares very favorabl y to EPA’s presumptive limits for oil and coal fired boilers. For BART, New Jersey

has established SO 2 emission limits, expressed in pounds per hour for any 60
- minute period, and H 2 S emission limits in the refinery fuel gas, expressed as ppmd for a three hour rolling average, for the eleven process heater s, as summarized in Table 16 on p 26 of the State’s TSD. New Jersey is requiring CP to be in full compliance with Subpart J requirements b y June 30, 2011. One of the process heaters (E258), the largest of the 11 BART subject heaters, was already in compl iance with Subpart J. As stated earlier, New Jersey is expected to approve and submit the BART elements of the title V permits to EPA, as a supplement to the July

2009 RH SIP, in November 2011. PM New Jersey

considered three control measures as potenti ally BART applicable for control of PM emissions and determined that the continued requirement of “good combustion practices” and the upgrade to the refinery

fuel gas sy stem represents BART for the eleven process heaters. For30

details, the reader is referr ed to Table 7 on p 16 of New Jersey ’s TSD and to CP’s analy sis found in Appendix G8 of the State’s July 2009 RH SIP. New Jersey determined that implementation of either wet scrubbers or ESPs were not technicall y feasible with refinery fuel gas that alread y has low sulfur concentrations. In addition, New Jersey ’s NO x regulation, Subchapter 19, requires annual adjustment of the process heaters in accordance with manufacture’s recommended procedure and maintenance schedule to ensure complete combustion throu gh “good combustion practices.” Annual adjustment to the combustion practice is expected to limit NO x and also PM emissions. Furthermore, the upgrade to the refinery fuel gas s ys tem will lower SO 2 emissions, a precursor of fine PM, from the process heater s. New Jersey expects PM emissions to be in the approximate range of 0.01 to 0.02 lb/MM BTU (see Table 16 on p 26 of New Jersey ’s TSD). EPA does not have an y BART presumptive limits for PM. New Jersey

has established BART PM emission limits, exp ressed in pounds per hour, for the eleven process heaters and are summarized in Table 16 on p 26 of the State’s TSD. As stated above, New Jersey

is expected to approve and submit the BART elements of the title V permits to EPA, as a supplement to the July 2009 RH SIP, in November 2011. EPA’s Evaluation of New Jersey ’s BART Determination for ConocoPhillips EPA agrees with New Jersey ’s determinations for establishing BART requirements on the eleven process heaters subject to BART at the ConocoPhillips Bay way Refinery . Since the State determined that the existing control measures are BART, New Jersey conducted a limited rather than a full 5

- factor anal ysis for determining BART. In its analy sis, New Jersey examined applicable control technologies and establis hed that SCR technology was not cost effective for controlling NOx emissions. For SO 2 and PM, New Jersey determined that that the evaluated control technologies were not practically feasible. In its March 2011 TSD, and as noted above, New Jersey

also est ablished that either the actual or permitted emission limits are as follows: NO x (0.04 lb/MM BTU measured average; and approximately 0.09 lb/MM BTU permit ), SO 2 (0.033 lb/MM BTU equivalent permitted) and PM (0.01

- 0.02 lb/MM BTU permit). EPA considers that these emissions are equivalent to or better than what could be achieved on a coal fired boiler using maximum controls, i.e. SCR, scrubber and a baghouse (see discussion above for the PSEG Hudson Unit 2 that has the SCR, scrubber and baghouse configuration that EPA considers as maximum controls). EPA is in agreement with New Jersey ’s limited evaluation for determining BART for the eleven process heaters at CP for the following reasons: (1) emission levels of the three visibility impairing pollutants at CP are low and equivalent to emissions levels at coal

- fired EGUs that implement maximum control technology ; and (2) in accordance with EPA guidance, a state is not required to include a five factor anal ys is for a BART source that implements maximum controls; and (3) New Jersey evaluated alternative control technologies that were determined to be not feasible. New Jersey

will be including the BART requirements in a SIP supplement including final title V permits and a summary

of BART compliance requirements for monitoring, reporting and recordkeeping. New Jersey plans to submit this SIP supplement during November 2011. Since New Jersey

has establishing BART requirements and is including these requirements in enforceable permits, in accordance with EPA guidance, EPA recommends proposed approval of New Jersey ’s BART determination for the ConocoPhillips Bay way Refinery
. **Determination of BART**

