IMPLICATIONS OF FEDERAL IMPLEMENTATION PLANS (FIP'S)
FOR POST-1987 OZONE NONATTAINMENT AREAS
-------
-DRAFT-
IMPLICATIONS OF FEDERAL IMPLEMENTATION PLANS (FIP'S)
FOR POST-1987 OZONE NONATTAINMENT AREAS
- AN EPA STAFF REVIEW -
TECHNICAL GUIDANCE SECTION
CONTROL PROGRAMS OPERATIONS BRANCH
CONTROL PROGRAMS DEVELOPMENT DIVISION
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
ENVIRONMENTAL PROTECTION AGENCY
MARCH 1987
1100Rs-7115
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TABLE OF CONTENTS
Pre f ac e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Ta b 1 es/ Fi gu re . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Append i x. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
I.
II.
I I I.
Sum mar y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- Resource Requi rements......................................
- F I P Me a sur e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- Co n c 1 us; 0 n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Introduction. ................................................
- Study Approach.............................................
- Key Features of a FIP......................................
- Scope of the Nonattainment Problem.........................
-- Air Quality Data......................................
-- Grouping of Areas.....................................
- Background legal Issues....................................
-- Statutory Background..................................
-- EPA's Implementation of the 1977 Amendments...........
-- Federal Implementation Plans..........................
F I P Pl an n i n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- Guidance Development.......................................
-- Assumed FIP Scenario. .................................
-- Analysis of Resource and Time Requirements............
- Tr a in i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- - As s umed F I P Sc e n a r i 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Analysis of Time and Resource Requirements............
- Interaction With State and Local Agencies and Officials....
- - Ass urn e d F IPSe en a r ; 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..
-- Analysis of Time and Resource Requirements............
- Da t a Sa s e De v e'l a pm e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- - As 5 umed F I P Seen a ri 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Analysis of Time and Resource Requirements............
- Mod e 1 i n9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- - As s urn ed F IPSe en a r i o. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Analysis of Time and Resource Requirements............
- St rategy Se 1 ecti on. ..................................... ...
- - As S umed F IPSe e n a r i 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Analysis of Time and Resource Requirements............
- Pl an Dev e 10 pment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- AsslJ11ed FIP Scenario..................................
-- Analysis of Time and Resource Requirements............
- Pl an Rev i ew and Ad opt ion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Assumed FIP Scenario..................................
-- Analys~s of Time and Resource Requirements............
Page.
v
iv
A-I
1-1
1-2
1-4
1-4
II-I
11-2
11-4
11-6
11-6
11-9
11-11
11-11
11-13
11-14
111-1
II 1-4
111-8
II 1-9
111-12
II 1-13
111-14
111-15
I I 1-16
111-17
111-18
II 1-22
111-24
I I 1-25
I I 1-27
I I 1-28
111-29
111-31
111-33
111-34
111-37
II 1-38
I 11-39
111-42
111-43
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i i
TABLE OF CONTENTS
(cont.)
IV.
FIP
Implementation.......
...... .... ... ............... .... ....
- Gu i dance Deve 1 oprnent. . . . . . . . . . .. . . . . . . . . . . .. . . . . . . . . . . . . . . .
- Tra; n i n9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- Mobile Source Control Program..............................
FMVCP (Tailpipe Controls).............................
I / M Pro gram s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Gasoline Volatility...................................
- - St age I I. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Transportation Control Measures (TCM's)...............
Stationary Source Control Program..........................
Po ; n t 50 U rc e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Area Sources..........................................
Overall Program Evaluation and Audit.......................
-- Evaluation of Emissions Reductions....................
Evaluation of Air
- - Au d i tin 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- FIP Modifications and Supplemental
Qu a 1 i ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Planning.....~..........
V.
Selection of Heasures.
.. ...... .... ... ... ..... ........... .....
Introduction...............................................
- Mo del i n 9 An a 1 y s is. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . . . . . . .
- - Data[[[
- - T ran s po r t . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Role of NOx...........................................
-- Emission Reduction Targets............................
Comparison to Other Modeling Analysis.................
Emi 55 i on In ventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Description...........................................
- - Sou rc e Mi x. .. .. . . . . . . . . .. .. .. . .. . . . . . . . . . . . .. .. . . . . . . . . . . .. . . . .
Proj ect ions and Growth..................................
Defi nit i on of "Factors Used in
Description of
Implementation
Emission
- - Co st s . . . . . .. . . .. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .
Social Impacts........................................
-- Feasibil ity..............................................
Selection Process..........................................
Improvements in
Stationary
Se 1 ect i on of Measures........
Mea sure s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Da te .. . . . .. .. . . . . . . . . . .. . .. . . . . . . . . . . . . . . . . .
Red uc t ion. . . . . . .. . .. . . . . .. . . . . . .. . .. . . . . .. . . . .. . . . . .
Existing SIP Regul at ions ...................
Source RACT Regulations....................
Page
IV-l
IV-4
IV-5
IV-8
IV-8
IV-9
IV-ll
IV-12
IV-13
IV -16
IV-16
IV-I?
IV-19
IV-19
IV-21
IV-22
I V -24
V-I
V-I
V-2
V-3
V-5
V-5
V-6
V-9
V-IO
V-IO
V-ll
V-15
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i i i
TABLE OF CONTENTS
(cont.)
-- Summary of Impacts of Policy Conformity Efforts
for RAGT Regulations................................
-- New Source Review (NSR) Regulations...................
