1

APPENDIX A7 

1.0 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) 

ANALYSIS 

This appendix provides an analysis of potential control measures for major point source 

categories in order to determine whether or not any of these measures could be 

considered a reasonably available control technology (RACT) for the annual Fine 

Particulate Matter (PM2.5) National Ambient Air Quality Standard (NAAQS). 

This appendix includes 1) a discussion of the PM2.5 RACT requirements, 2) a discussion 

of New Jersey’s public process to date, 3) New Jersey’s PM2.5 RACT analysis and 4) 

New Jersey’s PM2.5 RACT commitments. While this RACT analysis focused on control 

measures that reduce direct PM2.5 and SO2 (a PM2.5 precursor) emissions for annual PM2.5

attainment, reductions in regional haze, transported emissions, PM-related air toxics, and 

24-hour PM2.5 levels will also result from the implementation of the RACT measures 

identified by this analysis. 

1.1 PM2.5 RACT Requirements 

42 U.S.C. §7502(c)(1) (Section 172(c)(1) of the Clean Air Act) requires states with 

nonattainment areas to submit State Implementation Plans (SIPs) implementing emission 

controls that are economically and technologically feasible. Specifically, Section 

172(c)(1) of the Clean Air Act states: 

“In general – such plan provisions shall provide for the implementation of all 

reasonably available control measures as expeditiously as practicable (including such 

reductions in emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonably available control technology) 

(emphasis added).

Emissions control technologies that meet these criteria for major stationary sources are 

known as Reasonably Available Control Technology or “RACT.” 

On April 25, 2007, the USEPA issued the Clean Air Fine Particle Implementation Rule.1

 

This final rule provides guidance on the Clean Air Act requirements for State and Tribal 

plans to implement the annual PM2.5 NAAQS, including guidelines for making RACT 

determinations in nonattainment areas. 

The PM2.5 Implementation Rule establishes a combined approach to RACT and RACM, 

where the RACT analysis is simply a part of the overall RACM analysis, defining them 

as those measures that a state finds are both reasonably available and contribute to 

attainment as expeditiously as practical in the specific nonattainment area. Since the final 

determinant of RACM is that measures, either alone or in combination, can advance the 

 

1

 72 Fed. Reg. 20586; April 25, 2007 
2

attainment date by one year in order to require implementation, this combined 

RACM/RACT approach would apply that criterion to RACT measures. This is contrary 

to the USEPA’s RACT approach under Subpart 2 of the Clean Air Act for ozone, where 

RACT is required as a separate analysis from RACM, and does not consider advancing 

the attainment date a criterion for required implementation. New Jersey believes that the 

approach taken for ozone is the correct interpretation of the Clean Air Act requirements 

for RACT, and has therefore chosen to complete its PM2.5 RACT analysis separate and 

apart from its RACM analysis, and without consideration of advancing the attainment 

date. New Jersey’s PM2.5 RACM analysis is included in Appendix A8 of this SIP 

document. 

In establishing RACT, states must address direct emissions of PM2.5, and the precursors 

to PM2.5 formation, (SO2 and NOx), from sources contributing to downwind PM2.5

nonattainment areas, as well as local sources in a nonattainment area. The USEPA has 

designated specific nonattainment areas. New Jersey intends to apply its PM2.5 measures 

throughout New Jersey, in the 13 counties that are designated nonattainment, as well as 

the remaining eight counties that may contribute to nonattainment. The USEPA chose 

not to classify the degree of nonattainment for PM2.5 as it has in the past for ozone and 

PM10 nonattainment designations. Consequently, the Final Rule provides no 

corresponding emissions thresholds to ensure that states with more severe PM2.5

nonattainment designations are subject to stricter RACT requirements for attainment. 

The NJDEP believes that the “no classification” option2 selected by the USEPA for 

implementing RACT fails to meet the standards of the Clean Air Act and could 

negatively impact the ability of nonattainment areas to meet the PM2.5 NAAQS by 

providing “potential exemptions for large sources of particulate matter that could impact 

the attainment status of the area in which they are located, as well as impact the ability of 

downwind areas to make progress towards attainment.”3

The Clean Air Act requires States with nonattainment areas to implement RACT on 

existing major sources, but provides no specific list defining specific stationary sources 

of direct PM2.5 emissions and precursor emissions, or “major” cutoff thresholds of the 

potential to emit from these sources, that must be evaluated.4 Table A1 shows a 

comparison of various RACT thresholds, as well as cutoffs from other control programs 

for facilities and equipment, in order to inform its decision process. 

Table A1. Major Source/Equipment Thresholds (tons per year) 

Regional 

Haze/ 

BART 

PM10

RACT 

1-hour 

Ozone 

RACT 

8-hour 

Ozone 

RACT 

PM2.5

RACT 

PM2.5

RACT – NJ 

Comments 

Sub 18 

Significant 

Increases 

Criteria PSD SOTA 

Pollutant 

CAA/USEPA NJ 

PM2.5 -- N/A -- -- None 10-25/5 -- -- -- 

PM10 15 70* -- -- N/A N/A 15 15 5 

NOx 40 70* 25/10 100** None 25-50/10 25 40 5 

 

2

 72 Fed. Reg. 20611; April 25, 2007 3

 70 Fed. Reg. 65984; November 1, 2005 4

 72 Fed. Reg. 20620; April 25, 2007 
3

SO2 40 70* -- -- None 25-50/10 40 40 5 

Notes: *Major source cutoff threshold for PM10 and its precursors for serious nonattainment areas from 

CAA, Subpart 4 of Part D, “Additional Provisions for Particulate Matter Nonattainment Areas.” 

 **In New Jersey, major thresholds for 1-hr ozone continue to apply for 8-hr ozone to prevent 

backsliding. 

The NJDEP established RACT thresholds at 25 tons per year at the facility level for each 

PM2.5 pollutant. This is lower than the 70 tons per year established in subpart 4 for PM10

to capture major sources of PM2.5, a subset of PM10. This ensures a thorough evaluation 

of the full range of contributing stationary sources in New Jersey and prevents 

backsliding. Next the NJDEP evaluated PM2.5 emissions at the equipment level down to 

5 tons per year. New Jersey requires that new and modified equipment with greater than 

five tons per year criteria pollutant emissions incorporate advances in the art of air 

pollution control, referred to as “state-of-the-art” (SOTA) requirement. In the Regulatory 

Impact Analysis, the USEPA determined that sources emitting less than 5 tons per year 

“were likely to have existing controls in place, and further control was typically not costeffective and inefficient in reducing area-wide concentrations of PM.”5

 The NJDEP 

chose to set an equipment level threshold of 10 tons per year for each attainment plan 

pollutant as the cutoff for existing equipment in its RACT analysis. The 25/10 thresholds 

coincide with the cutoff levels initially chosen by the NJDEP in our preliminary 

evaluation of NOx, VOC, SO2, and PM2.5 control measures, which began in early 2005, 

with the intention of integrating the 8-hour ozone, fine particle and regional haze SIP 

requirements to achieve concurrent benefits. 

