SIP Completeness Checklist

 

Administrative Support 

1. A formal letter of submittal from the Governor or designee requesting USEPA 

approval of the revision.

Letter included with package 

2. Evidence that the State has adopted the revision in the State code or body of 

regulations; or issued the permit, order, consent agreement (hereafter document) in 

final form. That evidence should include the date of adoption or final issuance as well 

as the effective date of the revision if different from the adoption/issuance date.

A copy of the alternative emission limit (AEL) for NOx approval is enclosed 

(Enclosure 2). This approval is fully enforceable by the State, and contains 

conditions consistent with N.J.A.C. 7:27-19 (Control and prohibition of Air Pollution 

from Oxides of Nitrogen) most recently amended on November 21, 2005. The AEL 

approval included conditions pursuant to the requirements of N.J.A.C. 7:27-19.13. 

 

3. Evidence that the State has the necessary legal authority under State law to adopt and 

implement the revision.

N.J.A.C. 7:27-19.13 (Facility-specific NOx emission limits) gives the legal authority 

to the Department to approve the AEL. A copy of the rule is available at 

http://www.state.nj.us/dep/aqm/Sub19.htm 

4. A copy of the actual regulation, or document submitted for approval and incorporation 

by reference into the SIP, including indication of the changes made to the existing 

approved SIP, where applicable. The submittal should be a copy of the official state 

regulation/document signed, stamped, dated by the appropriate State official 

indicating that it is fully enforceable by the State. The effective date of the 

regulation/document should, whenever possible, be indicated in the document itself.

A copy of the AEL approval is enclosed (Enclosure 2). The approval was issued on 

May 12, 2009 signed by the Chief, Bureau of Operating Permits. The approval is 
fully enforceable by the State, and contains conditions consistent with N.J.A.C. 

7:27-19 (Control and Prohibition of Air Pollution from Oxides of Nitrogen). 

5. Evidence that the State followed all the requirements of its Administrative Procedures 

Act (or equivalent) in conducting and completing the adoption/issuance of the revision.

Provisions in N.J.A.C. 7:27-19.8(c) and N.J.A.C. 7:27-19.8 (e) specify that on and 

after March 7, 2007, the maximum allowable NOx emission rate from an existing 

lean burn stationary reciprocating engine capable of producing an output of 370 kW 

or more, fueled by liquid fuel and used to generate electricity shall not exceed 2.3 

grams per brake horsepower hour and for a new lean burn stationary reciprocating 

engine capable of producing an output of 370 kW or more, fueled by liquid fuel and 

used to generate electricity shall not exceed 0.90 grams per brake horsepower hour. 

These limits reflect installation of reasonably available control technology (RACT). 

The reasonably available control measures such as selective catalytic reduction, 

selective non catalytic reduction, lean NOx catalyst, catalytic adsorption, water 

injection, exhaust gas recirculation and ignition timing retardation are neither 

technically feasible nor cost effective. Therefore, an alternative emission limit 

(AEL) as described in N.J.A.C. 7:27-19.13 must be implemented. Naval Weapons 

Station Earle submitted an application pursuant to N.J.A.C. 7:27-19.13 for an AEL. 

Naval Weapons Station Earle has proposed to limit the combined hours of operation 

for both engines to less than 675 hours per year and to limit the annual fuel usage to 

20,047.5 gallons per year combined for both engines. The proposed AEL would 

allow Naval Weapons Station Earle to operate both of these engines on 100% fuel oil 

for up to 675 total hours per year, limit the annual fuel usage to 20,047.5 gallons per 

year, and limit the allowable NOx emissions to 11.3 grams /brake horsepower-hour 

and 4.67 tons per year. As specified in N.J.A.C. 7:27-19.13(f), the Department is 

required to seek comments from the general public prior to issuing a final decision 

on a proposed AEL. The public notice for the approval of the AEL was published in 

The Star Ledger newspaper on January 16, 2009 (Enclosure 5). The comment period 

ended on February 16, 2009. 

6. Evidence that Public Notice was given of the proposed change consistent with 

procedures approved by EPA, including the date of publication of such notice.

As described above, the public notice for the approval of AEL was published in The 

Star Ledger newspaper on January 16, 2009 (Enclosure 5). The comment period 

ended on February 17, 2009. Copies of the Affidavit of Publication of the Public 

Notice are included in Enclosure 6. 

 

7. Certification that public hearing(s) were held in accordance with the information 

provided in the public notice and the State's Administrative Procedures Act (or 

equivalent), if applicable. 

There were no requests to conduct a public hearing before, after or during the public 

comment period; therefore, no public hearing was conducted. 
8. Compilation of public comments and the State's response thereto. 

