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Presentation - 8-Hour Ozone RACT
State Implementation Plan

SIP Steering Committee
5/4/06

8-Hour Ozone Related SIPs

  • RACT SIP that meets RACT requirements under 8-hour ozone implementation rule due September 15, 2006
  • 8-hour Attainment Demonstration SIP due June 2007.
  • Reasonable Further Progress SIP (showing 15% reductions from 2002 base year) - due with ozone attainment SIP.
  • CAIR SIP setting up CAIR ozone season trading program due in March, 2007.

Background - RACT

What is RACT (Reasonably Available Control Technology)?
  • Defined as: lowest emission level a facility is capable of meeting through the application of control technology, considering both technical and economic feasibility.
  • Required on existing major stationary emission sources in non-attainment areas.
  • 1970s through 1990s EPA issued Control Technology Guidelines (CTGs) and Achievable Control Technologies (ACTs) to establish 1-hour standard RACT. 

8-hour Ozone RACT SIP

RACT SIP will entail:

  • Review of state 1-hour RACT.
  • Identification of some source categories where new 8-hour RACT determinations may be needed.
  • Certification for some categories that 1-hour standard RACT = 8-hour standard RACT
  • Based on analysis of current technology, economics, and potential for emission reductions.

8-hour Ozone RACT SIP

EPA's Phase 2 Ozone Implementation Rule (11/95) established 8-hour RACT requirements:  

  • For some categories, fundamental control technologies required in 1970s-1990s are still applicable. 
  • Requiring incremental emission reductions from a 2nd round of controls on some categories would not be reasonable. 
  • Need a state-by-state review with regional EPA office of 1-hour RACT regulations and current sources within each state.

1-hour Ozone RACT - MA

Multiple VOC RACT source categories regulated in late 1980s and 1990s: 

  • Various surface coating operations, degreasing, textile finishing, bakeries etc.

1995 NOx RACT categories

  • Large boilers (> 100 MMBtu/hr)
  • Medium boilers (50 - 100 MMBtu/hr)
  • Small boilers (20 - 50 MMBtu/hr)
  • Reciprocating engines
  • Combustion turbines
  • Municipal waste incinerators
  • Glass furnaces

8-Hour Ozone RACT - OTC

  • OTC analysis of control strategies includes review of RACT for various categories.
  • OTC reviewing Institutional, Commercial, Industrial (ICI) Boiler category as a regional control measure. 
  • Category has potential for significant reductions in OTC region.

OTC Draft Control Measure


ICI Boilers

  • OTC evaluating 2 control levels for large (>250 mmBtu/hr) and medium (100-250 mmBtu) ICI boilers (reductions are from uncontrolled levels):
    • 60% NOx reductions; 40% SO2 reductions
    • 80% NOx reductions;  90% SO2 reductions.
  • OTC may evaluate reductions and cost effectiveness for 10-100 mmBtu/hr units or units with NOx emissions > 25 TPY
1-Hour Ozone RACT - MA Boilers

MA 1995 Boiler RACT  determinations based on:

  • Energy input capacity
  • Fuel type
  • Combustion approach (stoker-fired, face-fired, etc…)
  • Heat release rate
  • Potential Emissions

Examples:

  • Small Boilers > 20-50 mmBtu/hr - NOx RACT = annual tune-up.
  • Tangential fired coal dry bottom boilers >100mmBtu/hr - NOx RACT = 0.38 lbs NOx/mmBtu

ICI Boilers - MA RACT Review

  • Region 1 EPA has suggested MA consider tighter emission rates on ICI boilers.
  • Must analyze and determine if RACT for this category should be tighter to meet 8-hour RACT SIP requirement.
  • ICI Stakeholder Meeting -April 27, 2006
  • MA boilers being reviewed - capacity >100mmBtu/hr.
  • MassDEP is not considering review of RACT for boilers < 100mmBtu/hr or < 50 tons.

ICI Boilers - MA RACT Review

  • Sources asked to provide information on
    • Current control technologies at facility.
    • Technological feasibility of additional controls.
    • Estimated costs of additional controls.
    • Potential for use of CAIR allowances or ERCs as a compliance option.
  • Asked for comments/feedback in writing by May 26, 2006

OTC Control Measures -RACT SIP

  • OTC June 6-7 meeting.  Will make recommendations to states to adopt certain regional control measures. Some may be for RACT source categories.
  • Recommendations will be a separate determination, independent of state RACT SIP requirement.
  • OTC analysis of control measures will provide technical support for state RACT SIPs.
  • Each state must still do a state-specific analysis to support its RACT SIP.

Summary - 8-hour Ozone RACT SIP

  • Analysis of all VOC and RACT categories.
  • Certify 1-hour RACT = 8-hour RACT for some.
  • May include new RACT determinations for some NOx categories - ICI boilers likely.
  • September 2006 SIP commitment to adopt new RACT regulations as appropriate based on analyses.
  • If new RACT determinations are made, state must require RACT implementation by May 2009.

 

 

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