1.2 Public Process 

Starting in 2005, the NJDEP began its effort to identify promising source categories with 

the potential for significant emission reductions of NOx, VOC, SO2, and PM2.5 to reduce 

ozone, fine particles and regional haze. The NJDEP hosted a public workshop entitled, 

“Reducing Air Pollution Together” and established pertinent workgroups, participated in 

the development of regional control measures, and conducted its own preliminary RACT 

assessments. The recommendations from these three venues were consolidated and 

presented to the NJDEP’s Air Quality Management team for their consideration. The Air 

Quality Management team then discussed and prioritized the recommendations resulting 

in a list of approximately 60 potential control measures for further evaluation. 

Using the same template as the Ozone Transport Commission’s control measure 

worksheets, the NJDEP staff wrote white papers addressing the recommendations from 

the air quality workgroups, regional and local perspectives that were determined to be the 

most promising by the NJDEP. These white papers were used in deciding the strategies 

to include in the 8-hour ozone, PM2.5 and regional haze SIPs. The white papers relevant 

to this PM2.5 RACT analysis are listed in Table A2. 

 

5

 U.S.EPA 2006. Regulatory Impact Analysis for the Particulate Matter National Ambient Air Quality 

Standards. Air Benefits and Costs Group, Office of air Quality Planning and Standards, Research Triangle 

Park, NC, October 6, 2006. 
4

Table A2. List of White Papers Relevant to PM2.5 Control Measures 

SCS003 ICI Boilers 

SCS004A Process Heaters & Boilers in a Petroleum Refinery 

SCS004B Flares in a Petroleum Refinery 

SCS004C Fluid Catalytic Cracking Unit (FCCU) in a Petroleum Refinery 

SCS006A Coal Fired EGU Boilers 

SCS006B No. 6 Fuel Oil-Fired EGU Boilers 

SCS007 Glass/Fiberglass Furnaces 

SCS008 Asphalt Production Plants 

SCS009 Municipal Waste Combustors (MWCs) (Incinerators) 

DI014 Control Measures for Stationary Diesel Engines 

HR001 Regional Sulfur Fuel Oil Controls 

The white papers were made available to the public for their review and comment. Based 

on comments received, other information obtained by the NJDEP, or regional control 

strategy development efforts, several of the white papers were revised. The white papers 

are available on the NJDEP’s website at 

www.nj.gov/dep/airworkgroups/docs/wp_summary_table_web.xls. More detailed evaluations 

were done subsequent to the white papers in order to develop this SIP and the rules which 

implement the SIP.

The NJDEP met with industry representatives to acquire input on the source categories 

selected for rule development. Control measures under consideration for meeting the 

PM2.5 NAAQS emission sources may also be affected by the NJDEP’s rule proposals to 

lower the levels of ozone and regional haze. Strategies are being coordinated to the 

extent reasonable to help affected stakeholders in planning their retrofit, or add-on, 

controls to meet the more specific provisions of those strategies. This outreach effort on 

reducing or controlling air pollutants helped determine reasonable measures to improve 

air quality and public health, and achieve federal health and visibility standards. The 

NJDEP will continue to reach out to all interested parties, including industry and 

environmental organizations, when it develops rule strategies to address the problems of 

air pollution most effectively. 

1.2.1 “Reducing Air Pollution Together” Initiative 

The NJDEP commenced a collaborative effort to discuss the air quality challenges facing 

New Jersey by hosting a public workshop on Wednesday, June 29, 2005, at the Trenton 

War Memorial Building, Trenton, New Jersey. This workshop served to initiate a 

dialogue between the NJDEP and interested and affected parties about reducing 

emissions in order to improve air quality in New Jersey. As a result of the Reducing Air 

Pollution Together workshop, six air quality workgroups were formed and collaborated 

over several months to develop recommendations on how to reduce air emissions from 

their specific source categories, including stationary sources, area sources and mobile 

sources, both on road and off road. The workgroups were tasked with identifying 
5

reasonable and effective control measures that impact any of the four ozone, fine particle 

and regional haze precursors: VOC, NOx, SO2, and direct PM2.5. See Chapter 4 for more 

details regarding the workshop. 

Through the cooperative efforts of the NJDEP, federal agencies, industry, consultants, 

environmental groups, and other members of the regulated community, the workgroups 

evaluated available emission inventories, technical information and field data to develop 

a list of potential air emission control strategies. The workgroups identified the most 

promising areas where further evaluation of emission reduction opportunities should be 

focused for possible inclusion in the SIP revisions addressing 8-hour ozone, fine particles 

and regional haze. The criteria used by the workgroups to prioritize control measures 

included technical feasibility, economic feasibility, environmental benefits, and 

implementation feasibility. 

The air quality workgroups compiled their recommendations into reports that are 

available at http://www.nj.gov/dep/airworkgroups/index.html. The Diesel Initiatives (DI) 

and Stationary Combustion Sources (SCS) workgroups addressed the stationary source 

categories and available control measures pertinent to this PM2.5 RACT evaluation. The 

following table summarizes the stationary source categories, available control measure(s) 

and the effected air pollutant(s) highly recommended by the DI and SCS workgroups as 

promising control strategies. 

Source Category Available Control Measure Effected Air Pollutant(s) 

PM2.5 SO2 NOx VOC

Diesel Initiatives Workgroup 

Stationary diesel engines Federal New Source 

Performance Standards 

X X X X 

Generators Ultra low sulfur diesel X 

Stationary Combustion Sources Workgroup 

Fuel-oil combustion sources Lower sulfur content of 

fuel oil 

* X 

No. 6 fuel oil combustion 

sources 

Fuel switching to lower 

sulfur fuel content 

* X 

* cobenefit

The workgroup processes were an early stage in the development of the SIP revisions. 

The NJDEP held a follow-up workshop on Wednesday, May 17, 2006, to provide an 

update on efforts during the preceding year to address air quality challenges facing New 

Jersey and to share preliminary regulatory and nonregulatory plans to reduce air 

emissions. The public provided feedback on the workshop, and on the 60 white papers 

drafted by the NJDEP and discussed at the workshop, through an online survey and/or 

directly contacting the NJDEP by email or mail. Comments received on the white papers 

are posted at www.nj.gov/dep/airworkgroups/comments.html. Many Workgroup 

members continued to be active in developing and commenting on both the draft 

emission control measures and the ongoing SIP revisions. 
6

1.2.2 Regional Actions 

The Department worked with the other jurisdictions in the Ozone Transport Commission 

(OTC), the Mid-Atlantic Regional Air Management Association (MARAMA), MidAtlantic/Northeast Visibility Union (MANE-VU), and Northeast States for Coordinated 

Air Use Management (NESCAUM) to identify reasonable control measures which could 

be implemented regionally, yielding greater air quality benefits for nonattainment areas 

and providing industry a level playing field with consistent requirements. 

