United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-452/R-94-011
January 1995
Air
& EPA
STAGE II COMPARABILITY STUDY
FOR THE NORTHEAST
OZONE TRANSPORT REGION
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EPA-452/R-94-011
STAGE II COMPARABILITY STUDY
FOR THE NORTHEAST
OZONE TRANSPORT REGION
Air Quality Strategies and Standards Division
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
January 1995
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This report has been reviewed by the Air Quality Strategies and
Standards Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of trade
names or commercial products is not intended to constitute
endorsement or recommendation for use.
Copies of this report are available through the Library Services
Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, NC 27711, or for a fee from National Technical
Information Services, 5285 Port Royal Road, Springfield, VA
22161, (703) 487-4650 or (800) 553-NTIS. The document is also
available on the Technology Transfer Network (TTN) under the
Clean Air Act Amendments Main Menu, Title I, Policy and Guidance.
NOTICE OF ERROR IN EARLIER PRINTING
After distribution of the first printing of this
document, it was discovered that there were errors in
Tables 5-2, 5-4, and 5-5. In calculating the comparable
VOC reductions in these tables, the NOx reductions were
inadvertently multiplied by, rather than divided by, the
NOx ratios. These errors have been corrected in this
printing. In addition, the text which summarizes the data
in Section 5.2 (page 45), Section 5.3.3 (page 51), Section
5.4.2 (page 57) and Section 5.4.3 (page 57) has been
revised to reflect the corrected tables.
11
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TABLE OF CONTENTS
LIST OF TABLES AND FIGURES V
ACRONYMS AND ABBREVIATIONS vii
PREFACE ix
EXECUTIVE SUMMARY xi
1.0 INTRODUCTION 1
1.1 Ground-level Ozone 1
1.2 Clean Air Act Requirements 2
1.3 Study Approach 6
1.4 Organization of Report 8
2.0 COMPARABILITY DETERMINATIONS 9
2.1 Applicability 9
2.2 Time Frame for Comparability 9
2.3 Comparable Measure Selection 9
2.4 Conducting an Independent Comparability Analysis . 10
3.0 STAGE II EMISSIONS REDUCTIONS 11
3.1 Modeling Assumptions 11
3.1.1 Refueling Emissions 11
3.1.2 Stage II Control Assumptions 13
3.1.3 Onboard Vapor Recovery Control Assumptions . 15
3.2 Modeling Results 16
3.3 Cost-Effectiveness 16
4.0 CONTROL MEASURES FOR VOLATILE ORGANIC COMPOUNDS .... 21
4.1 Motor Vehicle Measures 21
4.1.1 Modeling Analyses 22
Base Case Controls and VMT Estimates ... 22
Enhanced I/M 26
Reformulated Gasoline 26
Combination of Measures 28
4.1.2 Cost-Effectiveness 31
Enhanced I/M 31
Reformulated Gasoline 31
4.2 Stationary Source VOC Control Measures 32
More Stringent Controls on Existing Sources 33
5.0 NOX CONTROL MEASURES 37
5.1 NOX Substitution Methodology 37
NOX Substitution Ratios 38
5.2 Motor Vehicle Control Measures 42
5.3 Utility Control Measures 45
111
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5.3.1 Modeling Assumptions 48
Determining NOX RACT and Title IV NOX
Control Measures 48
5.3.2 NOX RACT to 25 tpy 50
5.3.3 More Stringent Control for Existing
Major Sources 51
5.4 Non-Utility Point Source Control Measures 51
5.4.1 Modeling Assumptions 52
Determining RACT Level and More
Stringent Controls 52
5.4.2 NOX RACT to 25 tpy Sources 56
5.4.3 More Stringent NOX Control to 100 tpy
Sources 57
6.0 CONDUCTING AN INDEPENDENT COMPARABILITY ANALYSIS .... 59
6.1 Comparability Demonstrations 59
6.2 Determining Stage II Emissions Reductions 60
6.3 Determining Emissions Reductions from Alternative
Measures 61
REFERENCES 63
APPENDIX A - OZONE NONATTAINMENT CLASSIFICATIONS A-l
APPENDIX B - VOC EMISSION REDUCTION SUMMARIES
BY SOURCE CATEGORY B-l
APPENDIX C - NOX EMISSION REDUCTION SUMMARIES
BY SOURCE CATEGORY C-l
IV
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LIST OF TABLES AND FIGURES
Table Page
1-1 Ozone Nonattainment Areas in the Ozone Transport Region 4
3-1 National Gasoline Consumption Projections 11
3-2 MOBILESa Model Inputs Summer Season Temperatures and RVPs 12
3-3 Stage II Penetration Rates 13
3-4 Stage II Rule Effectiveness 14
3-5 Stage II Vapor Recovery VOC Emission Reductions for
Projection Year 1999 17
3-6 Cost Effectiveness of Stage II 19
4-1 Base Case Motor Vehicle Controls 23
4-2 Current and Projected Nationwide Vehicle Miles Traveled 24
4-3 Average Speeds by Roadway Classification and
Vehicle Type 25
4-4 Enhanced I/M Program Modeling Assumptions 27
4-5 Motor Vehicle Control Measure VOC Reductions -
Projection Year 1999 29
4-6 Stationary Source Control Measure VOC Emission
Reductions - Projection Year 1999 35
5-1 NOX to VOC Substitution Ratios 40
5-2 Motor Vehicle NOX Reductions - Projection Year 1999 . . 43
5-3 NOX RACT and More Stringent Control Technologies .... 46
5-4 Utility Control Measure Emission Reductions -
Projection Year 1999 47
5-5 Non-Utility Control Measure Emission Reductions -
Projection Year 1999 53
A-l Ozone Nonattainment Classifications A-l
B-l Stationary Source VOC Control Measure Emission
Reductions by Source Category - Projection Year 1999 B-l
C-l Utility Control Measure Emission Reductions
by Source Category - Projection Year 1999 C-l
C-2 Non-Utility Control Measure Emission Reductions
by Source Category - Projection Year 1999 .... C-4
Figure Page
1-1 Northeast Ozone Transport Region Ozone
Nonattainment Areas 3
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Preceeding Page Blank
ACRONYMS AND ABBREVIATIONS
Act
AF
BACT
BEA
BOOS
CMSA
CO
CTG
DOE
EPA
ERCAM
FGR
FIP
HPMS
I/M
1C
IR
ISBM
L-E
LDAR
LDGT
LDGV
LEA
LEV
LNB
MSA
NAAQS
NAPAP
NCR
NOX
NSCR
NSPS
OFA
QMS
ORVR
OTR
PC
RACT
ROM
RVP
SCR
SEDS
SIP
SNCR
SOCMI
TCM
tpd
tpy
1990 Clean Air Act
air-to-fuel (ratio)
best available control technology
Bureau of Economic Analysis
burners out of service
consolidated metropolitan statistical area
carbon monoxide
control techniques guideline
U.S. Department of Energy
U.S. Environmental Protection Agency
emission reduction and cost analysis model
fuel-gas reburning
Federal implementation plan
highway performance monitoring system
inspection and maintenance
internal combustion
ignition timing retardation
independent small business marketer
low emission
leak detection and repair
light-duty gasoline truck
light-duty gasoline vehicle
low excess air
low emission vehicle
low-NOx burner
metropolitan statistical area
national ambient air quality standard
national acid precipitation assessment program
natural gas reburning
nitrogen oxides
non-selective catalytic reduction
new source performance standard
overfire air
Office of Mobile Sources
onboard refueling vapor recovery
Northeast Ozone Transport Region
pulverized coal
reasonably available control technology
Regional oxidant model
Reid vapor pressure
selective catalytic reduction
State energy data system
State implementation plan
selective non catalytic reduction
synthetic organic chemical manufacturing industry
transportation control measure
tons per day
tons per year
VII
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ACRONYMS AND ABBREVIATIONS (continued)
ULNB ultra-low NOX burner
VMT vehicle miles traveled
VOC volatile organic compound
viii
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PREFACE
In order to address the problem of interstate ozone air
pollution in the Northeast, section 184 of the Clean Air Act of
1990 (Act) established the Ozone Transport Region (OTR). The OTR
is comprised of 12 Northeastern States and the District of
Columbia. An Ozone Transport Commission (OTC) was also
established, composed of representatives of the 13 OTR
jurisdictions and EPA, to coordinate ozone control efforts in the
OTR. The section 184 provisions contain additional control
requirements which apply throughout the OTR, even in ozone
attainment areas. One of these is the 184(b)(2) requirement for
Stage II vapor recovery (Stage II) or comparable measures. Stage
II control devices at gasoline pumps capture volatile organic
compounds (VOC) emissions from vehicle refueling.
Since passage of the Act, EPA has been working with the OTC
member States to evaluate the ozone problem in the OTR through
the use of the Regional Oxidant Model. The modeling results
indicate that, beyond the basic VOC control programs, additional
nitrogen oxides (NOx) reductions appear to be more effective than
VOC controls, particularly in attainment areas, in helping
control ozone levels in downwind nonattainment areas. Based on
these findings, the OTC has been focusing its efforts on
developing regional NOx control strategies.
For example, on September 27, 1994, the OTC signed a
Memorandum of Understanding (MOU) to control NOx emissions from
power plants and other large fuel combustion sources. The NOx
MOU will result in substantial NOx reductions throughout the OTR.
In addition, on February 10, 1994, the OTC recommended that EPA
require the low emission vehicle (LEV) program to reduce motor
vehicle NOx and VOC emissions in the region. The EPA has
recently taken final action to approve this petition. The OTC is
continuing to investigate additional regional NOx control
strategies.
Moreover, on January 24, 1994, EPA promulgated the onboard
refueling vapor recovery (ORVR) rules (at 59 FR 16262, April 6,
1994) which require onboard refueling emissions controls on
passenger cars and light-duty trucks. When fully phased in, the
ORVR rule will control 95 percent of refueling emissions
nationwide from these vehicles. Because onboard controls and
Stage II target the same emissions source, the benefits of Stage
II will steadily decrease as more and more vehicles with onboard
controls enter the fleet. Ultimately, the Stage II program will
become largely a redundant control effort. The authors of the
Act recognized this and released moderate ozone nonattainment
areas from the general Stage II requirement under section
182(b)(3) upon promulgation of the ORVR rule. See section
202(a)(6) of the Act. (However, inasmuch as it will take 10 to
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15 years for onboard controls to be fully phased in, early
emissions reductions from Stage II can be beneficial in reducing
air toxics and States may want to implement it for this purpose.)
Considering the significant NOx reductions that the OTR
States have committed to achieve through their regional NOx
control strategies and that, in the long term, onboard controls
will render Stage II largely redundant, EPA is concerned that
emissions reductions from the section 184(b)(2) Stage II
requirement for regional ozone purposes may not justify the cost,
particularly in attainment areas. Therefore, EPA will
immediately begin working with the OTC and affected States to
determine how to best achieve the required ozone benefits in each
affected area.
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EXECUTIVE SUMMARY
This report was prepared in response to section 184(b)(2) of
the 1990 Clean Air Act (Act) which requires the U.S.
Environmental Protection Agency (EPA) to conduct a study to
identify control measures capable of achieving emissions
reductions comparable to those achievable by Stage II vehicle
refueling controls in the Northeast Ozone Transport Region (OTR).
Ground-level Ozone
Ground-level ozone has been a pervasive pollution problem in
the United States for several decades. In the upper atmosphere
ozone occurs naturally and forms a protective layer to shield the
earth from the sun's harmful ultraviolet rays. However, in the
lower atmosphere, or at "ground level," man-made ozone can cause
a variety of problems to human health, crops, and trees. Ground-
level ozone is the focus of this report.
Ground-level ozone causes health problems because it damages
lung tissue, reduces lung function, and sensitizes the lungs to
other irritants. Scientific evidence indicates that ambient
levels of ozone not only affect people with impaired respiratory
systems, but healthy adults and children, as well. Each year
ground-level ozone is also responsible for several billion
dollars worth of agricultural crop yield loss. Studies also
indicate that current ambient levels of ozone are responsible for
damage to forests and ecosystems.
Ground-level ozone is particularly difficult to control
because it is not emitted directly into the atmosphere, but
instead is formed by a complex photochemical reaction caused
primarily by volatile organic compounds (VOCs), nitrogen oxides
(NOX) , heat, and sunlight. The VOCs are emitted from a variety
of sources, including industrial and chemical processes, and
automobile refueling, among others. The NOX is emitted from the
combustion of fuels from sources such as automobiles, power
plants, and industrial boilers.
One of the major VOC control programs that has been
implemented by many States is controls at gasoline stations to
capture emissions that occur during automobile refueling. These
programs are known as Stage II vapor refueling controls (Stage
II).
Historically, there has been a major ozone nonattainment
problem in the Northeastern United States. Much of the problem
is due to regional transport of ozone and ozone precursors (VOC
and NOX) . To address this problem of interstate ozone air
pollution, section 184(a) of the Act specifically created the
XI
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OTR, which is comprised of 12 Northeastern States and the
District of Columbia. Because of concern about the emissions
from attainment areas contributing to violations of the ozone
standard in downwind areas, the Act also requires the OTR States
to adopt Stage II or a comparable measure in attainment areas, as
well as nonattainment areas.
Stage II Comparability Study
The section 184(b)(2) requirement to adopt Stage II or a
comparable measure applies to all attainment and nonattainment
areas in the OTR. However, because States must adopt Stage II in
serious and severe nonattainment areas under a separate
requirement under section 182(b)(3), only moderate and below
nonattainment areas and attainment areas may take advantage of
the flexibility provided in the section 184(b)(2) provision to
adopt a comparable measure instead of Stage II. For this reason,
emissions reductions estimates for various control measures are
only provided for moderate and below nonattainment areas and
attainment portions in the OTR. Because the OTR States of
Connecticut, Massachusetts, and Rhode Island, and the District of
Columbia consolidated metropolitan statistical area (CMSA) are
comprised solely of serious and severe areas, they must adopt
Stage II statewide. Therefore, these States and the District of
Columbia CMSA are not included in this study.
Only measures not already prescribed in the Act may be
considered as potential comparable measures. Under EPA's
interpretation of section 184(b)(2), such prescribed measures or
measures already required under the State's implementation plan
prior to 1990 may not be substituted for Stage II. For example,
onboard refueling vapor recovery controls cannot be considered as
a comparable measure because they are required of all areas by a
Federal rule. However, control measures that are used to meet
rate-of-progress requirements or to reach attainment, but are not
otherwise required by the Act, may be used to meet the section
184(b)(2) requirement.
The emissions reductions estimates for Stage II and
alternative measures are given for future year 1999. This year
corresponds to the attainment date for serious ozone areas. This
year was selected as the timeframe for comparability because it
is the first statutory attainment date and milestone year that
would occur following full phase-in of a Stage II program, if a
State chose to adopt Stage II rather than a comparable measure.
The Act provides for a 2-year phase-in schedule for Stage II,
with an optional third year to phase-in independent small
business marketers.
To provide flexibility to the States, this report does not
specify a list of comparable measures from which each area must
select. Rather, emission reduction estimates are provided for a
xii
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variety of measures that a State can examine for a strategy
comparable to Stage II. The emission reduction estimates for the
alternative measures are given for nonattainment and attainment
areas on an area-by-area basis. A State may select comparable
measures for each individual affected area or may determine
comparability on an aggregate basis for affected areas in the
State.
Some alternative measures may not be comparable alone, but
in combination with other measures may achieve comparable
emissions reductions to Stage II. The State may choose to adopt
a single measure or a number of control measures whose emissions
reductions equal or exceed Stage II reductions. As single
measures, reformulated gasoline, enhanced inspection and
maintenance programs (in areas where they are not already
required), and more stringent stationary source NOX controls show
comparability for a number of areas. (States should be aware
that there are significant legal and technical issues regarding
whether and how reformulated gasoline programs can be applied in
attainment areas and nonclassifiable nonattainment areas. The
EPA is currently exploring these issues.)
States may substitute NOX emissions reductions for VOC
reductions according to the methodology given in this document.
If a particular measure provides both VOC and NOX reductions,
these may be added together to yield a total emissions reduction
estimate for the measure.
States have the option of conducting an independent
comparability analysis to re-examine measures covered in this
report using up-to-date, State-specific information or to
evaluate control measures not included in this report.
Within one year of completion of the study, States must
adopt and submit as a State implementation plan (SIP) revision
either Stage II or a comparable measure. States are encouraged
to rely on the information presented in this study report as
guidance in determining which measures may be considered
comparable to Stage II for their areas. The EPA believes this is
what Congress intended by requiring EPA to issue this study.
However, because this study report did not go through notice-and-
comment rulemaking, it is not EPA's final action on the question
of which measures are comparable to Stage II. The EPA will
entertain comments on the study findings for a specific area in
the context of rulemaking on a SIP submittal intended to satisfy
the Act requirement for Stage II or a comparable measure.
Xlll
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1.0 INTRODUCTION
This document was prepared in response to section 184(b)(2)
of the 1990 Clean Air Act (Act) which requires the U.S.
Environmental Protection Agency (EPA) to conduct a study to
identify control measures capable of achieving emissions
reductions comparable to those achievable by Stage II vehicle
refueling controls (Stage II) in the Northeast Ozone Transport
Region (OTR).
1.1 Ground-level Ozone
Ground-level ozone has been a pervasive pollution problem in
the United States for several decades. In the upper atmosphere,
or stratosphere, ozone occurs naturally and forms a protective
layer to shield the earth from the sun's harmful ultraviolet
rays. However, in the lower atmosphere, or at "ground level,"
man-made ozone can cause a variety of problems to human health,
crops, and trees.
