1 APPENDIX A7

1.0 REASONABLY AVAILABLE CO NTROL TECHNOLOGY (RACT)
ANALYSIS

This appendix provides an analysis of poten tial 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 (PM 2.5 ) National Ambient Air Quality Standard (NAAQS).

This appendix includes 1) a discussion of the PM 2.5 RACT requirements, 2) a discussion of New Jersey’s public process to date, 3) New Jersey’s PM 2.5 RACT analysis and 4) New Jersey’s PM 2.5 RACT commitments. While this RACT analysis focused on control

measures that reduce direct PM 2.5 and SO 2 (a PM 2.5 precursor) emissi ons for annual PM 2.5 attainment, reductions in regi onal haze, transported emissions , PM-related air toxics, and

24-hour PM 2.5 levels will also result from the implementation of the RACT measures identified by this analysis.

1.1 PM 2.5 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 Implemen tation Plans (SIPs) implementing emission controls that are economically and technol ogically feasible. Specifically, Section 172(c)(1) of the Clean Air Act states:

“In general – such plan provisions sha ll 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 re asonably available control technology ) (emphasis added).

Emissions control technologies that meet thes e criteria for major st ationary 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 guida nce on the Clean Air Act requir ements for State and Tribal plans to implement the annual PM 2.5 NAAQS, including guidelines for making RACT

determinations in nonattainment areas.

The PM 2.5 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 availa ble 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, 20072 attainment date by one year in order to require implementation, this combined RACM/RACT approach would apply that criteri on 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 inte rpretation of the Clean Air Act requirements for RACT, and has therefore chosen to complete its PM 2.5 RACT analysis separate and apart from its RACM analysis, and without consideration of adva ncing the attainment date. New Jersey’s PM 2.5 RACM analysis is included in Appendix A8 of this SIP

document.

In establishing RACT, states must address direct emissions of PM 2.5 , and the precursors

to PM 2.5 formation, (SO 2 and NO

x ), from sources contributing to downwind PM 2.5 nonattainment areas, as well as local sources in a nonattai nment area. The USEPA has designated specific nonattainment areas. New Jersey intends to apply its PM 2.5 measures throughout New Jersey, in the 13 counties that are designated nonattainment, as well as the remaining eight counties that may cont ribute to nonattainment. The USEPA chose not to classify the degree of nonattainment for PM 2.5 as it has in the past for ozone and

PM 10 nonattainment designations. Conseque ntly, the Final Rule provides no corresponding emissions thresholds to ensu re that states with more severe PM 2.5 nonattainment designations are subject to stri cter RACT requirements for attainment. The NJDEP believes that the “no classification” option 2 selected by the USEPA for implementing RACT fails to meet the st andards of the Clean Air Act and could negatively impact the ability of nona ttainment areas to meet the PM 2.5 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 pr ogress 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 PM 2.5 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 we ll as cutoffs from other control programs for facilities and equipment, in orde r to inform its decision process.

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

Regional
Haze/

BART PM 10 RACT 1-hour
Ozone
RACT 8-hour
Ozone
RACT PM 2.5 RACT PM 2.5 RACT – NJ
Comments Sub 18 Significant

Increases PSD SOTA Criteria

Pollutant

CAA/USEPA NJ

PM 2.5 -- N/A -- -- None 10-25/5 -- -- --

PM 10 15 70* -- -- N/A N/A 15 15 5

NO

x 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, 20073 SO 2 40 70* -- -- None 25-50/10 40 40 5 Notes: *Major source cutoff threshold for PM 10 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 t ons per year at the facility level for each

PM 2.5 pollutant. This is lower than the 70 tons per year established in subpart 4 for PM 10 to capture major sources of PM 2.5 , a subset of PM 10 . This ensures a thorough evaluation of the full range of contributing stationa ry sources in New Jersey and prevents backsliding. Next the NJDEP evaluated PM 2.5 emissions at the equipment level down to 5 tons per year. New Jersey requires that ne w 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 reducin g 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 NO

x , VOC, SO 2 , and PM 2.5 control measures, which began in early 2005, with the intention of integr ating the 8-hour ozone, fine pa rticle 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 NO

x , VOC, SO 2 , and PM 2.5 to reduce ozone, fine particles and regional haze. The NJDEP hosted a public workshop entitled,