Mid-Atlantic/Northeast Visibility Union (MANE-VU)

The states of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) signed a 

statement6

 on June 20, 2007, that outlines long-term strategies to reduce and prevent 

regional haze. The MANE-VU states, including New Jersey, plan on lowering the sulfur 

content in fuel oil, implementing Best Available Retrofit Technology requirements of the 

Regional Haze Rule and reducing emissons from electric generating units (EGUs) and 

industrial, commercial and institutional (ICI) boilers, as part of these long-term strategies. 

New Jersey intends to implement these long-term, regional strategies to improve 

visibility as well as attain the new, more stringent, 24-hour fine particle and 8-hour ozone 

NAAQS. These strategies also reduce annual PM2.5 emissions. For more information 

about the MANE-VU Statement of Principles, please see Chapter 4, Control Measures 

and Appendix B5. 

Ozone Transport Commission (OTC)

New Jersey worked concurrently with other jurisdictions in the Ozone Transport Region 

(OTR) to explore reasonable control measures for potentially significant reductions to 

attain the 8-hour ozone and PM2.5 NAAQS and to achieve regional haze goals. The 

Ozone Transport Commission (OTC) staff and member jurisdictions formed workgroups 

to review mobile, point and area sources, identify candidate source categories; and 

consider potential control strategies to reduce NOx, VOC, PM2.5, and SO2 emissions. 

The workgroup that focused on major stationary point sources compiled a list of 

candidate control measures from sources published by the USEPA and various regional 

associations, OTC member state-specific control strategies already in place, and emission 

control initiatives from states outside the Ozone Transport Region, such as California. 

Then using 2002 emission inventories as the base year, the workgroups determined 

projected 2009 emission reductions, based on currently mandated controls including 

Federal rules, adoption of OTC model rules by member jurisdictions, enforcement 

settlements, and other state-specific control measures. For most categories, control 

measure worksheets summarizing key facts about the relevant control alternatives were 

developed by the OTC workgroup and posted on the OTC website for stakeholder 

comments. 

 

6

 Statement of the MANE-VU Concerning a Course of Action within MANE-VU toward Assuring 

Reasonable Progress, June 20, 2007. 
7

Based on the assessment of the OTC workgroup, and input from various industry groups, 

the OTC selected control measures for source categories and the pollutants, primarily 

NOx and VOC, which would be most effective in reducing ozone levels throughout the 

Ozone Transport Region. The State of New Jersey and other OTC member jurisdictions 

have resolved to pursue necessary and appropriate rulemakings to implement the 

emission reduction percentages, emission rates or technologies for asphalt paving, asphalt 

production plants, glass furnaces, and Industrial, Commercial and Institutional (ICI) 

boilers. Guidelines are found in OTC Resolution 06-02, adopted on June 7, 2006, and 

amended on November 15, 2006. The suggested compliance date for these guidelines is 

January 1, 2009, or as soon as practicable thereafter.7 

Reductions of NOx, and to a lesser degree, VOC, will also result in reductions to fine 

particles and regional haze. In addition to NOx, the OTC initiatives for ICI boilers 

address reductions of sulfur dioxide (SO2) emissions. (See Chapter 4 for information 

regarding the MANE-VU regional fuel strategy.) Others, such as glass furnace measures, 

will have SO2 and PM2.5 cobenefits, as well as NOx reductions. For more information 

about the OTC control measure identification process, or the control measures identified 

for implementation through this process, please see Chapter 4, Control Measures and 

Appendix B3. 

Mid-Atlantic Regional Air Management Association (MARAMA)

The MARAMA states sought to identify and analyze emissions from certain refinery 

operations to help member states with petroleum refineries in developing their SIPs for 

ozone, fine particles and regional haze. MARAMA determined from this study that there 

is the potential for additional emission reductions from the following sources: 1) fluid 

catalytic cracking units, 2) flares and 3) equipment leaks. 

Subsequently, MARAMA drafted a technical report and three multipollutant model rules 

to (a) codify and perpetuate the requirements of consent decrees, and (b) provide more 

stringent requirements where practicable for these three refinery processes. MARAMA 

posted these documents on their website for input from stakeholders, environmental 

groups, and the general public, and also held a conference call to give stakeholders an 

opportunity to ask questions about the report and model rules. The NJDEP also sent 

letters to environmental groups in New Jersey informing them of the availability of the 

model rules and the supporting technical report posted on MARAMA’s website. This 

letter was sent to the environmental commissions of Westville, Perth Amboy, Linden, 

and Paulsboro as well. 

MARAMA posted its Final Report, “Assessment of Control Technology Options for 

Petroleum Refineries in the Mid-Atlantic Region,” and the three model rules in January 

2007. The Model Rules for Fluidized Catalytic Cracking Units and Petroleum Refinery 

Flares, in particular, benefit reduction of fine particles by addressing PM, SO2 and NOx. 

For more information about the MARAMA control measure identification process, or the 

control measures identified for implementation through this process, please see Chapter 

4, Control Measures, and Appendix B4. 

 

7

 Ozone Transport Commission Resolution 06-02 
8

1.2.3 8-Hour Ozone RACT State Implementation Plan Revision 

The source categories and affected emission units discussed in the 8-hour Ozone RACT 

SIP revision represent the most reasonable emissions control strategies identified through 

the internal, regional and public efforts to improve air quality, most notably ozone. The 

air contaminants most important in the formation of ozone are oxides of nitrogen (NOx) 

and volatile organic compounds (VOC). Reductions of these pollutants, particularly 

NOx, also result in reductions to fine particles and regional haze. Hence, some of the 8-

hour ozone RACT measures from New Jersey’s ozone SIP will also reduce emissions of 

sulfur dioxide (SO2) and direct fine particles (PM2.5). Therefore, the 8-hour ozone RACT 

analysis also addressed in part PM2.5 RACT requirements and the Regional Haze Rule 

Best Available Retrofit Technology (BART) requirement. 

The NJDEP held a public hearing on the 8-hour ozone RACT SIP revision proposal in 

Trenton, New Jersey on March 19, 2007. No oral testimony was given at the hearing, but 

written comments were received from the following parties: PSEG, Connecticut 

Department of Environmental Protection, Conectiv Energy, ConocoPhillips – Bayway 

Refinery, and Valero – Paulsboro Refinery. The comment period closed on March 26, 

2007. The NJDEP finalized its RACT SIP for 8-hour ozone on August 1, 2007.8

 

Table A3 lists the selected source categories and the targeted pollutants that were 

discussed in New Jersey's 8-Hour Ozone RACT SIP and/or in New Jersey's rule making 

process, which will not only reduce precursors to ozone, but will also reduce precursors 

to PM2.5 and regional haze as well. 