- Mobile Source Controls.....................................
-- FMVCP.................................................
-- New Tailpipe Standards. ...............................
-- Gasoline Volatility...................................
-- Vehicle Refuleing (Stage II)..........................
-- Enhanced Inspection/Maintenance (I/M) .................
-- Methanol
-- Transportation Control Measures.......................
- Stationary Source Controls.................................
-- Point Source Controls.................................
-- Area Source Emission Controls.........................
Fue 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
- Th ree Ex amp 1 e F I Pis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- Low Target Areas......................................
- - Med i urn Ta rget Ar eas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
-- High Target Areas.....................................
Page
V-32
V-33
V-38
V-38
V-39
V-40
V-43
V-44
V-46
V-49
V-54
V-54
V-76
V-91
V-95
V-95
V-96
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Table
1-1
1-2
1-3
II-I
11-2
I II-I
IV-l
V-I
V-2
V-3
V-4
V-5
V-6
V-7
V-8
V-9
V-I0
V-II
V-12
V-I
iv
TABLES
Summary of Resource Requirements.........................
Control Strategies Long-Tenn Projection..................
Three Example Control Strategies: 1992 Analysis.........
Ozone Design Values (1982-84) - 73 Metropolitan Areas....
Groupings of MSA's for Ozone Modeling....................
FIP Planning National Resource Summary...................
FIP Implementation National Annual Resource Summary......
Median NMOC/NDx Rations( 1984-1985).......................
Approximate Reduction Required in 1983 VOC Emission
Inventory to Attain Ozone National Ambient Air
Quality Standard in 73 Metropolitan Statistical
Areas> 0.12 ppm (1982-84).............................
Mix of Mobile/Nonmobile Sources in 1983 VOC Emission
Inventory 73 Metropolitan Statistical Areas
> 0.12 ppm (1982-84) Ranked by 1983 Total VOC
Inventory (1000 tons/year) .............................
VOC Emissions in 73 Metropolitan Areas - 1983............
Recommended Source Categories............................
Add i t ion a 1 So u rc e Ca t eg 0 r i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Potential Stationary Source Emission
Reductions (1000 tpy Cutoff/Category)..................
Consumer Product Sub-Categories Ranked in Order
of Average Total Emissions (for California)............
Summary of Stationary Source Impacts.....................
Three Example Control Strategies: 1992 Analysis.........
Control Strategies Long-Term Projection..................
Transportation Control Measures..........................
FIGURE
Ranking of
Measures" . . . . . . . . " " " " " " . " " " " " " . " " " " ". " . . " " " " .
Pag~
1-3
1-6
1-7
11-7
11-9
111-3
IV-3
V-4
V-7
V-12
V-14
V-54
V-58
V-66
V-82
V-90
V-93
V-97
V-98
V-22
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v
PREFACE
This report summarizes the results of a short-term study of the
resource requirements and possible control measures that would be associated
with EPA's developing and implementing Federal implementation plans
(FIP's) to achieve the ozone standard in areas which continue to be
nonattainment.
The report is intended to provide background information
that can be used in evaluating alternative responses to the continuing
nonattainment problem.
The study of FIP's has been performed "in-house" and, therefore,
does not necessarily reflect the views of State or local air agencies or
others who have historically been involved in developing and implementing
ozone control strategies.
The study has drawn on the experiences of many
of those in EPA who are or have been involved in such activities.
However,
the study was conducted over a very short time period, and was unable to
consider the specific circumstances involved in planning and implementing
control strategies in individual nonattainment areas.
Nevertheless, the
study is considered to have produced a reasonable approximation of what
resources might be required to develop and implement FIP's and what
control measures those FIP's might contain.
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1.
SUMMARY
Since many areas of the country are not expected to attain the ozone
standard by the end of 1987, the statutory deadline, EPA is examining possible
options to address this continuing nonattainment.
One approach that some
have suggested is for EPA to disapprove the State implementation plans (SIP's)
that are inadequate and develop and impl ement Federal impl ementat i on pl ani s
(FIP's) that will provide for expeditious attainment of the standard.
A
short study has been conducted to determine what the implications would be of
EPA's developing and implementing FIPls which would ensure attainment of the
ozone standard in all areas.
The primary objective of this study has been
(1) to determine the resource requirements associated with developing and
implementing FIP's and (2) to identify the types of control measures which
might be needed in the various nonattainment areas to produce attainment.
Because of the short time frame, this study has relied mostly on
II brai nstormi ng" among EPA staff fami 1 i ar with past experi ences in Federal
promulgations of plans and SIP work.
Particularly in regard to the FIP
measures or requirements, the analysis has been limited to lion hand" data;
therefore, precise con~ent of a given city's FIP needed ultimately to achieve
attainment is not presented.
However, the requi rements for the "generic"
areas (discussed in the report) are considered to provide a general indication
of the types and magnitude of measures that would be needed.
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1-2
~esource Requirements
The results of the study indicate that about 600 EPA work-years and $230
million would be needed to develop the FIP's and initiate the controls in
the post-1987 nonattainment areas.*
Most of the work-years would come from
EPA Regional Offices who would carry out most of the planning and regulation
development activities, based on guidance provided by Headquarters.
Most of
the $230 million would be for contract work to analyze alternative mobile and
stationary source controls and to establish upgraded inspection and maintenance
(11M) programs where needed.
For ongoing implementation of the FIP's, over
1,000 EPA work-years and about $220 million would be needed annually.