“ Reducing Air Pollution Together ” and established pertinent wo rkgroups, participated in the development of regional control measur es, and conducted its own preliminary RACT

assessments. The recommendations from thes e three venues were consolidated and presented to the NJDEP’s Air Quality Manageme nt team for their consideration. The Air Quality Management team then discussed a nd 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 pape rs addressing the recommendations from the air quality workgroups, regional and local pe rspectives that were determined to be the most promising by the NJDEP. These white pa pers were used in d eciding the strategies to include in the 8-hour ozone, PM 2.5 and regional haze SIPs. The white papers relevant

to this PM 2.5 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 PM 2.5 Control Measures

SCS003 ICI Boilers

SCS004A Process Heaters & Boile rs in a Petroleum Refinery SCS004B Flares in a Petroleum Refinery SCS004C Fluid Catalytic Cracking Un it (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 Combus tors (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 obt ained by the NJDEP, or regional control strategy development efforts, several of the wh ite papers were revise d. 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 th e source categories selected for rule development. Control m easures under consideration for meeting the

PM 2.5 NAAQS emission sources may also be a ffected 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 stakehol ders in planning their retrofit, or add-on, controls to meet the more specific provisions of those strategies. Th is outreach effort on reducing or controlling air pollutants helped determine reasonable measures to improve air quality and public health, an d achieve federal health and visibility standards. The
NJDEP will continue to reach out to all in terested 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 qualit y 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 deve lop recommendations on how to reduce air emissions from their specific source categorie s, including stationary source s, area sources and mobile sources, both on road and off road. The workgroups were tasked with identifying5 reasonable and effective control measures that impact any of the four ozone, fine particle and regional haze precursors: VOC, NO

x , SO 2 , and direct PM 2.5 . See Chapter 4 for more details regarding the workshop.

Through the cooperative efforts of the NJDEP, federal agencies, i ndustry, consultants, environmental groups, and other members of the regulated community, the workgroups evaluated available emission inventories, tech nical information and fi eld data to develop a list of potential air emission control strategies. The wo rkgroups identified the most promising areas where further evaluation of emission reduction opportunities should be focused for possible inclusion in the SIP revi sions addressing 8-hour ozone, fine particles and regional haze. The criteria used by the workgroups to prioritize control measures included technical feasibility, economic f easibility, 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) wo rkgroups addressed the stationary source categories and available control measures pertinent to this PM 2.5 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 M easure Effected Air Pollutant(s)

PM 2.5 SO 2 NO

x 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 regulat ory 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 de veloping 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 juri sdictions in the Ozone Transport Commission (OTC), the Mid-Atlantic Regional Air Management Association (MARAMA), MidAtlantic/Northeast Visibility Union (MANE-V U), 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 le vel playing field with c onsistent requirements.

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

statement 6 on June 20, 2007, that outlines long-ter m strategies to reduce and prevent regional haze. The MANE-VU states, includin g New Jersey, plan on lowering the sulfur content in fuel oil, implementing Best Ava ilable Retrofit Technology requirements of the Regional Haze Rule and reducing emissons from electric generating units (EGUs) and industrial, commercial and instit utional (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 pa rticle and 8-hour ozone NAAQS. These strategies also reduce annual PM 2.5 emissions. For more information
about the MANE-VU Statement of Principles, please see Ch apter 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 PM 2.5 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 contro l strategies to reduce NO

x , VOC, PM 2.5 , and SO 2 emissions.

The workgroup that focused on major statio nary 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 th e 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 contro l measures. For most categories, control measure worksheets summarizing key facts about the relevant control alternatives were developed by the OTC workgroup and poste d 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 workgr oup, and input from various industry groups,
the OTC selected control measures for sour ce categories and the pollutants, primarily

NO

x and VOC, which would be most effectiv e 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 ap propriate rulemakings to implement the emission reduction percentages, emission rates or technologies for asphalt paving, asphalt production plants, glass furnaces, and Industr ial, Commercial and Institutional (ICI)
boilers. Guidelines are found in OTC Re solution 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 NO

x , and to a lesser degree, VOC, will al so result in reductions to fine particles and regional haze. In addition to NO

x , the OTC initiatives for ICI boilers address reductions of sulfur dioxide (SO 2 ) emissions. (See Chapter 4 for information regarding the MANE-VU regional fuel strategy.) Others, such as glass furnace measures,
will have SO 2 and PM 2.5 cobenefits, as well as NO

x reductions. For more information about the OTC control measure identification pr ocess, or the control measures identified for implementation through this process, please see Chapter 4, Control Measures and Appendix B3.