 

8 NJDEP. Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient 

Air Quality Standard (NAAQS) and other Associated State Implementation Plan (SIP) Revisions for the 

Fine Particulate Matter National Ambient Air Quality Standard (NAAQS), Regional Haze, and the 

Clean Air Act Requirements on Transport of Air Pollution. New Jersey Department of Environmental 

Protection. August 1, 2007. 
9

Table A3. New Jersey Ozone RACT 

Candidate Source Categories Targeted Pollutants Affected Rules 

 NOx VOC SO2 PM2.5 

8-hour Ozone RACT 

Asphalt used for paving (emulsified 

and cutback) 

 X N.J.A.C. 7:27-

16.191 

Asphalt pavement production plants X N.J.A.C. 7:27-

19.91 

Glass manufacturing furnaces X 4 4 N.J.A.C. 7:27-19.2, 

19.101 

Adhesives and sealants X N.J.A.C. 7:27-262 

Industrial/commercial/institutional 

boilers 

X N.J.A.C. 7:27-

19.71 

Oil and Gas Fired Electric 

generating units (EGUs) 

X N.J.A.C. 7:27-

19.41 

High Electric Demand Day (HEDD) 

units 

X N.J.A.C. 7:27-19.4, 

19.5, 19.291 

Coal-fired boilers serving EGUs X X X N.J.A.C. 7:27-4, 10 

& 19.41 

VOC stationary storage tanks X N.J.A.C. 7:27-

16.21

Case by Case, Facility-specific 

emission limit and alternate 

emission limit 

X X N.J.A.C. 7:27-

16.17 & 19.131

2006 Control Techniques Guidelines X N.J.A.C. 7:27-

16.71

Municipal solid waste combusters 

(incinerators) NOx rule 

X N.J.A.C. 7:27-

19.121

Sewage sludge incinerators X N.J.A.C. 7:27-

19.281

Notes: 1. Proposed on August 4, 2008 

 2. Adopted on October 30, 2008 

3. Replacing fossil fuel with oxygen, as in oxy-fuel firing, reduces NOx emissions while providing 

SO2 and PM2.5 cobenefits. 

1.3 PM2.5 RACT Assessment 

As discussed in Section 1.2 (Public Process) section, the NJDEP actively sought input in 

developing revisions to the SIP for 8-hour ozone, fine particulates and regional haze. A 

RACT analysis focusing on the ozone precursors (NOx and VOC) is included in a 

separate document that was finalized on August 1, 2007.9 New Jersey’s nonattainment 

areas for PM2.5 are also nonattainment for 8-hour ozone. Since NOx is considered an 

attainment plan precursor for PM2.5 as well as ozone, the 8-hour ozone RACT analysis 

 

9 Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient Air Quality 

Standard (NAAQS) and other Associated State Implementation Plan (SIP) Revisions for the 

Fine Particulate Matter National Ambient Air Quality Standard (NAAQS), Regional Haze, and the 

Clean Air Act Requirements on Transport of Air Pollution. New Jersey Department of Environmental 

Protection. August 1, 2007. 
10

was proposed for the PM2.5 RACT requirement as well. In addition, any control 

measures presented in the 8-hour ozone RACT SIP that have co-benefits for PM2.5

precursors will in part address the PM2.5 RACT requirement. Although the USEPA does 

not consider VOC as a PM2.5 precursor for SIP and conformity purposes, there will be 

some PM2.5 benefit from the VOC control measures that New Jersey committed to 

implement in the 8-hour ozone RACT SIP. 

Given the overlap of precursors and timing of SIP submittals, the NJDEP initially began 

work in 2005 to integrate its fine particle control efforts with those for the 8-hour ozone 

and regional haze SIPs. The NJDEP initially identified about 100 facilities with actual 

2002 and 2003 emissions of 5 tons per year or more of PM10 (as surrogate for PM2.5) or 

SO2. Upon closer examination, the NJDEP calculated that facilities with greater than 25 

tons per year emissions accounted for 80 percent (%) and 98 percent (%) of total 

stationary source emissions statewide for PM10 and SO2, respectively. 

Then the NJDEP reviewed the source equipment, and corresponding emissions 

inventories, located at these facilities, and developed a list of types of equipment, or 

emission units, with actual emissions of at least 5 tons per year of PM10 and SO2. 

Focusing its feasibility assessment on these emission units, the NJDEP conducted a 

review of current state and federal requirements such as N.J.A.C.7:27-4, N.J.A.C.7:27-6 

and N.J.A.C.7:27-9, New Source Performance Standards (NSPS), and Maximum 

Available Control Technology (MACT), and an evaluation of whether existing controls at 

the time of installation were previously considered Best Available Control Technology 

(BACT), Lowest Achievable Emission Rate (LAER) or State of the Art (SOTA). In 

addition the NJDEP evaluated other states’ regulations, such as those in effect in 

California, and information listed in the USEPA’s RACT/BACT/LAER Clearinghouse 

(RBLC). Based on this analysis, the NJDEP narrowed the preliminary list of sources to 

those with the greatest potential for significant reductions of PM10 and SO2 emission 

levels. The following were the source categories initially selected for further 

consideration: 

 Boilers – serving electric generating units (EGUs) firing No. 6 fuel oil and coal, 

 and industrial, commercial and institutional (ICI) fossil fuel-fired units; 

 Fluid catalytic cracking units (FCCUs) at petroleum refineries; 

Furnaces – such as glass, and iron and steel; 

Municipal waste combustors (MWCs) (Incinerators) PM portion; and 

Stationary diesel engines. 

Several source categories from the NJDEP’s original short-list were also identified in 

conjunction with the public and regional efforts to identify reasonable multi-pollutant 

control options for possible inclusion in the 8-hour Ozone, PM2.5 and regional haze SIPs. 

Some of these same sources were ultimately addressed in the 8-hour ozone RACT SIP. 

Although the USEPA encouraged states with overlapping ozone and PM2.5 nonattainment 

areas to coordinate the required SIP revisions, the 8-hour Ozone RACT SIP submittal 
11

was due to the USEPA by September 16, 2006, prior to the finalization of the USEPA’s 

Clean Air Fine Particle Implementation Rule on April 25, 2007, that included details of 

the PM2.5 RACT requirements. According to the Final Rule, states must conduct RACT 

determinations for stationary sources of direct PM2.5 emissions, not PM10 as was used in 

the original RACT analysis. The NJDEP reexamined its earlier 2005 RACT analysis to 

ensure the NJDEP’s presumptive RACT assessment of stationary sources potentially 

contributing to the PM2.5 nonattainment areas and evaluation of potential emission 

reduction control measures meets the Final Rule’s guidance to identify RACT. 

In determining RACT for PM2.5, the Final Rule requires states address direct emissions of 

PM2.5, and the PM2.5 attainment plan precursors, SO2 and NOx. Since New Jersey 

recently conducted a NOx RACT analysis for the 8-hour ozone standard, the preexisting 

determination is valid for this RACT analysis. Therefore the NJDEP focused its PM2.5 

RACT reevaluation on direct PM2.5 emissions. 