**– Additional BART Eligible Facilities in New Jersey**  During EPA’s review of New Jersey ’s July 2009 and March 2011 RH SI P, EPA discovered that two other facilities within the State had units that were BART eligible. These two facilities were not originall y identified by New Jersey as BART eligible since the facilities indicated they31

planned to shut down but later withdrew this request. EPA has worked closely with New Jersey in determining BART for these two facilities. As a result, in a letter dated July 25, 2011 from the State addressed to EPA, New Jersey provides an addendum to its March 2011 TSD that discusses its BART determination for the two additional facilities that are BART eligible. For additional details, the reader is referred to New Jersey ’s July 2011 letter to EPA that is located in the electronic docket for this rulemaking. In the July 2011 letter, New Jers ey

has indicated that its BART determination, as summarized in a new addendum to the March 2011 TSD, will be submitted to EPA in November for approval as a supplement to the State’s July 2009 RH SIP, after the opportunity

for public comment
. Following is New Jersey’s determination of BART for the two facilities, Vineland Municipal Electric Utility

and BL England Generating Station, as indicated in New Jersey ’s July 2011 letter to EPA, as well as EPA’s evaluation of New Jersey ’s BART determination. Vi neland Municipal Electric Utility The first BART eligible source, Unit 10 at Vineland Municipal Electric Utility ’s Howard M. Down Station is under a F ederal consent decree 12 to either install additional pollution control measures or to permanently shut down by

September 1, 2012. On July 1, 2011, Vineland’s Director submitted written certification to EPA and New Jersey that Unit 10 will be retired from service b y September 1, 2012. Vineland is required to submit a permit application by July 30, 2011 and New Jersey

plans to submit this element of the permit to EPA as a supplement to the RH SIP by

November 2011. Itshould be noted that after Unit 10 is permanently shut down, the facility , in accordance with EPA’s Guidelines, will no longer be BART eligible si nce the PTE of each visibility

impairing pollutant will be less than 250 tpy . An additional BART eligible unit at this facility

is a distillate fuel oil

- fired emergency generator, rated at 2.3 MM BTU/hr, that has not operated for more than 10 y ears. Sinc e this emergency generator is small and rarely used, New Jersey

and EPA consider the current operation as BART and therefore does not need to implement additional controls. New Jersey requires that the facility

maintain records of emergency

use and report any

annual emissions. Furthermore, as previously stated, once Unit 10 is permanentl y shut down, the facility, including the emergency generator, will no longer be BART eligible. EPA is in agreement with New Jersey ’s BART determination for the two units at Vineland because it conforms to EPA’s BART Guidelines. Therefore, EPA proposes approval of New Jersey ’s BART determination for Vineland. BL England Generating Facilit y The second BART eligible facility is the BL England Generating Station , located in Cape May County , owned

/operated by

R C Cape May

Holding. This facility

has three electric generating units that are BART eligible

- Units 1, 2 and 3

- as well as three miscellaneous units including a coal handling sy stem that supports Units 1 and 2; a cooling tower that supports Unit 3; and an emergency

fire water diesel engine. Units 1 and 2 are currentl y under an administrative compliance order 13 (ACO), as amended in January 2010, with New Jersey to either repower or meet performance requirements for NOx, SO2 and PM. The ACO requirements for Units 1 and

12 US District Court in New Jersey, Civil Action 1:11

- cv - 1826(RMB

- JS), see paragraph 14. 13 See Attachment 5 and 6 to New Jersey’s TSD dated July 25, 2011.32

2 are alread y included in the title V permit. New Jersey has determined that the required future controls on Units 1 and 2, both coal

- fired boilers, and the current and future controls on Unit 3, an o il

- fired boiler, are BART. New Jersey defines “repowering” to mean the replacement of an existing coal

