DATE: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

SUBJECT: Technical Support Document (TSD) for the Pennsylvania 

Regional Haze State Implementation Plan - Mid Atlantic 

and Northeast Visibility Union (MANE-VU) "Asks" 

Reasonable Progress Goals 

FROM: 

TO: 

Melissa Linden, Environmental Scientist 

Office of Air Program Planning (3AP30) 

SIP Docket File 

REVIEWED a~~~ 

BY: 

Cristina Fernandez, Associate Director 

Office of Air Program Planning (3AP30) 

I. Background 

Regional haze is visibility impairment caused by the cumulative effect of air pollution from 

numerous sources over a wide geographic area. Regional haze results in impaired visibility over 

a large region, affecting urban and rural areas including national parks, forests, and wilderness 

areas (federal "Class I" areas). In the eastern United States, average visual range has been 

reduced to approximately 30 kilometers or one-fifth of the visual range that would exist under 

natural conditions. 

EPA provided grant funding for five Regional Planning Organizations (RPOs) throughout the 

country to assist with the multi-state coordination and cooperation needed to address regional 

haze issues. In 2001, the Mid-Atlantic and Northeast states, the District of Columbia, and tribes 

within the region formed the Mid-AtlanticlNortheast Visibility Union (MANE-VU) to coordinate 

regional haze planning activities for the region. 

EPA's regional Haze rule (RHR) was published in the Federal Register on July 1, 1999. The 

RHR aims to achieve the national visibility goal set by the Clean Air Act (CAA) by 2064. The 

rule addresses the combined visibility effects of various pollution sources over a wide geographic 

region. The RHR requires all states, even those that do not contain a Class I area, to submit a 

revision to their State Implementation Plan (SIP) containing emission reduction strategies to 

improve visibility in Class I areas that their emissions affect. Guidelines for implementation of 
the Best Available Retrofit Technology (BART) requirements of the federal RHR were initially 

proposed on July 20,2001 (66 FR 38108). 

EPA's RHR was subsequently revised in response to a legal challenge brought by industry and 

environmental groups. On May 24, 2002, the United States Court of Appeals for the District of 

Columbia Circuit issued a ruling vacating the RHR in part and sustaining it in part. The ruling 

vacated and remanded to EPA the BART provisions of the rule. The court's ruling denied 

industry's challenge to the RHR's goal of natural visibility and requirement of no degradation of 

visibility. On May 5, 2004, EPA published proposed revisions to the regional haze rule and 

guidelines for BART determinations in the Federal Register (69 FR 25184). The final RHR and 

BART guidelines were published in the Federal Register on July 6,2005 (70 FR 39104). A 

further revision to the rule was proposed August 1, 2005 (70 FR 44154) and finalized October 

13,2006 (71 FR 60612), pertaining to requirements for alternative trading programs. The 

regulations can be found at 40 CFR Part 51, subpart P (relating to protection of visibility). 

II. Reasonable Progress Goal Requirements 

Section 51.308(d) of the RHR requires states to demonstrate reasonable progress toward meeting 

the national goal of a return to natural visibility conditions by 2064. As a guide for reasonable 

progress, the RHR directs states to consider what would be a "uniform rate of progress" toward 

natural conditions for each mandatory Class I Federal area within the state and/or for each 

mandatory Class I Federal area located outside the State, which may be affected by emissions 

from sources within the State. States with Class I areas are to establish baseline visibility 

conditions for 2000-2004, natural background visibility conditions in 2064, and the rate of 

uniform progress between baseline and background conditions. The uniform rate of progress is 

also known as the "glidepath." The RHR stipulates that visibility targets and tracking of 

visibility changes over time be expressed in terms of the "deciview" haze metric. Deciview is an 

atmospheric haze index that expresses changes in visibility, and is a measurement of visibility 

impairment. See 40 CFR section 51.301. This means that the lower the deciview value, the 

better the perception of visibility. 

The RHR also requires states with Class I areas to establish reasonable progress goals (RPGs), 

expressed in deciviews, for visibility improvement at each Class I area. The goals must provide 

for reasonable progress toward achieving natural visibility conditions, provide for improvement 

in visibility for the most impaired days over the period of the implementation plan, and ensure no 

degradation in visibility for the least impaired days over the same period. See 40 CFR 

51.308(d)(I). 

This first set of reasonable progress goals must be met through measures contained in each 

state's long-term strategy covering the period from the present until 2018. The long-term 

strategy includes enforceable emissions limitations, compliance schedules, and other measures as 

necessary to achieve the reasonable progress goals, including all controls required or expected 

under all federal and state regulations by 2009 and by 2018. During development of the longterm strategy, states are also required to consider specific factors, such as the abovementioned 

ongoing control programs, measures to mitigate construction activities, source retirement and 

replacement schedules, smoke management programs for agriculture and forestry, and 

enforceability of specific measures. See 40 CFR 51.308(d)(3). 
III. MANE-VU's Approach to Reasonable Progress Goals 

A summary of the reasonable progress goals developed by MANE-VU is listed below in Table 1 

and Table 2. 