Ground-level ozone causes health problems because it damages
lung tissue, reduces lung function, and sensitizes the lungs to
other irritants. Scientific evidence indicates that ambient
levels of ozone not only affect people with impaired respiratory
systems, such as asthmatics, but healthy adults and children, as
well. Exposure to ozone for six to seven hours at relatively low
concentrations has been found to significantly reduce lung
function in normal, healthy people during periods of moderate
exercise. This decrease in lung function is often accompanied by
such symptoms as chest pain, coughing, nausea, and pulmonary
congestion.
Though not as well established in humans, animal studies
have demonstrated that repeated exposure to ozone for many months
can produce permanent structural damage in the lungs and
accelerate the rate of lung function loss, as well as the aging
of lungs. Each year ground-level ozone is also responsible for
several billion dollars worth of agricultural crop yield loss.
It also causes noticeable foliar damage in many crops and species
of trees. Studies also indicate that current ambient levels of
ozone are responsible for damage to forests and ecosystems.
Ground-level ozone is particularly difficult to control
because it is not emitted directly into the atmosphere, but
instead is formed by a complex photochemical reaction caused
primarily by volatile organic compounds (VOCs), nitrogen oxides
(NOX) , heat, and sunlight. The VOCs are emitted from a variety
of sources, including automobile exhaust, industrial and chemical
processes, evaporating gasoline vapors, and automobile refueling,
among others. The NOX is emitted from the combustion of fuels
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from sources such as automobiles, power plants, and industrial
boilers.
One of the major VOC control programs that has been
implemented by many States is Stage II controls at gasoline
stations to capture emissions that occur during automobile
refueling. (Controls put into place to capture VOC emissions
that occur earlier in the gasoline marketing chain, during
loading/unloading gasoline from bulk terminals, are known as
Stage I controls.)
By 1990, there were 98 areas in the country that did not
meet the EPA-established national ambient air quality standard
for ozone. About 140 million Americans lived in these areas.
Many of these areas were in the Northeastern United States. That
same year the U.S. Congress passed new amendments to the Clean
Air Act. The amended Act requires a broad array of programs to
further reduce emissions of VOCs, NOX, and other pollutants from
the automobile, petroleum, chemical, steel, utility, and pulp and
paper industries, as well as a wide variety of other large and
small sources.
1.2 Clean Air Act Requirements
Historically, there has been a major ozone nonattainment
problem in the Northeastern United States. Much of the problem
is due to regional transport of ozone and ozone precursors (VOC
and NOJ . To address this problem of interstate ozone air
pollution, section 184(a) of the Act specifically created the
OTR, which is comprised of the entire States of Connecticut,
Delaware, Maine, Maryland, Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania, Rhode Island, and Vermont, and
the District of Columbia consolidated metropolitan statistical
area (CMSA), which includes a portion of Virginia.
Figure 1-1 provides a map of the OTR showing the designated
attainment and nonattainment areas. The Act established five
classifications of ozone nonattainment areas. In ascending order
of severity of the air pollution problem, these are: marginal,
moderate, serious, severe, and extreme. In addition, there are
three types of nonclassifiable ozone nonattainment areas:
submarginal, transitional, and incomplete/no data. (See Appendix
A for the definitions of the ozone nonattainment area types.)
The OTR ozone areas are listed by classification in Table 1-1.
Within the OTR, there are no extreme, submarginal, or
transitional areas.
The Act requires specific control requirements according to
the designation and classification of each area. Section 184
also provides for a specific set of additional requirements for
the OTR designed to address the regional transport problem.
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Maine
New York
New Hampshire
Massachusetts
Rhode Island
Connecticut
Maryland
New Jersey
Pennsylvania
Delaware
Virginia
Washington, DC
Nonattainment Classification
H Incomplete/No Data
B Marginal
& Moderate
B Serious
E Severe-15
Severe-17
* Rural Transport Area. This small
mountaintop area is classified as
Marginal.
Figure 1-1 Northeast Ozone Transport Region Ozone Nonattainment Areas
3
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Table 1-1. Ozone Nonattainment Areas in the Ozone Transport Region
Severe-17
New York-N New Jer-Long Is, NY-NJ-CT
Severe-15
Baltimore, MD
Philadelphia-Wilm-Trent, PA-NJ-DE-
MD
Serious
Boston-Lawrence-Worcester (E.MA), MA-NH
Greater Connecticut
Portsmouth-Dover-Rochester, NH
Providence (All Rl), Rl
Springfield (Western MA), MA
Washington, DC-MD-VA
Moderate
Atlantic City, NJ
Knox & Lincoln Cos, ME
Lewiston-Auburn, ME
Pittsburgh-Beaver Valley, PA
Albany-Schenectady-Troy, NY
Allentown-Bethlehem-Easton, PA-NJ
Altoona, PA
Buffalo-Niagara Falls, NY
Erie, PA
Essex Co (Whiteface Mtn), NY
Hancock & Waldo Cos, ME
Harrisburg-Lebanon-Carlisle, PA
Jefferson Co, NY
Franklin Co (part), ME
Oxford Co (part), ME
Somerset Co (part), ME
Belknap Co, NH
Cheshire Co, NH
Sullivan Co, NH
Crawford Co, PA
Franklin Co, PA
Greene Co, PA
Marginal
Portland, ME
Poughkeepsie, NY
Reading, PA
Johnstown, PA
Kent and Queen Anne's Cos, MD
Lancaster, PA
Manchester, NH
Scranton-Wilkes-Barre, PA
Sussex Co, DE
York, PA
Youngstown-Warren-Sharon, OH-PA*
Incomplete/No Data
Juniata Co, PA
Lawrence Co, PA
Northumberland Co, PA
Pike Co, PA
Schuylkill Co, PA
Snyder Co, PA
Susquehanna, Co, PA
Warren Co, PA
Wayne Co, PA
'Only the Pennsylvania counties of this nonattainment area are in the OTR.
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These additional requirements include control measures for
attainment areas as well as nonattainment areas.
For the OTR, there are two requirements related to Stage II
vehicle refueling controls. One is the section
182(b)(3)requirement that all moderate and above nonattainment
areas must adopt Stage II vehicle refueling controls. However,
pursuant to section 202(a)(6), moderate areas were released from
this requirement when EPA promulgated onboard vapor recovery
rules. (See reference l.)
The second is the section 184(b)(2) requirement that all
areas in the OTR must adopt Stage II or alternative measures
capable of achieving comparable emissions reductions, as
identified in this study. Because States that contain serious
and above nonattainment areas must implement Stage II programs
under the first requirement above, even after promulgation of the
onboard regulations, they cannot take advantage of the
flexibility provided by section 184(b)(2) to adopt a comparable
measure instead. Therefore, this document only evaluates
alternative measures for moderate and below nonattainment areas
and attainment portions of the OTR. Affected States have within
1 year of the completion of this study to adopt and submit as a
State implementation plan (SIP) revision either Stage II or a
comparable measure.
Section 182(b)(3) of the Act sets forth the general
requirements for Stage II gasoline vapor recovery programs as
follows:
(3) GASOLINE VAPOR RECOVERY.
(A) GENERAL RULE - Not later than 2 years after the
date of the enactment of the Clean Air Act Amendments of
1990, the State shall submit a revision to the applicable
implementation plan to require all owners or operators of
gasoline dispensing systems to install and operate, by the
date prescribed under subparagraph (B), a system for
gasoline vapor recovery of emissions from the fueling of
motor vehicles. The Administrator shall issue guidance as
appropriate as to the effectiveness of such system. This
subparagraph shall apply only to facilities which sell more
than 10,000 gallons of gasoline per month (50,000 gallons
per month in the case of an independent small business
marketer of gasoline as defined in section 324).
(B) EFFECTIVE DATE - The date required under
subparagraph (A) shall be -
(i) 6 months after the adoption date, in the
case of gasoline dispensing facilities for which
construction commenced after the date of the enactment of
the Clean Air Act Amendments of 1990;
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(ii) one year after the adoption date, in the
case of gasoline dispensing facilities which dispense at
least 100,000 gallons of gasoline per month, based on
average monthly sales for the 2-year period before the
adoption date; or
(iii) 2 years after the adoption date, in the case
of all other gasoline dispensing facilities.
Any gasoline dispensing facility described under both clause
(i) and clause (ii) shall meet the requirements of clause
(i).
(C) REFERENCE TO TERMS - For purposes of this
paragraph, any reference to the term "adoption date" shall
be considered a reference to the date of adoption by the
State of requirements for the installation and operation of
a system for gasoline vapor recovery of emissions from the
fueling of motor vehicles.
Section 182(b)(3)(A) requires Stage II vapor recovery on all
gasoline dispensing facilities that dispense more than 10,000
gallons of gasoline per month or 50,000 gallons of gasoline per
month for independent small business marketers (ISBM's).
In addition to the 2-year phase-in schedule of section
182(b)(3)(B), States can also opt for a 3-year phase-in period
for ISBM's.
1.3 Study Approach
The major objectives of this study are to:
assess the emission reductions associated with the
implementation of Stage II vapor recovery in the study
areas, and
analyze the emission reductions associated with
alternative control measures that may be selected as a
control strategy comparable to Stage II.
A secondary objective is to examine the costs of the control
measures analyzed to assist the States in their decisions of
whether to adopt Stage II or comparable measures.
The Emission Reduction and Cost Analysis Model for VOC
(ERCAM-VOC) was selected as the primary modeling tool in the
study analysis. This model was used throughout the debate
leading to the passage of the 1990 Clean Air Act Amendments to
analyze the costs and emission reductions associated with the
alternative measures aimed at controlling VOC.
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The ERCAM-VOC was created to analyze the national impacts of
VOC controls; thus, many of the modeling techniques reflect the
needs for analyzing this large domain. Since the study only
addresses certain areas in the OTR, improvements in the modeling
methods were implemented for the Stage II and motor vehicle
components of the model. State-specific emission factor
(MOBILESa) modeling was performed for these sectors. The
specific modeling techniques are discussed in more detail in
Chapters 3 and 4 of this report.
The EPA promulgated regulations for onboard vapor recovery
on January 24, 1994. In recognition of this, the Stage II
emission reduction benefit analysis assumes onboard vapor
recovery rules are promulgated in 1994 with a phase-in of onboard
controls beginning in model year 1998.
The base year emissions for the study area are from the
Interim 1990 Inventory. This data source was chosen because it
covers the entire geographical region studied under this
analysis. While SIP emissions inventory data may be available
for some areas, States are required to submit 1990 emission
inventories only for their nonattainment areas (data may also be
available for surrounding counties for modeling purposes) and the
inventories are not currently finalized. It is acknowledged that
State-submitted data may differ from the inventory data used in
this analysis.
The Interim Inventory point source emissions are projected
from the 1985 National Acid Precipitation Assessment Program
(NAPAP) Inventory. State point source inventories are expected
to be higher because the 1985 NAPAP Point Source Inventory
generally did not include sources in the 25 to 100 ton per year
range. However, the inventory may contain sources of nitrogen
oxides (NOJ within this size range if the source is a major
emitter of another criteria pollutant. While the effects of
applying reasonably available control technology (RACT) to
sources at this level are examined in this report, the effects
are expected to be underestimated due to the limitations of the
inventory.
Control measures were selected for analysis based on the
availability of data on control effectiveness, coverage of
emissions in the inventory, effectiveness in less urbanized
areas, and availability of modeling approaches for assessing the
emission reductions. Only measures not already prescribed in the
Act were considered because, under EPA's interpretation of
section 184(b)(2), such prescribed measures and measures already
required under the State's implementation plan prior to 1990 may
not be substituted for Stage II. Control measures that are used
to meet rate-of-progress requirements or to reach attainment, but
-------
are not otherwise required by the Act, may be used to meet the
section 184(b)(2) requirement.
Initially, a comprehensive list of alternative control
measures was developed and each was examined with respect to the
criteria above. The list was then narrowed, based on the
criteria discussed above, to include the following measures:
enhanced inspection and maintenance (I/M),
reformulated gasoline program,
more stringent control on existing VOC stationary
sources,
RACT to 25 tpy NOX stationary sources, and
more stringent control of existing NOX stationary
sources.
These control measures are evaluated in Chapters 4 and 5. States
also have the option to evaluate other control measures.
1.4 Organization of Report
The information in this report provides the basis for State
selection and adoption of control measures comparable to Stage
II.
Chapter 2 discusses how the information presented in this
report is to be used by States in making a comparability
determination.
Chapter 3 discusses the methods used to model Stage II
emission reductions and presents the emissions reductions
estimates on an area-by-area basis.
Chapter 4 evaluates mobile and stationary VOC control
measures as potential comparable measures. The modeling
assumptions used for each control measure are described.
Chapter 5 evaluates mobile and stationary source NOX control
measures as potential comparable measures. The chapter provides
a NOX substitution method for determining what level of NOX
emissions reductions is comparable to the VOC emissions
reductions from Stage II.
Chapter 6 describes a method by which States can conduct an
independent comparability analysis to re-examine measures covered
in this report using up-to-date, State-specific information or to
evaluate control measures not included in the report.
-------
2.0 COMPARABILITY DETERMINATIONS
2.1 Applicability
The section 184(b)(2) requirement to adopt Stage II or a
comparable measure applies to all attainment and nonattainment
areas in the OTR. However, because States must adopt Stage II in
serious and severe nonattainment areas under a separate
requirement under section 182(b)(3), only moderate and below
nonattainment areas and attainment areas may take advantage of
the flexibility provided in the section 184(b)(2) provision to
adopt a comparable measure instead of Stage II. For this reason,
emissions reductions estimates for various control measures are
only provided for moderate and below nonattainment areas and
attainment portions in the OTR. Because the OTR States of
Connecticut, Massachusetts, and Rhode Island, and the District of
Columbia CMSA are comprised solely of serious and severe areas,
they must adopt Stage II statewide. Therefore, these States and
the District of Columbia CMSA are not included in this study.
2.2 Time Frame for Comparability
In the following chapters, emissions reductions for Stage II
and alternative measures are given for the future year 1999.
This year corresponds to the attainment date for serious ozone
areas. This year was selected because it is the first statutory
attainment date that would occur following full phase-in of a
Stage II program, if a State chose to adopt Stage II rather than
a comparable measure. The Act provides for a 2-year phase-in
schedule for Stage II, with an optional third year to phase-in
ISBM's. For marginal and below nonattainment areas and
attainment areas, the emissions reductions achieved from
application of this requirement are clearly intended to assist in
the attainment of downwind areas of higher classifications rather
than for attainment in the controlled area. (Marginal areas were
required to be in attainment by November 15, 1993.) For moderate
areas, the emissions reductions may also help bring the local
area into attainment.
2.3 Comparable Measure Selection
Only measures not already prescribed in the Act may be
considered as potential comparable measures. Under EPA's
interpretation of section 184(b)(2), such prescribed measures or
measures already required under the State's implementation plan
prior to 1990 may not be substituted for Stage II. For example,
onboard refueling vapor recovery (ORVR) controls cannot be
considered as a comparable measure because they are required of
all areas by a Federal rule. However, control measures that are
used to meet rate-of-progress requirements or to reach
-------
attainment, but are not otherwise required by the Act, may be
used to meet the section 184(b)(2) requirement.
To provide flexibility to the States, this report does not
specify a list of comparable measures from which each area must
select. Rather, emission reduction and cost information are
provided for a variety of measures that the State can examine for
a strategy comparable to Stage II for a particular area. Stage
II emissions reductions are contained in Chapter 3. These
emissions reductions estimates establish the level of emissions
reductions that an alternative control measure must achieve or
exceed to be comparable. Emissions reductions estimates for
alternative VOC and NOX control measures are given in Chapters 4
and 5, respectively.
Some alternative measures may not be comparable alone, but
in combination with other measures may achieve comparable
emissions reductions to Stage II. The State may choose to adopt
a single measure or a number of control measures whose emissions
reductions equal or exceed Stage II reductions. In addition,
States may substitute NOX emissions reductions for VOC reductions
according to the methodology given in Chapter 5.0. If a
particular measure provides both VOC and NOX reductions, these
may be added together to yield a total emissions reduction
estimate for the measure.
Emissions reduction estimates for the alternative VOC and
NOX control measures are given for nonattainment and attainment
areas on an area-by-area basis. A State may select comparable
measures for each individual affected area or may determine
comparability on an aggregate basis for affected areas in the
State. In the second case, if the sum of the projected emissions
reductions from the selected alternative measure in applicable
areas equals or exceeds the sum of the projected Stage II
reductions for the same areas, the alternative measure would be
considered comparable.
2.4 Conducting an Independent Comparability Analysis
States have the option of conducting an independent analysis
to re-examine measures covered in this report using up-to-date,
State-specific information or to evaluate control measures not
included in this report. The methodology for the analysis is
provided in Chapter 6.0.
10
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3.0 STAGE II EMISSION REDUCTIONS
This chapter describes the emission projection methodology
and modeling assumptions used to estimate VOC emission reductions
from Stage II vapor recovery controls. Results of the modeling
analyses are provided on an area-by-area basis for the year 1999.
The emissions reductions estimated for Stage II establish the
level of emissions reductions that an alternative control
strategy must meet to be considered a comparable measure.
3.1 MODELING ASSUMPTIONS
3.1.1 Refueling Emissions
Base year vehicle refueling emissions are estimated from
gasoline consumption (by county) and State-specific MOBILESa
emission factors. (See reference 2.) Gasoline consumption
estimates are based on the Interim 1990 Inventory. (See
reference 3.) The Interim Inventory gasoline consumption
estimates were projected from the 1985 NAPAP Inventory (see
reference 4) based on State-level historical estimates of motor
vehicle gasoline consumption from the U.S. Department of Energy
(DOE) State Energy Data System (SEDS). (See reference 5.) The
emission estimates presented in this analysis parallel those in
the Interim Inventory with the exception that State-specific
emission factors, rather than a national average emission factor,
were used to estimate emissions.