- fired boiler with a new heat source (e.g., natural gas or distillate oil) or new coal

combustion technology

(e.g., circulating fluidized bed boilers or integrated gasification combined

- cycle (IGCC) technology
. RC Cape May Holding has indicated to New Jersey that it is evaluating the conversion of Units 1, 2 and 3 to either natural gas or No. 2 fuel oil. It should be noted that the State’s Sulfur in Fuel Oil regulation, Subchapter 9, limits the sulfur content of No. 2 Fuel Oil to not more than 0.015% effective July 1, 2016. To the extent that RC Cap May decides to convert one or all of the units, New Jersey anticipates that RC Cape May would submit a spe cific proposal that addresses applicable requirements including BART . For the reasons stated in the discussion below, EPA is proposing approval of New Jersey ’s BART determination for the BL England facilit y. Following are additional details for each unit
. Unit 1 Unit 1 is a 129 MW cyclone wet bottom coal fired boiler and permitted to combust up to 8% tire derive fuel (TDF) or No. 6 Fuel Oil. Under the amended ACO, this unit must either repower b y December 15, 2011 or meet performance standards by D ecember 15, 2013. The new performance standards are as follows: (1) for NOx, the existing SNCR will be replaced with SCR and the existing over fire air (OFA) control system will remain

- to lower NOx emissions from 0.60 lb/MM BTU (seasonal) to 0.11 lb/MM BTU on a 30
- day average and 0.15 lb/MM BTU on a 24
- hr average; (2) for SO2, install a circulating dry scrubber to meet an emission limit of 0.15 on a 30

- day

rolling average and 0.25 lb/MM BTU on a 24

- hr average; for PM, upgrade the electrostatic precipitator, and meet an emission limit of 0.03 lb/MM BTU
. As a result, New Jersey ’s TSD indicates that NO x emissions will be reduced b y about 85% and SO 2 emissions will be reduced b y about 97% (see Table 9A in New Jersey ’s TSD)
. EPA considers that, by December 15, 2013, Unit 1 will be implementing maximum control measures for limiting emissions of NO x , SO 2 and PM that meet EPA’s BART guidance 14 and therefore EPA agrees with New Jersey ’s determination . I f the owners decide to repower, New Jersey requires the owne rs to incorporate advances in the art of air pollution control and EPA expects that emissions will be at least equal to or lower than the performance standards indicated above. It should be noted that RC Cape May , the owner/operator, has indicated to New Jersey that there is some uncertaint y as to the start

- up date of Unit1 and therefore they believe that this Unit may possibly not be BART eligible. However, New Jersey has indicated that until RC Cape May can provide proper documentation as to the start

- up date, Unit 1 will be considered BART eligible. Unit 2 Unit 2 is a 160 MW cyclone wet bottom coal

- fired boiler and permitted to combust up to 8% TDF or No. 6 Fuel Oil. In accordance with the amended ACO, Unit 2 must repower b y December 15, 2011 or mee t performance standards for SO2 and PM by May 1, 2010, and NOx

14 See EP A’s document “Additional Regional Haze Questions” August 24, 2001. See Q&A # 15.33

performance standards by May 1, 2012. The required performance standards are as follows: (1) for NO x , upgrade the current controls (selective non

- catal yt ic reduction (SNCR) by i nstall ing select ive catal yt ic reduction (SCR) and continue to implement the existing over fire air (OFA) controls to achieve an emission limit of 0.11 lb/MM BTU on a 30

- day rolling average and 0.15 lb/MM BTU on a 24

- hr average; (2) for SO 2 , continue utilizing (compliance as of May 1, 2010) wet flue gas desulfurization (FGD) controls for limiting emissions to 0.15 lb/MM BTU on a 30

- day rolling average and 0.25 on a 24

- hr average; (3) for PM, continue (compliance as of May 1, 2010) the use of an electrostatic precipitator (E SP) for controlling emissions to 0.030 lb/MM BTU on a 3
- hr average
. EPA considers that, b y May 1, 2012, Unit 2 will be implementing maximum control measures for limiting emissions of NO x , SO 2 and PM that meet EPA’s BART guidance and therefore EPA agrees w ith New Jersey ’s BART determination . If the owners decide to repower, New Jersey requires the owners to incorporate advances in the art of air pollution control and EPA expects that emissions will be at least equal to or lower than the required amended AC O performance standards indicated above. Unit 3 Unit 3 is a 160 MW oil

- fired tangential boiler that combusts No. 6 Fuel Oil and primaril y operates during the summer season on day s when the demand for electricity is high (high electric demand day s (HE DD)). Since 2008, the annual operating capacit y factor has averaged about 3% and has not been more than 32% since 1999. This unit annually employ s SNCR controls and must meet a NO x permit limit of 2.0 lb/MW