Comments were received from Rickard Ruvo, Chief State Implementation Planning 

Section, Air Programs Branch, USEPA Region II. The Department’s response to 

these comments is attached. 
Technical Support

1. Identification of all regulated pollutants affected by the revision:

Oxides of Nitrogen (NOx) emissions. 

2. Identification of the locations of affected sources including the EPA attainment 

or nonattainment designation of the locations, and the status of the attainment 

plan for the affected sources: 

The facility is located in Monmouth County, New Jersey. Monmouth County 

is part of the NY-NJ-CT 8 hour Ozone Nonattainment Area and is classified 

as moderate, and it is also part of NY-NJ-CT PM2.5 Nonattainment Area. 

The USEPA did not classify the severity of nonattainment for PM2.5. (Note: 

NOx is a precursor for ozone and PM2.5). In general, New Jersey SIP 

revisions demonstrate attainment of both these NAAQS by their mandatory 

attainment dates (June 15, 2010 for O3, and April 5, 2010 for PM2.5) 

3. Quantification of the changes in SIP allowable emissions from affected sources. 

Estimates of changes in current actual emissions from affected sources or, where 

appropriate, quantification of changes in actual emissions from affected sources 

through calculations of the differences between certain baseline levels and 

allowable emissions anticipated post revision: 

These engines are 2-stroke, lean-burn, compression-ignition, diesel fuel fired, 

turbocharged, stationary internal combustion engines with a heat input rating 

of 5.36 and 5.72 MM BTU/hr HHV, respectively. Each engines is capable of 

generating 500 kW of electrical power. The engines will fire diesel fuel with 

a maximum allowable sulfur content of 0.2 percent (%) by weight. There 

will be no increase in actual emissions. The engines will be limited to 675 

hours of operation per year and 20,047.5 gallons of fuel oil per year 

combined for both engines. Potential annual NOx emissions will be reduced 

from 15.98 tons per year to 4.67 tons per year combined for both engines. 

The allowable AEL NOx limit will be 11.3 grams/brake horsepower-hour. 

4. Demonstration that the NAAQS/PSD increments/RFP demonstrated/ visibility 

are protected if revision is approved and implemented: 

This SIP revision is being submitted pursuant to N.J.A.C. 7:27-19.13, the 

NOx RACT rule promulgated to attain the ozone NAAQS by June 15, 2010. 
5. Modeling information required to support the proposed revision, including 

input data, output data, models used, justification of model selections, ambient 

monitoring data used, meteorological data used, justification for use of off-site 

data (where used), modes of models used, assumptions, etc.:

This proposed SIP revision addressing NOx RACT compliance pursuant to 

N.J.A.C. 7:27-19.13 is for ozone attainment. The rule does not require single 

source modeling for ozone and therefore, no modeling for ozone was 

conducted. 

6. Evidence, where necessary, that emission limitations are based on continuous 

emission reduction technology, e.g., add-on controls, industrial/process 

equipment designs, reformulated materials, etc.:

An analysis of available control technology options for reducing NOx 

emissions from the generators was conducted to determine the control 

technology and NOx emissions limits that would represent the best achievable 

level of control that is both technically and economically feasible. A total of 

sixteen NOx emissions control technology options were evaluated to 

determine if they were technically feasible for application to the either 

generator, and, if so, how effective they would be in reducing NOx emissions 

from these units and how much they would cost. The list of options was 

compiled based on the list of technologies set forth in the EPA’s “Alternative 

Control Techniques (ACT) Document and the New Jersey Department of 

Environmental Protection (NJDEP) SOTA Manual for Reciprocating Internal 

Combustion Engines. The findings of the analysis of technical feasibility 

were that none of the NOx control technology options that were identified 

were considered to be technically feasible for either of the generators. More 

specifically: 

TABLE 1 

Option 

Listed 

in 

NJDEP

SOTA 

Listed in

Original

ACT 

Listed 

in 

ACT 

Update 

Technical

ly 

Feasible 

Basis for Determination 

 

Ignition 

timing 

retardation 

(ITR) 

Yes 

(Table 

4) 

Yes 

(Section 

5.3.1.1) 

No No 

There is no clear proof that ITR both 

reduce NOx emissions and not cause 

problems for the engine operation 

Prestratified 

charge 

Yes 

(Table 

4) 

Yes 

(Section 

5.1.4) 

Yes 

(Section 

4.4) 

No Prestratified charge combustion is 

limited to 4-cycl natural gas engines 
TABLE 1 

Option 

Listed 

in 

NJDEP

SOTA 

Listed in

Original

ACT 

Listed 

in 

ACT 

Update 

Technical

ly 

Feasible 

Basis for Determination 

 

Low 

emission 

combustion 

Yes 

(Table 

4) 

Yes 

(Section 

5.1.6) 

Yes 

(Section 

4.1) 

No This technology is not effective on 

diesel engines 

Water 

injection 

Yes 

(Table 

4) 

Yes 

(Section 

5.4.4) 

No No 

This technology for diesel engines 

remains uncertain due to the limited 

theoretical and experimental 

knowledge. 