Again,
most of the work-years would be needed in the Regional Offices, primarily for
administration, inspection, and enforcement activities regarding the stationary
and mobile source controls.
Most of the $220 million would be needed to pay
for contractor support to administer mobile source controls, primarily 11M
programs.
Table 1-1 summarizes these FIP planning and implementation resource
requirements.
Even though this study has assumed that EPA would be responsible for
most of the planning and implementation activities regarding FIP's, a certain
level of additional work** from States has also been assumed.
About 50
additional work-years of State effort would be expected in developing the
FIP, most of that to provide an adequate data base (i .e., emission inventory).
Almost 800 work-years of State effort would be needed annually for implementing
the FIP's, most of that for monitoring and inspecting the stationary and
*The study assumed that FIP's would be needed for 60 nonattainment areas.
**The study assumed that States would continue to maintain their current
ozone program as well as other pollution control programs.
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1-3
TABLE 1-1
SUMMARY OF RESOURCE REQUIREMENTS
EPA (HQ & RO)
Othe-r-
.!'J0rk-years a ($1000)
216,500
State
Other Tota 1 b
_Work-years a ($1000) ($1000)
54 64 259.910
752 1484 314.000
.-----.-
Start-up
Annual (ongoing)
600
1006
3.930
5,020
Contractor
( $1000t
226.9~0
-------
aWork-year = 1 full-time equivalent (FTE)
bAssumes 1 work-year = $50.000
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1-4
mobile source controls.
Local agencies, too, along with other State agencies
(e.g.. OaTis) would play important roles in the development and implementation
of the Flp.s.
Resource requirements for these agencies have not been estimated,
although the importance of their participation is discussed in the report.
The additional State air agency resource requirements are also summarized in
Tabl e 1-1.
FIP Measures
The study has examined those control measures that would most likely be
included on a "menu" of measures to be considered for any FIP.
To ill ustrate
the range of control strategies that could result from FIP.s, the study has
characterized three "generic" areas:
one, a nonattainment area with a
relative\y low emission reduction requirement; one, with a moderate requirement;
and one, with a high emission reduction requirement.*
Control measures have
been assigned to these areas based on the emission reduction requirements and
the emission reduction -potentials of the measures.
Table 1-2 illustrates which
measures would be needed in the three "generic" areas to achieve attainment
as expeditiously as practicable.
The study has also examined the implications
for control if attainment in the near-term (1992 assumed) is required in all
areas.
Measures needed for near-term attainment are shown in Table 1-3.
The measures needed for attainment in areas requiring low emission
reductions would be readily available and would rely significantly on existing
programs [e.g., the Federal Motor Vehicle Control Program, improvements to
existing reasonably available control technology (RACT) rules, etc.].
Some
additional stationary source categories would also be regulated.
For areas
*Emission reduction requirement refers to the percent reduction in VOC
emissions needed to.attain the ozone standard.
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1-5
needing medium or high emission reductions, a number of new measures
would be required which could be expensive and have substantial social
impacts.
For example, for both medium and high reduction areas, additional
transportation control measures (TGM's) such as a substantial gas tax
(say, $2 to $3 per gallon) and a vehicle use tax (say, $1000 per year per
second family car) would be required.
The high reduction areas would
also need tighter tailpipe standards and programs to promote vehicle
fleets to convert from using gasoline to using methanol.
Stationary source measures in all three areas could also have
substantial impacts.
In all areas, major restrictions (such as high
offset requirements) would apply to new sources planning to locate there.
In medium and high reduction areas, all existing regulations would be
tightened to the extent possible (i .e., to the level achieved anywhere in
the county); many consumer products (residential paint, household cleaners,
personal care products, etc.) would have to be reformulated to eliminate
or greatly reduce the use of VOG's as solvents or propellants; and in the
high reduction areas, major industrial facilities (e.g., petroleum
refineries) might have to be relocated out of the nonattainment area.
A requirement for near-term attainment (e.g., 1992) would force
severe requirements on medium and high reduction areas.
Gas rationing
programs would be required to reduce travel by 25 to 50 percent.
A
greater number of industrial VOG emitters would probably have to be
relocated out of the nonattainment area.
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1-6
Conclusions
This short study of the implications of FIP's has indicated that a
considerable resource burden would be placed on EPA to develop and implement
the pl ans.
A significant number of additional work-years of effort would be
needed mostly at the Regional level.
State responsiveness or reluctance
to support EPA efforts in implementing a promulgated FIP (different from that
assumed in this study) could substantially change the overall resource require-
ments.
Additional funding would be needed to support the required contractor
work.
The measures which might be needed to achieve near-term attainment appear
feasible for the areas which would have low emission reduction requirements,
but the type and number of measures needed in the IImoderatell and IIhighll areas
could produce significant social and economic impacts.
Measures in the latter
two areas would call for a significant expansion of direct Federal involvement
in many decisions traditionally made at the State and local level (e.g.. land
use planning).
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1-7
TABLE 1-2
CONTROL STRATEGIES
LONG-TERM PROJECTION
Potential Attainment Year:
Measures
Mobile Sources and Related
- FMVCP + I/M (without VMT growth)
- VMT growth
- Gasoline volatility
- Enhanced I/M
- Onboard
- TCM's (up to 40% VMT red.)
- Tighten tailpipe standards
- Methanol fleet conversions
(50% of fleet, 80% reduction)
Net, mobile sources
Stationary Sources
- Implement & clean up existing rules
- New point source control
(new CTG's, TSDF's, etc.)