- hr (equivalent to 0.20 lb/MM BTU) b y M ay 1, 201 5. For controlling SO 2 emissions this unit combusts No. 6 fuel oil with a sulfur limit of 0.70% which is lower than EPA’s presumptive limit for an oil fired boiler. In accordance with New Jersey ’s Sulfur in Fuels regulation, Subchapter 9, this unit will be required to combust No. 6 Fuel Oil with a sulfur content of not more than 0.50% by July 1, 2014. PM emissions are controlled with a mechanical cyclone and permitted at 505 lb/hr (equivalent to 0.29 lb/MM BTU). Since this is an HEDD unit that operates for very limited periods and includes SNCR control and low sulfur fuel oil, emissions are relatively low. EPA considers that, by May 1, 2015, Unit 3 will be implementing maximum control measures for limiting emissions of NOx, SO2 and PM that meet EPA’s BA RT guidance and therefore EPA agrees with New Jersey ’s BART determination. Coal Handling Sy stem There are nine units in the coal handling s ys tem that provides support to the two coal

- fired units. These units emit PM but not NOx or SO 2 . To minimize PM emissions, these unloading, processing and transfer units are covered and an y fugitive PM emission are controlled with surfactant

- based wet suppression (with the exception of 3 of the 9 units). New Jersey has indicated that the cumulative PTE for these ni ne units is 6.1 tpy . As with the PSEG coal handling s ys tem (see previous PSEG discussion for BART in this TSD), New Jersey and EPA consider these fugitive emissions to be minimal and therefore the existing controls are BART. Emergency

Fire Water Diesel Engine When in operation, this diesel engine emits NOx, SO 2 and PM. New Jersey notes that this unit ty picall y operates for less than two hours per ye ar and, by July 1, 2016, will be required to combust oil with a sulfur content not more than 0.015% (15 pp m). This lower sulfur oil is much lower than EPA’s presumptive limit (1.0% sulfur) for an oil fired boiler. Because of limited use, the implementation of any control on this emergency engine is most probably

not cost effective. Therefore, New Jersey

and EPA conclude that this engine does not need additional controls34

because its emissions are small and it operates very infrequentl y. For these reasons, EPA agrees with New Jersey ’s BART determination. Unit 3 Cooling Tower PM are the onl y emissions from this unit. This natural draft cooling tower circulates treated sea water in a closed loop system and is equipped with high efficiency mist eliminators. The use of a high efficiency

mist eliminator minimizes PM emissions and therefore this control measure is considered BART.

Recommendation In summary , EPA should propose approval of New Jersey ’s BART eligibility determinations and BART requirements as they provide for maximum controls where feasible. EPA agrees with New Jersey ’s evaluation of those units which are not eligible for BART or are too small for control.35 

### Attachm ent Review of New Jersey State
- wide 2002 and 2018 Projection Modeling Inventories

and Reasonable Progress Goal Inventory Demonstration for the Regional Haze SIP , December 7, 2010 

## PREFACE This document is to support EPA's evaluation of the 2 018 projection inventories and Reasonable Progress Goal (RP G ) Plan included in New Jersey’s Regional Haze State Implementation Plan (SIP) for the entire State of New Jersey . The intende d effect of this action is to evaluate inventory components required by

the Clean Air Act (Act) to summarize the emission reductions needed from 2002 to 2018 to meet the goal of improving visibility at Class I areas affected by New Jersey
. However, detail ed evaluation of the 2002 inventory will not be addressed in this document. The reader is referred to Region 2’s document entitled New Jersey State 2002 Base Year Inventory

SIP Technical Support Documentation for details on the approval of New Jersey ’s 20 02 base y ear inventory . EPA proposed to approve New Jersey ’s 2002 Base Year inventories on May

9, 2006, (71 FR 26895) and approved the emission inventories on July 10, 2006 (71 FR 38770). This document contains a detailed review of the New Jersey ’s sub mittal. Among the topics discussed below are: background and criteria for approval and EPA’s final recommendation. 