T a bl e 1 R • easona bl e P rogress G I oa s fi ort h e 20% W ° orst D ays 

Baseline Reasonable 

Visibility Progress Deciview 

(deciviews) Goals, 20% improvement Natural 

(20% worst days expected by Visibility 

Worst (expected 2018 Conditions 

Class I Area Days 2000- deciview level (20% worst 

2004) by 2018) days) 

Acadia National Park 22.9 19.4 3.5 12.4 

Roosevelt/Campobello 21.7 19.0 2.7 12.0 

International Park 

Moosehorn 21.7 19.0 2.7 12.0 

Wilderness Area 

Presidential 22.8 19.1 3.7 12.0 

RangelDry River 

Wilderness Area 

Great Gulf Wilderness 22.8 19.1 3.7 12.0 

Area 

Lye Brook Wilderness 24.5 20.9 3.6 11.7 

Brigantine Wilderness 29.0 25.1 3.9 12.2 .... Source: 2018 VISibilIty ProjectIOns Report, May 2008, (Appendix L of the Pennsylvania Submittal). 

T a e . bl 2 R easona bl e P r02ress G oa Is fi or th e 20°1« B t D ° es ays 

Reasonable 

Baseline Progress 

Visibility Goals, 20% Deciview Natural 

(deciviews) best days improvement Visibility 

(20% Best (deciviews) expected by (20% best 

Class I Area Days) (expected by 2018 days) 

2018) (deciviews) 

Acadia National Park 8.8 8.3 0.5 4.7 

Roosevelt/Campobello 9.2 8.6 0.6 5.0 

International Park 

Moosehorn 9.2 8.6 0.6 5.0 

Wilderness Area 

Presidential 7.7 7.2 0.5 3.7 

RangelDry River 

Wilderness Area 
Great Gulf Wilderness 7.7 7.2 0.5 3.7 

Area 

Lye Brook Wilderness 6.4 5.5 0.9 2.8 

Brigantine Wilderness 14.3 12.2 2.1 5.5 

.... Source: 2018 VIsibilIty ProjectIOns Report, May 2008, (Appendix L of the Pennsylvania Submittal). 

In 2006, MANE-VU conducted an assessment of the default and alternative approaches for 

calculation of baseline and natural background conditions at MANE-VU Class I areas. Based on 

that assessment, in December 2006, MANE-VU recommended adoption of the alternative 

reconstructed extinction equation for use in the December 2007 regional haze SIPs. Both natural 

conditions and baseline visibility for the 5-year period from 2000 through 2004 were calculated 

in conformance with an alternative method recommended by the IMPROVE Steering 

Committee. 1 Progress toward the 2018 target will be calculated based on 5-year averages 

calculated in a nationally consistent manner consistent with EPA's Guidance for Tracking 

Progress Under the Regional Haze Rule (EPA-4541B-03-004, September 2003), as updated by 

the alternative method for calculating regional haze recommended by the IMPROVE Steering 

Committee. 

To determine the reasonable progress goals in deciviews, the MANE-VU Class I area states 

conducted modeling with certain control measure assumptions. The control measures reflected 

in these reasonable progress goals are summarized below in MANE-VU "Asks." In establishing 

these reasonable progress goals for 2018, the MANE-VU Class I area states recognize that 

Pennsylvania and other contributing states have the flexibility to adopt control measures to 

implement these goals between now and 2018. The overall approach to reducing and preventing 

emissions that contribute to regional haze will allow each state up to 10 years to pursue adoption 

and implementation of reasonable and cost-effective nitrogen oxides (NOx) and S02 control 

measures, as appropriate and necessary. . 

The reasonable progress goals shown above in Tables 1 and 2 represent implementation of the 

regional course of action set forth by MANE-VU on June 20, 2007 and entitled, "Statement of 

the Mid-AtlanticlNortheast Visibility Union (MANE-VU) Concerning a Course of Action Within 

MANE-VU toward Assuring Reasonable Progress," (Appendix M of the Pennsylvania 

Submittal), also known as the "Ask" Statement. As such, these goals are intended to reflect the 

pursuit by MANE-VU states, including Pennsylvania, of a course of action, including pursuing 

the adoption and implementation of the following "emission management" strategies: 

• "Timely implementation of BART requirements; and 

• "A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, 

Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of: 

o Distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2012, 

\"Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of Baseline 

and Natural Visibility Conditions at MANE-VU Class I Areas," NESCAUM, December 2006, Appendix E of the 

Pennsylvania Submittal. 
o #4 residual oil to 0.25% sulfur by weight by no later than 2012, 

o #6 oil to 0.3 - 0.5% sulfur by weight by no later than 2012, and 

o Further reduce the sulfur content of distillate oil to 15 ppm by 2016; and 

• "A low sulfur fuel oil strategy in the outer zone states (the remainder of the MANE-VU 

region) to reduce the sulfur content of: 

o Distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2014, 

o #4 residual oil to 0.25%-0.50% sulfur by weight by no later than 2018, 

o #6 oil to no greater than 0.5% sulfur by weight by no later than 2018, and 

o Further reduce the sulfur content of distillate oil to 15 ppm by 2018; and 

• "A 90% or greater reduction in sulfur dioxide (S02) emissions from each of the electric 

generating unit (EGU) stacks identified by MANE-VU (Attachment I-comprising a total 

of 167 stacks, dated June 20, 2007) as reasonably anticipated to cause or contribute to 

impairment of visibility in each mandatory Class I Federal area in the MANE-VU region. 