Mid-Atlantic Regional Air Mana gement Association (MARAMA) The MARAMA states sought to identify and analyze emissions from certain refinery operations to help member stat es with petroleum refineries in developing their SIPs for ozone, fine particles and regional haze. MARA MA determined from this study that there is the potential for additional emission reductio ns from the following sources: 1) fluid catalytic cracking units, 2) flar es and 3) equipment leaks.

Subsequently, MARAMA drafte d a technical report and thr ee multipollutant model rules to (a) codify and perpetuate the requirement s 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 gi ve 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 re port posted on MARAMA’s website. This
letter was sent to the environmental co mmissions of Westville, Perth Amboy, Linden,
and Paulsboro as well.

MARAMA posted its Final Report, “Assessm ent 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 Catalyti c Cracking Units and Petroleum Refinery Flares, in particular, bene fit reduction of fine par ticles by addr essing PM, SO 2 and NO

x . For more information about the MARAMA cont rol measure identification process, or the

control measures identified fo r implementation through this pr ocess, please see Chapter 4, Control Measures, and Appendix B4.

7 Ozone Transport Commission Resolution 06-028 1.2.3 8-Hour Ozone RACT State Impl ementation Plan Revision

The source categories and affected emission un its discussed in the 8-hour Ozone RACT SIP revision represent the most reasonable emissions c ontrol strategies identified through the internal, regional and public efforts to im prove air quality, most notably ozone. The air contaminants most important in the fo rmation of ozone are oxides of nitrogen (NO

x ) and volatile organic compounds (VOC). Reduc tions of these polluta nts, particularly

NO

x , 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 (SO 2 ) and direct fine particles (PM 2.5 ). Therefore, the 8-hour ozone RACT analysis also addressed in part PM 2.5 RACT requirements and the Regional Haze Rule
Best Available Retrofit T echnology (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 th e following parties: PSEG, Connecticut Department of Environmental Protection, Co nectiv Energy, ConocoPhillips – Bayway Refinery, and Valero – Paul sboro Refinery. The commen t 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 categor ies 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 precursor s to ozone, but will also reduce precursors

to PM 2.5 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 Target ed Pollutants Affected Rules

NO

x VOC SO 2 PM 2.5 8-hour Ozone RACT Asphalt used for paving (emulsified and cutback) X N.J.A.C. 7:27-
16.19 1
Asphalt pavement production plants X N.J.A.C. 7:27-

19.9 1
Glass manufacturing furnaces X 4 4 N.J.A.C. 7:27-19.2,
19.10 1

Adhesives and sealants X N.J.A.C. 7:27-26 2

Industrial/commercial/institutional
boilers X N.J.A.C. 7:27-
19.7 1

Oil and Gas Fired Electric generating units (EGUs) X N.J.A.C. 7:27-
19.4 1
High Electric Demand Day (HEDD)

units X N.J.A.C. 7:27-19.4, 19.5, 19.29 1
Coal-fired boilers serving EGUs X X X N.J.A.C. 7:27-4, 10
& 19.4 1
VOC stationary storage tanks X N.J.A.C. 7:27-

16.2 1
Case by Case, Facility-specific
emission limit and alternate

emission limit X X N.J.A.C. 7:27-
16.17 & 19.13 1

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

16.7 1
Municipal solid waste combusters (incinerators) NOx rule X N.J.A.C. 7:27-
19.12 1
Sewage sludge incinerators X N.J.A.C. 7:27-

19.28 1

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 NO

x emissions while providing

SO 2 and PM 2.5 cobenefits.

1.3 PM 2.5 RACT Assessment

As discussed in Section 1.2 (Public Process) section, the NJDEP actively sought input in developing revisions to the SI P for 8-hour ozone, fine partic ulates and regional haze. A RACT analysis focusing on the ozone precursors (NO

x and VOC) is included in a separate document that was finalized on August 1, 2007. 9 New Jersey’s nonattainment

areas for PM 2.5 are also nonattainment fo r 8-hour ozone. Since NO

x is considered an attainment plan precursor for PM 2.5 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 PM 2.5 RACT requirement as well. In addition, any control measures presented in the 8-hour ozone RACT SIP that have co-benefits for PM 2.5 precursors will in part address the PM 2.5 RACT requirement. Although the USEPA does
not consider VOC as a PM 2.5 precursor for SIP and conformity purposes, there will be

some PM 2.5 benefit from the VOC control measur es 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 faci lities with actual 2002 and 2003 emissions of 5 tons per year or more of PM 10 (as surrogate for PM 2.5 ) or

SO 2 . Upon closer examination, th e NJDEP calculated that facili ties with greater than 25 tons per year emissions accounted for 80 percent (%) and 98 pe rcent (%) of total stationary source emissions statewide for PM 10 and SO 2 , respectively.