High 

pressure fuel 

injection 

No No 

Yes 

(Section 

4.6.3) 

No 

This technology is unproven in 

practice for diesel fuel-fired stationary 

RICEs 

High energy 

ignition 

Yes 

(Table 

4) 

No 

Yes 

(Section 

4.5) 

No 

This technology is employed only for 

natural gas-fired, spark-ignition 

engines 

Exhaust gas 

recirculation

(EGR) 

Yes 

(Table 

4) 

Yes 

(Section 

5.4.2) 

No No 

There is no dedicated application that 

EGR technology will reduce NOx 

emissions from the specific model 

engine employed for the MSNAP 

training modules. 

Aftercooling 

Yes 

(Table 

4) 

No No No 

This technology is not feasible 

because aftercooler retrofit kits are not 

available for the MSNAP engines. 

Selective 

Catalytic 

Reduction 

(SCR) 

Yes 

(Table 

5) 

Yes 

(Section 

5.3.1.2) 

Yes 

(Section 

4.2) 

No 

The exhaust temperature of MSNAP 

generator is below the SCR 

temperature window, the system 

cannot be altered to heat the exhaust 

gas so that it would be within the SCR 

temperature window, and 

backpressure cannot be added that 

would alter generator combustion 

equipment or mechanics 

Selective 

NonCatalytic 

Reduction 

(SNCR) 

Yes 

(Table 

5) 

No No No 

The exhaust temperature of MSNAP 

generator is below SNCR temperature 

window 
TABLE 1 

Option 

Listed 

in 

NJDEP

SOTA 

Listed in

Original

ACT 

Listed 

in 

ACT 

Update 

Technical

ly 

Feasible 

Basis for Determination 

 

NonSelective 

Catalytic 

Reduction 

(NSCR) 

Yes 

(Table 

5) 

Yes 

(Section 

5.1.5) 

Yes 

(Section 

4.3) 

No This technology is employed only for 

rich-burn, spark-ignition engines 

Catalytic 

adsorption 

Yes 

(Table 

5) 

No No No 

This technology is unproven in 

practice for diesel fuel-fired stationary 

RICEs 

SCONOxTM No No 

Yes 

(Section 

4.6.1) 

No 

This technology is unproven in 

practice for diesel fuel-fired stationary 

RICEs 

Lean NOx 

catalyst 

Yes 

(Table 

5) 

No No No 

This technology is unproven in 

practice for diesel fuel-fired stationary 

RICEs 

Ozone 

injection 

Yes 

(Table 

5) 

No No No 

This technology is unproven in 

practice for diesel fuel-fired stationary 

RICEs that are operated in the same 

manner as the MSNAP engines 

NOx Tech 

Emission 

Control 

System 

No No 

Yes 

(Section 

4.6.3) 

No 

This technology is focused on sparkignition engines that burn natural gas 

or dual fuel and not diesel fired 

engines. 

• 

Because there are no available technically feasible NOx emissions control technologies 

that can be applied, no control technology would be economically feasible. 
7. Evidence that a revision contains emission limitations, work practice standards 

and record keeping/reporting requirements, where necessary, to ensure emission 

levels:

The AEL when approved will include the following conditions: 

Conditions Where specified in the FSEL approval 

1. NOx Emission Limit Condition B. 

2. Combustion Process Adjustment Condition C. 

3. Emissions Testing and Monitoring Condition D. 

3. Recordkeeping Requirements Condition E. 

These requirements are consistent with the NOx RACT requirements specified in 

N.J.A.C. 7:27-19.13 (Facility Specific NOx Emission Limits). 

8. Compliance/enforcement strategies including how compliance will be 

determined in practice, and at what frequency:

The maximum allowable NOx emission rates are specified in condition B. 

Continuous compliance/enforcement with the allowable NOx emission rate 

will be determined through periodic emission monitors as specified in the 

condition D and recordkeeping requirements specified in the condition E. 

Please refer to final AEL approval document to locate these requirements. 

(Enclosure 2). 

9. As appropriate, special economic and technological justifications per applicable 

EPA policies. For example, economic and technological justification for 

alternative RACT, for long-term averaging for VOC emission limits, or its 

support bubble proposals. 

Estimates of the cost-effectiveness of applying SCR were developed, based 

on several extreme assumptions. The estimates indicated that even if there 

were some way of applying SCR to the generators and achieve 90% 

reduction of NOx emissions at all times; it would still result in a cost of more 

than $29,400 per ton of emissions reduction.. That was considered to be an 

unreasonable cost and therefore SCR is both not technically feasible and not 

economically feasible for this application.