If it is infeasible to achieve that level of reduction from a unit, alternative measures will 

be pursued in such State; and 

• "Continued evaluation of other control measures including energy efficiency, alternative 

clean fuels, and other measures to reduce S02 and nitrogen oxide (NOx) emissions from 

all coal-burning facilities ,by 2018 and new source performance standards for wood 

combustion. These measures and other measures identified will be evaluated during the 

consultation process to determine if they are reasonable and cost-effective." 

The MANE-VU states, including Pennsylvania, agreed on the additional reasonable strategies 

listed above after consideration of an analysis of the four factors that the CAA requires to be 

considered in determining whether controls are reasonable. This analysis is described in detail in 

the Reasonable Progress Report (Appendix 0 of the Pennsylvania Submittal). The Reasonable 

Progress Report summarizes MANE-VU' s assessment of pollutants and associated source 

categories affecting visibility in Class I areas in and near MANE-VU, lists possible control 

measures for those pollutants and source categories, and develops the requisite four factor 

analysis. Table 3 below presents a summary of the four factor analysis for the source categories 

analyzed in the Reasonable Progress Report. 

T a e . bl 3 S ummaryo fR esu It s f rom th e F our F ac t or A I . nalYSIS 

Average 

Cost in 2006 Energy and 

Primary dollars (per Non-Air 

Regional ton of Quality Remaining 

Source Haze Control pollutant Compliance Environmental Useful 

Cat~ory Pollutant Measure(s) reduction) Timeframe Impacts Life 

Electric S02 Switch to a low IPM®* 2-3 years Fuel supply 50 years or 

Generating sulfur coal v.2.1.9 following SIP issues, potential more 

Units (generally <1 % predicts submittal permitting 

sulfur), $775-$1,690. issues, 

switch to $170-$5,700 reduction in 

natural gas based on electricity 

(virtually 0% available production 

sulfur), coal literature capacity, 
cleaning, wastewater 

Flue Gas issues 

Desulfurization 

(FGD)-Wet, -

Spray Dry, or -

Dry. 

Industrial, S02 Switch to a low $130- 2-3 years Fuel supply 10-30 years 

Commercial, sulfur coal $11,000 following SIP issues, potential 

Institutional (generally <1 % based on submittal pennitting 

Boilers sulfur), available issues, control 

switch to literature. device energy 

natural gas Depends on requirements, 

(virtually 0% Size. wastewater 

sulfur), switch issues 

to a lower 

sulfur oil, coal 

cleaning, 

combustion 

control, Flue 

Gas 

Desulfurization 

(FGD)- Wet,-

Spray Dry, orDry. 

Cement and S02 Fuel switching, $1,900- 2-3 years Control device 10-30 years 

Lime Kilns Dry Flue Gas $73,000 following SIP energy 

Desulfurization- based on submittal requirements, 

Spray Dryer available wastewater 

Absorption literature. issues 

(FGD), Wet Depends on 

Flue Gas size. 

Desulfurization 

(FGD), 

Advanced Flue 

Gas 

Desulfurization 

(FGD). 

Heating Oil S02 Lower the $550-$750 Currently Increases in 18-25 years 

sulfur content in based on feasible. furnacelboiler 

the fuel. available Capacity issues efficiency, 

Depends on the literature. may influence Decreased 

state. There is a timeframe for furnacelboiler 

high implementation maintenance 

uncertainty of new fuel requirements 

associated standards 

with this cost 

estimate. 
Residential PM State $0-$10,000 Several years - . Reduce 10-15 years 

Wood implementation based on dependent on greenhouse gas 

Combustion ofNSPS, Ban available mechanism for emlsslOns, 

on resale of literature emission mcrease 

uncertified reduction efficiency of 

devices, combustion 

installer device 

training 

certification or 

inspection 

program, pellet 

stoves, EPA 

Phase II 

certified RWC 

devices, retrofit 

requi.rement, 

accelerated 

changeover 

requirement, 

accelerated 

changeover 

inducement. 

*Integrated Plannmg Model® 

IV. Pennsylvania's Demonstration of Implementing the MANE-VU "Asks" 

Pennsylvania has reviewed and determined the appropriate BART controls for its 34 sources. 

These determinations can be found in Appendix J of the Pennsylvania submittal. Some of the 

BART determinations are missing the deciview impact on the most impacted Class I area and 

that modeling can be found in Appendix I of the Pennsylvania submittal. A summary of the 

BART determined control limits can be found in Table 4 below. 