Then the NJDEP reviewed the source e quipment, and corresponding emissions inventories, located at these facilities, and devel oped a list of types of equipment, or emission units, with actual emissions of at least 5 tons per year of PM 10 and SO 2

. Focusing its feasibility assessment on th ese 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 Perfor mance Standards (NSPS), and Maximum Available Control Technology (MACT), and an ev aluation of whether existing controls at
the time of installation were previously considered Best Available Control Technology (BACT), Lowest Achievable Emission Rate (L AER) or State of the Art (SOTA). In
addition the NJDEP evaluated ot her states’ regulations, such as those in effect in California, and information listed in the USEPA’s RACT/BACT/LAER Clearinghouse (RBLC). Based on this analys is, the NJDEP narrowed the prel iminary list of sources to those with the greatest potential for significant reductions of PM 10 and SO 2 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 in stitutional (ICI) fossil fuel-fired units; Fluid catalytic cracking units (F CCUs) 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 e fforts to identify reasonable multi-pollutant control options for possible inclusion in the 8-hour Ozone, PM 2.5 and regional haze SIPs. Some of these same sources were ultimately addressed in the 8-hour ozone RACT SIP.

Although the USEPA encouraged stat es with overlapping ozone and PM 2.5 nonattainment areas to coordinate the required SIP revi sions, the 8-hour Ozone RACT SIP submittal11 was due to the USEPA by September 16, 2006, prior to the finalizat ion of the USEPA’s Clean Air Fine Particle Implementation Rule on April 25, 2007, that included details of

the PM 2.5 RACT requirements. According to th e Final Rule, states must conduct RACT determinations for stationary sources of direct PM 2.5 emissions, not PM 10 as was used in the original RACT analysis. The NJDEP r eexamined its earlier 2005 RACT analysis to ensure the NJDEP’s presumptive RACT asse ssment of stationary sources potentially contributing to the PM 2.5 nonattainment areas and evaluation of potential emission

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

In determining RACT for PM 2.5 , the Final Rule requi res states address direct emissions of

PM 2.5 , and the PM 2.5 attainment plan precursors, SO 2 and NO

x . Since New Jersey recently conducted a NO

x RACT analysis for the 8-hour ozone standard, the preexisting determination is valid for this RACT analysis. Therefore the NJDEP focused its PM 2.5 RACT reevaluation on direct PM 2.5 emissions.

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

PM 2.5 RACT in the Final Rule, the NJDEP set emission cutoffs it believes are necessary and appropriate to implement controls to ach ieve attainment of the annual and the new daily PM 2.5 NAAQS. Then the NJDEP conducted an internal assessment of major stationary source categories using the cutoff levels consis tent with the 8-hour ozone RACT thresholds. To evaluate RACT, the NJ DEP 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 PM 2.5 . See the Section on “PM 2.5 RACT Requirements” in the beginning of this Appendix. Si nce facilities did not report PM 2.5 emissions in 2002, the
NJDEP used 2005 actual emissions as a baseline in this RACT reevaluation to ascertain the potential for real reductions in determin ing what source categories and which types of emission units may require additional control.

A search of facilities with actual PM 2.5 emissions greater than 25 tons per year reported to the State via its Emissions Statement progr am yielded a list of approximately 40 facilities. Among the largest emitters were elec tric utilities, petroleum refineries, glass manufacturing, municipal waste combusti on, and iron and steel production. Some facilities also reported considerable amounts, gr eater than 5 tons per year, of facility-level fugitive PM 2.5 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 PM 2.5 and Precursors,” a technical document in tended to assist States in developing plans to achieve attainment 10 . See Table A4 on the following pages.