Since the USEPA did not use a classification system to establish emissions thresholds for 

PM2.5 RACT in the Final Rule, the NJDEP set emission cutoffs it believes are necessary 

and appropriate to implement controls to achieve attainment of the annual and the new 

daily PM2.5 NAAQS. Then the NJDEP conducted an internal assessment of major 

stationary source categories using the cutoff levels consistent with the 8-hour ozone 

RACT thresholds. To evaluate RACT, the NJDEP set cutoff thresholds of 25 tons per 

year at the facility level, and equipment emitting 10 tons per year located at such a 

facility, of actual PM2.5. See the Section on “PM2.5 RACT Requirements” in the 

beginning of this Appendix. Since facilities did not report PM2.5 emissions in 2002, the 

NJDEP used 2005 actual emissions as a baseline in this RACT reevaluation to ascertain 

the potential for real reductions in determining what source categories and which types of 

emission units may require additional control. 

A search of facilities with actual PM2.5 emissions greater than 25 tons per year reported to 

the State via its Emissions Statement program yielded a list of approximately 40 

facilities. Among the largest emitters were electric utilities, petroleum refineries, glass 

manufacturing, municipal waste combustion, and iron and steel production. Some 

facilities also reported considerable amounts, greater than 5 tons per year, of facility-level 

fugitive PM2.5 emissions. 

Table A4 compares New Jersey’s identified sources with the stationary sources and 

related control measures compiled in the USEPA’s “Lists of Potential Control Measures 

for PM2.5 and Precursors,” a technical document intended to assist States in developing 

plans to achieve attainment10. See Table A4 on the following pages. 

 

10 http://epa.gov/pm/measures/pm_control_measures_tables_ver1.pdf
12

Table A4. Review of USEPA List of Stationary Source Control Measures for PM2.5 and SO2 Precu

PM2.5

Source Category Description Potential Control Measures No

Cement manufacturing Process equipment Baghouse  Open storage piles, primary 

crushing operations and conveying systems 

Various controls 

SCAQMDNJ sources 

Ferrous metals processing Blast furnace casthouse Capture hood and baghouse No sources  Basic oxygen furnace Secondary capture and control 

system 

No sources 

 Sinter cooler baghouse No sources Petroleum refining FCCUs Wet scrubbers; 

ESP; Sodium bisulfate injection 

MARAMA PM limit); N.J.A.C. 7

Stationary diesel engines Including generators and other 

prime service engines 

Diesel particulate filter (DPF); Diesel oxidation catalyst (where DPF not feasible) 

NESCAUMSTAPPA/AParticulate 2006 

Utility and ICI boilers Residual oil ESP 

Cyclone 

N.J.A.C. 7

Utility boilers Coal-fired with ESP Indigo agglomerator; 

Add collection area to ESP equal to one (or two) fields 

N.J.A.C. 7

Ferroalloy production Open furnaces Improve capture No sources 

Pouring and casting Capture fugitives No sources 

Refractory products manufacturing 

N/A N/A No sources 

Notes: 1. PSEG Sewaren Generating Station has four uncontrolled #6 FO-fired utility boilers.  2. Covanta Essex and Camden County MWCs have no baghouses.  3. Several glass manufacturers have no particulate controls. 
13

SO2

Source Category Description Potential Control Measure(s) Note

Cement kilns N/A N/A No sources ICI boilers Coal-fired N/A No sources  Residual oil Flue gas desulfurization  Distillate oil 500 ppm sulfur content 

80% PM2.5 co-benefit 

MANE-VU, 20N.J.A.C. 7:27-9 

Inorganic chemical manufacture operations Carbon black production N/A No sources Iron and steel Coke ovens N/A No sources Oil & gas production Process heaters Flue gas desulfurization No sources Petroleum refining FCCUs Catalyst additives; 

Wet gas scrubbers; Feed hydrotreatment 

MARAMA moN.J.A.C. 7:27-3

 Flares Reduce flaring MARAMA mo

N.J.A.C. 7:27-3

 Process heaters Scrubber (wet/dry/spray dry) MARAMA TS FO fired process heaters Eliminate oil fired combustion MARAMA TS Sulfur recovery units Increased efficiency and tail gas 

treatment 

MARAMA TS

Primary aluminum plants N/A N/A No sources Primary smelters -sintering Zinc N/A No sources  Lead N/A No sources Pulp & paper Acid sulfite pulping Alkaline scrubber; 

Raise digester pH 

 Recovery furnaces Reduce S content of black liquor; 

Regulate furnace temperature 

No sources (rec

Sulfur recovery plants N/A N/A No sources Sulfuric acid plants -- Increased recovery efficiency No sources 
14

Coal-fired Scrubber Mercury rule, C

N.J.A.C 7:27-1

Residual oil Scrubber 

0.3 – 0.5% fuel sulfur content 

Utility Boilers 

Distillate oil 0.05% fuel sulfur content 

MANE-VU, 20N.J.A.C. 7:27-9 
15

Based upon this comparison, the following sources were subsequently identified by the 

NJDEP for further evaluation of available control measures to reduce PM2.5 and SO2

emissions: 

Glass Furnaces 

Stationary Diesel Engines 

Petroleum Refineries 

Municipal Waste Combustors (Incinerators) PM portion 

Iron and Steel Furnaces 

No. 6 Fuel-oil Fired Boilers 

Fugitive Dust Sources 

Evaluations of the emission units and available control measures for each of these 

categories are summarized below. Each section describes the source category, affected 

equipment, viable control technologies, existing regulations, potential rule strategies, 

projected emissions reductions, and supporting references. 

1.3.1 Technical Feasibility Determinations 

Following the methodology used for the earlier 2005 assessment of feasible control 

measures, the NJDEP engineers and scientists completed the technical analysis to identify 

the most reasonable control opportunities by identifying the number of units in each 

category, units with existing air pollution control devices, uncontrolled units, effective 

control measures and efficiencies, reduction benefits, and costs where available. 

A. Glass Furnaces 

New Jersey has seven existing glass manufacturing plants with a total of 25 furnaces that 

produce container glass, pressed glass, blown glass, and fiberglass. Nine of these 

furnaces are electric. Five others use oxy-fuel firing, in which nearly pure oxygen is used 

for combustion instead of ambient air, reducing the presence of nitrogen which reduces 

NOx emissions, a precursor to PM2.5 formation, and direct emissions of PM2.5. The 8-

hour ozone NOx rule committal would require the remaining furnaces to implement 

additional emission control measures to comply with the proposed emission limit. 

Although New Jersey does not intend to stipulate a particular control technology in the 

rule proposal, the NJDEP anticipates that most furnaces will likely install oxy-fuel firing 

to meet the more stringent NOx limits. 

