Two good defenses with solid defensive lines. Notre Dame moves the ball on the ground well, with a game managing QB who isn't likely to gift a lot to the other side. Penn State is a balanced team with a better throwing game, also unlikely to throw many INTs.
They had two common opponents. Both destroyed Purdue, ND by a little more. Both had to fight to beat USC in Los Angeles, though PSU needed OT, whereas ND dominated the 3rd quarter to give themselves a solid, if not safe, lead to the end. If those common opponents tell us anything, ND has an edge, but within a reasonable margin of error.
ND's win over Georgia was a "better" playoff win than PSU has, but it's not as though they had any impressive offensive production. ND dominated Indiana more than the score showed, but PSU stomped SMU and easily dispatched Boise State.
I expect a low scoring, defensive battle. A "classic" kind of a college football game between a pair of traditional Kings of the sport. In this kind of a game, turnovers and the kicking game feel like they will rule the day. The kicking game is a place ND should be somewhat concerned. Their kicker and their return for a touchdown essentially won the Georgia game for them, but throughout the season their field goals were a bit like my golf game: you never really know what you're going to get, and it's not what you want more often than you'd care to admit.
I think ND is rightly ever so slightly favored, but don't be surprised if this is a 13-12 kind of a game, with one team staring down a FG for the win at the end of regulation.