10 http://epa.gov/pm/measures/pm_control_measures_tables_ver1.pdf12Table A4. Review of USEPA List ofStationary Source Control Measures for PM2.5and SO2PrecursorsPM2.5Source CategoryDescriptionPotential Control MeasuresNotes/CommentsCement manufacturingProcess equipmentBaghouseOpen storage piles, primarycrushing operations and conveyingsystemsVarious controlsSCAQMD, 2005, limitsNJ sources - < 25 tpy (FC)Ferrous metals processing Blast furnace casthouse Capture hood and baghouse No sourcesBasic oxygen furnace Secondary capture and controlsystemNo sourcesSinter cooler baghouse No sourcesPetroleum refining FCCUs Wet scrubbers;ESP;Sodium bisulfate injectionMARAMA model rule (includesPM limit);N.J.A.C. 7:27-33 (new)Stationary diesel engines Including generators and otherprime service enginesDiesel particulate filter (DPF);Diesel oxidation catalyst (whereDPF not feasible)NESCAUM, 2003;STAPPA/ALAPCO, FineParticulate Matter report, March2006Utility and ICI boilers Residual oil ESPCycloneN.J.A.C. 7:27-4 (revision)Utility boilers Coal-fired with ESP Indigo agglomerator;Add collection area to ESP equalto one (or two) fieldsN.J.A.C. 7:27-4 (revision)Open furnaces Improve capture No sourcesFerroalloy productionPouring and casting Capture fugitives No sourcesRefractory productsmanufacturingN/A N/A No sourcesNotes: 1. PSEG Sewaren Generating Station has four uncontrolled #6 FO-fired utility boilers.2. Covanta Essex and CamdenCounty MWCs have no baghouses.3. Several glass manufacturershave no particulate controls.13SO2Source CategoryDescriptionPotential Control Measure(s)Notes/CommentsCement kilnsN/AN/ANo sourcesICI boilers Coal-fired N/A No sourcesResidual oil Flue gas desulfurizationDistillate oil 500 ppm sulfur content80% PM2.5co-benefitMANE-VU, 2010 complianceN.J.A.C. 7:27-9 (revision)Inorganic chemical manufactureoperationsCarbon black productionN/ANo sourcesIron and steel Coke ovens N/A No sourcesOil & gas production Process heaters Flue gas desulfurization No sourcesPetroleum refining FCCUs Catalyst additives;Wet gas scrubbers;Feed hydrotreatmentMARAMA model ruleN.J.A.C. 7:27-33 (new)Flares Reduce flaring MARAMA model ruleN.J.A.C. 7:27-33 (new)Process heaters Scrubber (wet/dry/spray dry) MARAMA TSDFO fired process heaters Eliminate oil fired combustion MARAMA TSDSulfur recovery units Increased efficiency and tail gastreatmentMARAMA TSDPrimary aluminum plants N/A N/A No sourcesPrimary smelters -sintering Zinc N/A No sourcesLead N/A No sourcesPulp & paper Acid sulfite pulping Alkaline scrubber;Raise digester pHRecovery furnaces Reduce S content of black liquor;Regulate furnace temperatureNo sources (recycled only)Sulfur recovery plants N/A N/A No sourcesSulfuric acid plants -- Increased recovery efficiency No sources14Coal-fired Scrubber Mercury rule, CAIR, Consent DecreesN.J.A.C 7:27-10 (revision)Residual oil Scrubber0.3 – 0.5% fuel sulfur contentUtility BoilersDistillate oil 0.05% fuel sulfur contentMANE-VU, 2010 complianceN.J.A.C. 7:27-9 (revision)15 Based upon this comparison, the following sources were subsequently identified by the
NJDEP for further evaluation of available control measures to reduce PM 2.5 and SO 2 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 avai lable control measures for each of these categories are summarized below. Each sect ion describes the sour ce category, affected equipment, viable control technologies, exis ting regulations, potential rule strategies, projected emissions reductions , and supporting references.

1.3.1 Technical Feasibility Determinations

Following the methodology used for the ear lier 2005 assessment of feasible control measures, the NJDEP engineers and scientists completed the technical analysis to identify

the most reasonable control opportunities by identifying th e number of units in each category, units with existing air pollution control devices, uncontro lled units, effective control measures and efficiencies, reducti on benefits, and costs where available.