T a bl e 4 • BART D t . e ermlDa f Ions ~ or P ennsYI I vaDla 

BART Source Name Permit No. and Pollutant and Emission Emissions Reporting 

& UnitId Date of Issue Limit and Monitoring 

ConocoPhillips Consent Decree, S02: 25 ppmvd (365-day 25 Pa. Code §§ 

FCCU/CO Boiler Civil Action H-05- rolling average). 127.441, 127.442, 

Unit ID #COI 0258 PM: 0.5 Ib/l000 lb coke 127.511, and 

(1/27/05) burn (3-hr average). §§ 123, 135 and 139. 

Title V Permit 23- NOx: 121.1 ppmvd (365- 40 CFR Parts 60 and 

00003 (12/22/08) day) 63. 

155.3 ppmvd (7- See Consent Decree, 

day). Appendix DD. 

40 CFR Part 60 and 

Part 60 Appendices A, 

B andF. 

ConocoPhillips Title V Permit 23- NOx: 0.12 IbIMMBtu. 25 Pa. Code §§ 

Platform Feed Heater 00003 (12/22/08) S02: O.OlllblMMBtu 127.441, 127.442, 

UnitID 738 (both limits are on an 127.511, and 
BART Source Name Permit No. and Pollutant and Emission Emissions Reporting 

& UnitId Date of Issue Limit and Monitoring 

annual basis). §§ 123, 135 and 139. 

40 CFR Parts 60 and 

63. 

Sunoco Inc. Consent Decree, S02: 25 ppmvd (365-day See Consent Decree, 

Marcus Hook Refinery Civil Action 05- rolling average). Appendix EE. 

FCCU/CO Boiler CV-02866 NOx: 20 ppmvd (365-day 40 CFR Part 60 and 

Unit ID 101 and (6/16/05) rolling average). Part 60 Appendices A, 

COBI Title V Permit 23- PM: 1.0 Ib/l000 lb coke B andF. 

00001 (11/18/08) burn. 

Sunoco Inc. Title V Permit 23- NOx: 0.25 IblMMBtu (24- 25 Pa. Code §§ 

Marcus Hook Refinery 00001 (11118/08) hr basis). 127.441, 127.442, 

17-2A, H-Ol Heater S02: 500 ppmvd. 127.511, and 

§§ 123, 135 and 139. 

40 CFR Parts 60 and 

63. 

United Refining Co. Title V Permit 62- NOx: 0.173 IbIMMBtu. 25 Pa. Code §§ 

Boiler 4 00017 (8/20/07) S02: 24.3 lbslhr. 127.441, 127.442, 

127.511, and 

§§ 123, 135 and 139. 

40 CFR Parts 60 and 

63. 

United Refining Co. Title V Permit 62- NOx: 0.226 IbIMMBtu. 25 Pa. Code §§ 

Crude Heater- North 00017 (8/20/07) S02: 207.7 lbslhr. 127.441, 127.442, 

127.511, and 

§§ 123, 135 and 139. 

40 CFR Parts 60 and 

63. 

Carmeuse Lime Inc. Title V Permit 38- NOx: 6.0 lb/ton lime. 25 Pa. Code §§ 

Kiln Number 5 05003 (4/27/06) S02: 500 ppmvd. 127.441, 127.442, 

127.511, and 

§§ 123, 135 and 139. 

40 CFR Part 64. 

Lehigh Cement Co. Title V Permit 06- NOx: 367.7 lbslhr. 25 Pa. Code §§ 

Evansville Plant 05002 (9114/09) S02: 59.4lbs/hr. 127.441, 127.442, 

Kiln Number 1 PM: 34.8 tonsl12 month 127.511, and 

period. §§ 123, 135 and 139. 

PMlO: 87.4 tons/12 month 40 CFR Part 63. 

period. 

Lehigh Cement Co. Title V Permit 06- NOx: 367.7 lbslhr. 25 Pa. Code §§ 

Evansville Plant 05002 (9/14/09) S02: 59.4 lbslhr. 127.441, 127.442, 

Kiln Number 2 PM: 34.8 tons/12 month 127.511, and 

period. §§ 123, 135 and 139. 

PMI0: 87.4 tons/12 month 40 CFR Part 63. 

period. 

Lehigh Cement Co. Title V Permit 67- NOx: 8.2 lbs/ton. 25 Pa. Code §§ 

York Operations 05024 (2/17/06) S02: 500 ppmvd. 127.441, 127.442, 

White Cement Kiln PM: 0.02 grains/dscf. 127.511, and 
BART Source Name Permit No. and Pollutant and Emission Emissions Reporting 

& UnitId Date of Issue Limit and Monitoring 

§§ 123, 135 and 139. 

40 CFR Part 63. 

Lafarge Corp. Title V Pennit 39- NOx: 297.7Ibslhr. 25 Pa. Code §§ 

Whitehall Plant 00011 (12/31/00) NOx: 260.5 lbslhr (TDF). 127.441, 127.442, 

Kiln K-2 S02: 362 lbslhr. 127.511, and 

PM: 14.8 lbslhr. §§ 123, 135 and 139. 