- Revisit/tighten existing regs. to
most stringent levels in country
- Area sources
-- consumer products-control or ban
up to 50% ..
-- commercial solvents-control or ban
up to 50%
- Relocation of major emitters (petro.
refine, large printing plants, etc.)
- t1aj or energy conservation measures
(solar water heating, etc.)
- Restrictive NSR (ban net, high
offsets)
- Gasoline storage, marketing,
refining due to VMT reduction
- New source growth
- Existing source growth
Net, stationary sources
TOTAL REDUCTIONS
Approximate Emission Reductions
by Nonattainment Area Type
Low (25%)
1995
Medium (50%)
2000
28%
- 6%
8%
30%
- 8%
8%
2%
2%
4%
30%
38%
4%
5%
4%
6%
3%
4%
3%
4%
2%
- 3%
- 4%
-s%
- 4%
- 7%
12%
35%
50%
Hi gh (75% L
2010
30%
-13%
8%
2%
2%
8%
3%
6%
46%
6%
6%
6%
7%
4%
3%
2%
11%
4%
- 8%
-12%
20%
75%
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1-8
TABLE 1-3
THREE EXAMPLE CONTROL STRATEGIES:
1992 ANAL YS IS
Prescribed Attainment Year:
Measures
Mobile Sources & Related
- FMVCP + I/M (without VMT growth)
- VMT growth
- Gasoline volatility
- En hanced I/M
- Stage II
- TCM's (gas rationing with 25-50%
vtn reduction)
Net. mobile sources
Stationary Sources (point and area)
- Implement and clean up existing rules
- New point source control
(new CTG's. TSDF's. etc.)
- Revisit/tighten existing regs. - most
stringent level in county - incinerate/
convert all solvents at stationary
sources
- Area sources ban or convert up to
50% of all consumer products
with VOC solvents (house paints, etc.)
- Relocation of major emitters (petro-
refineries, large printing and auto
plants)
- Restrictive NSR (ban netting, high offsets)
- Gasoline storage, marketing.
refining (due to gas rationing)
- New source growth
- Existing source growth
Net. stationary sources
TOTAL REDUCTIONS
Low
(up to 25%)
1992
25%
- 5%
8%
28%
4%
5%
2%
- 2%
- 3%
6%
34%
Me d i urn
(25-50%)
1992
25%
- 5%
8%
2%
2%
5%
37%
4%
6%
3%
3%
2%
3%
- 2%
- 3%
16%
53%
High
(50-75%)
1992
25%
- 5%
8%
2%
2%
10%
42%
4%
6%
6%
6%
7%
3%
5%
- 2%
- 3%
32%
74%
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II.
INTRODUCTION
This study brings together in one document what EPA believes the
implications would be of developing and implementing ozone Federal
implementation plans (FIP's) in all areas that will fail to attain the
national ambient air quality standards (NAAQS) by 1987.
The study identi-
fied those activities which would be expected to occur in developing and
implementing FIP's.
The activities identified and discussed in this
report are considered to be necessary to ensure that technically and
legally sound ozone control strategies would be developed.
The study also examines measures that could be included in FIP's for
various nonattainment areas.
The study presents the likely content of
three "generic" areas, which indicate the range of control measures that
might be required.
In determining the likely FIP rates, the analysis has
been limited to data "on hand"; therefore, precise content of a given
city's FIP needed to show attainment is not presented.
However, the
staff feels that the general nature of the example FIP's are certainly in
the "ball park" of what will be required to attain.
The remainder of this introductory chapter discusses the study
approach, key features of the FIP, the scope of the nonattainment problem,
and the background legal issues related to FIP's.
Chapter III describes
the major planning activities and associated resource requirements involved
in developing the FIP's.
Similarly, Chapter IV describes the activities
and resource requirements of implementing the FIP's.
Chapter V illustrates
the types of control measures that could be included in FIP's and control
strategies for three example areas.
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11-2
Study Approach
The study approach has primarily been "brai nstormi ng" among EPA
staff to assemble EPA's knowledge and experience in all aspects of air
quality management plans.
The vast majority of this experience is in the
area of State implementation plans (SIP's) with some 1 imited experience
with past Federal promulgations.
The limited time for this FIP assessment
has not allowed for specific surveys or updating of city-specific data
bases.
A limited number of interviews with EPA staff having prior FIP
experiences have been conducted.
While there are two general ways that ozone nonattainment problems
can be addr~ssed, an air quality management (AQM) approach or a technology
approach, there is a significant constraint EPA must follow in developing
FIP's.
The FIP must be able to provide an adequate level of assurance
that the NAAQS will be attained by some specified date.
The AQM approach
utilizes a modeling demonstration that predicts the level of emissions
reduction necessary to allow attainment of the ozone NAAQS at a future
date.
As long as the necessary emissions reduction as prescribed by the
model is achieved by the designated date, a FIP is considered adequate
to achieve attainment of the NAAQS.
Generally, the emissions reduction
required will not be more than predicted by the model.
However, in the
more severely polluted areas, there may be little if any potential emission
reductions left untouched.
The technology approach on the other hand does not necessarily
involve modeling.
Emissions reduction requirements are specified based
on various criteria with the belief that either attainment or significant
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II-3
progress toward attainment will be achieved.
After actual monitoring is
accomplished, another round of emissions reductions may be necessary if
attainment has not yet occurred.
The real advantage of the technology
approach is that much of the resource-intensive planning phase can be
avoided.