Vehicle refueling emission projections are calculated by
applying growth factors to the gasoline consumption estimates and
multiplying this by the State-specific MOBILE5a refueling
emission factor (in grams per gallon) for the projection year.
National projections of gasoline usage from the MOBILE4.1 Fuel
Consumption Model (see reference 6) were used to estimate growth
for each area. The national estimates of gasoline consumption
and corresponding annual (compounded) growth rates are shown in
Table 3-1.
Table 3-1. National Gasoline Consumption Projections
Gasoline Usage Equivalent Annual
Projection Year (million gallons) Growth {% per year)
1990
1999
94,585
105,221
1.2 (1990-1999)
11
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State-specific refueling emission factors are used to
account for differences in temperature and gasoline Reid vapor
pressure (RVP). Summer (ozone) season temperatures and RVPs were
used to calculate ozone season daily emissions. Table 3-2
presents the minimum and maximum temperatures, as well as the
1990 RVP, the phase II RVP, and the projection year RVP used as
model inputs for each State. For areas with a 9.0 phase II
limit, the projection year RVP is the phase II RVP minus a 0.3
psi default compliance safety margin. For areas with a phase II
limit of 7.8 psi, no safety margin is applied. This is in
accordance with EPA's Office of Mobile Sources (QMS) guidance on
the selection of RVPs for modeling purposes. (See reference 7.)
The MOBILESa emission factor accounts for refueling vapor
displacement and spillage losses. Underground tank breathing
losses were estimated using AP-42 emission factors. (See
reference 8.) These calculations are consistent with the
methodologies recommended in the mobile source inventory
guidance.
Table 3-2. MOBILESa Model Inputs
Summer Season Temperatures and RVPs
State
Delaware
Maine
Maryland
New Hampshire
New Jersey
New York
Pennsylvania
Vermont
Minimum
Temperature"
(°F)
64
55
65
54
62
61
62
56
Maximum
Temperature"
(°F)
84
76
85
80
82
81
83
78
RVP
(1990)"
8.4
8.3
8.3
8.3
8.4
8.3
8.6
8.3
RVP
(Phase I!
Limit)0
9.0
9.0
7.8
9.0
9.0
9.0
9.0
9.0
RVP
(Projection
Year)
8.7
8.7
7.8
8.7
8.7
8.7
8.7
8.7
SOURCES:
"See reference 9.
bSee reference 10.
°See reference 11.
12
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3.1.2 Stage II Control Assumptions
The Act and the General Preamble for the Implementation of
Title I of the Clean Air Act Amendments of 1990 (Title I General
Preamble) (see reference 12) include the following specifications
for Stage II vapor recovery programs:
Stage II must be applied to facilities that sell more
than 10,000 gallons of gasoline per month (50,000
gallons per month for ISBN's). States are not
precluded from adopting lower source size cutoffs
(section 182(b)(3)).
States should prescribe the use of Stage II systems
that are certified to achieve at least 95 percent
control of VOCs and that are properly installed and
operated (General Preamble).
For modeling purposes, the control program requirements
should be translated into a control device efficiency, a rule
penetration (fraction of sources affected), and rule
effectiveness (to account for equipment malfunctions and
noncompliance). These three variables are combined to form an
overall effectiveness for Stage II, which is input to MOBILE5a.
Because the Title I General Preamble specifies that the
systems should be tested or certified at 95 percent reduction of
VOC (for properly installed and operated systems), a 95 percent
control device efficiency was used for the modeling analysis.
The penetration rate depends on the size cutoffs implemented
by the area. The national average percentage of consumption
excluded at various size cutoffs and corresponding penetration
rates are shown in Table 3-3. (See reference 13.)
Table 3-3. Stage II Penetration Rates
Exemption Scenario
< 2,000 gal/month
< 10,000 gal/month
< 1 0,000 gal/month &
ISBM's < 50,000 gal/month
Percentage
of Consumption
Excluded (%)
2.4
2.8
10.0
Penetration
Rate (%)
97.6
97.2
90.0
13
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The consumption estimates in Table 3-3 are based on a study
of metropolitan area service station size distributions. This
represents the best survey information to date and was used to
determine overall effectiveness of Stage II. However, size
distribution varies from area to area, and rural areas may tend
to have a greater population of ISBM's.
The Act-mandated cutoffs of 10,000 gallons per month for
gasoline dispensing facilities, or 50,000 per month in the case
of ISBM's, were used in the modeling, with a penetration rate of
90 percent. If States opt to establish programs with a single
size cutoff of 10,000 gallons per month, this would increase the
emissions reductions from Stage II.
Rule effectiveness discounts the control device efficiency
to account for noncompliance, equipment malfunctions, improper
installation and maintenance, and improper use of the equipment.
Table 3-4 shows the in-use efficiency and corresponding rule
effectiveness values at various inspection levels. (See
reference 13.)
The certification efficiency is the control device
efficiency standard that Stage II vapor recovery systems are
required to achieve. This is the baseline for measuring rule
effectiveness. The Stage II Technical Guidance Document (see
reference 13) notes that these in-use efficiency calculations do
not account for misinstallation of underground vapor piping.
Nevertheless, this represents the best available data on Stage II
rule effectiveness.
Table 3-4. Stage II Rule Effectiveness
Inspection Frequency
Certification
Semi-Annual
Annual
Minimal
In-Use
Efficiency (%)
95
92
86
62
Rule
Effectiveness (%)
....
96.8
90.5
65.3
The Enforcement Guidance for Stage II Vehicle Refueling
Control Programs (see reference 14) sets minimal standards for
compliance inspections at gasoline dispensing facilities. This
guidance specifies that a minimum of one compliance inspection
should be conducted at each facility every year. Therefore, this
14
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analysis assumed annual inspections and used the corresponding
rule effectiveness value from Table 3-4. Combining the control
device efficiency (95 percent), rule penetration (90 percent),
and rule effectiveness (90.5 percent) yields an overall
effectiveness of 77 percent for Stage II. This was input to the
MOBILE5a model to estimate projection year emission factors.
The emission factor for breathing losses with Stage II
controls was calculated as a 77 percent reduction from
uncontrolled levels, or 0.23 Ibs VOC per 1,000 gallons of fuel.
3.1.3 Onboard Refueling Vapor Recovery Control Assumptions
Section 202 of the Act requires implementation of ORVR
systems beginning with the fourth model year after the rules are
promulgated. The ORVR rules were promulgated on January 24,
1994; therefore, the controls are required to be installed
beginning with model year 1998 vehicles.
The ORVR rules require ORVR systems to be installed on 40
percent of light-duty gasoline vehicles (LDGV) in 1998, 80
percent in 1999, and 100 percent thereafter. Because MOBILE5a
does not model this type of phase-in for ORVR controls (MOBILE5a
only accepts a start year of input and assumes that all new
vehicles in that model year install ORVR controls), a start date
of model year 1999 was assumed in this analysis for LDGV. The
effect of modeling ORVR control requirements with full
implementation in the second model year rather than as phased-in
over 3 years will tend to slightly underestimate the benefits of
ORVR controls in 1999. This is because the sum of 40 percent of
model 1998 LDGVs and 80 percent of model year 1999 LDGVs is
greater than 100 percent of the new model cars in 1999. Slightly
underestimating the reductions from ORVR controls, in turn, will
cause reductions from Stage II to be slightly overestimated.
The ORVR rules also require a similar phase-in for controls
on light-duty gasoline trucks (LDGT) beginning in 2001 for
vehicles with a gross weight rating of 0-6,000 Ibs, and in 2004
for vehicles with a gross weight rating of 6,001-8,500. Because
emission reductions from controls on these vehicles begin after
1999, they do not affect the Stage II comparability analyses.
However, in the future, as more and more vehicles with ORVR
controls enter the fleet, the benefits of Stage II (incremental
to ORVR) will decrease.
MOBILE5a applies a 96 percent reduction (from uncontrolled
levels) to the refueling emissions from cars with ORVR controls.
ORVR controls do not reduce breathing losses.
Because ORVR controls are mandated by the Act for all areas,
ORVR controls have been applied first in the modeling simulations
15
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and will be attributed with controlling the refueling emissions
in cases where redundancy occurs.
3.2 MODELING RESULTS
The emission reductions attributable to Stage II vapor
recovery were calculated for each area by comparing the
projection year with the uncontrolled baseline. As discussed
above, emission reductions from Stage II are estimated assuming
ORVR controls are installed. The results are presented in Table
3-5 for projection year 1999.
In general, emission reductions from Stage II are highest in
larger and/or more urbanized areas. Urban areas exhibit a higher
population density and thus higher gasoline usage. This
increases the baseline vehicle refueling emissions from which
emission reductions are measured. In many States, the area
designated "Attainment Counties" in Table 3-5 shows the highest
emission reduction simply because this division encompasses more
counties than the individual nonattainment areas.
3.3 COST EFFECTIVENESS
The Stage II Technical Guidance Document (see reference 13)
provides cost-effectiveness estimates for Stage II at various
size cutoffs. Annual inspections are assumed in deriving these
cost effectiveness values, which is consistent with the
requirements of the Act and the modeling assumptions used in this
analysis. Cost effectiveness may vary from area to area
depending on the distribution of service station sizes and single
versus multiproduct dispensers. The cost-effectiveness values
shown in Table 3-6 are based on a nationwide survey of service
stations that were classified into model plants. The cost-
effectiveness estimates assume an equal distribution between
single and multiproduct dispensers. Costs per ton are higher for
multiproduct than for single-product dispensers.
At the Act-mandated size cutoffs of 10,000 and 50,000 for
non-ISBM's and ISBM's, respectively, the average cost
effectiveness is estimated to be $930 per ton.
16
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Table 3-5. Stage II Vapor Recovery VOC Emission Reductions
Projection Year 1999
Ozone Area
Stage II Reduction
(tpd)
Delaware
Sussex County
Maine
Hancock & Waldo Counties
Knox & Lincoln Counties
Lewiston-Auburn
Portland
Franklin County
Oxford County
Somerset County
Attainment Counties
Maryland
Kent & Queen Anne's Counties
Attainment Counties
New Hampshire
Manchester
Belknap County
Chesire County
Sullivan County
Attainment Counties
New Jersey
Allentown-Bethlehem-Easton
Atlantic City
New York
Albany-Schenectady-Troy
Buffalo-Niagara Falls
Essex County
Jefferson County
Poughkeepsie
Attainment Counties
0.58
0.23
0.29
1.14
2.11
0.13
0.22
0.18
1.44
0.29
2.74
2.13
0.25
0.17
0.15
0.78
0.78
3.37
3.84
4.39
0.14
0.40
0.99
15.32
17
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Table 3-5 (continued)
Ozone Area
Stage II Reduction
(tpd)
Pennsylvania
Allentown-Bethlehem-Easton
Altoona
Erie
Harrisburg-Lebanon-Carlisle
Johnstown
Lancaster
Pittsburgh-Beaver Valley
Reading
Scranton-Wilkes-Barre
York
Youngstown-Warren-Sharon
Crawford County
Franklin County
Greene County
Juniata County
Lawrence County
Northumberland County
Pike County
Schuylkill County
Snyder County
Susquehanna County
Warren County
Wayne County
Attainment Counties
Vermont
Attainment Counties
2.12
0.45
1.54
3.18
0.88
1.19
10.95
1.16
2.51
1.38
0.49
0.34
0.35
0.14
0.07
0.53
0.28
0.08
0.36
0.08
0.16
0.17
0.22
4.35
2.64
18
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Table 3-6. Cost-Effectiveness of Stage II
Cost-Effectiveness
Exemption Scenario ($/ton)
No exemptions 1,230
< 2,000 gal/month 1,130
< 10,000 gal/month 1,000
< 10,000 gal/month & ISBM's < 50,000 gal/month 930
SOURCE: See reference 13.
19
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Preceeding Page Blank
4.0 CONTROL MEASURES FOR VOLATILE ORGANIC COMPOUNDS
This chapter presents the results of the analysis of a
variety of VOC control measures. Section 4.1 examines motor
vehicle control measures and Section 4.2 examines stationary
source measures. Emission reduction estimates provided for these
measures should be compared with the emission reduction estimates
for Stage II in Chapter 3.0 to determine whether a measure or
combination of measures achieves comparable reductions to Stage
II. Some of the measures also reduce NOX emissions (see Chapter
5). In determining comparability to Stage II emissions
reductions, the VOC and NOX emissions reductions from an
alternative measure may be combined according to the methodology
provided in Section 6.1.
4.1 MOTOR VEHICLE MEASURES
The motor vehicle measures analyzed in the study that
provide VOC emission reductions are: (1) enhanced I/M programs
and (2) reformulated gasoline. Some areas (metropolitan
statistical areas (MSA's) of 100,000 population or greater) are
already required by the Act to implement enhanced I/M. For these
areas, enhanced I/M cannot be considered as a comparable measure.
The following measures were considered but not included in
the final study:
Clean fuel fleets were evaluated in a preliminary
scoping study and the resulting emission benefits were
low. Programs targeting vehicle fleets show higher
benefits in more urban areas. The affected areas in
this study, in large part, are the less urbanized
portions of the States. This measure was therefore not
examined in the final study.
Transportation control measures (TCM's) are also not
included in the analysis. TCM's are, by nature, area
specific and usually developed as a package of
measures. It is beyond the scope of this study to
develop potential TCM programs for each area. In
addition, TCM's are generally most effective in
urbanized areas. States wishing to consider TCM's
instead of Stage II may conduct an independent analysis
of the measures using the procedures provided in
Chapter 6.
The California low emission vehicle (LEV) program is
also not included in this study. On February 10, 1994,
the OTC submitted a recommendation to EPA that EPA
require the LEV program throughout the OTR. Under this
21
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recommendation, the LEV program is scheduled to begin
in model year 1999. Because the emissions reductions
benefits from this program rely on fleet turnover, only
limited reductions will be achieved in the first model
year due to the limited number of vehicles in the fleet
that will be meeting the standard.
Accelerated vehicle scrappage results in higher fleet
turnover and speeds up the benefits of programs such as
the Tier 1 tailpipe standards if people replace their
scrapped vehicles with new cars. Because of the
uncertainty in benefits, this measure was not included
in the final study.
4.1.1 Modeling Analyses
Base Case Controls and VMT Estimates
The base case motor vehicle projections include all of the
mandatory control requirements of the Act. This includes
enhanced I/M in MSA's with a population of 100,000 or more for
all areas in the OTR, and basic I/M for moderate areas not
required to implement enhanced I/M. In the case of enhanced I/M,
the Act only mandates that the program apply to the urbanized
portions of the MSA. Under the base case modeling scenario, no
judgement was made as to whether specific counties would be
exempt based on this provision; the enhanced I/M controls were
applied to the entire MSA. The base case motor vehicle controls
are summarized in Table 4-1.
Highway vehicle emissions are projected by combining
estimated vehicle miles traveled (VMT) with MOBILE5a (see
reference 2) emission factors. Base year VMT estimates are from
the Interim 1990 Inventory. (See reference 3.) The VMT
estimates were retained by county, vehicle type, and roadway
classification. Ozone season daily VMT was estimated from annual
VMT by applying seasonal and daily temporal allocation factors.
(See reference 15.) Projection year VMT was calculated using
national VMT growth from the MOBILE4.1 Fuel Consumption Model
(see reference 16), which was scaled to each area based on
expected population growth. Table 4-2 shows the national VMT
projections and corresponding annual growth rates.
State-specific MOBILESa emission factors were applied to the
VMT estimates to calculate emissions. The ozone season
temperatures and RVP's used in the modeling are the same values
used for the vehicle refueling projections, as shown in Table
3-2. Each vehicle type/roadway classification was matched to an
average speed used in the MOBILESa modeling. The correspondence
between roadway classifications and speeds is shown in Table 4-3.
22
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Table 4-1. Base Case Motor Vehicle Controls
Attainment, Marginal, and Moderate Areas in the OTR
Program
Description
RVP
Tailpipe Standards
Evaporative Test Procedure
I/M
Phase II RVP minus a 0.3 psi margin of safety.
For areas with a 7.8 psi limit, no safety margin
is applied.
Federal Tier I standards are required nationally.
Tier II standards are optional (the Act
mandates a study investigating the need for
the standards) and were not modeled.
The new Federal evaporative test procedure
applies to all vehicles certified outside
California.
Enhanced I/M was applied in MSA's with a
population of 100,000 or more. Basic I/M was
applied in moderate areas unless enhanced I/M
is required.
23
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Table 4-2. Current and Projected Nationwide Vehicle Miles Traveled
Vehicle Miles Traveled
(billions)
Equivalent Annual
Growth Rate
(percent per year)
LDGV
LDGT
HDGV
Diesel
Total
1990
1,169.22
444.19
55.70
130.45
1,799.56
1999
1,361.35
617.03
72.02
174.38
2,224.78
1990-1990
1.7
3.7
2.9
3.3
2.4
NOTES:
LDGV = light-duty gasoline vehicle
LDGT = light-duty gasoline truck
HDGV = heavy-duty gasoline vehicle
SOURCE:
EPA, 1991f.
24
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Table 4-3. Average Speeds by Roadway Classification and Vehicle Type
(mph)
Rural
LDV
LOT
HDV
Interstate
60
55
40
NOTES:
01 SOURCE:
Principal Minor Major
Arterial Arterial Collector
45 40 35
45 40 35
35 30 25
Minor
Collector Local
30 30
30 30
25 25
Urban
Other Freeways
Interstate & Expressways
45 45
45 45
35 35
Principal
Arterial
20
20
15
Minor
Arterial Collector Local
20 20 20
20 20 20
15 15 15
LDV = light-duty vehicle
LOT = light-duty truck
HDV = heavy-duty vehicle
Derived from the Highway Performance Monitoring System Impact Model.