Of the 16 non-electric furnaces, four have existing air pollution control devices, 

electrostatic precipitators, to reduce particulate emissions. The NJDEP compared 

available stack test results, PM10 or TSP as available, to PM10 emission rates proposed by 

the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) in the draft 

amendments to Rule 435411, New Jersey’s State of the Art manual and the USEPA’s 

Final Rule for National Emission Standards for Hazardous Air Pollutants for glass 

 

11 http://www.valleyair.org/Workshops/postings/2007/10-08-07/R4354_rule_W1.pdf
16

manufacturing area sources12. The NJDEP will consider further controls for direct 

emissions of PM2.5 as part of its RACM analysis for the 2006 PM2.5 daily standard after 

further PM2.5 emission data is available. 

B. Stationary diesel engines 

Incomplete combustion of diesel fuel results in direct particle emissions. Based upon the 

electronic permitting and emissions inventory database information, the NJDEP estimates 

there are a total of 352 non-emergency stationary diesel engines greater than or equal to 

50 horsepower currently in-use in New Jersey. Through the use of add-on particle 

control, the NJDEP estimates an 85 percent reduction, about 130 tons per year of PM2.5

emissions, may be achieved. New Jersey will evaluate the feasibility of an engine control 

technology retrofit program comparable to California’s engine compliance certification 

program.13 Provisions of this rule proposal may include emission limits for PM, NOx, 

CO, and VOC. Available retrofit add-on controls, engine timing, feasibility of regulating 

smaller engines (25 – 50 hp), and attainment dates will be considered during rule 

development. 

New Jersey will also propose rules to implement MANE-VU’s long-term, regional fuel 

oil strategy, which would require use of ultra low sulfur diesel (ULSD), 15 ppm sulfur, in 

stationary diesel engines by 2016. ULSD use for emergency generators is federally 

mandated by October, 2010. 

C. Fluid catalytic cracking unit regenerators at petroleum refineries 

As part of a regional effort to attain the 8-hour ozone and fine particle NAAQS, New 

Jersey is evaluating a rule regulating emissions of PM, NOx, SO2, and CO from fluid 

catalytic cracking units (FCCUs). There are four FCCUs at four facilities located in New 

Jersey, each equipped with wet scrubbers to absorb SO2 and remove PM10. All units 

meet the PM limit, 0.5 lb/1000 lb coke, suggested in MARAMA’s model rule for FCCUs. 

D. Municipal waste combustors (incinerators) PM portion 

In December 1995, USEPA adopted new source performance standards (NSPS) (40 CFR 

60 subpart Eb) and emission guidelines (EG) (subpart Cb) for municipal waste combustor 

(MWC) units with combustion capacity greater than 250 tons per day. Both the NSPS 

and emission guidelines require compliance with emission limitations for nine pollutants 

that reflect the performance of maximum achievable control technology (MACT). The 

emission guidelines required compliance by December 2000, for all existing MWC units, 

while the NSPS apply to new MWC units. Currently, all New Jersey MWC units are in 

compliance with the federal plan standards. 

On December 19, 2005, the USEPA proposed revisions to the NSPS and EGs for Large 

Municipal Waste Combustors to reflect the levels of performance achieved due to the 

 

12 72 Fed. Reg. 73182, December, 26, 2007. 13 California Code Rules, Air Toxic Control Measures (CCR-ATCM: September, 2005) 
17

installation of control equipment. The final rule14 includes a revision to PM emission 

limits for existing units from 27 milligrams per dry standard cubic meter to 24 milligrams 

per dry standard cubic meter after April 29, 2009. In practice, all New Jersey Municipal 

Solid Waste Facilities currently operate below the new Federal guidelines. 

In New Jersey, there are 13 MWCs at five resource recovery facilities in Essex, Union, 

Camden, Gloucester and Warren counties. With the exception of one facility with three 

MWCs, all have installed selective non-catalytic reduction (SNCR) as NOx control. All 

units are equipped with scrubbers for SO2 control, and electrostatic precipitators (ESP), 

or baghouses, for PM control. The NOx RACT rule is being revised to reduce allowable 

NOx levels, which will result in SNCR being installed at the one facility without SNCR. 

E. Iron furnaces including electric arc furnaces and cupolas 

Minimills produce steel by using electric arc furnaces (EAF) and cupolas produce iron 

pipe from scrap metal. There is one minimill and a cupola currently operating in New 

Jersey. The operating cupola and the EAF are already equipped with baghouses. In a 

preapplication meeting with the NJDEP, another cupola, which is currently not operating, 

presented their plan to replace their high pressure drop venturi scrubber with a baghouse 

to meet New Jersey’s mercury rule15 requirements for iron or steel melters by January 3, 

2010. The addition of a baghouse may result in the added benefit of reduced PM2.5

emissions from this cupola. Baghouse control is reasonably available control technology 

for PM2.5 emission reduction from this source category. Although the NJDEP may 

evaluate this source category as part of its fugitive dust control initiative (see G. below), 

no additional rule making for PM2.5 emissions is required at this time. The NJDEP will 

reconsider this source category at the time the more stringent daily PM2.5 SIP is due. 

F. No. 6 fuel oil-fired boilers 

Among the main combustion sources emitting direct PM2.5 are coal and oil-burning utility 

boilers. As part of its 8-hour ozone SIP committal, New Jersey is drafting a rule proposal 

that will limit multiple pollutant emissions including NOx, PM and SO2 from coal-fired 

boilers serving electric generating units (EGUs), and NOx from utility boilers burning 

natural gas, #2 fuel oil and #4 or #6 fuel oil. After reviewing stack test results for PM10

from #6 fuel oil-firing utility boilers, the NJDEP is evaluating a particulate limit of 

0.0300 lb/MMBtu, consistent with the limit proposal for existing coal-fired EGUs, based 

on installation of an electrostatic precipitator for control. Upon further evaluation at the 

time of rule making, including evaluation of the effects of low sulfur oil on particulate 

emissions, the NJDEP may propose this particulate limit for all boilers firing #6 fuel oil 

that are greater than 100 MMBtu/hr, if deemed feasible, making the residual oil 

particulate requirements equivalent to those for coal. 

New Jersey also intends to propose rules to implement MANE-VU’s long-term, regional 

strategy to reduce the sulfur content of #6 residual oil to 0.5 percent (%) sulfur by weight 

 

14 70 Fed. Reg. 75348-69, May 10, 2006 

15 N.J.A.C. 7:27-27.6 
18

by 2012 in those zones throughout the State that now use #6 fuel oil with a sulfur content 

in excess of the proposed 0.5 percent (%) maxium. The reduced sulfur fuel is currently 

available for sale and regulated for use in certain zones of New Jersey and can be 

considered reasonable. Areas which currently have 0.3 percent (%) sulfur content limits 

for #6 fuel oil would continue at this level. 