## BACKGROUND **REASONABL E**  **PROGRESS GOALS**  Section 51.308(d)(4)(v) of EPA’s Regional H aze Rule (RHR) , 40 CFR 51.308, requires the establis hment of a statewide emissions inventory of pollutants that are reasonably anticipated to c a use or contribute to visibility impairment in an y mandatory Class I area. The pollutants inventoried by New Jersey include VOC, NOx, PM2.5, PM10, SO2 and NH3
. In a ddition, Section 51.308(d)( 3 )( iii ) of RHR requires the State to identify a baseline emissions inventory upon which future projections will be based and from which necessary emission reductions for meeting reasonable progress goals can be determined. This document provides information on the development of a projected inventory for 2018 from the 2002 base y ear.
**The 2018**  **Reasonable Progress Goal**  **Plans Inventory Demonstration**  The State is required to submit a Regional Haze SI P that includes a Reasonable P rogress Goal (RPG) Plan inventory

demonstration for pollutants that contribute to Regional Haze . The SIPs must demonstrate that the 2002 base ye ar inventory , projected to 2018 with growth and includ ing control measures incorporated in rules that are adequ ate to provide for the timely reasonable progress in reducing emissions to reach 2018 projected emissions inventory control levels.36

There are general and specific components for an acceptable 20 18 projection inventory and RPG inventory demonstration . In general, the State must submit a revision to its SIP and the aforementioned components must meet certain minimum requirements for reporting b y source category . Specificall y, the source requirements are detailed below. A review process is used to determi ne that all components of the projection inventories and RPG inventory demonstration are present. The review also evaluates the level of supporting documentation provided by the State and assesses whether the emissions were developed according to current EPA or acceptable alternative guidance. 

## CRITERIA FOR APPROVAL **Projection and RPG**  **Inventory Demonstration**  There are several points that the projection inventories and RPG inventory demonstration must adequatel y address. For the projection inventories and RPG inventory demonstration to be acceptable they

must pass the following acceptance criteria: 1. **W ere**  **the 20 18**  **projection inventories developed in accordance with the procedures outlined EPA’s latest guidance**  **1,3,4,6,7 ?** 
2. **Were the Plans developed in ac**  **cordance with EPA’s latest guidance for Growth Factors, Projections, and Control Strategies for R**  **easonable Progress**  **Goal Plans 1,3,4,6,7**  **?**
**DETAILED ACTION AND EVALUATION** This portion of the report contains a discussion and summary of the review conducte d by EPA for the 20 18 projection inventories and RPG inventory demonstration
. 

### Section 1: **2002 BASE YEAR INVENTORY Calculation of 2002 Base Year Emission Inventory**  The reader is referred to Region 2’s document entitled New Jersey State 2002 Base Year Inventory SIP Technical Support Documentation for details on the approval of New Jersey ’s 2002 base year inventory. EPA proposed to approve New Jersey’s 2002 Base Year inventories on May 9, 2006, (71 FR 26895) and approved the emission inventories on July 1 0, 2006 (71 FR 38770). The reader is referred to these rulemakings for additional information concerning the emission inventories and EPA’s approval.37

**Table 1** below shows the revised 2002 VOC, NOx, PM2.5, PM10, SO2 and NH3 state

- wide modeling base ye ar emission inventories for the New Jersey
. 

### Table 1 **2002 New Jersey Statewide Base Year Modeling Inventory (Tons/Year)** 

Pollutant Major Point

Sources Area Sources Nonroad Mobile Sources Onroad

Mobile Sources Total **VOC** 16,547 167,883 83,919 110,529 378,877 **NOx** 51,593 26,692 63,479 161,289 303,053 **PM 2.5**  4,779 17,004 4,997 2,529 29,350 **PM 10**  6,072 31,664 5,501 3,785 47,021 **SO2** 61,217 10,744 15,686 3,627 91,373 **NH 3**  0 17,572 43 7,316 24,931 

## Section 2: **Calculation of 2018 Projection Year Emission Inventories**  A projection of 2002 VOC, NOx, PM2.5, PM10, SO2 and NH3 anthropogenic emissions to 20 18 is required to determine the emission reductions needed for RPG inventory demonstration . The 20 18 projection y ear emission inventories are calculated by multiplying the 2002 base y ear inventory by factors which estimate growth from 2002 to 20 18 . A specific growth factor for each source t ype in the inventory is required since sources t ypicall y grow at different rates. Projection Methodology **Point Sour ces**  **Electric Generating Units (EGU s**  **)** For the major point source category , the projected emissions inventories were first calculated b y estimating growth in each source category . As appropriate, the 2002 emissions inventory was used as the base for applyi ng factors to account for inventory growth. The point source inventory was grown from the 200 2 inventory to 20 18 for each facility