-------
Enhanced I/M
Enhanced I/M modeling parameters are described in Table 4-4.
These are based on each area meeting I/M performance standard
requirements from the Inspection/Maintenance Program
Requirements; Final Rule. (See reference 17.) States may vary
the I/M program parameters (e.g., biennial versus annual,
stringency of outpoints, waiver rates) as long as the resulting
emission benefits are equivalent to those of the model program.
In fact, the guidance suggests a biennial program, which is
generally more cost effective than an annual program. Emission
reductions for enhanced I/M are measured incremental to Act
requirements. In areas where basic I/M is required, the
reductions for enhanced I/M are measured incremental to this
baseline. This analysis assumes that all counties within MSAs of
population greater than 100,000 implement enhanced I/M under
baseline Act requirements. The Act requires enhanced I/M only
within the urbanized portions of these areas. Thus, Act
requirements may be overstated in this analysis. Benefits from
extending enhanced I/M to non-urbanized portions of nonattainment
areas or MSAs may be substituted for Stage II reductions.
Enhanced I/M shows comparable reductions in all areas where
this measure not already required under the Act.
Reformulated Gasoline
Section 211(k) of the Act requires EPA to promulgate
regulations establishing requirements for reformulated gasoline
for conventional vehicles in the nine worst ozone nonattainment
areas. This provision also allows other areas classified as
marginal, moderate, serious, and severe to opt into the Federal
reformulated gasoline program at the request of the Governor of
the State. The final rules were published on February 16, 1994.
(See reference 18.) The reformulated gasoline program will be
implemented in two phases. Phase I begins on January 1, 1995 and
will achieve a 15 to 17 percent reduction in both VOC emissions
and toxic emissions from motor vehicles. Phase II begins on
January 1, 2000 and will achieve a 25 to 29 percent VOC
reduction, a 20 to 22 percent reduction in toxics emissions, and
a 5 to 7 percent reduction in NOX emissions.
Reformulated gasoline was modeled according to the Federal
program requirements using the MOBILE5a reformulated gasoline
routines. This simply involved setting an input flag within the
MOBILESa input file. The model then calculated the projection
year emission factors using Phase I or Phase II reformulated gas,
depending on the projection year. The reformulated gasoline
program will be in Phase I in 1999, the year selected for
comparability demonstration. Therefore, only the emissions
26
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Table 4-4. Enhanced I/M Program Modeling Assumptions
I/M Program:
Start year:
Pre-1981 MYR stringency rate:
Model years covered:
Waiver rate (pre-1981):
Waiver rate (1981 and newer):
Compliance rate:
Inspection type:
Inspection frequency:
Vehicle types covered:
Test Type:
1996
20%
1986 - 2020
3%
3%
96%
Centralized
Annual
LDGV, LDGT 1 & 2
1968- 1985 MY
2500/ldle
1986-2020 MY
Transient
Cutpoints (g/mile):
0.80 HC
20.0 CO
2.0 NO,
Anti-tampering Program:
Start year:
Model years covered:
Vehicle types covered:
Inspection type:
Inspection frequency:
Compliance rate:
Tampering inspections performed:
1996
1984 - 2020
LDGV, LDGT 1 & 2
Centralized
Annual
96%
Catalyst, Fuel inlet
restrictor
Evaporative System Pressure Test:
Start year:
Model years covered:
Vehicle types covered:
Inspection type:
Inspection frequency:
Compliance rate:
1996
1983-2020
LDGV, LDGT 1 & 2
Centralized
Annual
96%
Functional Purge Test:
Start year:
Model years covered:
Vehicle types covered:
Inspection type:
Inspection frequency:
Compliance rate:
1996
1986-2020
LDGV, LDGT 1 & 2
Centralized
Annual
96%
27
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reductions attributable to Phase I were evaluated for possible
comparability to Stage II reductions.
Table 4-5 includes data on emissions reductions from
reformulated gasoline in all areas affected by the Stage II or
comparable measure requirement. However, States should be aware
that there are significant outstanding legal and technical issues
regarding whether and how reformulated gasoline programs may be
applied in attainment and incomplete data nonattainment areas.
The EPA is currently exploring these issues. States should
contact the EPA Office of Mobile Sources for further information.
The emission reductions achieved by reformulated gasoline
depend on the mix of emission control measures already in place.
Reformulated gasoline standards include a further reduction in
gasoline RVP. Therefore, a lower RVP in the baseline lessens the
effectiveness of reformulated gasoline. To a smaller degree, the
impacts of reformulated gasoline are also dependent on whether
the area is subject to an enhanced I/M program in the baseline.
The majority of areas will achieve comparable reductions
with reformulated gasoline. Exceptions in 1999 include the two
areas in New Jersey; Portland, ME; Manchester, NH; Albany and
Buffalo, NY; and Erie, Harrisburg, and Pittsburgh, PA. The
common characteristic of these areas is that all require enhanced
I/M under the Act that reduces the baseline from which
reformulated gasoline reductions are measured.
Because opting into the Federal reformulated gasoline
program is a voluntary action, the program may be selected as a
comparable measure in marginal and moderate areas if it is shown
to achieve emissions reductions equal to or greater than Stage
II. However, section 184(b)(2) requires that either Stage II or
the comparable measure be reflected in the SIP. Therefore, the
opt-in letter from the Governor would need to undergo the SIP
rulemaking process.
Combination of Measures
Enhanced I/M and reformulated gasoline programs were
combined to estimate the overall benefit of the two measures.
The benefits of motor vehicle measures are not additive because
the controls may be affecting the same emission component (i.e.,
exhaust, evaporative loss, resting loss, or running loss).
Separate MOBILESa runs were therefore completed combining the
measures and emissions projected using the resulting emission
factors.
The estimated emission reductions for each of the motor
vehicle measures, as well as the combination of the measures, are
shown in Table 4-5. The same areas that show comparable benefits
28
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Table 4-5. Motor Vehicle Control Measure VOC Reductions
Projection Year 1999
Ozone Area
Delaware
Sussex County
Maine
Hancock & Waldo Counties
Knox & Lincoln Counties
Lewiston-Auburn
Portland
Franklin County
Oxford County
Somerset County
Attainment Counties
Maryland
Kent & Queen Anne's Counties
Attainment Counties
New Hampshire
Manchester
Belknap County
Chesire County
Sullivan County
Attainment Counties
New Jersey
Allentown-Bethlehem-Easton
Atlantic City
New York
Albany-Schenectady-Troy
Buffalo-Niagara Falls
Essex County
Jefferson County
Poughkeepsie
Attainment Counties
Enhanced
I/M
3.10
1.73
1.49
4.26
NA*
0.72
1.20
1.02
6.61
1.18
7.22
NA
1.00
1.45
0.78
3.14
NA
NA
NA
NA
0.75
1.63
NA
30.97
VOC Reduction (tpd)
Reformulated
Gasoline
1.25
0.62
0.53
1.54
1.76
0.26
0.43
0.37
2.38
0.47
3.84
2.00
0.39
0.57
0.30
1.23
0.40
1.42
3.50
4.13
0.29
0.63
1.28
21.08
Enhanced
+
Reform
3.79
2.06
1.77
5.08
NA*
0.86
1.43
1.22
7.87
1.43
9.70
NA
1.21
1.76
0.95
3.83
NA
NA
NA
NA
0.91
1.97
NA
46.65
*NA = not applicable, enhanced I/M is already required by the Act in this area. All counties within the area
were assumed to apply enhanced I/M under the Act. If certain counties are exempt (i.e., not urbanized), then
reductions in these counties would be creditable for substitution.
29
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Table 4-5 (continued)
Ozone Area
Pennsylvania
Allentown-Bethlehem-Easton
Altoona
Erie
Harrisburg-Lebanon-Carlisle
Johnstown
Lancaster
Pittsburgh-Beaver Valley
Reading
Scranton-Wilkes-Barre
York
Youngstown-Warren-Sharon
Crawford County
Franklin County
Greene County
Juniata County
Lawrence County
Northumberland County
Pike County
Schuylkill County
Snyder County
Susquehanna County
Warren County
Wayne County
Attainment Counties
Vermont
Attainment Counties
Enhanced
I/M
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.78
2.25
0.87
0.43
1.95
1.76
0.41
2.86
0.70
0.85
0.95
0.74
15.98
9.17
VOC Reduction (tpd)
Reformulated
Gasoline
2.08
0.50
0.89
2.56
1.02
1.60
9.87
1.23
2.59
1.78
0.51
0.70
0.89
0.34
0.17
0.77
0.70
0.16
1.13
0.28
0.34
0.38
0.29
7.28
4.18
Enhanced
+
Reform
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.17
2.75
1.06
0.53
2.38
2.14
0.50
3.49
0.86
1.04
1.16
0.91
20.45
11.78
*NA = not applicable, enhanced I/M is already required by the Act in this area. All counties within the area
were assumed to apply enhanced I/M under the Act. If certain counties are exempt (i.e., not urbanized), then
reductions in these counties would be creditable for substitution.
30
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with enhanced I/M alone also show comparable benefits with
enhanced I/M and reformulated gasoline combined.
4.1.2 Cost Effectiveness
Enhanced I/M
The EPA has developed estimates of inspection and repair
costs for enhanced I/M programs. (See reference 19.) A biennial
enhanced I/M program that would satisfy the requirements of EPA's
final rule has an estimated net annual cost of $5.4 million per
year per million vehicles. If all program costs are allocated to
VOC reductions, the biennial enhanced I/M program has an annual
cost-effectiveness of $880 per ton of VOC. If program costs are
allocated among the three criteria pollutants reduced by enhanced
I/M NOX, carbon monoxide (CO), and VOC the cost per ton of
VOC reduced is estimated to be $500 for a biennial enhanced I/M
program. Although EPA's performance standards are based on an
annual program, most areas required to implement enhanced I/M are
expected to implement biennial programs that have been shown to
be more cost effective. It should be noted that EPA's estimates
of inspection and repair costs are based on programs implemented
in urbanized areas. Costs for rural areas may be higher because
fewer cars would be serviced by each inspection station.
Inconvenience to vehicle owners in rural areas may also be higher
than in urban areas because distances to inspection stations may
be greater in less populated areas.
Reformulated Gasoline
The final rule for reformulated gasoline estimates an
incremental cost of approximately 3 to 5 cents per gallon for
Phase I reformulated gasoline above the cost of conventional
gasoline.
The cost per ton of VOC reduced varies from State to State
based on the estimated emission benefit. The cost has generally
been estimated to be less than $5,000 per ton. Emission benefits
depend on the baseline from which reductions are measured. Areas
with enhanced I/M programs and lower RVP values in the baseline
show lower benefits attributable to reformulated gasoline. The
costs of producing Phase I reformulated gasoline result from the
required addition of oxygenates to gasoline, RVP reductions, and
refinery processing changes.
4.2 STATIONARY SOURCE VOC CONTROL MEASURES
The stationary source measures analyzed by the study are
more stringent controls on existing sources for several selected
source categories.
31
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The following measures were considered but not included in
the final study:
Control of industrial adhesives was considered as a
potential measure. The 1990 Interim Inventory emission
estimates for industrial adhesives are based on a
national material balance. Resulting emissions are
higher than any previous estimates and are considered
uncertain. Because of this uncertainty, this measure
is not included in the final study, but may be
independently analyzed by the States.
RACT to smaller sources was also considered as a
potential measure. RACT to 50 tpy is already required
for VOC sources in the OTR (severe areas are required
to install RACT on 25 tpy and greater sources). The
Interim Inventory point source data base is based on
the 1985 NAPAP inventory, which has a major stationary
source size cutoff of 100 tpy for VOC. Because the
inventory does not cover the smaller sources and
because the fraction of area source emissions in the 25
or 10 to 50 tpy range is unknown, this measure cannot
be adequately assessed.
Increased offsets were also considered. This measure
could include extending offsets to smaller sources or
increasing the offset ratio. Benefits are difficult to
quantify because growth cannot be accurately allocated
between major new sources and modifications (subject to
offsets) and increases in activity or operating rates
(not subject to offsets unless a permit modification is
triggered).
Emissions from the application of pesticides can be
reduced through reformulation, reduced use of
fumigants, and increases in application efficiency.
Reformulation of pesticides is a lengthy and relatively
expensive process since the reformulated product must
undergo testing and be permitted for use. This measure
is being considered in California and other areas. The
California Federal Implementation Plan (FIP) calls for
a study of pesticide formulations leading to the
establishment of standards to reduce overall emissions
in the range of 20 to 40 percent. Because of the
uncertainty in potential benefits and costs, this
measure was not further analyzed.
32
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More Stringent Controls on Existing Sources
Stationary source VOC control measures were analyzed using
ERCAM-VOC. Base year emissions are from the 1990 Interim
Inventory. Emissions are projected to future years using
State/2-digit SIC earnings growth and population projections.
The Act requires RACT for major sources (those emitting
50 tpy VOC) in the OTR. To represent a more stringent set of
controls than RACT, best available control technology (BACT) or
new source performance standard (NSPS) level controls were
applied to existing major (point) sources, or controls were
applied to area source emitters that would be expected to be
below the source size cutoff for RACT. The controls applied are
based on the set of existing control measures in ERCAM-VOC. It
is likely that there are additional source categories to which
additional controls could be applied; however, these controls may
vary significantly by area, so no attempt has been made to
identify new control techniques.
More stringent controls were applied to five source
categories as follows:
SOCMI fugitives Synthetic organic chemical manufacturing
industry (SOCMI) fugitives are controlled through improved
equipment and leak detection and repair (LDAR) programs.
The baseline (RACT) control level assumed for this area
source category is 37 percent. A more stringent program was
applied at a 56 percent VOC emission reduction under the
more stringent control on existing sources scenario. The
estimated cost effectiveness is $200 per ton from
uncontrolled levels. The estimated incremental (incremental
to RACT level control) cost effectiveness is $375 per ton.
Petroleum refinery fugitives Petroleum refinery fugitive
(equipment leak) emissions are controlled through equipment
(e.g., seals) and maintenance (e.g., leak detection and
repair (LDAR)). A 69 percent control level was applied to
represent RACT. A control level of 93 percent was applied
under the more stringent control scenario. The higher level
of control can be achieved through more frequent inspections
for leaks and more sophisticated equipment, such as double
mechanical seals or seals with a buffer or barrier fluid.
The estimated cost effectiveness is $2,030 per ton from
uncontrolled levels. The estimated incremental cost
effectiveness is $8,200 per ton reduced.
Pharmaceutical manufacturing Baseline controls for this
area source category (which includes mainly fugitive
emissions) include an LDAR program at an estimated control
level of 37 percent. A more stringent LDAR program and
improved equipment are applied to achieve a 56 percent
33
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reduction in the more stringent control scenario. The
estimated cost is $340 per ton from uncontrolled levels.
The incremental cost is estimated to be $480 per ton.
Bakeries No controls are applied to this area source
category in the baseline (emission levels are assumed to be
below the major source size cutoff). An 80 percent control
level, representing afterburners, is applied in the more
stringent control case. Cost effectiveness is estimated to
be $1,275 per ton reduced.
Small drycleaners No controls are applied to this area
source category in the baseline scenario. A 70 percent
control, representing recovery dryers, is applied in the
more stringent control scenario. This includes small
commercial drycleaners using both petroleum solvent and
perchloroethylene. Approximately half of the emissions in
this category are from perchloroethylene drycleaning.
Reductions from these operations are included here but may
not be creditable, since it has been proposed that
perchloroethylene be exempted as a VOC. Cost effectiveness
is estimated to be $200 per ton reduced.
Emission reductions attributable to more stringent controls
on existing stationary sources from the RACT-level or
uncontrolled baseline are shown in Table 4-6. These emissions
estimates represent the total emissions reductions if the
existing sources for the five source categories listed above are
controlled to the more stringent level. Applying these VOC
stationary source control measures does not provide comparable
benefits for any area. A detailed summary by source category is
given in Appendix B.
34
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Table 4-6. Stationary Source Control Measure VOC Emission Reductions
Projection Year 1999
VOC Reduction (tpd)
More Stringent
Ozone Area Existing Source Controls
Delaware
Sussex County 0.17
Maine
Hancock & Waldo Counties 0.05
Knox & Lincoln Counties 0.03
Lewiston-Auburn 0.56
Portland 0.79
Franklin County 0.00
Oxford County 0.01
Somerset County 0.01
Attainment Counties 0.25
Maryland
Kent & Queen Anne's Counties 0.07
Attainment Counties 0.52
New Hampshire
Manchester 1.05
Belknap County 0.03
Chesire County 0.09
Sullivan County 0.00
Attainment Counties 0.10
New Jersey
Allentown-Bethlehem-Easton 0.09
Atlantic City 0.36
New York
Albany-Schenectady-Troy 1.07
Buffalo-Niagara Falls 1.82
Essex County 0.00
Jefferson County 0.07
Poughkeepsie 0.14
Attainment Counties 5.19
35
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Table 4-6 (continued)
VOC Reduction (tpd)
More Stringent
Ozone Area Existing Source Controls
Pennsylvania
Allentown-Bethlehem-Easton 0.69
Altoona 0.19
Erie 0.30
Harrisburg-Lebanon-Carlisle 0.66
Johnstown 0.12
Lancaster 0.63
Pittsburgh-Beaver Valley 3.48
Reading 0.79
Scranton-Wilkes-Barre 0.61
York 0.72
Youngstown-Warren-Sharon 0.16
Crawford County 0.22
Franklin County 0.04
Greene County 0.02
Juniata County 0.00
Lawrence County 0.02
Northumberland County 0.17
Pike County 0.02
Schuylkill County 0.05
Snyder County 0.02
Susquehanna County 0.00
Warren County 0.02
Wayne County 0.01
Attainment Counties 0.81
Vermont
Attainment Counties 0.77
36
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5.0 NOX CONTROL MEASURES
Under EPA's interpretation of section 184(b)(2), States have
the option of adopting comparable NOX control measures instead of
Stage II. Section 5.1 provides the method for determining what
level of NOX emission reductions is comparable to Stage II VOC
emissions reductions for a particular area and therefore can be
substituted. NOX may not be substituted for VOC in areas where a
waiver under section 182(f) of the Act from some or all NOX
requirements has been obtained because such a waiver indicates
that NOX reductions are either excess and not necessary for
attainment, or NOX reductions are otherwise not beneficial.