40 CFR Parts 60 and 

63. 

Lafarge Corp. Title V Pennit 39- NOx: 202.3 lbslhr. 25 Pa. Code §§ 

Whitehall Plant 00011 (12/31/00) NOx: 166.0 lbslhr (TDF). 127.441, 127.442, 

KilnK-3 S02: 195.0 lbslhr. 127.511, and 

PM: 7.3 lbslhr. §§ 123, 135 and 139. 

40 CFR Parts 60 and 

63. 

CEMEXInc. Title V Pennit 37- NOx: 6.2 lbs/ton clinker 25 Pa. Code §§ 

Wampum Plant 00013 (3/5/07) (May-Sep 6.0 lbslton). 127.441, 127.442, 

Kiln No. 3 S02: 500 ppmvd. 127.511, and 

PM: 0.02 grains/dscf. §§ 123, 135 and 139. 

40 CFR Part 63. 

ESSROC Cement Title V Pennit 37- NOx: 4761bslhr. 25 Pa. Code §§ 

Bessemer Plant 00003 (1/18/07) S02: 500 ppmvd. 127.441, 127.442, 

Kiln No. 5 PM: 0.02 grains/dscf. 127.511, and 

§§ 123, 135 and 139. 

40 CFR Part 63. 

Keystone Cement Co. Title V Pennit 48- NOx: 529 lbslhr 25 Pa. Code §§ 

East Allen Plant 00003 (8/31/01) S02: 500 ppmvd 127.441, 127.442, 

Kiln No. 2 PM: 0.02 grains/dscf 127.511, and 

§§ 123 and 139. 

40 CFR Part 63. 

ISG Plate LLC Title V Pennit 15- S02: 500 ppmvd. 25 Pa. Code §§ 

Coatesville Plant 00010 (1/7/08) 127.441, 127.442, 

Electric Arc Furnace D PM: 0.02 grains/dscf 127.511, and 

(primary baghouse). §§ 123, 135 and 139. 

PM: 0.0052 grains/dscf 40 CFR Part 64. 

(secondarybaghouses). 

AK Steel Corp. Title V Pennit 10- NOx: 75 lbslhr. 25 Pa. Code §§ 

Butler Works 00001 (2/13/06) S02: 500 ppmvd. 127.441, 127.442, 

Electric Arc Furnaces: PM: 0.0036 grains/dscf. 127.511, and 

#2, #3, and #4 §§ 135 and 139. 

40 CFR Part 64. 

PH Glatfelter Co. Title V Pennit 67- NOx: 0.66 IblMMBtu (30- 25 Pa. Code §§ 

Spring grove Plant 05004 (11/8/07) day rolling average). 127.441, 127.442, 

No.1 Power Boiler S02: 3.71b1MMBtu (30- 127.511, and 

day rolling average). §§ 123, 135 and 139. 

PM: 3.6 x Heat Input 40 CFR Parts 63 and 

(lbsIMMBtu) raised to a 64. 

negative 0.56 power. 
BART Source Name Permit No. and Pollutant and Emission Emissions Reporting 

& Unit Id Date of Issue Limit and Monitoring 

Appleton Papers Inc. Title V Pennit 07- NOx: 0.63 IbIMMBtu. 25 Pa. Code §§ 

Spring Mill Plant 05001 (10/1/07) S02: 4.0 IblMMBtu (over 127.441, 127.442, 

No.3 Power Boiler any 1-hr period). 127.511, and 

PM: 3.6 x Heat Input §§ 123, 135 and 139. 

(lbsIMMBtu) raised to a 40 CFR Parts 63 and 

negative 0.56 power. 64. 

Dyno Nobel Inc. Title V Pennit 63- NOx: 396 tons/12-month 25 Pa. Code §§ 

Donora Plant 00070 (12/31/07) period. 127.441, 127.442, 

Ammonia Oxidation N02: 5.5 lb/ton acid 127.511, and 

Plant product (expressed as §§ 135 and 139. 

100% HN03). 40 CFR Parts 64 and 

70. 

Allegheny Energy Title V Pennit 30- PM: 0.075 IblMMBtu for 25 Pa. Code §§ 

Hatfields Ferry Power 00099F (9/12/07) each boiler. 127.441, 127.442, 

Main Boilers (#1, #2, 127.511, and 

and #3) §§ 123, 135 and 139. 

PPL Brunner Island Title V Pennit 67- PM: 0.1 IblMMBtu for 25 Pa. Code §§ 

Brunner Island 05005 (4/16/07) each boiler. 127.441, 127.442, 

Boilers 2 and 3 127.511, and 

§§ 123, 135 and 139. 

Exelon Generation Title V Pennit 23- PM: 0.1 IblMMBtu for 25 Pa. Code §§ 

Eddystone Plant 00017 (12/29/04) each boiler. 127.441, 127.442, 

Boilers 3 and 4 127.511, and 

M 123, 135 and 139. 