using growth factors utilized in Integrated Planning Model to forecast growth based on the following variables/factors: elec tric demand; natural gas, oil and coal suppl y forecasts; pollution control and performance; capacity cost and performance, and replacement of older less efficient and polluting power plants with newer more efficient units to meet future growth and state by state NOx and SO2 caps. The reader is referred to Section 5 o f State of New Jersey Department of Environmental Protection SIP for Regional Haze Final , dated July 2009, and Documentation of 2018 Emissions38

from EGUs in the Eastern United States for MANE

- VU ’s Regional H aze Modeling , dated August 15, 2009. These document s provide further details and references on how projections were performed. **Non -**  **Electric Generating Units ( Non**  **- EGU**  **s )**  For the major point source category , the projected emissions inventories were first calculated b y estimating growth in each source category . As appropriate, the 2002 emissions inventory was used as the base for applying factors to account for inventory growth. The point source inventory was grown from the 2002 inventory to 20 18 for each facility

based on source classification codes using growth factors generated from EPA’s Economic Growth Anal ys is Sy stem (EGAS) version 5.0, United States Department of Energy ’s (USDOE) Annual Energy Outlook Projections (AEO) 2005, state supplie d population and employ ment data, where appropriate. The reader is referred to Section 5 of State of New Jersey Department of Environmental Protection SIP for Regional Haze Final , dated July 2009 and Development of Emissions Projections for 2009, 2012 and 2018 for Non

- EGU Point, Area and Nonroad Mobile Sources in the MANE

- VU Region, Final Report , dated February 2007 . Th ese document s provide further details and references on how projections were performed. Since these methods and growth indicators are some of the preferred growth indicators to use as outlined in EPA Guidance, 1,3,4,6,7 **EPA finds New Jersey**  **’s methodology for projecting point sources to be acceptable. Area Sources**  For the area source category , New Jersey projected emissions from 2002 t o 2018 using growth factors generated from EPA’s EGAS version 5.0, USDOE AEO 2005, state supplied population and employ

ment data, where appropriate. This is in accordance with EPA’s recommended growth indicators for projecting emissions for area source categories as outlined in EPA Guidance. 1,3,4,6,7 The reader is referred to Section 5 of State of New Jersey Department of Environmental Protection SIP for Regional Haze Final , dated July 2009 and Development of Emissions Projections for 2009, 2012 and 2018 for Non

- EGU Point, Area and Nonroad Mobile Sources in the MANE

- VU Region, Final Report , dated February 2007 . Th ese document s provide further details and references on how projections were performed.
**EPA finds New Jersey**  **’s methodology for projecti ng area sources to be acceptable.** 39

**Non -**  **Road Mobile Sources** Non
- road vehicle equipment emissions were projected from 2002 to 20 18 using the EPA’s National Mobile Inventory Model (NMIM) 2005 . N MIM 2005 contains growth factors, which are based on the historical trends in nonroad equipment activity . This model was use to calculate past and future emission inventories for all nonroad equipment categories except commercial marine vessels, locomotives and aircrafts. Emissions were determined on a monthly basis and combined to provide annual emission estimates. **Aircrafts , Locomotives and Commercial Marine Vessels (CMV)**  Aircraft , l ocomotives and CMV emissions were projected based on combined growth and control factors from USEPA Clean Air Interstate Ru le (CAIR) by determining the level of emissions and their associated ratios between 2002 base and 2025 projection y ear. From this point, the State determine the ratio of emissions between 2002 and 2018 projection y ear using linear interpolation. The rati os between 2002 and 2018 were determined and then multiplied by the 2002 base year to determine 2018 projection year emissions. The reader is referred to Section 5 of State of New Jersey Department of Environmental Protection SIP for Regional Haze Final , dated July 2009 and Development of Emissions Projections for 2009, 2012 and 2018 for Non

- EGU Point, Area and Nonroad Mobile Sources in the MANE

- VU Region, Final Report , dated February 2007 . Th ese document s provide further details and references on how pro jections were performed.
**EPA finds New Jersey**  **’s methodology for projecting non -**  **road mobile sources to be acceptable.** 
**Onroad Mobile Sources** For the onroad mobile source category , the primary indicator and tool for developing on

- road mobile growth and expected emissions are vehicle miles traveled (VMT) and US EPA’s mobile emissions model Mobile 6.2.03 (Mobile6.2). The 20 18 pollutant emission factors were generated b y Mobile6.2 (with the associated controlled measures applied , wh ere appropriate) and app lied to the monthly