The NOX control measures evaluated in the study have been
divided into three categories: motor vehicle, utility point
source, and non-utility point source. The emissions reduction
estimates for these categories are provided in sections 5.2, 5.3,
and 5.4, respectively. Calculations of the VOC equivalency for
the NOX emissions reductions, according to the methodology in
section 5.1, are provided. If a measure controls both NOX and
VOC emissions (see Chapter 3 for VOC emissions reductions
estimates), the emissions reductions may be combined to yield a
total emissions reduction estimate for the measure.
5.1 NOX SUBSTITUTION METHODOLOGY
To determine whether a NOX control measure achieves
comparable emissions reductions to Stage II, the NOX reductions
for the measure and Stage II VOC reductions are compared on the
basis of percentage reductions of the respective NOX and VOC base
year anthropogenic emission inventories (rather than on a ton-
per-ton basis). For example, a 10 percent reduction in the NOX
inventory would be considered comparable to a 10 percent
reduction in the VOC inventory. (By this method, the ton-per-ton
equivalency will vary by area according to the ratio of the VOC
and NOX emissions inventories.)
Comparability determinations for NOX control measures are
illustrated by the following example.
Example A. Consider an area with a 1990 base year VOC emissions
inventory of 500 tons per day (tpd) and a NOX emissions inventory
of 400 tpd. Stage II, more stringent controls on coal-fired
boilers, and enhanced I/M (which controls both VOC and NOX) are
analyzed below for projection year 1999.
Assume Stage II control yields a 2 percent reduction from
the 1990 VOC base year emissions inventory (10 tpd reduction
divided by 500 tpd total). Therefore, to be comparable, a NOX
control measure must achieve a reduction of 2 percent or more in
37
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Example A
VOC Reduction
Control Measure
Stage II
More Stringent Controls on Coal-Fired
Utilities
Enhanced I/M
tpd
10
0
7
%
2
0
1.4
NOX Reduction
tpd
9
1.5
%
--
2.3
0.4
emissions from the 1990 NOX base year emissions inventory (8 tpd
or more reduction from 400 tpd total). More stringent control
for NOX on coal-fired utilities would be considered comparable
where this measure yields a reduction of 2.3 percent from base
year emission levels (9 tpd NOX reduction divided by 400 tpd NOX
total) . Enhanced I/M reduces both VOC and NOX emissions.
Therefore, the VOC reductions and the NOX reductions may be
summed for this measure. Enhanced I/M would not be considered
comparable because the sum of the percent NOX and VOC emissions
reductions is only 1.8 percent: 1.4 percent for VOC (7 tpd VOC
reduction divided by 500 tpd VOC total) and 0.4 percent for NOX
(1.5 tpd NOX reduction divided by 400 tpd NOX total) .
NOTC Substitution Ratios
The calculations for comparing emissions reductions using
the percent of inventory method can be simplified by deriving the
NOX substitution ratio for an area. The NOX substitution ratio is
simply the NOX inventory divided by the VOC inventory. In
Example A, the NOX substitution ratio would be 0.8 (400 tpd NOX
divided by 500 tpd VOC). Thus, 0.8 tpd NOX is comparable to 1
tpd VOC for that area. The NOX substitution ratio will vary area
by area according to the relative amounts of VOC and NOX
emissions.
The NOX emissions reductions estimated for an alternative
measure can be divided by the NOX substitution ratio to convert
the NOX emissions to comparable VOC reductions. The VOC
reductions can then be compared on a ton-for-ton basis with the
Stage II VOC reductions. This is illustrated by the following
example.
Example B,
Example A.
This example uses the same scenario described in
The 1990 NOX inventory is 400 tpd and the 1990 VOC
inventory is 500 tpd. Dividing the NOX inventory by the VOC
inventory produces a NOX substitution ratio of 0.8. In the table
below, the NOX emissions reductions have been divided by the NOX
substitution ratio to produce the VOC equivalent reductions for
the measures.
38
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Example B
Control Measure
Stage II .
More Stringent Controls on Coal-Fired
Utilities
Enhanced I/M
voc
Reduction
(tpd)
10
0
7
NO,
Reduction
(tpd)
-
9
1.5
Comparable VOC
Reduction (tpd)
-
11.3
1.9
Stage II achieves a VOC reduction of 10 tpd. More stringent
NOX control on coal-fired utilities is comparable because it
achieves NOX emissions reductions comparable to 11.3 tpd
reduction in VOC. Enhanced I/M is not comparable because it
achieves only an 8.9 tpd reduction in VOC emissions (7 tpd VOC +
1.9 tpd in VOC comparable emissions).
In data tables in this chapter, all of the NOX emissions
reductions estimates for the measures evaluated have been
converted into comparable VOC equivalent reductions for ease in
comparing the reductions to the applicable Stage II VOC emissions
reductions. The ratios for determining equivalent VOC reductions
are shown in Table 5-1.
The method for substituting NOX for the Stage II or
comparable measure requirement is based, in part, on the NOX
Substitution Guidance (see reference 20) developed for States to
use to meet post-1996 emission reduction requirements under
section 182(c)(2)(B) of the Act. Section 182(c)(2) requires each
serious and above ozone nonattainment area to submit a SIP
revision by November 15, 1994, which describes how the area will
achieve an actual VOC emissions reduction of 3 percent per year,
averaged over consecutive 3-year periods beginning November 15,
1996 until the area's attainment date. Substitution of NOX
emissions reductions is permitted if certain conditions are met.
Central to both substitution procedures is that NOX and VOC
emissions reductions are compared on a percentage of the base
year inventory basis rather than on a ton-per-ton basis.
However, there are some significant differences. The two NOX
substitution methods differ in regard to applicability and the
approvability criteria for the substitution. The post-1996 NOX
substitution guidance applies only to serious and above ozone
nonattainment areas. The approvable degree of NOX substitution
in the rate-of-progress plans is linked to an area's attainment
demonstration. NOX emissions reductions must be shown to be
necessary for attainment and be included in the area's SIP
control strategy before they may be substituted for VOC emissions
reductions in the rate-of-progress plans.
39
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Table 5-1. NOX to VOC Substitution Ratios - Percent of Inventory Method
Ozone Area
Delaware
Sussex County
Maine
Hancock & Waldo Counties
Knox & Lincoln Counties
Lewiston-Auburn
Portland
Franklin County
Oxford County
Somerset County
Attainment Counties
Maryland
Kent & Queen Anne's
Counties
Attainment Counties
New Hampshire
Manchester
Belknap County
Chesire County
Sullivan County
Attainment Counties
New Jersey
Allentown-Bethlehem-Easton
Atlantic City
New York
Albany-Schenectady-Troy
Buffalo-Niagara Falls
Essex County
Jefferson County
Poughkeepsie
Attainment County
Pennsylvania
Allentown-Bethlehem-Easton
Altoona
Erie
1990 VOC
(tpd)
173.3
14.5
11.3
39.4
79.7
5.7
11.9
9.8
66.6
11.4
128.7
82.4
8.5
12.4
6.4
27.1
21.6
52.6
196.2
226.7
6.5
17.0
53.1
937.8
102.2
22.1
184.3
1990 NOX
(tpd)
67.8
13.6
10.6
26.4
69.1
9.2
9.6
10.3
56.7
9.8
116.1
102.2
6.7
9.2
4.9
24.4
22.1
70.0
135.6
237.1
7.4
13.4
32.8
719.4
116.0
19.7
45.1
NOxto
VOC Ratio
0.4
0.9
0.9
0.7
0.9
1.6
0.8
1.0
0.9
0.9
0.9
1.2
0.8
0.7
0.8
0.9
1.0
1.3
0.7
1.0
1.1
0.8
0.6
0.8
1.1
0.9
0.2
40
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Table 5-1 (continued)
Ozone Area
Harrisburg-Lebanon-Carlisle
Johnstown
Lancaster
Pittsburgh-Beaver Valley
Reading
Scranton-Wilkes-Barre
York
Youngstown-Warren-Sharon
Crawford County
Franklin County
Greene County
Juniata County
Lawrence County
Northumberland County
Pike County
Schuylkill County
Snyder County
Susquehanna County
Warren County
Wayne County
Attainment Counties
Vermont
Attainment Counties
1990 VOC
(tpd)
106.8
42.2
83.2
441.0
64.3
131.3
82.4
22.6
26.0
22.7
7.4
4.4
17.6
18.4
12.5
28.2
7.2
56.4
16.6
7.0
215.6
110.5
1990NOX
(tpd)
80.3
33.9
62.2
658.2
58.3
91.2
133.7
20.0
18.9
16.1
115.2
3.3
39.9
12.5
3.3
19.5
37.7
6.2
16.2
5.3
543.2
77.9
NOxto
VOC Ratio
0.8
0.8
0.7
1.5
0.9
0.7
1.6
0.9
0.7
0.7
15.6
0.8
2.3
0.7
0.3
0.7
5.3
0.1
1.0
0.8
2.5
0.7
NOTE: Base year anthropogenic emissions are taken from the 1990 Interim Inventory. (See reference 3.)
41
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In contrast, the Stage II Comparability Study NOX
substitution guidance applies to moderate, marginal, and
incomplete data ozone nonattainment areas and attainment
portions of the OTR.1 Most of these areas are already at ornear
attainment and are not required to submit attainment
demonstrations. Therefore, approvability of the degree of NOX
substitution for the purposes of this requirement cannot be
related to attainment demonstrations.
Instead, EPA believes any mix of VOC and NOX emissions
reductions is permissible to meet the comparability requirement.
This is supported by the findings of the National Academy of
Science report Rethinking the Ozone Problem in Urban and Regional
Air Pollution (see reference 21) and the results of Regional
Oxidant Model (ROM) simulations, which suggest that substantial
reductions of both NOX and VOC emissions will be needed to bring
the OTR into attainment.
5.2 MOTOR VEHICLE CONTROL MEASURES
The enhanced I/M program was evaluated as a potential
comparable NOX control measure for motor vehicles. This control
measure was also evaluated for VOC emissions reductions in
Chapter 4. The program parameters are described in that chapter.
The projection methodology and the modeling assumptions used to
examine this measure for NOX control are identical to those used
for the VOC analysis. These are described in detail in Chapter
4. Also provided in Chapter 4 are the cost estimates for
implementing this measure. Federal reformulated gas was analyzed
as a motor vehicle control measure for VOC, but it is not
included in this section because the Act only requires that Phase
I reformulated gasoline not increase NOX emissions. Phase II
reformulated gasoline will reduce NOX emissions; however, Phase
II reformulated gasoline does not begin until the year 2000.
Other motor vehicle measures were considered, as discussed in
Chapter 4, but not included in the final study.
The estimated NOX reductions from enhanced I/M are shown in
Table 5-2. No benefit is shown for areas where enhanced I/M
programs are already required. For the purposes of making a
comparability determination, an area can only take credit for
emissions reductions from control measures that are in excess of
control measures prescribed under the Act. As discussed in
Section 5.1, the NOX and VOC emissions reductions may be combined
'Technically, the section 184(b)(2) requirement to adopt Stage II or a
comparable measure, and thus the related NOX substitution guidance, applies to
all areas in the OTR, including serious and severe areas. However, as
discussed in Chapter 2.0, because States with serious and severe areas must
adopt Stage II under section 182(b)(3), they cannot take advantage of the
option to adopt a comparable measure.
42
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Table 5-2. Motor Vehicle NOX Reductions - Projection Year 1999
Ozone Area
Delaware
Sussex County
Maine
Hancock & Waldo Counties
Knox & Lincoln Counties
Lewiston-Auburn
Portland
Franklin County
Oxford County
Somerset County
Attainment Counties
Maryland
Kent & Queen Anne's Counties
Attainment Counties
New Hampshire
Manchester
Belknap County
Chesire County
Sullivan County
Attainment Counties
New Jersey
Allentown-Bethlehem-Easton
Atlantic City
New York
Albany-Schenectady-Troy
Buffalo-Niagara Falls
Essex County
Jefferson County
Poughkeepsie
Attainment Counties
NOX
(tpd)
1.81
1.13
0.98
2.33
NA*
0.48
0.78
0.65
3.94
0.83
4.90
NA
0.62
0.89
0.46
1.99
NA
NA
NA
NA
0.48
0.96
NA
18.19
Enhanced I/M
Comparable VOC
(tpd)
4.53
1.26
1.09
3.33
NA
0.30
0.98
0.65
4.38
0.92
5.44
NA
0.78
1.27
0.58
2.21
NA
NA
NA
NA
0.44
1.20
NA
22.74
*NA = not applicable; enhanced I/M is mandated by the Act for these areas.
43
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Table 5-2 (continued)
Ozone Area
Pennsylvania
Allentown-Bethlehem-Easton
Altoona
Erie
Harrisburg-Lebanon-Carlisle
Johnstown
Lancaster
Pittsburgh-Beaver Valley
Reading
Scranton-Wilkes-Barre
York
Youngstown-Warren-Sharon
Crawford County
Franklin County
Greene County
Juniata County
Lawrence County
Northumberland County
Pike County
Schuylkill County
Snyder County
Susquehanna County
Warren County
Wayne County
Attainment Counties
Vermont
Attainment Counties
NOX
-------
to determine comparability to Stage II VOC reductions. As shown
in Chapter 4, areas where enhanced I/M is applicable show
comparable benefits with the VOC reductions alone. Examining the
NOX benefits alone shows comparable benefits in all applicable
areas except Greene, Lawrence, Snyder, and the attainment
counties in Pennsylvania. These latter areas all have NOX to VOC
ratios greater than 2.
5.3 UTILITY CONTROL MEASURES
Utility boilers are affected by both Title I and Title IV of
the Act. Under Title I, utility units are subject to NOX RACT
requirements for major stationary sources (100 tpy or greater in
the OTR). Through Title IV, many utility units will be subject
to NOX emission limits.
The NOX control measures examined for utility boilers are
lowering the NOX RACT source size cutoff from 100 tpy to 25 tpy,
and requiring more stringent controls for existing major sources
(i.e., 100 tpy or greater sources). Table 5-3 shows the control
technologies selected to represent RACT and the more stringent
control for utility as well as non-utility point sources (see
section 5.4 for the analysis of the latter source category).
The 1990 Interim Inventory was used as the basis for
evaluating control measures for fossil-fuel steam utility units.
The utility component of the inventory includes all plants of at
least 10 megawatts and that have at least one operating boiler.
An electric plant is a station containing prime movers, electric
generators, and auxiliary equipment for converting mechanical,
chemical, and/or fission energy into electric energy. The
Interim Inventory utility data base contains fossil-fuel fired
boilers only. Electric utilities include facilities which
produce electricity primarily for use by the public.
NOX reductions expected to be achieved through these
controls are shown in Table 5-4. The emissions reductions broken
down by boiler type are given in Table C-l in Appendix C. Areas
not appearing on these tables do not have existing utility units
and therefore have no emissions from utility boilers. Areas
appearing on the results tables all have utility boilers;
however, the resulting emission reductions are sometimes (often
for RACT) zero. This indicates that the control measures applied
do not result in emission reductions in excess of existing levels
and Act requirements. Therefore, the controls could not be
considered as potential comparable measures.
45
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Table 5-3. NOX RACT and More Stringent Control Technologies
Source Category
Utility Boilers - PC Wall Fired
Utility Boilers - PC Tangential
Utility Boilers - Oil/Gas Wall Fired
Utility Boilers - Oil/Gas Tangential
Utility Boilers - Cyclone
Industrial Boilers - PC
Industrial Boilers - Stoker
Industrial Boilers - Residual Oil
Industrial Boilers - Distillate Oil
Industrial Boilers - Natural Gas
1C Engines - Natural Gas
1C Engines - Oil
Gas Turbines - Natural Gas
Gas Turbines - Oil
Process Heaters - Natural Gas
Process Heaters - Distillate Oil
Process Heaters - Residual Oil
Adipic Acid Manufacturing Plants
Nitric Acid Manufacturing Plants
RACT Control
LNB
LNB
BOOS + FGR
BOOS + FGR
NGR
LNB
SNCR
LNB
LNB
LNB
AF + IR
IR
LNB
Water Injection
ULNB
ULNB
ULNB
Thermal Reduction
Extended Absorption
Abbreviations: LNB = low NOX burner
LEA = low excess air
BOOS = burners out of service
FGR = flue gas reburning
NGR = natural gas reburning
SNCR = selective non-catalytic reduction
Percent
Control
45
29
39
42
53
50
55
50
50
50
30
25
84
70
75
74
73
81
95
AF
IR
ULNB
SCR
L-E
1C
NSCR
Cost
($/ton)
305
880
645
940
650
1,350
1,800
620
1,180
770
551
518
236
1,166
532
735
442
459
173
More Stringent
Control
SCR
SCR
SCR
SCR
NGR
SCR
SNCR
SCR
SCR
SCR
L- E
SCR
SCR + Steam Injection
SCR + Water Injection
LNB + SCR
LNB + SCR
LNB + SCR
Thermal Reduction
NSCR
Percent
Control
79
79
72
75
53
75
55
80
80
80
87
80
95
94
88
92
91
81
98
Cost
($/ton)
2,435
1,645
3,750
5,500
650
6,600
1,800
2,450
3,950
3,000
618
1,540
5,581
2,835
3,905
6,340
3,820
459
601
air-to-fuel (ratio)
ignition timing retard
ultra-low NOX burner
selective catalytic reduction
low emission
internal combustion
non-selective catalytic reduction
-------
Table 5-4. Utility Control Measure Emission Reductions
Projection Year 1999
Ozone Area*
Delaware
Sussex County
Maine
Knox & Lincoln Counties
Portland
Attainment Counties
Maryland
Attainment Counties
New Hampshire
Manchester
New Jersey
Atlantic City
New York
Albany-Schenectady-Troy
Buffalo-Niagara Falls
Attainment Counties
Pennsylvania
Allentown-Bethlehem-Easton
Altoona
Erie
Lancaster
Pittsburgh-Beaver Valley
Reading
Scranton-Wilkes-Barre
York
Greene County
Lawrence County
Snyder County
Warren County
Attainment Counties
Vermont
Attainment Counties
RACT
NOX
(tpd)
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
to 25tpy**
Comparable
VOC
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
More Stringent Control
to 100 tpy**
NOX
(tpd)
21.40
0.03
5.08
0.00
5.27
0.00
1.09
8.37
43.67
57.18
25.82
0.00
3.92
0.00
183.73
6.14
0.00
45.67
45.94
11.28
14.79
0.00
179.39
0.00
Comparable
VOC
53.50
0.03
5.64
0.00
5.86
0.00
0.84
11.96
43.67
71.48
23.47
0.00
19.60
0.00
122.49
6.82
0.00
28.54
2.94
4.90
2.79
0.00
71.76
0.00
NOTES: 'Areas not appearing on the table do not have existing utility boilers and therefore have zero
emissions.
