On May 30, 2019, the Maryland Department of the Environment (MDE) petitioned the Ozone Transport Commission (OTC), under Clean Air Act (CAA) Section 184(c), to develop a recommendation for EPA to require coal-fired Electricity Generating Units (EGUs) in Pennsylvania to run their existing NOX controls (i.e., SCR and SNCR) in an optimized manner every day of the ozone season.

In the petition, MDE provides an analysis of “excess emissions” from Pennsylvania coal-fired EGUs in 2017 and 2018, which is based on a modeling analysis performed by the University of Maryland to support their request. MDE also includes an initial draft of the recommendation that it is petitioning OTC to develop. MDE's proposal includes 24-hour and 30-day rolling average NOX emission limits (in lb/MMBTU) for Pennsylvania's coal-fired EGUs that are currently equipped with NOX controls, which are much more stringent than Pennsylvania's current RACT 2 requirements.

On June 26, 2019, the OTC voted to proceed with the initial steps associated with CAA Section 184(c) petition process, including analyzing the potential need for daily limits at coal-fired EGUs in Pennsylvania. The OTC has scheduled a public hearing for August 16, 2019 and is soliciting public comment on:

  1. Whether the OTC should develop additional control measures for Pennsylvania, and if so,
  2. How those specific control measures should be structured

Comments will be accepted through 5:00 p.m. on August 16, 2019, and the hearing will be held at the EPA Region III Public Information Center in Philadelphia. If you have any questions regarding this petition or potential impacts on your facility, please contact Wendy Merz at wmerz@trinityconsultants.com or (610) 280-3902, ext. 301.