A. Glass Furnaces

New Jersey has seven existing glass manufactur ing plants with a tota l of 25 furnaces that produce container glass, pressed glass, blown glass, an d fiberglass. Nine of these furnaces are electric. Five others use oxy-fu el firing, in which nearly pure oxygen is used for combustion instead of ambient air, reduci ng the presence of nitrogen which reduces

NO

x emissions, a precursor to PM 2.5 formation, and direct emissions of PM 2.5 . The 8-
hour ozone NO

x 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 stipul ate 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 NO

x limits.

Of the 16 non-electric furnaces, four have existing air pollution control devices, electrostatic precipitators, to reduce part iculate emissions. The NJDEP compared available stack test results, PM 10 or TSP as available, to PM 10 emission rates proposed by the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) in the draft
amendments to Rule 4354 11 , New Jersey’s State of th e Art manual and the USEPA’s Final Rule for National Emission Standards for Hazardous Air Pollutants for glass

11 http://www.valleyair.org/Workshops/pos tings/2007/10-08-07/R4354_rule_W1.pdf16 manufacturing area sources 12 . The NJDEP will consider further controls for direct

emissions of PM 2.5 as part of its RACM analysis for the 2006 PM 2.5 daily standard after

further PM 2.5 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-emerge ncy stationary diesel engine s 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 percen t reduction, about 130 tons per year of PM 2.5 emissions, may be achieved. New Jersey will eval uate the feasibility of an engine control technology retrofit program co mparable to California’s engi ne compliance certification

program. 13 Provisions of this rule proposal may include emission limits for PM, NO

x , CO, and VOC. Available retr ofit add-on controls, engine ti ming, feasibility of regulating smaller engines (25 – 50 hp), and attainment dates will be considered during rule development.

New Jersey will also propose rules to impl ement MANE-VU’s long-term, regional fuel oil strategy, which would require use of ultra low sulfur dies el (ULSD), 15 ppm sulfur, in stationary diesel engines by 2016. ULSD us e for emergency generators is federally mandated by October, 2010.

C. Fluid catalytic cracking unit regene rators at petroleum refineries

As part of a regional effort to attain th e 8-hour ozone and fine particle NAAQS, New Jersey is evaluating a rule regulating emissions of PM, NO

x , SO 2 , and CO from fluid catalytic cracking units (FCCUs). There are f our FCCUs at four facilities located in New Jersey, each equipped with wet scrubbers to absorb SO 2 and remove PM 10 . All units meet the PM limit, 0.5 lb/1000 lb coke, suggest ed 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) (s ubpart Cb) for municipal waste combustor (MWC) units with combustion capacity greate r than 250 tons per day. Both the NSPS and emission guidelines require compliance wi th 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 re visions to the NSPS and EGs for Large Municipal Waste Combustors to reflect the le vels 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 e quipment. The final rule 14 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 opera te 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 NO

x control. All units are equipped with scrubbers for SO 2 control, and electrostat ic precipitators (ESP), or baghouses, for PM control. The NOx RACT rule is being revise d to reduce allowable NOx levels, which will result in SNCR being in stalled at the one facility without SNCR.

E. Iron furnaces including electri c arc furnaces and cupolas

Minimills produce steel by using electric ar c 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 ar e already equipped with baghouses. In a preapplication meeting with the NJDEP, anothe r cupola, which is cu rrently not operating, presented their plan to replace their high pr essure drop venturi scrubber with a baghouse to meet New Jersey’s mercury rule 15 requirements for iron or steel melters by January 3, 2010. The addition of a baghouse may result in the added benefit of reduced PM 2.5 emissions from this cupola. Baghouse contro l is reasonably available control technology

for PM 2.5 emission reduction from this sour ce category. Although the NJDEP may evaluate this source category as part of its f ugitive dust control initiative (see G. below), no additional rule making for PM 2.5 emissions is required at this time. The NJDEP will reconsider this source category at the time the more stringent daily PM 2.5 SIP is due.