Data base development and modeling are not necessary.
Howeve r ,
the work to successfully select and promulgate measures may be even
harder without the modeling.
To a limited degree, EPA believes that there should be a blend of
these two approaches.
If the many moderate and highly polluted areas are
to attain the NAAQS within a reasonable time frame, the best technology
that is reasonably available (RACT) must be required for all areas.
To accomplish this, EPA would prescribe at minimum a "common" set of
measures for these areas.
Additional measures would then be applied in
each area for attainment as indicated by modeling.
In summary, the AQM approach and the blend with the technology
provide that level of assurance, or prediction, that the NAAQS will be
attained by a certain date without an unknown number of iterations of
emissions reduction requirements.
The FIP process must have this type of
assurance to be legally defensible.
The study of FIP's is based on several assumptions, both legal and
practical.
From a legal perspective, the FIP for all areas must require
attainment with the NAAQS as expeditiously as practicable and by a date
certain.
For practical reasons, it is assumed that EPA will be primarily
responsible for developing the FIP with various levels of coordination
with State and local officials.
It is assumed that States will share
some of the implementation of the FIP after it is promulgated.
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11-4
Key Features of a FIP
Federal implementation plans, though developed and promulgated by
EPA, are structured much like State implementation plans (SIP's).
FIP's,
like SIP's, would be designed to bring nonattainment areas into attainment
with the NAAQS by requiring reductions in emissions of volatile organic
compounds (VOC's).
Such reductions would be at least equal to reasonably
available control technology (RACT) level and specified in federally
enforceable emissions limiting regulations.
The test to assure that
sufficient regulations are applied is expeditious attainment of the NAAQS
by a certain date.
The same models used in SIP's, either city-specific
empirical kinetic modeling approach (EKMA) or a photochemical grid dispersion
model such as Airshed, would be used in FIP's.
Additionally, the existing
SIP rules that are federally enforceable will remain in effect and would
complement the new Federal promulgations.
The FIP's would rely on a VOC emissions reduction approach.
Nitrogen
oxides (NOx) control to supplement available VOC control would be considered
in nonattainment areas where NOx emissions regulation would be a necessary
addition to VOC emission control in order to show attainment of the
standards.
A more detailed discussion of the utility of NOx control
will be discussed in Chapter V of this document.
Legal defensibility is an important criterian to follow in designing
a FIP.
These FIP's would be very controversial and subject to immense
public debate.
First, to assure that a FIP could stand the test of a legal
challenge, the foundation or data base on which it is constructed must be
the best possible.
This data base (emission inventory, air quality, and
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Il-5
meteorology) must be complete and up to date.
As discussed later, EPA
would expend considerable effort and resources to assure that these data
bases are reasonably beyond question.
This effort would include extensive
"real world" data gathering, not merely performing paper analyses such as
an emissions inventory based on "national data" currently on hand.
The
strategy should be conservative in order to ensure the highest probability
of attaining the NAAQS.
This conservativeness could be achieved through
a combination of the number and/or stringency of various control measures.
FIP's that are marginal in the demonstration would not likely sustain a
1 egal chall enge.
Regarding the predicted attainment date, the FIP must
contain a realistic approach to the compliance schedules imposed on
sources.
Compliance schedules should be ambitious, even though this could
involve a certain degree of "technology forcing."
However, a FIP that
relies too greatly on "technology forcing" schedules may not reach attain-
ment as predicted because of the uncertainty associated with such schedules.
Experience suggests that this has been a problem with past SIP's.
A more
conservative approach to schedules should be balanced with "technology
forcing" approach in FIP's.
Scope of the Nonattainment Problem
Ozone is produced through a combination of hydrocarbons, nitrogen
oxides (NOx) and conducive meteorological conditions such as sunlight and
high temperatures.
Most of the major population centers in the country
do not meet the current ozone standard.
The nonattainment problem is
most severe in Los Angeles, the "Northeast Corridor" (from Washington to
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II-6
Boston), Houston", Chicago, San Diego and Oxnard-Ventura, CA.
These and
other cities are not likely to attain the standard for years, perhaps
decades.
Air Quality Data - The ambient standard of 0.12 ppm is violated when
the number of exceedances (values greater than 0.12) is greater than one
per year, averaged over the latest 3 years and adjusted for missing data.
Because one exceedance per year is allowed, the fourth highest value over
3 years is an important indicator of attainment.
This value is typically
called the ~design value.~
During the period 1982-1984, 73 metropolitan areas violated the
ozone standard.
Design values and the number of exceedances per year are
listed for these areas in Table II-I.
Thirty-three of these 73 areas
fall in the marginal (design values of 0.13-0.14 ppm) range.