G. Fugitive Dust Sources 

Fugitive dust is made up of suspended particles caused by human activities and wind. 

Industrial activities such as quarries and mineral processing can emit significant amounts 

of fugitive dust. New Jersey intends to address fugitive dust emissions in a new rule 

proposal twhich contains rule provisions requiring a dust management plan for any 

facility with a history of dust emissions. The proposal will include a list of source 

categories that must have a dust management plan and the minimum requirements for a 

dust management plan. 

1.4 Final Technical RACT determinations for PM2.5 

Table A5 lists the New Jersey candidate source categories identified by the Department 

for potential emission reductions, not including those already addressed in the 8-Hour 

Ozone RACT SIP16. 

Table A5. New Jersey Candidate Source Categories for PM2.5 

Candidate Source Categories Targeted Pollutants 

 NOx VOC SO2 PM 

Sulfur in fuel oil X * 

Fugitive dust X 

Municipal waste combustors 

(incinerators) PM portion 

X X 

No. 6 fuel oil-fired boilers * X 

Stationary diesel engines X X X X 

*Note: Lowering the sulfur content in fuel oil reduces SO2 emissions while providing PM2.5 cobenefit. 

1.5 Economic Feasibility Determinations 

The USEPA has defined RACT as “the lowest emission limitation that a particular source 

is capable of meeting by the application of control technology that is reasonably available 

 

16 NJDEP. Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient 

Air Quality Standard (NAAQS) and other Associated State Implementation Plan (SIP) Revisions for the 

Fine Particulate Matter National Ambient Air Quality Standard (NAAQS), Regional Haze, and the 

Clean Air Act Requirements on Transport of Air Pollution. New Jersey Department of Environmental 

Protection. August 1, 2007. 
19

considering technological and economic feasibility.”

17 In the final PM2.5 Implementation 

Rule, the USEPA also defines “Presumptive RACT” as the norm achievable by the 

source category.18 The NJDEP has concluded that where several facilities in a source 

category are currently controlled to a lower emission level, then that level should be 

presumed to be RACT for the other facilities in that source category. Also, even without 

existing controls on any units in a source category, technology transfer from similar 

source categories with more effective controls should be considered. For technology 

transfer, the determination of economic feasibility for RACT purposes is an estimation of 

whether or not the costs are “reasonable” in comparison with the costs of similar controls 

for comparable industries. In general, the costs and cost effectiveness of much larger 

sources, such as 1000 ton per year EGUs, should not be compared to smaller sources, 

such as 10 ton per year industrial boilers, for the purpose of avoiding control of smaller 

sources. 

RACT rule economic analysis generally focuses on average cost for a source category to 

determine if the source category should be further regulated. This average cost is not an 

appropriate cutpoint to decide the reasonableness of regulating individual sources. 

Actual costs for sources will be a range of costs below and above the average cost. Also, 

there may be considerable difference in costs for individual sources because some 

sources are already controlled to some degree. In view of the variability of RACT costs 

among sources and source categories, and for emission reductions of different pollutants, 

the NJDEP concludes that once a number of sources in a source category achieve a lower 

emission level, it is reasonable for other similar sources to do the same, unless there are 

site specific circumstances that result in costs much higher than the average costs. 

Otherwise about half the sources in the source category would not be controlled if an 

emission limit were based on costs exceeding an average cost. RACT rules should 

require that lowest reasonable limits be achieved by almost all units in the source 

category. For some sources, an alternate emission limit (AEL) may be appropriate if site 

specific circumstances and the resulting costs are truly unusual, that is significantly 

higher than almost all other sources. 

In conducting its PM2.5 NAAQS Regulatory Impact Analysis (RIA)19, the USEPA used 

the AirControlNet tool to identify and rank stationary source controls based on estimates 

of costs and benefits that may result from attainment nationwide. In this RIA the USEPA 

selected controls costing from $20,000 per ton to $350,000 per ton for direct PM2.5, SO2

and NOx for evaluation. The USEPA did not include “a fixed dollar per ton cost 

threshold for RACT”20 in the Final Rule. In considering what level of control is needed 

for attainment, the cost per ton is logically higher for sources that are in, or impact, more 

serious attainment problems. The USEPA also stated that it is inappropriate to establish a 

fixed cost per ton range for direct PM2.5 and the fine particle precursors, NOx and SO2, 

because the same reduction of each pollutant has a different impact on attainment. The 

 

17 44 Fed. Reg. 53762, September 17, 1979. 18 72 Fed. Reg. 20610, April 25, 2007. 

19 U.S.EPA 2006. Regulatory Impact Analysis for the Particulate Matter National Ambient Air Quality 

Standards. Air Benefits and Costs Group, Office of air Quality Planning and Standards, Research Triangle 

Park, NC, October 6, 2006. 

20 70 Fed. Reg. 20619, April 25, 2007. 
20

NJDEP agrees that much higher costs are reasonable for direct emissions of PM2.5 in or 

near a nonattainment area. However, RACT is a baseline requirement that should be 

applied in nonattainment areas independent of the severity of nonattainment. 

Despite the USEPA’s “no classification” approach to PM2.5 designations, the USEPA 

states in the rule “that areas with more severe attainment problems will need to 

implement more stringent measures to attain.”21 Therefore, for nonattainment areas with 

higher ambient PM2.5 levels, higher costs for PM2.5, SO2 and NOx controls are reasonable. 

This statement is appropriate for measures to attain the standards, but not for RACT. 

New Jersey’s precedents for already requiring costs at the higher end of the USEPA’s 

range for retrofitting fine particle control on existing mobil sources, and increasing 

difficulty of finding source categories where emission reductions are feasible, justify 

relatively high cost effectiveness ratios to achieve healthy air. For example, ongoing 

retrofits of particulate traps on diesel vehicles have a cost effectiveness of greater than 

$100,000 per ton, which is reasonable given the health effects of fine particles. 

RACT is also important in reducing transported air pollution from states downwind of 

nonattainment areas. In determining economic feasibility, we need to recognize the 

economic and health costs of fine particles both within New Jersey and outside our 

borders, which is the price of continuing nonattainment. The USEPA estimated that 

relatively small reductions in ambient PM2.5 levels produce worthwhile public health 

benefits.22 

Reductions of PM2.5, and particularly the precursors, SO2 and NOx, are necessary over 

broad regions because of their impacts on levels of fine particles and regional haze 

downwind. The recognized difficulty in achieving the annual and newer, more stringent 

daily fine particle NAAQS justifies RACT throughout New Jersey and elsewhere, 

especially in those areas upwind of areas designated nonattainment. New Jersey is one of 

those states upwind of fine particle nonattainment areas in other states. The high fine 

particle levels in New York justify and require meaningful RACT rules in New Jersey. 

Likewise the high fine particle levels in New Jersey justifies and requires meaningful 

RACT measures in the states upwind of New Jersey. 

