### SIP Completeness Checklist

Administrative Support

1. A formal letter of submittal from the Governor o r 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 a greement (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 (Contro l and prohibition of Air Pollution from Oxides of Nitrogen) most recently amended on N ovember 21, 2005. The AEL approval included conditions pursuant to the requir ements 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 th e rule is available at http://www.state.nj.us/dep/aqm/Sub19.htm

4. A copy of the actual regulation, or document sub mitted for approval and incorporation by reference into the SIP, including indication of the changes made to the existing approved SIP, where applicable. The submittal shou ld be a copy of the official state regulation/document signed, stamped, dated by the a ppropriate State official indicating that it is fully enforceable by the Stat e. The effective date of the regulation/document should, whenever possible, be i ndicated 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 Operati ng Permits. The approval isfully enforceable by the State, and contains condit ions consistent with N.J.A.C. 7:27-19 (Control and Prohibition of Air Pollution f rom Oxides of Nitrogen).

5. Evidence that the State followed all the require ments of its Administrative Procedures Act (or equivalent) in conducting and completing th e 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 NO x emission rate from an existing lean burn stationary reciprocating engine capable o f 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 ava ilable control technology (RACT). The reasonably available control measures such as s elective catalytic reduction, selective non catalytic reduction, lean NOx catalys t, catalytic adsorption, water injection, exhaust gas recirculation and ignition t iming 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 i mplemented. 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 t he combined hours of operation for both engines to less than 675 hours per year and to limit the annual fuel usage t o 20,047.5 gallons per year combined for both engines . The proposed AEL would allow Naval Weapons Station Earle to operate both o f these engines on 100% fuel oil for up to 675 total hours per year, limit the annua l 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 p rior to issuing a final decision on a proposed AEL. The public notice for the appro val of the AEL was published in The Star Ledger newspaper on January 16, 2009 (Encl osure 5). The comment period ended on February 16, 2009.

6. Evidence that Public Notice was given of the pro posed change consistent with procedures approved by EPA, including the date of p ublication of such notice.

As described above, the public notice for the appro val of AEL was published in The Star Ledger newspaper on January 16, 2009 (Enclosur e 5). The comment period ended on February 17, 2009. Copies of the Affidavi t of Publication of the Public Notice are included in Enclosure 6.

7. Certification that public hearing(s) were held i n accordance with the information provided in the public notice and the State's Admin istrative 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 co nducted.8. Compilation of public comments and the State's r esponse thereto.

Comments were received from Rickard Ruvo, Chief Sta te 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 affec ted by the revision:

Oxides of Nitrogen (NO x ) emissions.

2. Identification of the locations of affected sour ces 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 Jer sey. 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 nonattai nment for PM2.5. (Note: NOx is a precursor for ozone and PM2.5). In general , New Jersey SIP revisions demonstrate attainment of both these NAAQ S 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 e missions from affected sources. Estimates of changes in current actual emissions fr om affected sources or, where appropriate, quantification of changes in actual em issions from affected sources through calculations of the differences between cer tain baseline levels and allowable emissions anticipated post revision:

These engines are 2-stroke, lean-burn, compression- ignition, diesel fuel fired, turbocharged, stationary internal combustion engine s 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 engin es 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 em issions will be reduced from 15.98 tons per year to 4.67 tons per year comb ined for both engines. The allowable AEL NOx limit will be 11.3 grams/brak e horsepower-hour.

4. Demonstration that the NAAQS/PSD increments/RFP demonstrated/ visibility are protected if revision is approved and implement ed:

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 pro posed revision, including

input data, output data, models used, justification of model selections, ambient monitoring data used, meteorological data used, jus tification for use of off-site data (where used), modes of models used, assumption s, etc.:

This proposed SIP revision addressing NO x RACT compliance pursuant to N.J.A.C. 7:27-19.13 is for ozone attainment. The r ule does not require single source modeling for ozone and therefore, no modelin g for ozone was conducted.

6. Evidence, where necessary, that emission limitat ions are based on continuous emission reduction technology, e.g., add-on control s, industrial/process equipment designs, reformulated materials, etc.:

An analysis of available control technology options for reducing NOx emissions from the generators was conducted to dete rmine the control technology and NOx emissions limits that would repr esent the best achievable level of control that is both technically and econo mically feasible. A total of sixteen NOx emissions control technology options we re evaluated to determine if they were technically feasible for app lication 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 fort h in the EPA’s “Alternative Control Techniques (ACT) Document and the New Jerse y Department of Environmental Protection (NJDEP) SOTA Manual for Re ciprocating Internal Combustion Engines. The findings of the analysis o f technical feasibility were that none of the NOx control technology option s that were identified were considered to be technically feasible for eith er 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 enginesTABLE 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
windowTABLE 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

SCONOx TM 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 limit ations, work practice standards

and record keeping/reporting requirements, where ne cessary, to ensure emission levels:

The AEL when approved will include the following co nditions:

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 NO x 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 specif ied in condition B. Continuous compliance/enforcement with the allowabl e NOx emission rate will be determined through periodic emission monito rs as specified in the condition D and recordkeeping requirements specifie d in the condition E. Please refer to final AEL approval document to loca te these requirements. (Enclosure 2).

9. As appropriate, special economic and technologic al justifications per applicable EPA policies. For example, economic and technologi cal justification for alternative RACT, for long-term averaging for VOC e mission limits, or its support bubble proposals.

Estimates of the cost-effectiveness of applying SCR were developed, based on several extreme assumptions. The estimates indi cated 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 s till 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 tec hnically feasible and not economically feasible for this application.