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1I-7
TABLE 11-1
OZONE DESIGN VALUES (1982-84) - 73 METROPOLITAN AREAS
DESIGN
VALUE EXPECTED
(PPM) EXCEEDANCES
NAME OF MSA OR CMSA*
(Ranked by Design Value)
1 LOS ANGELES-LONG BEACH,CA
2 HOUSTON,TX
3 GREATER CONNECTICUT#
4 NEW YORK,NY
5 BEAUMONT-PORT ARTHUR,TX
6 OXNARD-VENTURA,CA
7 SAN DIEGO,CA
8 CHICAGO,IL
9 ATLANTIC CITY
10 BOSTON
11 NEW BEDFORD,MA
12 SPRINGFIELD, MA
13 PHILADELPHIA,PA-NJ
14 A TLA NT A ,GA
15 BAL TIMOR E ,MD
16 BATON ROUGE,LA
17 EL PASO, TX
18 GALVESTON-TEXAS CITY,TX
19 MILWAUKEE,WI
20 SAN FRANCISCO,CA
21 ST LOUIS,MO-IL
22 BAKERSFIELD,CA
23 DALLAS-FT WORTH,TX
24 FRESNO,CA
25 PROVIDENCE,RI
26 SACRAMENTO,CA
27 WASHINGTON,DC-MD-VA
28 ALLENTOWN-BETHLEHEM, PA-NJ
29 BIRMINGHAM,AL
30 CINCINNATI,OH-KY~IN
31 LAKE CHARLES,LA
32 LONGVIEW-MARSHALL,TX
33 LOUISVILLE,KY-IN
34 MODESTO,CA
35 NEW ORLEANS,LA
36 PHOENIX,AZ
37 PORTLAND,ME
38 SALT LAKE CITY-OGDEN,UT
39 SANTA BARBARA-SAN MARIA-LOMPOC,CA
40 VISALIA-TULARE-PORTERVILLE,CA
41 BRAZOR lA, TX
42 CLEVELAND,OH
43 DENVER,CO
0.36
0.25
0.23
0.23
0.21
0.21
0.21
0.20
0.19
0.19
0.19
0.19
0.18
0.17
0.17
0.17
0.17
0.17
0.17
0.17
0.17
0.16
0.16
0.16
0.16
0.16
0.16
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.14
0.14
0.14
139.6
11.9
32.8
34.4
5.4
50.4
8.9
7.0
9.7
9.7
9.7
9.3
10.7
6.1
8.4
1.4
18.9
9.6
5.4
3.9
8.6
22.5
9.4
20.5
10.2
11.8
7.1
4.7
2.5
3.3
2.5
1.1
9.1
14.4
3.5
4.2
7.2
3.0
2.5
33.1
3.2
3.6
3.8
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II-8
TABLE 11-1 (CONT.)
OZONE DESIGN VALUES (1982-84) - 73 METROPOLITAN AREAS
NAME OF MSA OR CMSA*
(Ranked by Design Value)
DESIGN
VALUE EXPECTED
(PPM) EXCEEDANCES
44DETROIT,MI 0.14
45 HUNTINGTON-ASHLAND,WV-KY-OH 0.14
46 KANSAS CITY,MO-KS 0.14
47 LANCASTER,PA 0.14
48 MUSKEGON,MI 0.14
49 PITTSBURGH,PA 0.14
50 RICHMOND-PETERSBURG,VA 0.14
51 SAN ANTONIO,TX 0.14
52 VINELAND-MILLVILLE-BRIDGETON,NJ 0.14
53 WORCESTER,MA 0.14
54 AKRON,OH 0.13
55 CANTON,OH 0.13
56 CHARLOTTE-GASTON lA-ROCK HILL,NC-SC 0.13
57 CHATTANOOGA,TN-GA 0.13
58 DAYTON-SPRINGFIELD,OH 0.13
59 ERIE,PA 0.13
60 GRAND RAPIDS,MI 0.13
61 HARRISBURG-LEBANON-CARLISLE,PA 0.13
62 INDIANAPOLIS, IN 0.13
63 MEMPHIS,TN-AR-MS 0.13
64 MIAMI-HIALEAH,FL 0.13
65 NASHVILLE, TN 0.13
66 PORTSMOUTH-DOVER-ROCHESTER,NH-ME 0.13
67 READ I NG, PA 0.13
68 SCRANTON-WILKES BARRE,PA 0.13
69 STOCKTON,CA 0.13
70 TAMPA-ST PETERSBURG-CLEARWATER,FL 0.13
71 TULSA,OK 0.13
72 VALLEJO-FAIRFIELD-NAPA,CA 0.13
73 YORK,PA 0.13
2.9
4.9
2.0
3.6
3.0
2.9
2.6
1.3
4.1
2.4
2.1
1.5
1.7
1.6
3.4
1.4
1.3
1.7
2.5
1.6
1.1
1.3
2.0
3.1
1.3
1.8
1.4
2.5
1.4
1.7
*CMSA means Consolidated Metropolitan Statistical Area
#Greater Connecticut includes: Hartford, Middletown, New Britain,
New Haven, Meriden, New London, and Norwich, Connecticut.
Design Value is the fourth highest value measured during three complete
years of data. If less than three complete years are available, the
second or third highest is the design value. Most sites have three
complete years of data. Data were measured locally and have not been
adjusted for transport considerations.
Expected Exceedances are the average number of times the standard was
exceeded per year during the 3-year period, adjusted for incomplete
data.
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II-9
Grouping of.Areas - Metropolitan areas sharing a common design value
are grouped according to Table 11-2.
In the past. SIP's for these areas
have utilized a single design value and modeled reduction target.
It is
assumed that FIP's would follow the same groupings.
These groupings do not coincide with the CMSA groupings defined
by the Office of Management and Budget (OMB).
For example. Oxnard-Ventura
is in the Los Angeles CMSA. but it is not grouped with Los Angeles in
Table II-2.
These two areas have traditionally submitted separate SIP's
using separate design values.