EME Homer City Title V Pennit 32- PM: 0.1 IblMMBtu for 25 Pa. Code §§ 

Homer City Plant 00055 (1/30/04) each boiler. 127.441, 127.442, 

Main Boilers (#1, #2, 127.511, and 

#3) §§ 123, 135 and 139. 

PPL Montour LLC Title V Pennit 47- PM: 0.1 IblMMBtu for 25 Pa. Code §§ 

Montour SES 00001 (5/2/06) each boiler. 127.441, 127.442, 

Boilers 1 and 2 127.511, and 

§§ 123, 135 and 139. 

Reliant Energy LLC Title V Pennit 48- PM: 0.1 IbIMMBtu. 25 Pa. Code § § 

Portland Generating 00006 (5/31/06) 127.441, 127.442, 

Boiler #2 127.511, and 

§§ 123, 135 and 139. 

First Energy Corp. Title V Pennit 04- PM: O.llblMMBtu for 25 Pa. Code §§ 

Bruce Mansfield PIt 00235 (11/22/02) each boiler. 127.441, 127.442, 

Main Boilers (#1, #2, 127.511, and 

#3) §§ 123, 135 and 139. 

Allegheny Energy Title V Pennit 63- PM: O.llbIMMBtu. 25 Pa. Code §§ 

Mitchell Power 00016 (3/26/02) 127.441, 127.442, 

Station 127.511, and 

Boiler #3 §§ 123, 135 and 139. 

Orion Power Midwest Title V Pennit 37- PM: 0.1 IbIMMBtu. 25 Pa. Code § § 

New Castle Plant 00023 (1123/07) 127.441, 127.442, 

Boiler #5 127.511, and 
BART Source Name Permit No. and Pollutant and Emission Emissions Reporting 

& Unit Id Date of Issue Limit and Monitoring 

§§ 123, 135 and 139. 

Reliant Energy NE Title V Permit 03- PM: 0.1 IblMMBtu for 25 Pa. Code §§ 

Keystone Power Plant 00027 (12/18/06) each boiler. 127.441, 127.442, 

Boilers 1 and 2 127.511, and 

§§ 123, 135 and 139. 

PPL Martins Creek Title V Permit 48- PM: 0.1 IblMMBtu for 25 Pa. Code §§ 

Martins Creek Plant 00011 (4/15/08) each boiler. 127.441, 127.442, 

Boilers 3 and 4 127.511, and 

§~ 123, 135 and 139. 

Reliant Energy NE Title V Permit 32- PM: 0.1 IblMMBtu for 25 Pa. Code §§ 

Conemaugh Plant 00059 (3/28/08) each boiler. 127.441, 127.442, 

Boilers 1 and 2 127.511, and 

§§ 123, 135 and 139. 

Trigen Edison Station Title V Permit: NOx: 0.5 IblMMBtu for 25 Pa. Code §§ 

Philadelphia V06-11 (1/29/07) each boiler. 127.441(c), (d), 

Boilers 3 and 4 PM: 0.1 IblMMBtu for 127.442, 127.463(e), 

each boiler. 127.511(c), § 139, and 

S02: 0.5% sulfur (#6 fuel Philadelphia County 

oil), 0.2% sulfur (#2 oil). AMS Regulation I Sec. 

II and III. 

Trigen Schuylkill Title V Permit: NOx: 0.36 IblMMBtu (30- 25 Pa. Code §§ 

Station V06-007 (10112/06) day rolling avg). 127.441(c), (d), 

Philadelphia PM: 0.1 IbIMMBtu. 127.442, 127.463(e), 

Boiler # 26 S02: 0.5% sulfur (#6 fuel 127.511(c), § 139, and 

oil). Philadelphia County 

AMS Regulation I Sec. 

n and III. 

Sunoco Chemicals Title V Permit: NOx: 0.3 IbsIMMBtu. 25 Pa. Code §§ 

Frankfort Plant V95-047 (4/17/03) PM: 0.1 IbIMMBtu. 127.441(c), (d), 

Philadelphia S02: 0.52 IbsIMMBtu. 127.442, 127.463(e), 

Boiler No. 3 127.511(c), § 139, and 

Philadelphia County 

AMS Regulation I Sec. 

II and III. 

Sunoco Refinery, Inc Consent Decree, S02: 25 ppmvd (365-day See Consent Decree, 

Philadelphia Civil Action 05- rolling average). Appendix EE. 

FCCU/CO Boiler CV-02866, NOx: 20 ppmvd (365-day 40 CFR Part 60 and 

Unit ID 1232 (6116/05) rolling average). Part 60 Appendices A, 

Title V Permit: PM: 0.5 Ibl1 000 lb coke B andF. 

V95-038 (1/17/02) burn. 

AMS Plan 

ApproVal: 

04322 (2/28/06) 

Sunoco Refinery Inc. Consent Decree, NOx: 0.020 IblMMBtu See Consent Decree, 

Philadelphia Civil Action 05- (24-hr basis). Appendix EE. 