F. No. 6 fuel oil-fired boilers

Among the main combustion sources emitting direct PM 2.5 are coal and oil-burning utility boilers. As part of its 8-hour ozone SIP comm ittal, New Jersey is drafting a rule proposal that will limit multiple pollutant emissions including NO

x , PM and SO 2 from coal-fired boilers serving electric gene rating units (EGUs), and NO

x from utility boilers burning natural gas, #2 fuel oil and #4 or #6 fuel oil. After review ing stack test results for PM 10 from #6 fuel oil-firing utility boilers, th e NJDEP is evaluating a particulate limit of 0.0300 lb/MMBtu, consistent with the limit prop osal for existing coal-fired EGUs, based

on installation of an electrostat ic precipitator for control. Upon further evaluation at the time of rule making, including evaluation of th e effects of low sulfur oil on particulate emissions, the NJDEP may propose this particul ate limit for all boilers firing #6 fuel oil that are greater than 100 MMB tu/hr, if deemed feasible, making the residual oil particulate requirements equi valent to those for coal.

New Jersey also intends to propose rules to implement MANE-VU’s long-term, regional strategy to reduce the su lfur content of #6 resi dual oil to 0.5 percent (%) sulfur by weight

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

15 N.J.A.C. 7:27-27.618 by 2012 in those zones throughout th e State that now use #6 fuel oil with a sulfur content in excess of the proposed 0.5 pe rcent (%) 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 current ly 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 su ch as quarries and mineral proces sing can emit significant amounts of fugitive dust. New Jersey intends to addr ess fugitive dust emissions in a new rule proposal twhich contains rule provisions requiring a dust management plan for any facility with a history of dus t emissions. The proposal will include a list of source categories that must have a dust management plan and the minimu m requirements for a dust management plan.

1.4 Final Technical RACT determinations for PM 2.5

Table A5 lists the New Jersey candidate so urce categories identified by the Department for potential emission reductions, not includin g those already addressed in the 8-Hour

Ozone RACT SIP 16

.

Table A5. New Jersey Candidate Source Categories for PM 2.5
Candidate Source Categories Targeted Pollutants

NO

x VOC SO 2 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 SO 2 emissions while providing PM 2.5 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 c ontrol 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 PM 2.5 Implementation Rule, the USEPA also defines “Presumptive RACT” as the norm achievable by the
source category. 18 The NJDEP has concluded that wh ere 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 e ffective controls should be considered. For technology transfer, the determination of economic feasib ility for RACT purposes is an estimation of
whether or not the costs are “reasonable” in co mparison 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, s hould not be compared to smaller sources, such as 10 ton per year indus trial boilers, for the purpose of avoiding control of smaller

sources.

RACT rule economic analysis generally focuse s on average cost for a source category to determine if the source category should be furt her regulated. This average cost is not an appropriate cutpoint to decide the reasona bleness of regulating individual sources. Actual costs for sources will be a range of co sts 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 em ission 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 sim ilar sources to do the same, unless there are site specific circumstances that result in co sts much higher than the average costs.
Otherwise about half the sour ces in the source category w ould 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 emi ssion 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 PM 2.5 NAAQS Regulatory Impact Analysis (RIA) 19 , the USEPA used the AirControlNet tool to identify and rank st ationary source controls based on estimates of costs and benefits that may result from attainment nationw ide. In this RIA the USEPA selected controls costing from $20,000 per ton to $350,000 per ton for direct PM 2.5 , SO 2 and NO

x for evaluation. The USEPA did not include “a fixed do llar 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 hi gher for sources that are in, or impact, more serious attainment problems. The USEPA also stat ed that it is inappropriate to establish a fixed cost per ton range for direct PM 2.5 and the fine particle precursors, NO

x and SO 2 , 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 reas onable 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 independe nt of the severity of nonattainment.

Despite the USEPA’s “no classification” approach to PM 2.5 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 PM 2.5 levels, higher costs for PM 2.5 , SO 2 and NO

x controls are reasonable. This statement is appropriate for measures to attain the standards, but not for RACT. New Jersey’s precedents for already requiri ng costs at the higher end of the USEPA’s range for retrofitting fine particle contro l on existing mobil so urces, and increasing difficulty of finding source categories wher e emission reductions ar e feasible, justify relatively high cost effectiven ess 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 transp orted air pollution from states downwind of nonattainment areas. In determining econom ic feasibility, we need to recognize the economic and health costs of fine particle s both within New Jersey and outside our borders, which is the price of continuing nonattainment. The USEPA estimated that relatively small reductions in ambient PM 2.5 levels produce worthw hile public health

benefits. 22

Reductions of PM 2.5 , and particularly the precursors, SO 2 and NO

x , are necessary over broad regions because of their impacts on le vels of fine particles and regional haze downwind. The recognized difficulty in achie ving the annual and newer, more stringent daily fine particle NAAQS justifies RA CT throughout New Jersey and elsewhere, especially in those areas upwi nd of areas designated nonattainment. New Jersey is one of those states upwind of fine pa rticle 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 Ne w Jersey justifies and requires meaningful
RACT measures in the stat es 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 reasonabl e, not only in terms of its technological feasibility, but in terms of de termining 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 circumstan ces would make their costs much higher than the costs for sim ilar units and would also be economically
infeasible. The NJDEP will continue to eval uate 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 a pplicability of AELs to new requirements for SO 2 and PM emissions.