TABLE 11-2
GROUPINGS OF MSA'S FOR OZONE MODELING
Bo s ton
Metropolitan Area
Boston. MA
Brocton, MA
Lawrence-Haverhill, MA-NH
Lowell, MA-NH
New Bedford, MA
Pawtucket-Woonsocket-Attleboro,
RI-MA
Greater
Connecticut Metropolitan Area
Ha rt ford, CT
Middletown, CT
New Britain, CT
New Haven-West Haven, CT
New London-Norwich, CT-RI
New York Metropolitan Area
Bergen-Passaic, NJ
Jersey City. NJ
Middlesex-Somerset-Hunterdon. NJ
Naussau-Suffolk, NY
New Brunswick-Perth Amboy-Sayreville, NJ
New York. NY-NJ
Newark, NJ
Bridgeport, CT
Danbury, CT
Stamford, CT
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11-10
TABLE 11-2 (cont.)
Philadelphia Metropolitan Area
Philadelphia, PA-NJ
Trenton. NJ
Wilmington, DE-NJ-MD
Miami Metropolitan Area
Miami, FL
Ft. Lauderdale-Hollywood, FL
West Palm Beach-Boca Raton, FL
Cincinnati Metropolitan Area
Cincinnati, OH-KY-IN
Hamilton-Middletown, OH
Chi cago
Metropolitan Area
Chicago, IL
Gary-Hammond-East
Jol iet, IL
Kenosha, WI
Lake County, I L
Racine, WI
Ch i c ago, IN
Milwaukee Metropolitan Area
Milwaukee, WI
Sheboygan, WI
Los Angeles Metropolitan Area
Los Angeles-Long Beach, CA
Anaheim-Santa Ana-Garden Grove, CA
Riverside-San Bernardino-Ontario, CA
San Francisco-Oakland Metropolitan Area
Oakland, CA
San Francisco, CA
San Jose, CA
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Il-ll
Background Legal Issues
This section of the introductory chapter describes the legislative
history for air quality planning, EPA's recent experiences regarding SIP
calls in light of CAA schedules and requirements, and general experience
and legislative references to FIP's.
Statutory Background - The Clean Air Act includes two sets of
requirements on air quality planning.
The basic blueprint of requirements
is contained in section 110, which Congress enacted in 1970.
It provides
that, within 9 months of EPA's promulgation of an NAAQS, the States are
to submit SIP's containing, among other things, enough control measures
to provide for attainment of the NAAQS as expeditiously as practicable,
but within 3 years of EPA's approval of the SIP [section 110(a)(2)(A)].
It also provides that areas that cannot demonstrate attainment of the
standard within 3 years using all reasonably available control technology
may obtain an extension of up to 2 years [section 110(e)].
Section
110(a)(2)(H) provides that each SIP must contain a provision requiring
the State to revise the approved SIP in the event EPA finds that the plan
is "substantially inadequate" to attain the standards.
Finally, section
110(c) requires EPA to promulgate FIP's for areas for which the States
have failed to submit adequate plans under section 110(a), as well as for
areas for which the States do not respond adequately to calls for SIP
revisions under section 110(a)(2)(H).
Despite the planning that occurred under these provisions from 1970-
1977, many areas still did not attain the standards by the applicable
dates.
For that reason, Congress enacted a second blueprint as part of
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11-12
the Clean Air Act Amendments of 1977.
It added a new section llO(a) (2) (I) .
which required each State to insert into its SIP, for each area designated
as exceeding the NAAQS ("nonattainment area"), a construction ban that
would apply after mid-1979 in the event the SIP did not meet the requirements
of the new Part D of the Act.
Part D requires the SIP's for nonattainment
areas to provide for attainment "as expeditiously as practicable" but no
later than the end of 1982 (for "nonextension areas") or, in the case of
certain areas with especially difficult ozone and carbon monoxide (CO)
problems, the end of 1987 ("extension areas")*.
The States were to submit
SIP's by 1979 ("1979 SIP's") for all nonattainment areas and were to
submit a second installment in 1982 ("1982 SIP's) for areas with a 1987
target date.
Part D also requires these SIP's to contain all "reasonably available
control measures" and show "reasonable further progress" toward attainment
in the interim before the applicable attainment date.
Beyond that,
Congress in section 176(a) required EPA to impose restrictions on Federal
funding of highway and State air grant programs in the event EPA determines
that a State is not making reasonable efforts to submit an adequate Part D
plan.
Finally, it provided in section 316(b) that EPA could restrict
Federal funding of certain sewage treatment construction in the event a
State does not submit an adequate Part D plan accounting for emissions
resulting indirectly from the planned increase in sewage treatment
capacity.
*For a list of extension areas, see 48 FR 4972, February 3, 1983.
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11-13
EPA's Implementation of the 1977 Amendments - On July 2, 1979, EPA
promulgated the section 110(a) (2)(1) construction ban into all of the
SIP's because no State's 1979 plan had received EPA approval.
See 40 CFR
52.24 (1986).
Thereafter, EPA 1 ifted the ban in each area as its 1979
SIP did receive approval.
The 1979 ozone and CO SIP's for most areas
ultimately received either full or conditional approval and thereby
escaped the construction ban.*
Later, EPA approved the 1982 plans for
many extension areas and thereby withheld the section 110(a)(2)(I)
construction ban.
The EPA did not promulgate a Federal ozone or CO plan
for any area.
Despite their approved plans, many nonextension areas did not actually
attain the standards by the end of 1982.
The EPA published a policy on
November 2, 1983, stating that it would issue SIP calls to many of these
areas under section 110(a)(2)(H) and require them to revise their plans.