Process Heaters CV-02866 S02: 500 ppmvd. 40 CFR Part 60 and 

(6/16/05) Part 60 Appendices A, 
BART Source Name Permit No. and Pollutant and Emission Emissions Reporting 

& UnitId Date of Issue Limit and Monitoring 

Title V Pennit: B andF. 

V95-038 (1/17/02) 

Allegheny Ludlum ACHD Rules and 

Corp. Operating Pennits: Pennitted PTE: RegulationsAllegheny County 0025603-000- PM: 68tpy Article XXI, Part C, 

Basic Oxygen 82900 Operating Pennits (All 

Furnace~ (9/29/94) PM: 230 tpy Major & Minor) 

0025603-000- §21 03.l2.i, j &k, 

Slab Grinder 65304 PM: 13 tpy Issuance, Standard 

(12/14/73) Conditions-Standard 

Plate Burner/Torch 0025603-000-1160 PM: 14 tpy, NOx: 194 tpy Monitoring 

Cutter (12/14/73) Requirements, 

0025603-000- Standard 

Loftus Soaking Pits 22803, Recordkeeping 

0025603-000- Requirements, & 

22804 Standard Reporting 

(12/14/73) Requirements. 

Article XXI, Part H, 

§2108.01.e, Reports 

Required-Emissions 

Inventory Statements. 

US Steel Clairton See above citations of 

Allegheny County ACHD Rules and 

Clairton Coke Works Operating Pennits: Pennitted PTE: Regulations. 

Desulfurization Plant 7035003-010- S02: 590 tpy; NOx: 27 tpy 

25600 

Boiler #2 (12/14/73) S02: 1508 tpy; NOx: 1285 

7035003-010- tpy 

Rl Boiler 00800 

(11128/79) S02: 796 tpy: NOx: 525 

Tl Boiler 7035003-010- tpy 

01300 

(5/11/77) S02: 572 tpy; NOx: 358 

7035003-010- tpy 

00600 

(7/12/77) 

Orion Power See above citations of 

Cheswick Plant Operating Pennit: Pennitted PTE: ACHD Rules and 

Allegheny County 1065009-003- S02:67,452 Regulations. 

Boiler No. 1 00100 typ;NOx:IO,840 tpy 

(12/8/81) PMIO: 361 tpy 

Pennsylvania has 15 of the 167 stacks that were identified by MANE-VU. The controls being 

implemented on these 15 stacks are listed in Table 5 below. 
T a e . bl 5 P I ., P ennsyl vaDia s ortJon 0 f t e h 167 S tac ks 

Facility Unit Unit Facility Identified Anticipated Anticipated 

Name & ID Type ID Stacks Controls & Reduction 

StackID in Permit inS02 

Appendix I Status Emissions 

Armstrong 2 Coal 43086 D031782 

Steam 90% 

Brunner 2 Coal 45820 D03140C12 Wet Scrubber 95% 

Island Steam in 2009 

PA 26 Plan 

Approval 

No. 67-

05005D 

Brunner 3 Coal 45821 D031403 Wet Scrubber 95% 

Island Steam in 2009 

Plan 

Approval 

No. 67-

05005D 

Cheswick 1 Coal D082261 Wet Scrubber 95% 

AC 04 Steam in 2010 

Hatfields 2 Coal 43072 D03179COI Wet Scrubber 

Ferry Steam in 2009 95% 

PA 35 Plan 

Approval 

No. 30-

00099F 

Homer City 1 Coal 49780 D031221 95% 

PA 37 Steam 

Homer City 2 Coal 49781 D031222 95% 

PA 37 Steam 

Keystone 1 Coal 49769 D031361 Wet Scrubber 95% 

PA 39 Steam in 2009 

Plan 

Approval 

No. 03-

00027B 

Keystone 2 Coal 49770 D031362 Wet Scrubber 95% 

PA 39 Steam in 2010 

Plan 

Approval 

No. 03-

00027B 

Martins 2 Coal 45859 D03148C12 N/A 

Creek Steam 

PA 08 

Montour 1 Coal 45872 D031491 Wet Scrubber 95% 

PA 07 Steam in oQeration. 
Plan 

Approval 

No.:47-

00001B 

Montour 2 Coal 45873 D031492 Wet Scrubber 95% 

PA 07 Steam in operation. 

Plan 

Approval 

No.:47-

00001B 

Portland 1 Coal 45735 D031131 

PA 09 Steam 

Portland 2 Coal 45736 D031132 

Steam 

Shawville 1 Coal 49763 D03131CSI 

Steam 

Table 6. Additional Sources Controlled to Demonstrate 90% S02 Reduction in 167 Stacks 

Facility Unit Unit Facility Identified Anticipated Anticipated 

Name ID Type ID Stacks Controls & Reduction in 

Permit S02 

Status Emissions 

WPSRes. 1-4 Coal D03152CS2 Wet 

Sunbury Steam D03152CS3 Scrubber in 95% 

Six Boilers D03152CS4 2010 with a 

(Units 1-4) new stack 

that will 

exhaust all 

six boilers. 