The NJDEP intends to specify RACT at the lowest emission limit that a reasonable 

number of similar industries had already successfully implemented for each source 

category. This is appropriate and reasonable, not only in terms of its technological 

feasibility, but in terms of determining economic feasibility as well. As the State moves 

ahead to implement these emission levels, an economic analysis will be prepared for each 

source category when specific emission limits are developed. In addition, upon adoption 

of more stringent standards, a facility may conduct an individual emission unit economic 

impact analysis as part of an application for an alternative emission limit (AEL), if the 

facility documents and justifies that unusual site specific circumstances would make their 

costs much higher than the costs for similar units and would also be economically 

infeasible. The NJDEP will continue to evaluate AELs on a case by case basis, using the 

 

21 72 Fed. Reg. 20598, April 25, 2007. 

22 72 Fed. Reg. 20590, April 25, 2007. 
21

criteria previously adopted in N.J.A.C. 7:27-19; and expanding the applicability of AELs 

to new requirements for SO2 and PM emissions. 

Like the USEPA, the NJDEP does not expect to specify a single $/ton cost/effectiveness 

ratio for all source categories, because other factors could justify different costs for 

different source categories. These include, but not limited to: quantity of emissions, 

quality of emissions (including toxicity), seasonal and daily pattern of emissions, impacts 

on other states, affordability for the average facility in a source category, and the extent 

of current use of a control measure by other sources in the same category. The NJDEP 

will continue to base RACT primarily on technological feasibility and at least some 

degree of use for a particular source category. Costs will primarily be considered for 

technology transfer from one source category to another and on a unit specific basis 

where costs are shown in an Alternative Emission Limit (AEL) application23 to be 

economically infeasible because of unusual site specific circumstances and extreme costs. 

1.6 Commitments for PM2.5 Control 

Section 172(c)(6) of the Clean Air Act (42 U.S.C.§ 7502(c)(6)) requires nonattainment 

SIPs to “include enforceable emission limitations, and such other control measures, 

means or techniques... as well as schedules and timetables for compliance, as may be 

necessary and appropriate to provide for attainment.” The following presents New 

Jersey’s commitments to achieve additional PM, SO2, and NOx reductions that are most 

likely to result in a significant decrease in PM2.5, and address the RACT requirement for 

fine particle nonattainment. Table A6 lists the selected source categories and the targeted 

pollutants that were discussed in New Jersey's 8-Hour Ozone RACT SIP and/or in New 

Jersey's rule making process, which will not only reduce precursors to ozone, but will 

also reduce precursors to PM2.5 and regional haze as well. 

 

23 N.J.A.C. 7:27-19.13 
22

Table A6. New Jersey PM2.5 RACT 

Candidate Source Categories Targeted Pollutants Affected Rules Estimated Schedule

 NOx VOC SO2 PM2.5 

Asphalt pavement production 

plants 

X N.J.A.C. 7:27-19.91 Adoption by 4/1/09 

Glass manufacturing furnaces X 2 2 N.J.A.C. 7:27-19.2, 

19.101 

Adoption by 4/1/09 

Industrial/commercial/institution

al boilers 

X N.J.A.C. 7:27-19.71 Adoption by 4/1/09 

Oil and Gas Fired Electric 

generating units (EGUs) 

X N.J.A.C. 7:27-19.41 Adoption by 4/1/09 

High Electric Demand Day 

(HEDD) units 

X N.J.A.C. 7:27-19.4, 

19.5, 19.291 

Adoption by 4/1/09 

Coal-fired boilers serving EGUs X X X N.J.A.C. 7:27-4, 10 

& 19.41 

Adoption by 4/1/09 

Case by Case, Facility-specific 

emission limit and alternate 

emission limit 

X X N.J.A.C. 7:27-16.17 

& 19.131 

Adoption by 4/1/09 

Municipal solid waste 

combusters (incinerators) NOx 

rule 

X N.J.A.C. 7:27-

19.121 

Adoption by 4/1/09 

Sewage sludge incinerators X N.J.A.C. 7:27-

19.281 

Adoption by 4/1/09 

Notes: 1. Proposed on August 4, 2008 

2. Replacing fossil fuel with oxygen, as in oxy-fuel firing, reduces NOx emissions while providing 

SO2 and PM2.5 cobenefits. 

1.7 Additional New Jersey Actions for Future PM2.5 Control 

New Jersey has been working with other states, including the MANE-VU and 

MARAMA member states, in implementing reasonable measures to reduce PM, SO2 and 

NOx emissions to reduce interstate pollution. As a MARAMA member state, New Jersey 

is working on a new rule proposal for petroleum refineries using the MARAMA model 

rules developed for fluid catalytic cracking units (FCCUs), flares and equipment leaks as 

a guideline. Also, New Jersey intends to include provisions regulating NOx emissions 

from process heaters and boilers at petroleum refineries. 

The states of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) signed a 

statement24 on June 20, 2007 to evaluate lowering the sulfur content of fuel oil over time. 

New Jersey intends to propose rules to implement these long-term, regional strategies, 

consistent with the MANE-VU statement, affecting the sulfur content and corresponding 

emisson limits of the following types of fuel: 

 

 

24 Statement of the MANE-VU Concerning a Course of Action within MANE-VU toward Assuring 

Reasonable Progress, June 20, 2007. 
23

Light oil (No. 2 fuel oil, diesel fuel used by stationary sources) 

 Heavy oil (No. 4 fuel oil and No. 6 fuel oil). 

The Department identified additional potential sources of emission reductions through its 

internal technical analyses and the collaborative efforts of the New Jersey air quality 

workgroups. In addition to the regional measures cited above, New Jersey intends on 

addressing emissions from the following sources as follows: 

• Municipal waste combustors (incinerators) PM portion: New Jersey intends to revise 

the emission limit for PM as a compliance requirement in each facility’s Title V 

operating permit, upon promulgation of a Federal rule, State rule or modification of 

the MWC; 

• Fugitive dust (PM): New Jersey intends to address fugitive dust emissions in a new 

rule proposal that will include rule provisions requiring a dust management plan for 

any facility with a history of dust emissions. 

In addition, the Department intends on evaluating the feasibility of a more stringent 

particulate limit for No. 6 fuel oil-fired boilers and stationary diesel engines. 

Although emission reduction benefits from the efforts described above will occur after 

the 1997 PM2.5 NAAQS attainment date (April 5, 2010), the reductions will help the State 

attain the new 2006 24-hour PM2.5 standard, as well as all the other PM2.5-related air 

quality goals discussed in Chapter 1. 

1.8 Requests for USEPA Actions 

Based on estimates using AP 42 emissions factors, the emissions baselines may not 

accurately reflect filterable plus condensable PM2.5 emissions. The USEPA should 

expeditiously issue an approved test method to measure condensable PM2.5 so states may 

develop data to further assess available control measures and to establish enforceable 

PM2.5 emission limits.