Like the USEPA, the NJDEP does not expect to specify a single $/ton cost/effectiveness ratio for all source categories, because othe r 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 f acility in a source category, and the extent of current use of a control measure by othe r 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 a nd on a unit specific basis
where costs are shown in an Alternat ive Emission Limit (AEL) application 23 to be economically infeasible because of unusual si te specific circumstances and extreme costs.

1.6 Commitments for PM 2.5 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, SO 2 , and NO

x reductions that are most likely to result in a significant decrease in PM 2.5 , and address the RACT requirement for fine particle nonattainment. Table A6 lists th e selected source categ ories 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 no t only reduce precursors to ozone, but will also reduce precursors to PM 2.5 and regional haze as well.

23 N.J.A.C. 7:27-19.1322 Table A6. New Jersey PM 2.5 RACT

Candidate Source Categories Ta rgeted Pollutants Affected Rules Estimated Schedule

NO

x VOC SO 2 PM 2.5 Asphalt pavement production plants X N.J.A.C. 7:27-19.9 1 Adoption by 4/1/09

Glass manufacturing furnaces X 2 2 N.J.A.C. 7:27-19.2,
19.10 1 Adoption by 4/1/09

Industrial/commercial/institution
al boilers X N.J.A.C. 7:27-19.7 1 Adoption by 4/1/09

Oil and Gas Fired Electric generating units (EGUs) X N.J.A.C. 7:27-19.4 1 Adoption by 4/1/09

High Electric Demand Day (HEDD) units X N.J.A.C. 7:27-19.4, 19.5, 19.29 1 Adoption by 4/1/09

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

& 19.4 1 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
& 19.13 1 Adoption by 4/1/09

Municipal solid waste combusters (incinerators) NOx

rule X N.J.A.C. 7:27-
19.12 1 Adoption by 4/1/09

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

19.28 1 Adoption by 4/1/09

Notes: 1. Proposed on August 4, 2008 2. Replacing fossil fuel with oxygen, as in oxy-fuel firing, reduces NO

x emissions while providing

SO 2 and PM 2.5 cobenefits.

1.7 Additional New Jersey Actions for Future PM 2.5 Control

New Jersey has been working with ot her states, including the MANE-VU and MARAMA member states, in implementing reasonable measures to reduce PM, SO 2 and

NO

x emissions to reduce intersta te pollution. As a MARAMA member state, New Jersey is working on a new rule proposal for petr oleum refineries using the MARAMA model rules developed for fluid catalytic cracking uni ts (FCCUs), flares and equipment leaks as a guideline. Also, New Je rsey intends to include provisions regulating NO

x emissions from process heaters and boile rs at petroleum refineries.

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

statement 24 on June 20, 2007 to evaluate lowering the sulfur content of fuel oil over time. New Jersey intends to propose rules to implement these lo ng-term, regional strategies, consistent with the MANE-VU statement, a ffecting the sulfur c ontent 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 add itional potential s ources of emission reductions through its internal technical analyses and the collabora tive efforts of the New Jersey air quality workgroups. In addition to the regional m easures 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 Federa l 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 incl ude rule provisions requiring a dust management plan for any facility with a hi story of dust emissions.

In addition, the Department intends on eval uating 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 PM 2.5 NAAQS attainment date (April 5, 2010), the reductions will help the State
attain the new 2006 24-hour PM 2.5 standard, as well as all the other PM 2.5 -related air quality goals discussed in Chapter 1.

1.8 Requests for USEPA Actions

Based on estimates using AP 42 emissions f actors, the emissions baselines may not accurately reflect filterab le plus condensable PM 2.5 emissions. The USEPA should expeditiously issue an approved test method to measure condensable PM 2.5 so states may develop data to further assess available cont rol measures and to establish enforceable

PM 2.5 emission limits.