**Zeros under RACT or more stringent control indicate that there are no additional reductions
(above the Act requirements) for this measure. RACT to 25 tpy shows no reductions because
utility boilers in these areas all emit at levels greater than the major source size cutoff.
47
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5.3.1 Modeling Assumptions
Ozone season daily emissions for utility boilers were
estimated from annual emissions using seasonal and daily temporal
allocation factors developed for the 1985 NAPAP Inventory. (See
reference 15.) Temporal allocation factors were used because
operational data (seasonal throughput, weeks per year, days per
week) were not available for utilities in the Interim Inventory.
The temporal factors are State- and SCC (boiler type)-specific.
The typical weekday factor was used in conjunction with the
summer seasonal allocation factor to estimate ozone season daily
emissions.
Growth in emissions from existing sources occurs through
increased capacity utilization. Capacity utilization refers to
the actual power generation provided annually by a unit compared
with the potential output if the unit operated 24 hours per day
for 365 days per year. Growth in capacity utilization is a
function of fuel type, unit age, and State growth projections.
Projected capacity utilization for 1999 was estimated using
average capacity utilization factors, which were determined for
each boiler-fuel type with data from the Interim Inventory years
1987 through 1991. Where limited data were available, State
averages for each boiler-fuel type were used as the projected
capacity utilization. Additional power generation demands not
met by existing units would require new unit construction.
Growth estimates indicate that additional units will be
needed in many areas; however, since these new units will be
subject to new source review requirements, these units will
already be required to operate at the more stringent control
levels modeled in this analysis.
Determining NQ^ RACT and Title IV NQK Control Measures
In order to determine the emissions reductions attributable
to additional NOX control measures, first a baseline scenario was
developed that included NOX controls to represent NOX RACT applied
to major stationary sources (100 tpy or greater) (as required by
the Act) and NOX control measures to meet the acid deposition
provisions of Title IV.
Title IV NOX standards are 0.45 Ib/MMBtu for tangentially
fired coal boilers and 0.5 Ib/MMBtu for dry bottom wall-fired
coal boilers. The Title IV standard assumed for the remaining
coal-fired boilers is 1.0 Ib/MMBtu. Phase I units are subject to
Title IV standards in 1996. Phase I units include the 260
dirtiest S02 emitting units. In addition to being classified as
Phase I, the units must operate at least 50 percent on coal (on a
Btu basis) to be subject to the Title IV NOX standard. All units
are required to comply with Title IV NOX limits under Phase II
48
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beginning in 2002. Again, the units must operate at least 50
percent on coal.
The Nitrogen Oxides Supplement to the General Preamble for
the Implementation of Title I of the Clean Air Act Amendments of
1990 (NOX General Preamble) (see reference 22) specifies NOX RACT
limits of 0.2 Ib/MMBtu for tangentially fired oil and gas boilers
and 0.3 Ib/MMBtu for wall-fired oil and gas boilers. The NOX
RACT limits for coal-fired boilers are equivalent to the Title IV
acid deposition limits.
Controls modeled to meet RACT and Title IV standards are
described below. Selection of the particular controls was based
on a recent EPA report that evaluated NOX controls for existing
utility boilers in the NESCAUM region. (See reference 19.) One
control technique was chosen for each fuel/firing type of utility
boiler in the Interim Inventory. The selected control is applied
to all boilers with current NOX emission rates that are more than
10 percent above the Title IV standard. Boilers emitting within
10 percent of the standard were assumed to be able to make minor
combustion modifications to achieve the standard.
Coal Fired, Dry Bottom/ Wall If the boiler does not meet
the Title IV standard or is required to install RACT, low
NOX burner (LNB) was applied. LNB is estimated to achieve a
45 percent reduction in emissions. Based on the utility
boilers in the OTR, this is sufficient for most to achieve
the necessary reductions. Overfire air (OFA), with a
control efficiency of 21 percent, will not achieve the
reductions necessary to meet Title IV requirements.
Coal Fired, Tangential LNB was also applied to
tangentially fired coal boilers. The estimated reduction is
29 percent. This proved to be sufficient to bring all
boilers into compliance with the Title IV standard.
Coal, Cyclone Natural gas reburning (NCR) was applied to
cyclone boilers at a 53 percent reduction. NGR is the only
control technique applicable to cyclone boilers based on the
EPA/NESCAUM study.
Oil, Wall Burners out of service (BOOS) plus (+) fuel gas
reburning (FGR) was applied to wall-fired residual and
distillate oil utility boilers not meeting the RACT standard
(being within 10 percent of the standard). While FGR alone
will achieve the necessary reductions in some cases, BOOS +
FGR is more cost effective. LNB is as effective in reducing
NOX, but is more costly than BOOS + FGR. BOOS + FGR
provides a 39 percent reduction in emissions. All
distillate oil boilers are already below the expected RACT
limit (0.3 Ib/MMBtu).
49
-------
Oil, Tangential BOOS + FGR (at 42 percent control) was
modeled to bring tangential boilers into compliance with
RACT requirements. LNB (at 33 percent control) is
sufficient for most boilers, but is more costly than BOOS +
FGR. All distillate oil boilers are already below the RACT
limit (0.2 Ib/MMBtu).
Oil, Cyclone NCR (at a 53 percent reduction) is the only
control technique available for application to cyclone
boilers. According to the EPA/NESCAUM report, this
technique is not well demonstrated and will probably not be
commercially available. The Title I General Preamble does
not include specific RACT limits for cyclone boilers.
Gas, Wall BOOS + FGR (at a 39 percent reduction) was
estimated to achieve the necessary reductions for wall-fired
natural gas units. This brings most units into compliance.
Other controls that achieve necessary reductions for all
units are more costly, therefore BOOS + FGR is modeled based
on the assumption that other minor modifications in
operation will probably bring the boilers into compliance
with the standard.
Gas, Tangential BOOS is estimated to achieve the
necessary reductions to meet RACT limits for gas-fired
tangential utility boilers. The estimated efficiency used
for modeling is 25 percent.
Gas, Cyclone NCR was applied at a 53 percent reduction.
This is the only control technique available for cyclone
boilers based on the EPA/NESCAUM report. Again, this
technique is not well demonstrated. Specific RACT limits
for cyclone boilers are not included in the Title I General
Preamble.
5.3.2 NOX RACT to 25 tpy
The controls modeled as RACT for the 100 tpy and above
sources were also considered to be RACT for sources emitting 25
to 100 tpy under this scenario. Table 5-3 lists the RACT-level
controls along with cost estimates for implementing the controls.
RACT was applied to all boilers emitting above 25 tpy, rather
than the 100 tpy RACT cutoff mandated for the OTR.
As shown in Table 5-4, lowering the RACT cutoff does not
result in any incremental NOX benefits beyond those achieved
through Act-required measures. One reason for this is that
utility units tend to be above the 100 tpy RACT cutoff. In
addition, utilities may also be subject to Title IV limits.
Lastly, the utility data base from the 1990 Interim Inventory was
developed from fossil-fuel use data for plants of 10 MW or
50
-------
greater. It is difficult to quantify the potential NOX emissions
from smaller units because emissions depend on the fuel type, the
boiler configuration, and the hours operated. Smaller units,
however, tend to operate on oil or gas, which is less polluting
than coal. The State inventories may include these smaller
plants; however, the effect of extending RACT to these units is
expected to be small. Because it is likely the smaller plants
will operate on oil or gas, most will emit less than 50 tpy and
many will be below the 25 tpy cutoff to which RACT was extended
in this analysis.
5.3.3 More Stringent Control for Existing Major Sources
Selective catalytic reduction (SCR) was applied to all
existing 100 tpy or greater utility boilers (except stokers and
cyclones) under the more stringent control scenario. The
estimated control efficiencies are shown in Table 5-3. NCR was
applied to cyclone boilers, equivalent to what was assumed in
modeling RACT-level controls. NCR is the only control technique
applicable to cyclone boilers based on recent studies.
The emission reductions for applying more stringent controls
on utility boilers vary significantly from area to area as shown
in Table 5-4. The level of reductions achieved depends on the
magnitude of emissions in the baseline (i.e., the number and size
of boilers in each area) and the baseline emission level (Ibs NOX
per MMBtu). Gas- and oil-fired units emit less to begin with, so
corresponding reductions are lower. In areas where no reductions
are observed, the units are either below the 100 tpy cutoff
modeled or units are expected to be retired (and may be replaced
by new units). Comparing these reductions to the Stage II
reductions in Table 3-5 shows that more stringent controls on
utility boilers would result in comparable reductions in most
areas with existing utility units. Exceptions include those
where very low incremental reductions are shown, including Knox
and Lincoln Counties in Maine, and Atlantic City, New Jersey.
5.4 NON-UTILITY POINT SOURCE CONTROL MEASURES
Non-utility point sources examined in this analysis include
industrial boilers, internal combustion engines, stationary gas
turbines, process heaters, and acid manufacturing plants. As
with the utility point source category, the alternative measures
analyzed for non-utility point sources were lowering the NOX RACT
source size cutoff from 100 tpy to 25 tpy and requiring more
stringent control for existing 100 tpy or greater sources.
51
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5.4.1 Modeling Assumptions
Emissions were projected to future years by applying Bureau
of Economic Analysis (BEA) earnings-based growth factors by two-
digit SIC and State to the base year emission estimates. (See
reference 23.) Ozone season daily emissions were calculated from
the annual emissions by source category using operational data
from the Interim Inventory. Default values of 52 operational
weeks per year, 7 operational days per week, and a summer
percentage throughput of 25 percent were used in cases where data
were not available for ozone season calculations. The equations
used to estimate ozone season daily emissions were as follows:
Ozone Season Weeks = Max (13, (Summer Throughput Percentage * Weeks per Year))
Ozone Season Daily Emissions = (NO, Emissions * Summer Throughput Percentage)
(Ozone Season Weeks * Days per Week)
The results of the control analysis are presented in Table 5-5.
Detailed summaries by source category are provided in Appendix C.
Determining RACT Level and More Stringent Controls
NOX RACT and more stringent control strategies and
associated control costs are shown in Table 5-3 and described
below. Control measure information for non-utility point sources
was taken from the various EPA Alternative Control Technology
Documents as cited under each source category described below.
NOX RACT to 100 tpy sources is required under Title I of the Act.
The controls specified as RACT were applied to each individual
source if it qualified as a major source and if the existing
control level was lower than the RACT level.
1. Industrial Boilers
Pulverized Coal LNB was assumed as the RACT method of
control for pulverized coal (PC)-fired industrial boilers.
This control is expected to provide a NOX reduction of 45
percent at an average cost per ton of $1,350. SCR was
chosen as the more stringent control at an estimated 79
percent reduction in emissions $6,600 per ton reduced. (See
reference 24.)
Stokers Because limited data were available on control
techniques for stokers, the RACT and more stringent level of
control were assumed to be the same. Selective non-
catalytic reduction (SNCR) was the selected control
technique, with a NOX reduction of 55 percent and average
default cost of $1,800 per ton. (See reference 24.)
Residual Oil, Distillate Oil/ and Natural Gas RACT and
more stringent control techniques for each of the three oil
52
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Table 5-5. Non-Utility Control Measure Emission Reductions
Projection Year 1999
Ozone Area*
Delaware
Sussex County
Maine
Hancock & Waldo Counties
Knox & Lincoln Counties
Lewiston-Auburn
Portland
Franklin County
Oxford County
Somerset County
Attainment Counties
Maryland
Kent & Queen Anne's Counties
Attainment Counties
New Hampshire
Manchester
Chesire County
Attainment Counties
New Jersey
Allentown-Bethlehem-Easton
Atlantic City
New York
Albany-Schenectady-Troy
Buffalo-Niagara Falls
Essex County
Jefferson County
Poughkeepsie
Attainment Counties
Pennsylvania
Allentown-Bethlehem-Easton
Altoona
Erie
Harrisburg-Lebanon-Carlisle
RACT to
NOX
(tpd)
0.38
0.45
0.16
0.30
0.31
0.00
0.00
0.34
1.07
0.00
1.83
0.10
0.00
0.25
0.33
0.29
1.80
1.44
0.00
0.30
0.76
4.19
0.17
0.34
0.11
0.44
25tpy**
Comparable
VOC
0.95
0.50
0.18
0.43
0.34
0.00
0.00
0.34
1.19
0.00
2.03
0.08
0.00
0.28
0.33
0.22
2.57
1.44
0.00
0.38
1.27
5.24
0.15
0.38
0.55
0.55
More Stringent Control
to 100tpy**
IMOX
(tpd)
1.05
0.26
0.00
0.00
0.49
0.84
0.23
0.17
1.77
0.00
2.09
0.00
0.00
0.63
3.29
0.00
0.94
1.27
0.44
0.21
0.00
8.22
0.00
0.00
0.40
0.00
Comparable
VOC
2.63
0.29
0.00
0.00
0.54
0.53
0.29
0.17
1.97
0.00
2.32
0.00
0.00
0.70
3.29
0.00
1.34
1.27
0.40
0.26
0.00
10.28
0.00
0.00
2.00
0.00
53
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Table 5-5 (continued)
Ozone Area*
Johnstown
Lancaster
Pittsburgh-Beaver Valley
Reading
Scranton-Wilkes-Barre
York
Youngstown-Warren-Sharon
Crawford County
Franklin County
Greene County
Lawrence County
Northumberland County
Pike County
Schuylkill County
Warren County
Attainment Counties
Vermont
Attainment Counties
RACT to
NOX
(tpd)
0.81
0.20
3.40
1.05
0.79
0.43
0.56
0.00
0.07
0.00
0.00
0.22
0.07
0.07
0.79
5.18
0.13
25tpy**
Comparable
VOC
1.01
0.29
2.27
1.17
1.13
0.27
0.62
0.00
0.10
0.00
0.00
0.31
0.23
0.10
0.79
2.07
0.19
More Stringent Control
to 100tpy**
NOX
(tpd)
0.03
1.32
7.92
0.00
1.21
1.51
1.20
0.30
0.00
0.00
0.00
0.00
0.00
0.00
0.00
6.53
0.00
Comparable
VOC
0.04
1.89
5.28
0.00
1.73
0.94
1.33
0.43
0.00
0.00
0.00
0.00
0.00
0.00
0.00
2.61
0.00
NOTES: *Areas not appearing in the table do not have non-utility point source NOX emitters.
**Zeros indicate that additional reductions (above the Act) would not be achieved through the selected
control measures.
54
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and gas-fired boiler types were assumed to be the same.
RACT control via LNB provides NOX reductions of 50 percent,
while SCR control (more stringent) reduces emissions by 80
percent for all sources. Costs per ton for these RACT
controls average $620 for residual oil, $1,180 for
distillate oil, and $770 for natural gas. Estimated average
costs for SCR are $2,450 per ton reduced for residual oil,
$3,950 for distillate oil, and $3,000 for boilers fired with
natural gas. (See reference 24.)
2. Internal Combustion Engines
Natural Gas The RACT-level control technique chosen for
natural gas-fired internal combustion (1C) engines is an AF
ratio combustion modification coupled with an IR
modification expected to provide an emissions reduction of
30 percent at an average cost of $551 per ton reduced. Low
emission (L-E) combustion designs provide an emission
reduction of 80 percent for the more stringent control
technique at an average of $618 per ton reduced. (See
reference 25.)
Oil The ignition timing retardation (IR) method of
emissions control was used in determining RACT reductions
for oil fired 1C engines. The associated NOX reduction is
25 percent and costs an average of $518 per ton of NOX
reduced. SCR (more stringent control) is estimated to
reduce NOX emissions by 80 percent, costing an average of
$1,540 per ton of NOX reduced. (See reference 25.)
3. Gas Turbines
Natural Gas A LNB control method was chosen to reflect
RACT-level controls for natural gas-fired turbines with an
average default cost per ton of $236 and an emissions
reduction of 84 percent. SCR control in addition to a steam
injection system is estimated to reduce emissions by up to
95 percent, while costing $5,581 per ton of NOX reduced.