Plan 

Approval 

No. 55-

00001C 

Reliant 3 Coal 49765 D03131CS2 FGD-Dry 

Shawville 4 Steam 49766 Scrubber 95% 

Units 3 & 4 (spray dryer 

absorber) in 

2010. 

Plan 

Approval 

No. 17-

00001D 

On September 25,2010, the Pennsylvania Environmental Quality Board (EQB) proposed the 

Commonwealth's statewide low-sulfur heating and distillate oil regulation, in response to the 

MANE-VU "Ask" that states adopt a low-sulfur fuel oil strategy. In this proposal Pennsylvania 

calculated the S02 emission reductions in the phased in approach that MANE-VU agreed upon. 

These calculated reductions are listed in Table 7 below. This infonnation can be found on the 
MANE-VU Modelingfor Reasonable Progress Goals: Model Performance Evaluation in 

Appendix S of the Pennsylvania submittal. 

T a bl e 7 • P ennsyJ I . vama S02 E mission .. R d e uc f Ions f: rom t e h P ropose dL ow-Siti u ur RI ue 

Tons from reduction Tons from reduction Tons from reduction Total Tons of 

of#2 from 500 to 15 from baseline to of #2 from 2002 level Reduction 

ppm 0.25% for #4 and 0.3- to 500 ppm 

0.5% for #6 

4,034 3,924 20,795 28,753 

v. EPA's analysis of Pennsylvania's Share of Reductions for Reasonable Progress 

Pennsylvania did find more than the 90 percent reduction required in S02 reductions with the use 

of additional sources. EPA finds that Pennsylvania does satisfy this part of the MANE-VU Ask 

as demonstrated in Table 8 below. 

T a e bl 8 C • a I I cu a f Ion 0 fP ennsyJvama I ., s 900f« 0 SO 2 R d e uc f Ions ~ or th e 167 St ac ks 

Facilities in 167 2002 2018 reductions 

Armstrong 16741 1674.1 15066.9 

Brunner Island 2 17686 884.3 16801.7 

Brunner Island 3 39266 1963.3 37302.7 

Cheswick 40232 2011.6 38220.4 

Hatsfield Ferry 2 53016 2650.8 50365.2 

Homer City 1 45760 2288 43472 

Homer City 2 55356 2767.8 52588.2 

Keystone 1 87714 4385.7 83328.3 

Keystone 2 62906 3145.3 59760.7 

Martins Creek 2 22057 0 22057 

Montour 1 61010 3050.5 57959.5 

Montour 2 50448 2522.4 47925.6 

Portland 1 9740.2 9740.2 0 

Portland 2 14568.8 14568.8 0 

Shawville 1 7144.7 7144.7 0 

Additional Facilities for 167, 

90% S02 control 

Sunbury 1-4 (entire facility) 25219.4 1260.97 23958.43 

Reliant Shawville 3 and 4 (entire 

facility) 38243.8753 1912.2 36331.68 

Totals 647108.9753 61970.67 585138.31 

Extra Tons of 

Percent Reduction 90.42345761 Reduction 2477.826688 
Although Pennsylvania was not able to finalize their low sulfur fuel oil strategy, EPA has 

determined that additional federally enforceable measures will be implemented prior to the 2018 

timeframe. These additional measures and associated emission reductions are demonstrated 

below in Table 9. 

Table 9. Additional S02 Emission Reductions 

Source Source Type S02 Emission Enforcement 

Reduction Mechanism 

(tons) 

Portland Generating Electric 19,690 Section 126 

Station Units 1 and 2 ~eneratinK unit Final Ru1e 

EssroclBessemer Cement kiln 593 Federal 

consent 

decree 

(Closure) 

EssroclN azareth Cement kiln 290 Federal 

consent 

decree 

Additional reductions Electric 2,478 Pennsylvania 

from 167 stack generating units Regional 

obligation Haze SIP 

Total S02 Emission 23,051 

reduction (tons) 

The Commonwealth has not finalized its low-sulfur fuel strategy. However, following 

Pennsylvania'S SIP submittal on December 20,2010, additional point sources have become 

subject to federally enforceable S02 emission limits due to facility closures and federal actions as 

shown above in Table 9. These additional point source S02 reductions are 5,702 tons less than 

the reductions projected to result from adoption of a low-sulfur fuel oil strategy; however, this 

shortfall is not anticipated to interfere with the ability of other states to meet their respective 

reasonable progress goals. Additional federal measures are also anticipated to occur prior to 2018 

that will have additional S02 co-benefits such as the Mercury Air Toxic Standard that would 

result in additional reductions not quantified here. The federal consent decree for Essroc facilities 

is found in Appendix A of this TSD as well as a spread sheet of anticipated reductions from that 

consent decree. The final action taken on New Jersey's section 126 petition on Portland 

Generating Station can be found in Appendix B of this TSD. 

Pennsylvania will be required to review all of these emission reductions quantified in their SIP 

during the 5 year look back process and will need to ensure there are no shortfalls at that time.