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Federal Register / Vol. 86, No. 208 / Monday, November 1, 2021 / Rules and Regulations instances in which commenter claims there are minor errors are in the evaluation of a fuel switch to natural gas, water/steam injection, and SCR for boilers.
The commenter also raises concern with the use, in the economic feasibility analysis, of outdated interest rates that are not reflective of current economic conditions and the consumer price index CPI to adjust air pollution control costs to current dollar values.
Ultimately, the commenter acknowledges that if the RACT
evaluations were redone in a manner to address the identified concerns, the control technologies determined to be RACT would not change.
Response 2: The commenter correctly asserts that an evaluation of the technical feasibility of available controls should be conducted before evaluating the economic feasibility of the remaining available controls. 25 Pa.
Code 129.92b and 129.99d1. The TSD, which is included in the docket file for this action, explains the basis for EPAs approval of the RACT
determinations included in this rule.
From its review of the specific RACT
determinations made by AMS in this rule, EPA cannot locate a source where there was a determination where water/
steam injection was identified as technically infeasible. Similarly, except for two heaters at the PES facility, there are no determinations where SCR on a boiler was identified as technically infeasible. For the two exceptions, Heaters 8602H8 and 864PH7, SCR
was determined to be infeasible because of physical space constraints, not due to the use of ammonia or urea as identified by the commenter.
As to the commenters remarks about fuel switching, it appears that they may apply to the Exelon Generating CompanyRichmond Station where a fuel switch to natural gas was determined to be technically infeasible for Combustion Turbine 91 and 92. In this instance, Exelon identified the large-scale costs and related regulatory requirements as technical impediments to installing a natural gas line to the facility, and AMS agreed with this analysis and determined that it was not technically feasible. Whether or not AMS conclusion on the technical feasibility analysis was sufficient does not change the final conclusion on the overall feasibility of the potential use of fuel switching for the sources at this facility. EPA agrees with the commenter that determining fuel switching as a technically feasible control would not change the determination that this control is ultimately infeasible as RACT

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for the sources at hand and is finalizing AMS proposed RACT requirements.
EPA also agrees with the commenter that choosing suitable interest rates and cost escalation factors is a requirement of RACT determinations. Per 25 Pa.
Code 129.92b4, the cost effectiveness evaluation must be consistent with the OAQPS Control Cost Manual Fourth Edition EPA 450/390006 January 1990 Control Cost Manual and subsequent revisions.14 The Control Cost Manual addresses appropriate use of the CPI and lays out general principals to make accurate escalation calculations and choose appropriate interests rates. However, the Control Cost Manual in its current form does not specifically prohibit use of the CPI.
The commenter did not specify which economic feasibility determinations in this rule contain questionable interest rates or cost escalations but recognizes that updates to such factors in the economic analysis would not necessarily change the final RACT
determinations. These factors are among many other values used in a complex, multi-factor cost analysis. EPA agrees it is not clear that revised interest rate or cost escalations in the economic analysis would change the final conclusions of the determinations contained in this rule. Without a more specific allegation from the commenter about the sources in question, the commenters allegations are too general and speculative in nature to prevent EPA from approving AMS RACT II CbC
determinations for sources at the nine subject facilities.
Comment 3: The commenter raises concern with the Grays Ferry Cogeneration Partnership and Vicinity Energy NOX averaging plan and the Philadelphia Energy Solutions Refining and Marketing LLC PES NOX averaging plan. Specifically the commenter asserts: 1 In order to be protective of the 8-hour average of the 2008 ozone NAAQS, particularly during ozone season, these RACT determinations should include short term emissions limits on a calendar day basis as is done in New Jersey and other states, rather than a 30 operating day rolling average; 2 Grays Ferry Cogeneration Partnership and Vicinity Energy should be required to evaluate control options of combusting only natural gas, replacing No. 6 oil with No. 2 oil, and additional NOX controls; and 3 due to the recent events at PES, including shutting down operations, bankruptcy, 14 The OAQPS Control Cost Manual referenced in 25 Pa. Code 129.92b4 is also known as the EPA
Air Pollution Control Cost Manual. OAQPS is the acronym for EPAs Office of Air Quality Planning and Standards.

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and sale, EPA should not approve the proposed SIP revision until a new owner begins operations at the facility.
More generally, the commenter asserts that EPA should establish term limits for RACT plan approvals and ensure that facilities re-evaluate RACT plans to incorporate any future advancements in technology as is required by New Jersey RACT rules.
Response 3: In its conditional approval of Pennsylvanias overall RACT II program at 25 Pa. Code 129.96
129.100 84 FR 20274, May 9, 2019, EPA explained that under 25 Pa. Code 129.98, affected major sources unable to meet the applicable presumptive RACT
emissions limitation may choose to comply with alternative NOX
requirements based on averaging NOX
emissions from multiple sources.
Specifically, EPA explained that averaging plans pursuant to Pennsylvanias RACT II regulations are intended to demonstrate that the resulting NOX emissions using a 30-day rolling average would not be greater than NOX emissions from the group of included sources if they each complied with the applicable presumptive NOX
RACT emissions limit. Thus, the use of a 30-day rolling average for NOX
averaging plans under Pennsylvanias RACT II program was previously approved by EPA.
EPA guidance does highlight the need for emission controls that are reasonably consistent with protecting a short-term NAAQS such as ozone. However, in those cases where an emissions limit for a RACT control can be quantified, EPA
guidance states that averaging periods for such limits should be as short as practicable and in no case longer than 30 days. See the January 20, 1984 EPA
guidance memorandum titled Averaging Times for Compliance with VOC Emissions LimitsSIP Revision Policy.
In the instance of Grays Ferry Cogeneration Partnership and Vicinity Energy, the facilities are using an averaging plan to limit NOX emissions from the combustion turbine, Boiler 25, and Boiler 26 to no greater than the NOX emissions that would have resulted had each individual source complied with the presumptive RACT
limits of 25 Pa. Code 129.97g2iA
and B and 129.97g1i and ii. PES
is using averaging plans to limit emissions from Heaters 137 F1, 137 F
2, 137 F3, 1332 H400, and 1332 H
401 and 3 Boilerhouse Boilers 37, 39, and 40 to no greater than the NOX
emissions that would have resulted had each individual source complied with the presumptive RACT limits of 25 Pa.
Code 129.97g1iv. In each instance,
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