(See reference 26.)
Oil RACT control was chosen to be a water injection
system that reduces NOX emissions by 70 percent from
uncontrolled rates. This control technique costs an average
of $1,166 per ton of NOX reduced. The water injection
system, coupled with SCR, was selected as the more stringent
control option and is estimated to reduce emissions by 94
percent, costing an average of $2,835 per ton reduced. (See
reference 26.)
55
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4. Process Heaters
Natural Gas ULNB was utilized to reduce NOX emissions by
75 percent in the natural gas-fired process heaters. These
reductions cost an average of $532 per ton NOX reduced. A
combination of LNB and SCR controls reduced emissions by 88
percent, costing $3,905 per ton reduced. (See reference
27.)
Distillate Oil ULNB was chosen for RACT control, reducing
emissions by 74 percent, but with a slightly higher cost
than with gas-firing, at $735 per ton reduced. The more
stringent control option was estimated as the LNB + SCR
combination, reducing NOX emissions by 92 percent and
costing an average of $6,340 per ton reduced in distillate
oil fired heaters. (See reference 27.)
Residual Oil The ULNB and LNB + SCR methods of control
were again chosen to represent RACT and the more stringent
control option for residual oil-fired process heaters, with
emissions reductions of 73 percent and 91 percent, and
average NOX control costs of $442 and $3,820 per ton,
respectively. (See reference 27.)
5. Acid Manufacturing Plants
Adipic Acid Both the RACT and more stringent control
methods assumed were thermal reduction control in adipic
acid manufacturing plants. Very little data were available
for these plants, but reductions of 81 percent were reported
at an average cost of $460 per ton. (See reference 28.)
Nitric Acid A method of extended absorption was chosen
for RACT control in the nitric acid manufacturing plants.
This method reduces NOX emissions by 95 percent and costs an
average of $173 per ton reduced compared with the 98 percent
reduction and $600 per ton reduced listed for the more
stringent control technique of NSCR. (See reference 28.)
5.4.2 NOX RACT to 25 tpy Sources
The incremental effect of applying RACT to 25 tpy sources
was examined by comparing this scenario with the baseline (the
Act) scenario. The results of this analysis are shown in Table
5-5 for projection year 1999. Because the point source inventory
does not provide complete coverage of sources below 50 tpy for
NOX (sources less than 50 tpy would only appear if they are
considered major for one of the other criteria pollutants), the
effect of applying NOX RACT to 25 tpy is expected to be
underestimated. The magnitude of the emission reductions vary by
56
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area depending on the mix of sources in the individual areas.
Comparing the reductions with the Stage II reductions in
Table 3-5 shows comparable reductions for NOX RACT to 25 tpy in
Sussex County in Delaware, Hancock/Waldo and Somerset counties in
Maine, Poughkeepsie in New York, Johnstown, Reading, Youngstown-
Warren-Sharon, Northumberland County, Pike County, and Warren
County in Pennsylvania. For some areas, such as Sussex County in
Delaware and Poughkeepsie in New York, the low NOX to VOC ratio
contributes to the comparability.
5.4.3 More Stringent NOX Control to 100 tpy Sources
The incremental effects of applying more stringent controls
on NOX sources was examined by applying the control levels
discussed above and comparing this scenario with the baseline
control (the Act) scenario. These results are also shown in
Table 5-5. The reductions achieved depend on the mix of sources
within the area. Several areas show reductions comparable to
Stage II for more stringent NOX controls. Areas that do not
show comparable reductions are those where reductions are zero
(either no sources are above 100 tpy or more stringent control
options are not available for the types of sources in the area),
areas with high NOX to VOC substitution ratios, such as the
attainment counties in Pennsylvania, and other areas where the
NOX reductions are low due to the mix of sources. Detailed
results by source category are provided in Appendix C.
57
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Preceeding Page Blank
6.0 CONDUCTING AN INDEPENDENT COMPARABILITY ANALYSIS
States have the option of conducting an independent
comparability analysis to re-examine measures covered in this
report using up-to-date, State-specific information or to
evaluate control measures not included in this report. This
chapter describes the method that States may use for the
analysis. Included are procedures for determining the emission
reductions achieved by Stage II controls and the emission
reductions associated with alternative measures the State is
considering to adopt as comparable to Stage II.
6.1 COMPARABILITY DEMONSTRATIONS
To be comparable, the emissions reductions achievable
through the alternative measures must equal or exceed those
achievable by Stage II at projection year 1999. As discussed in
Chapter 2, States have some flexibility with regard to certain
aspects of their comparability determination. These items are
summarized below.
Both single measures and combinations of measures may
be considered as potential comparable measures.
States may adopt comparable NOX control measures
instead of Stage II.
VOC and NOX emissions reductions from an alternative
measure may be summed (in the manner described in
Chapter 5).
Measures may be shown to be comparable on an individual
ozone area basis or on an aggregate basis for affected
areas in the State.
Consistent data sets should be used to demonstrate
comparability. If the State elects to use its own 1990 base year
inventory instead of the 1990 Interim Inventory to project
emissions reductions for comparable measures, then to maintain
consistency, the entire demonstration should be made using the
State's inventory. Likewise, if the State uses its own inventory
to estimate reductions due to Stage II vapor recovery, then the
emission reductions associated with comparable measures should
also be estimated using the State inventory.
States may wish to substitute their own growth or control
information for the data used in this analysis. The EPA
recognizes that complete State inventories may not be available
for all areas covered under this study. States may therefore use
the Interim Inventory as the basis for demonstrating
59
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comparability of measures, substituting State-specific growth or
control assumptions. The Interim Inventory may also be used to
demonstrate the comparability of other measures not examined in
this study.
The States will have the responsibility to adequately
document the following: 1) the 1990 base year inventory for all
source categories affected by control measures used to ~
demonstrate comparability; 2) the growth factors used to project
emissions to 1999; 3) control measure assumptions for the
baseline (including Act-required measures) projection and the
control strategy (potential comparable measures) projection;
4) information on how the MOBILES model was run; 5) the expected
emissions reductions for Stage II and the comparable measures;
and 6) the equivalency of NOX reductions to VOC reductions (if NOX
control measures are used).
6.2 DETERMINING STAGE II EMISSIONS REDUCTIONS
In a State's own comparability analysis, the Stage II
emission reduction estimates may be taken directly from this
report or the State may utilize its own data to estimate VOC
emissions reductions attributable to Stage II. If a State
chooses to use its own data, the following information and
documentation should be provided:
Base year (1990) vehicle refueling emissions and
emission calculations States should follow SIP
emission inventory guidance and follow EPA-approved
methods for calculating base year emissions. The
recommended method is to apply MOBILESa emission
factors (in grams per gallon) to estimated gasoline
consumption. Alternatively, VMT-based emission factors
may be used. If the State uses the Interim Inventory
as the basis for projections, documentation is limited
to simply stating so.
Growth factors (and documentation if factors other than
BEA or E-GAS are used) for projecting activity to 1999.
If BEA or E-GAS (EPA-recommended sources) are used,
documentation is limited to simply stating this;
otherwise, documentation should be sufficient for EPA
to duplicate calculations and make a judgment as to the
acceptability of the growth factors.
MOBILESa emission factors and input files for the 1999
baseline scenario that includes mandatory controls but
not Stage II Mandatory controls affecting refueling
emissions include phase II RVP and ORVR controls
(discussed below).
60
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MOBILESa emission factors and input files for the 1999
scenario, with Stage II.
1999 projection year refueling emissions without Stage
II.
1999 projection year refueling emissions after Stage II
controls are applied.
Stage II emission reduction estimates for the
projection year.
Emission reductions for Stage II should be measured from a
future year baseline which includes the effects of ORVR. ORVR
controls should be modeled beginning in model year 1999 for LDGV
(because MOBILESa does not model phase-in for ORVR).
6.3 DETERMINING EMISSIONS REDUCTIONS FROM ALTERNATIVE MEASURES
As stated previously, States may re-examine measures covered
in this report or evaluate measures not covered by this report.
In either case, the State should clearly define the particular
measure(s) and document the methods used to estimate emissions
reductions from implementation of the measures. At a minimum,
the following information should be submitted:
Base year emissions and calculations for the source
category(s) affected States should follow EPA
guidance on the development of SIP inventories when
preparing base year emission estimates. Alternatively,
the State may use the Interim Inventory for the base
year emissions. The data selected should be consistent
with the emissions data used to estimate Stage II
emissions reductions.
Growth factors for projecting emissions to 1999. If
BEA or E-GAS (EPA-recommended sources) are used,
documentation is limited to simply stating this;
otherwise, documentation should be sufficient for EPA
to duplicate calculations and make a judgment as to the
acceptability of the growth factors.
Control assumptions for the baseline controls,
including the emission factors, control efficiency,
rule effectiveness, and rule penetration for each
source category. Documentation of MOBILESa input
should be provided if motor vehicle measures are
included.
Control assumptions for the control strategy
(comparable measure) projection, including the emission
factor, control efficiency, rule effectiveness, and
61
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rule penetration for each source category.
Documentation of MOBILESa input should be provided if
motor vehicle measures are included.
1999 projection year emissions by source category under
the mandatory Act requirements.
1999 projection year emissions by source-category after
application of comparable measures.
Estimated emissions reductions for comparable measures
calculated using the two projections above.
Calculation of VOC comparable emissions if a NOX
control measure is being substituted for Stage II. The
method for substituting NOX for VOC is given in Chapter
5 of this report. If the State uses its own inventory
data, then complete VOC and NOX inventories should be
provided in order to show equivalency of NOX measures
on a percent of inventory basis.
62
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REFERENCES
1. 59 FR 16262 "Control of Air Pollution From New Motor
Vehicles and New Motor Vehicle Engines; Refueling Emission
Regulations for Light-Duty Vehicles and Light-Duty Trucks,"
Final Rule, Federal Register. April 6, 1994.
2. "Users Guide to MOBILESa," Chapter 2, U.S. Environmental
Protection Agency, Office of Mobile Sources, Ann Arbor, MI.
March 1993.
3. "Regional Interim Emission Inventories (1987-1991) -
Volume 1: Development & Methodologies," Prepared by E.H.
Pechan & Associates, Inc., Prepared for U.S. Environmental
Protection Agency, Source Receptor Analysis Branch. May
1993.
4. "The 1985 NAPAP Emissions Inventory (Version 2); Development
of the Annual Data and Modeler's Tapes," EPA-600/7-89-012a,
U.S. Environmental Protection Agency, Air and Energy
Engineering Research Laboratory, Research Triangle Park, NC.
November 1989.
5. "State Energy Data Report Consumption Estimates 1960-
1989," DOE/EIA-0214(89), U.S. Department of Energy, Energy
Information Administration, Washington, DC. May 1992.
6. "MOBILE4.1 Fuel Consumption Model," Chapter 3, U.S.
Environmental Protection Agency, Ann Arbor, MI. January
1989.
7. "Procedures for Emission Inventory Preparation - Volume IV:
Mobile Sources," EPA-450/4-81-026d (Revised), U.S.
Environmental Protection Agency. 1992.
8. "Supplement D to Compilation of Air Pollutant Emission
Factors, Volume I: Stationary Point and Area Sources," AP-
42, U.S. Environmental Protection Agency. September 1991.
9. "Climatology of the United States," No. 81, U.S. National
Oceanic and Atmospheric Administration. September 1982.
10. "Motor Gasoline Survey," Motor Vehicle Manufacturers
Association. 1987-1991.
11. 55 FR 112 Table of RVP limits, pg. 23667, Federal Register,
U.S. Environmental Protection Agency. June 11, 1990.
12. 57 FR 13498 "General Preamble for the Implementation of
Title I of the Clean Air Act Amendments of 1990," Federal
Register. April 16, 1992.
63
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REFERENCES (continued)
13. "Technical Guidance Stage II Vapor Recovery Systems for
Control of Vehicle Refueling Emissions at Gasoline
Dispensing Facilities," Vol. 1, EPA-450/3-91-022a, U.S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
November 1991.
14. "Enforcement Guidance for Stage II Vehicle Refueling
Programs," U.S. Environmental Protection Agency, Office of
Air and Radiation. December 1991.
15. "The 1985 NAPAP Emissions Inventory: Development of
Temporal Allocation Factors," EPA-600/7-89-010d, U.S.
Environmental Protection Agency, Air and Energy Engineering
Research Laboratory, Research Triangle Park, NC. April
1990.
16. "Growth Factors from Draft MOBILE4 Fuel Consumption Model,"
memorandum to J. Wilson, E.H. Pechan & Associates, Inc., M.
Wolcott, Office of Mobile Sources, U.S. Environmental
Protection Agency. April 29, 1991.
17. 57 FR 52950 "Inspection/Maintenance Program Requirements,"
Final Rule, Federal Register, U.S. Environmental Protection
Agency. November 5, 1992.
18. 59 FR 7716 "Regulation of Fuels and Fuel Additives:
Standards for Reformulated and Conventional Gasoline," Final
Rule, Federal Register. February 16, 1994.
19. "I/M Costs, Benefits, and Impacts Analysis," (Draft), U.S.
Environmental Protection Agency. February 1992.
20. "NOX Substitution Guidance," U.S. Environmental Protection
Agency. December 1993.
21. "Rethinking the Ozone Problem in Urban and Regional Air
Pollution," National Research Council, National Academy
Press, Washington, DC. 1991.
22. 57 FR 55620 "State Implementation Plans; Nitrogen Oxides
Supplement to the General Preamble for the Implementation of
Title I of the Clean Air Act Amendment of 1990," Federal
Register. November 25, 1992.
23. "1990 BEA Regional Projections to 2040: Volume 1: States,"
U.S. Department of Commerce, Bureau of Economic Analysis,
Washington, DC. June 1990.
64
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REFERENCES (continued)
24. "Alternative Control Techniques Document - NOX Emissions
from Industrial/Commercial/Institutional Boilers," draft
chapters, U.S. Environmental Protection Agency. July 1993.
25. "Alternative Control Techniques Document NOX Emissions
from Stationary Reciprocating Internal Combustion Engines,"
EPA-453/R-93-032, U.S. Environmental Protection Agency.
1993.
26. "Alternative Control Techniques Document NOX Emissions
from Stationary Gas Turbines," EPA-453/R-93-007, U.S.
Environmental Protection Agency. 1993.
27. "Alternative Control Techniques Document NOX Emissions
from Process Heaters," EPA-453/R-93-015, U.S. Environmental
Protection Agency. 1993.
28. "Alternative Control Techniques Document Nitric and
Adipic Acid Manufacturing Plants," EPA-450/3-91-026, U.S.
Environmental Protection Agency. 1993.
65
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APPENDIX A
OZONE NONATTAINMENT CLASSIFICATIONS
-------
Table A-1. Ozone Nonattainment Classifications
Design Value*
Area Classification (parts per million)
Marginal 0.121 up to 0.138
Moderate 0.138 up to 0.160
Serious 0.160 up to 0.180
Severe-15 0.180 up to 0.190
Severe-17 0.190 up to 0.280
Extreme 0.280 and above
Submarginal - areas that violated the ozone standard during 1987-
1989 but had a design value during the period of less than
0.121 ppm (the lower limit for marginal areas) due to
adjustment for missing data when calculating expected
exceedances.
Transitional - areas designated nonattainment by operation of law
which did not violate the NAAQS for ozone during the 1987-
1989 period.
Incomplete data areas - ozone areas designated nonattainment
prior to enactment which did not have sufficient air quality
monitoring data to determine whether they were or were not
violating the NAAQS.
*EPA used 1987-89 as the primary data years in determining designations and classifications for ozone areas set forth in the
final rule on Air Quality Designations and Classifications (56FR56694, November 6, 1991).