VMT projections provided by the State. Monthl y emissions were then combined to develop annual emission estimates. The reader is referred to Section 5 of State of New Jersey Department of Environmental Protection SIP for Regional Haze Final , dated July 2009 and Development of MANE

- VU Mobile Source Projection Inventories for SMOKE/MOBILE6 Application , June 2006. This document provides further details and references on how projections were performed. Since these growth indicators are some of the preferred growth indicators to use, as outlined in EPA Guidance, 1,3,4,6,7 **EPA finds New Jersey**  **’s methodology for projecting on -**  **road mobile sources to be acceptable.** 40

**Table 2 A**  show s 20 18 projection emission inventories controlled after 2002 u sing the aforementioned growth indicators/methodologies for the New Jersey State
. **Table 2B** (attached, separately) shows the 2002

- 2018 control measures.



### Table 2 **A New**  **Jersey State 2018 Projection Year Modeling Inventory (Controlled)** 

**(Tons/Year)**

Poll utant Major Point

Sources Area Sources Nonroad Mobile Sources Onroad Mobile

Sources **Total VOC**  20,267 134,089 53,625 31,415 **239,396 NOx**  31,100 21,684 41,166 30,150 **124,100 PM**  **2.5** 7,745 15,220 3,143 1,140 **27,247 PM**  **10** 8,969 31,874 3,489 1,232 **45,564 SO2**  23,421 1,781 832 735 **26,819 NH**  **3** 564 21,435 52 8,555 **30,606**



## Section 3: 2008 R**PG Inventory Dem**  **onstration Section 3A: Inventory**  **Demonstration Requirements**  **1,2,3,4,5,6,7** 1. For the New Jersey, state - wide Regional Haze pollutant precursors’ annual em issions should be projected from the 2002 base to the future 20 18 year. Provide summary of statewide emissions for point, area, nonroad and onroad mobile sources. 2. State must provide a demonstration which shows that the 2002 base projected to 20 18 (with g rowth and controls) will reach 20 18 controlled emission levels. Provide state - wide summary of emissions for point, area, nonroad mobile and onroad mobile sources. 3. Provide an explanation on how the 2018 point, area, nonroad mobile and onroad mobile source projection inventories are41

developed. **Section 3**  **B: How**  **New Jersey Meets the Criteria for the**  **2018 RPG Inventory Demonstration** 

 **For the New Jersey**  **, state -**  **wide Regional Haze pollutant precursors’ annual emissions should be projected from the**  **2002 base to the future 2018 year. Provide summary of**  **statewide emissions for point, area, nonroad and onroad mobile sources.**  Sections 1 and 2, provide detailed answer s to these questions. **New Jersey has satisfied the**  **criteria for 2002 base year projected to**  **20 18**  **( c**  **ontrolled) projection inventory requirements.** 

 **State must provide a demonstration which shows that the 2002 base projected to 2018**  **( with growth**  **and controls) will reach 2018 controlled emission levels. Provide**  **state -**  **wide summary of emissions for point, a rea, nonroad mobile and onroad mobile**  **sources.** Sections 1 and 2 and Table s 2A and 2B provide detailed answers to these questions. **New Jersey has satisfied the criteria for 2002 base year**  **projected to 20**  **18 (controlled) projection**  **inventory requirements.**

 **Provide an explanation on how the 2018**  **point, area, nonroad mobile and onroad mobile source projection inventories are**  **developed.** Sections 1 and 2, provide detailed answers to these questions. **New Jersey has satisfied the**  **criteria for 2002 base year proj**  **ected to 2018 (controlled) projection inventory**  **requirements.**42

**Emission Inventory Guidance Documents** 1 Emission Inventory

Improvement Program guidance document titled Volume X, Emission Projections , dated December 1999
2 EPA Checklist for Regional Haze SIPs , dated August 4, 2006 3 Guidance for Growth Factors, Projections, and Control Strategies for the 15 Percent Rate of Progress Plans , dated March 1993
4 Guidance on the Post

- 1996 Rate of Progress Plan and Attainment Demonstration , dated January 1994?

5 Emission Inventory

Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation , dated August 2005 6 EPA’s follow

- up memo “ 8
- Hour Ozone National Ambient Air Quality Standards Implementation

- Reasonable Further Progress (RF P) , dated August 2006
7 Guidance on the Use of Models and Other Anal yses for Demonstration Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze , dated April 2007