A-1
-------
APPENDIX B
VOC EMISSION REDUCTION SUMMARIES
BY SOURCE CATEGORY
-------
Table B-1. Stationary Source VOC Control Measure Emission
Reductions by Source Category
Projection Year 1999
State Ozone Area VOC Reductions (tpd)*
Delaware
Sussex County
Dry cleaning 0.07
Bakeries 0.00
SOCMI fugitives 0.07
Pharmaceutical 0.02
manufacture 0.17
Ozone Area Total
Maine
Hancock & Waldo Counties
Dry cleaning 0.05
Ozone Area Total 0.05
Knox & Lincoln Counties
Dry cleaning 0.03
Bakeries 0.00
Ozone Area Total 0.03
Lewiston-Auburn
Dry cleaning 0.15
Bakeries 0.42
Ozone Area Total 0.56
Portland
Dry cleaning 0.47
Bakeries 0.32
Ozone Area Total 0.79
Franklin County
Dry cleaning 0.00
Ozone Area Total 0.00
Oxford County
Dry cleaning 0.01
Ozone Area Total 0.01
Somerset County
Dry cleaning 0.01
Ozone Area Total 0.01
Attainment Counties
Dry cleaning 0.15
Bakeries 0.10
Ozone Area Total 0.25
B-1
-------
Table B-1 (continued)
State Ozone Area VOC Reductions (tpd)*
Maryland
Kent & Queen Anne's Counties
Dry cleaning 0.03
SOCMI fugitives 0.04
Ozone Area Total 0.07
Attainment Counties
Dry cleaning 0.33
Bakeries 0.18
Pharmaceutical 0.00
manufacture 0.52
Ozone Area Total
New Hampshire
Manchester
Dry cleaning 0.72
Bakeries 0.05
SOCMI fugitives 0.28
Ozone Area Total 1.05
Belknap County
Dry cleaning 0.03
Bakeries 0.00
Ozone Area Total 0.03
Chesire County
Dry cleaning 0.09
Ozone Area Total 0.09
Sullivan County
Dry cleaning 0.01
Bakeries 0.00
Ozone Area Total 0.01
Attainment Counties
Dry cleaning 0.10
Pharmaceutical 0.00
manufacture 0.10
Ozone Area Total
New Jersey
Allentown-Bethlehem-Easton
Dry cleaning 0.07
SOCMI fugitives 0.02
Pharmaceutical 0.00
manufacture 0.09
Ozone Area Total
B-2
-------
Table B-1 (continued)
State Ozone Area VOC Reductions (tpd)'
Atlantic City
Dry cleaning 0.10
Bakeries 0.16
Pharmaceutical 0.10
manufacture 0.36
Ozone Area Total
New York
Albany-Schenectady-Troy
Dry cleaning 0.69
Bakeries 0.31
Pharmaceutical 0.06
manufacture 1.07
Ozone Area Total
Buffalo-Niagara Falls
Dry cleaning 0.69
Bakeries 0.53
SOCMI fugitives 0.49
Pharmaceutical 0.12
manufacture 1.82
Ozone Area Total
Essex County
Dry cleaning 0.00
Ozone Area Total 0.00
Jefferson County
Dry cleaning 0.07
Bakeries 0.00
Ozone Area Total 0.07
Poughkeepsie
Dry cleaning 0.12
Bakeries 0.02
Ozone Area Total 0.14
Attainment Counties
Dry cleaning 3.14
Bakeries 0.79
SOCMI fugitives 0.26
Pharmaceutical 0.76
manufacture 4.95
Ozone Area Total
B-3
-------
Table B-1 (continued)
State Ozone Area VOC Reductions (tpd)'
Pennsylvania
Allentown-Bethlehem-Easton
Dry cleaning 0.35
Bakeries 0.23
SOCMI fugitives 0.11
Pharmaceutical 0.01
manufacture 0.69
Ozone Area Total
Altoona
Dry cleaning 0.06
Bakeries 0.13
Ozone Area Total 0.19
Erie
Dry cleaning 0.22
Bakeries 0.08
Pharmaceutical 0.00
manufacture 0.30
Ozone Area Total
Harrisburg-Lebanon-Carlisle
Dry cleaning 0.29
Bakeries 0.32
Pharmaceutical 0.05
manufacture 0.66
Ozone Area Total
Johnstown
Dry cleaning 0.05
Bakeries 0.05
SOCMI fugitives 0.02
Ozone Area Total 0.12
Lancaster
Dry cleaning 0.18
Bakeries 0.30
Pharmaceutical 0.15
manufacture 0.63
Ozone Area Total
Pittsburgh-Beaver Valley
Dry cleaning 1.60
Bakeries 0.99
SOCMI fugitives 0.79
Pharmaceutical - 0.10
manufacture 3.48
Ozone Area Total
B-4
-------
Table B-1 (continued)
State Ozone Area VOC Reductions (tpd)1
Reading
Dry cleaning 0.29
Bakeries 0.50
Pharmaceutical 0.00
manufacture 0.79
Ozone Area Total
Scranton-Wilkes-Barre
Dry cleaning 0.43
Bakeries 0.18
Pharmaceutical 0.00
manufacture 0.61
Ozone Area Total
York
Dry cleaning 0.41
Bakeries 0.31
Ozone Area Total 0.72
Youngstown-Warren-Sharon
Dry cleaning 0.05
Bakeries 0.10
Ozone Area Total 0.16
Crawford County
Dry cleaning 0.04
Bakeries 0.01
Pharmaceutical 0.17
manufacture 0.22
Ozone Area Total
Franklin County
Dry cleaning 0.04
Ozone Area Total 0.04
Greene County
Dry cleaning 0.02
Ozone Area Total 0.02
Juniata County
Dry cleaning 0.00
Ozone Area Total 0.00
Lawrence County
Dry cleaning 0.02
Ozone Area Total 0.02
Northumberland County
Dry cleaning 0.00
Bakeries 0.17
Ozone Area Total 0.17
B-5
-------
Table B-1 (continued)
State Ozone Area VOC Reductions (tpdl*
Pike County
Dry cleaning 0.02
Ozone Area Total 0.02
Schuylkill County
Dry cleaning 0.02
Bakeries 0.03
Ozone Area Total 0.05
Snyder County
Dry cleaning 0.02
Ozone Area Total 0.02
Susquehanna County
Dry cleaning 0.00
Ozone Area Total 0.00
Warren County
Dry cleaning 0.02
Ozone Area Total 0.02
Wayne County
Dry cleaning 0.01
Ozone Area Total 0.01
Attainment Counties
Dry cleaning 0.25
Bakeries 0.39
SOCMI fugitives 0.17
Ozone Area Total 0.81
Vermont
Attainment Counties
Dry cleaning 0.57
Bakeries 0.20
Pharmaceutical 0.00
manufacture 0.77
Ozone Area Total
*NOTE: 'Zeros indicate that reductions are less than 0.01 tpd. If a source catagory is not listed for
the area, emissions for that source category are zero.
B-6
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APPENDIX C
NOX EMISSION REDUCTION SUMMARIES
BY SOURCE CATEGORY
-------
Table C-1. Utility Control Measure Emission Reductions by Source Category
Projection Year 1999
NO, Reductions (tpd)
State
Ozone Area1
RACT«»
to 25 tpy
More Stringent Control*
to 100 tpy
Delaware
Maine
Maryland
New Hampshire
New Jersey
New York
Sussex County
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
Knox & Lincoln Counties
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Ozone Area Total 0.00
Portland
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
Attainment Counties
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Ozone Area Total 0.00
Attainment Counties
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
Manchester
Utility - Pulverized Coal: Tangential 0.00
Utility Boiler - Gas 0.00
Ozone Area Total 0.00
Atlantic City
Utility - Pulverized Coal: Tangential 0.00
Utility Boiler - Gas 0.00
Ozone Area Total 0.00
Albany-Schenectady-Troy
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
Buffalo-Niagara Falls
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
21.40
0.00
21.40
0.03
0.03
4.57
0.51
5.08
0.00
0.00
2.45
2.81
5.27
0.00
0.00
0.00
1.09
0.00
1.09
8.37
8.37
33.32
10.35
43.67
C-1
-------
Table C-1 (continued)
NO, Reductions (tpd)
State Ozone Area*
Pennsylvania
Attainment Counties
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
Allentown-Bethlehem-Easton
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
Altoona
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
Erie
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
Lancaster
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
Pittsburgh-Beaver Valley
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
Reading
Utility - Pulverized Coal: Tangential
Ozone Area Total
Scranton-Wilkes-Barre
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
York
Utility - Pulverized Coal: Tangential
Ozone Area Total
Greene County
Utility Boiler - Pulverized Coal: Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
Lawrence County
Utility Boiler - Pulverized Coal: . Wall/Opposed
Utility - Pulverized Coal: Tangential
Ozone Area Total
RACT*»
to 25 tpy
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
More Stringent Control**
to 100 tpy
21.31
35.87
57.18
8.21
17.61
25.82
0.00
0.00
0.00
1.11
2.81
3.92
0.00
0.00
0.00
102.40
81.33
183.73
6.14
6.14
0.00
0.00
0.00
45.67
45.67
45.70
0.24
45.94
11.28
0.00
11.28
C-2
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Table C-1 (continued)
NO, Reductions (tpd)
State
Ozone Area*
RACT**
to 25 tpy
More Stringent Control**
to 100 tpy
Pennsylvania
Vermont
Snyder County
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
Warren County
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
Attainment Counties
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Utility - Pulverized Coal: Tangential 0.00
Ozone Area Total 0.00
Attainment Counties
Utility Boiler - Pulverized Coal: Wall/Opposed 0.00
Ozone Area Total 0.00
14.79
0.00
14.79
0.00
0.00
0.00
61.68
117.71
179.39
0.00
0.00
NOTES: *Areas not listed on the table do not have existing utility boilers.
* "Zeros indicate that no additional reductions are achieved incremental to mandatory Act requirements.
C-3
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Table C-2. Non-Utility Control Measure Emission Reductions by Source Category
Projection Year 1999
State Ozone Area*
Delaware
Sussex County
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Process Heaters - Oil
Ozone Area Total
Maine
Hancock & Waldo Counties
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Ozone Area Total
Knox & Lincoln Counties
Industrial Boiler - Residual Oil
Ozone Area Total
Lewiston-Auburn
Industrial Boiler - Residual Oil
Ozone Area Total
Portland
Industrial Boiler - Pulverized Coal
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Ozone Area Total
Franklin County
Industrial Boiler - Residual Oil
Ozone Area Total
Oxford County
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Ozone Area Total
Somerset County
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Ozone Area Total
Attainment Counties
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Ozone Area Total
NO,
RACT**
to 25 tpy
0.00
0.05
0.00
0.00
0.33
0.38
0.00
0.45
0.45
0.16
0.16
0.30
0.30
0.00
0.31
0.00
0.00
0.31
0.00
0.00
0.00
0.00
0.00
0.34
0.00
0.34
0.13
0.94
0.00
1.07
Reductions (tpd)
More Stringent
Control**
to 100 tpy
0.97
0.00
0.09
0.00
0.00
1.05
0.00
0.26
0.26
0.00
0.00
0.00
0.00
0.49
0.00
0.00
0.00
0.49
0.84
0.84
0.23
0.00
0.23
.0.17
0.00
0.17
0.00
1.77
0.00
1.77
C-4
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Table C-2 (continued)
State
Maryland
New Hampshire
New Jersey
New York
Ozone Area*
Kent & Queen Anne's Counties
Industrial Boiler - Residual Oil
Industrial Boiler - Natural Gas
Industrial Boilers - Other Oil/Gas
Ozone Area Total
Attainment Counties
Utility Boiler - Gas
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Internal Combustion Engines - Oil
Gas Turbines - Oil Fired
Ozone Area Total
Manchester
Industrial Boiler - Residual Oil
Industrial Boiler - Natural Gas
Ozone Area Total
Chesire County
Industrial Boiler - Residual Oil
Ozone Area Total
Attainment Counties
Industrial Boiler - Residual Oil
Ozone Area Total
Allentown-Bethlehem-Easton
Industrial Boiler - Residual Oil
Internal Combustion Engines - Oil
Ozone Area Total
Atlantic City
Industrial Boiler - Residual Oil
Internal Combustion Engines - Oil
Gas Turbines - Oil Fired
Ozone Area Total
Albany-Schenectady-Troy
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Ozone Area Total
NO,
RACT**
to 25 tpy
0.00
0.00
0.00
0.00
0.00
0.09
0.21
0.54
0.00
0.19
0.80
0.00
1.83
0.10
0.00
0.10
0.00
0.00
0.25
0.25
0.33
0.00
0.33
0.00
0.00
0.29
0.29
0.06
1.03
0.00
0.71
1.80
Reductions (tpd)
More Stringent
Control'*
to 100 tpy
0.00
0.00
0.00
0.00
0.00
1.31
0.00
0.00
0.00
0.00
0.78
0.00
2.09
0.00
0.00
0.00
0.00
0.00
0.63
0.63
0.15
3.14
3.29
0.00
0.00
0.00
0.00
0.00
0.66
0.00
0.28
0.94
C-5
-------
Table C-2 (continued)
State Ozone Area*
New York
Buffalo-Niagara Falls
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Natural Gas
Ozone Area Total
Essex County
Industrial Boiler - Residual Oil
Ozone Area Total
Jefferson County
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Ozone Area Total
Poughkeepsie
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Ozone Area Total
Attainment Counties
Utility Boiler - Gas
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Ozone Area Total
Pennsylvania
Allentown-Bethlehem-Easton
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Ozone Area Total
Altoona
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Ozone Area Total
NO,
RACT**
to 25 tpy
0.00
0.43
0.82
0.19
1.44
0.00
0.00
0.00
0.22
0.08
0.00
0.30
0.00
0.76
0.00
0.00
0.76
0.00
0.00
0.88
2.41
0.00
0.90
4.19
0.00
0.00
0.17
0.17
0.34
0.00
0.00
0.34
Reductions (tpd)
More Stringent
Control**
to 100 tpy.
0.35
0.00
0.50
0.43
1.27
0.44
0.44
0.21
0.00
0.00
0.00
0.21
0.00
0.00
0.00
0.00
0.00
0.00
2.83
0.00
5.22
0.00
0.17
8.22
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
C-6
-------
Table C-2 (continued)
State Ozone Area*
Pennsylvania
Erie
Utility Boiler - Gas
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Natural Gas
Ozone Area Total
Harrisburg-Lebanon-Carlisle
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Gas Turbines - Natural Gas
Ozone Area Total
Johnstown
Industrial Boiler - Stoker
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Internal Combustion Engines - Natural Gas
Gas Turbines - Natural Gas
Ozone Area Total
Lancaster
Industrial Boiler - Stoker
Internal Combustion Engines - Natural Gas
Ozone Area Total
Pittsburgh-Beaver Valley
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Internal Combustion Engines - Natural Gas
Gas Turbines - Natural Gas
Industrial Boilers - Other Coal
Ozone Area Total
Reading
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Gas Turbines - Natural Gas
Gas Turbines - Oil Fired
Ozone Area Total
NO,
RACT**
to 25 tpy
0.00
0.00
0.11
0.00
0.11
0.00
0.06
0.06
0.32
0.44
0.00
0.00
0.29
0.20
0.32
0.81
0.20
0.00
0.20
0.13
1.53
0.12
0.00
1.13
0.49
0.00
0.00
3.40
0.00
0.24
0.00
0.00
0.81
0.00
1.05
Reductions (tpd)
More Stringent
Control**
to 100 tpy
0.00
0.40
0.00
0.00
0.40
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.03
0.03
0.00
1.32
1.32
3.60
0.00
0.00
0.00
0.10
3.99
0.04
0.20
7.92
0.00
0.00
0.00
0.00
0.00
0.00
0.00
C-7
-------
Table C-2 (continued)
State Ozone Area*
Pennsylvania
Scranton-Wilkes-Barre
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Internal Combustion Engines - Natural Gas
Ozone Area Total
York
Industrial Boiler - Pulverized Coal
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Internal Combustion Engines - Natural Gas
Ozone Area Total
Youngstown-Warren-Sharon
Industrial Boiler - Natural Gas
Internal Combustion Engines - Natural Gas
Ozone Area Total
Crawford County
Industrial Boiler - Pulverized Coal
Ozone Area Total
Franklin County
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Ozone Area Total
Lawrence County
Industrial Boiler - Stoker
Ozone Area Total
Northumberland County
Industrial Boiler - Stoker
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Ozone Area Total
Pike County
Industrial Boiler - Residual Oil
Ozone Area Total
Schuylkill County
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Ozone Area Total
NO,
RACT**
to 25 tpy
0.32
0.20
0.23
0.00
0.04
0.00
0.79
0.00
0.11
0.00
0.00
0.32
0.00
0.43
0.35
0.21
0.56
0.00
0.00
0.07
0.00
0.07
0.00
0.00
0.17
0.00
0.05
0.22
0.07
0.07
0.07
0.00
0.07
Reductions (tpd)
More Stringent
Control**
to 1 00 tpy
0.00
0.00
0.00
0.00
0.00
1.21
1.21
1.10
0.00
0.00
0.00
0.00
0.41
1.51
0.24
0.96
1.20
0.30
0.30
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
0.00
C-8
-------
Table C-2 (continued)
NO, Reductions (tpd)
State
Ozone Area4
RACT**
to 25 tpy
More Stringent
Control**
to 100 tpy
Pennsylvania
Vermont
Warren County
Industrial Boiler - Stoker 0.12
Industrial Boiler - Residual Oil 0.00
Industrial Boiler - Natural Gas 0.28
Process Heaters - Natural Gas 0.30
Process Heaters - Oil 0.08
Ozone Area Total 0.79
Attainment Counties
Industrial Boiler - Pulverized Coal 0.07
Industrial Boiler - Stoker 1.35
Industrial Boiler - Residual Oil 0.00
Industrial Boiler - Distillate Oil 0.00
Industrial Boiler - Natural Gas 0.05
Internal Combustion Engines - Natural Gas 3.72
Process Heaters - Natural Gas 0.00
Process Heaters - Oil 0.00
Ozone Area Total 5.18
Attainment Counties
Industrial Boiler - Stoker 0.00
Industrial Boiler - Residual Oil 0.13
Gas Turbines - Oil Fired 0.00
Ozone Area Total 0.13
0.00
0.00
0.00
0.00
0.00
0.00
0.74
0.00
0.12
0.00
0.00
5.67
0.00
0.00
6.53
0.00
0.00
0.00
0.00
NOTES: 'Areas not listed on the table do not have existing utility boilers.
*'Zeros indicate that no additional reductions are achieved incremental to mandatory Act requirements.
C-9
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-452/R-94-011
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Stage II Comparability Study for the Northeast Ozone
Transport Region
5. REPORT DATE
January 1995
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Air Quality Strategies and Standards Division
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D3-0035
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
Work Assignment Manager - Carla Oldham
16. ABSTRACT
This document was prepared in response to section 184(b)(2) of the Clean Air Act which requires EPA
to conduct a study to identify control measures capable of achieving emission reductions comparable to
Stage II in the Northeast Ozone Transport Region (OTR). The report presents estimated emissions
reductions associated with Stage II and a variety of stationary and mobile source control measures. Both
VOC and NOx emissions reductions were evaluated. Results are given on an area-by-area basis for
moderate, marginal, and incomplete data nonattainment areas, and attainment portions of the OTR
States. Under the Clean Air Act, affected States have 1 year from completion of this study to adopt and
submit to EPA as State implementation plan revision either Stage II or a comparable measure.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Stage II, gasoline vapor recovery, refueling
emissions, comparable measure, Northeast
Ozone Transport Region, ozone, volatile
organic compounds, nitrogen oxides
Air Pollution control
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (ReOM-T3K>BSeBETE)US EDIT!
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