The EPA also promulgated a rule providing that areas with fully approved
Part D plans had discharged their obligations under Part 0 and, hence,
could no longer be subject to the section 110(a)(2)(I) construction ban.
By its policy and this rule, EPA suggested that the new planning in these
areas would be governed by the basic planning blueprint in section 110
instead of Part D.
Rather than specifying a single new attainment date
for nonextension areas receiving SIP calls, EPA stated that the
*In some cases, the States' submittal of adequate plans occurred only
after EPA had imposed the additional sanctions provided by sections
176(a) or 316(b).
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11-14
revised plans for these areas should provide for attainment as expeditiously
as practicable.
The EPA issued a series of SIP calls to nonextension areas in 1984
and 1985.
Most of the affected States have submitted new SIP revisions
in response to the calls and those plans are now awaiting EPA action.
In addition, the 1982 plans for some extension areas still have not
received EPA approval.
The EPA has disapproved some of those plans and
imposed the section 110(a)(2)(I) construction ban in the affected areas
(e.g., for CO in Phoenix and Albuquerque*).
It has not acted yet on the
other submittals (e.g., for ozone and CO in Los Angeles and Chicago).
It is likely that many extension areas with approved Part D plans
will not attain the standards by the end of 1987.
For these areas, EPA
may issue calls for revised SIP's providing for attainment of the standards
by some date after 1987.
Federal Implementation Plans - The EPA historically has promulgated
Federal plans for areas with disapproved SIP's only as a last resort.
Generally, the EPA first imposes sanctions--the section 110(a)(2)(I)
construction ban, followed by the section 176(a) sanctions and, in some
cases, the section 316(b) sanctions--in the belief that Congress created
the sanctions expressly as a means to induce the creation of State plans
and thereby avoid Federal intervention in areas traditionally left to
local management.
-------
*In Albuquerque, EPA has also imposed the section 176(a) sanctions and
proposed to impose the section 316(b) sanctions.
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II-IS
If a State failed to prepare and submit an acceptable SIP revision,
even after the pressure of sanctions had been applied, EPA was required
to promulgate a Federal plan (FIP).
Section 110(c)(I) describes what FIP's must contain.
It states
that, under certain circumstances, the Administrator must publish
regulations IIsetting forth an implementation plan, or portion thereof,
for a Statell unless the State adopts a plan IIwhich the Administrator
determines to be in accordance with the requirements of this section.1I
It is apparent from these passages that EPA must promulgate into FIP's
only those provisions necessary to meet the requirements of section 110
and possibly nothing more stringent.
The question, then, is what section 110 requires implementation
plans to contain once 1987 passes.
Since a critical element of any
implementation plan is the date by which the control measures must bring
about attainment, a threshold issue is what attainment date would apply
to these areas in a new, post-1987 round of planning under section 110.
Areas whose Part 0 SIP's have not .yet received EPA approval are
still subject to the section 110(a)(2)(I) requirement for Part 0 plans.
Since the 1987 deadline in Part 0, however, could not plausibly govern
. p1 anning after 1987, it is necessary to decide what other date Congress
would have intended to apply had it considered this situation when it
enacted Part O.
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II-16
Similar gap-filling is necessary to determine the attainment date
for areas whose Part 0 SIP's have already received approval but have
since been found inadequate.
The EPAls current position is that these
areas are no longer subject to Part O.
Hence, FIP's promulgated upon
inadequate State responses to SIP calls would be measured against the
attainment date requirements of the basic section 110 blueprint.
Arguab ly,
these plans would be subject to the requirement of section 110(a) (2)(A)
that plans provide for attainment "in no case later than 3 years from the
date of approval of such plan. . . ," with a possible extension of 2 years
under section 110(e).
On the other hand, these periods appear to apply
only to the initial SIP's and FIP's that were required in response to
EPA's initial promulgation of the ozone and CO NAAQS in the early 1970's.
If so, it is necessary to decide what period Congress would have intended
to apply to these areas this far along in the planning process.
The EPA is analyzing several possible views as to what Congress
would have intended in these circumstances.
One view is that Congress'
selection of fairly short, fixed periods in both section 110(a)(2)(A) and
Part 0 indicates that it would have intended EPA to apply a similarly
short period in post-1987 planning, whether under Part 0 or section 110.
Another argument is that, if Congress had known what EPA has learned from
its experience in implementing Part O--that fairly burdensome, perhaps
draconian, measures may be necessary to attain in many metropolitan areas--
it would have intended to apply longer periods for such areas.
In that
event, Congress might have chosen a long, but fixed, period, for the
worst areas so as to assure comprehensive planning with at least some
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II-17
degree of technology-forcing.
Or it might have opted to apply only the
requirement for attainment lias expeditiously as practicable," without any
fixed date for areas for which practicable attainment by any fixed date
were unforeseeable.
To inform the debate on post-1987 planning within
and outside EPA, this report examines the types of control measures that
EPA would need to be included in FIP's under both the short- and long-
term attainment date scenarios.
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III.
FIP PLANNING
The general procedure that would most likely be followed in the
development of Federal implementation plans (FIP's) involves a shared
role for EPA Headquarters and Regional staff.
The EPA Office of Air and
Radiation would provide overall guidance, coordination, and final approval
and the Regional Offices taking the lead developing the specific area
FIP's.
Such an arrangement of central guidance and decentralized plan
development has worked well with regard to SIP's where the States have
had the lead responsibility to actually develop the plans.
The central i zed
guidance development and coordination will also result in less resources
expended in FIP development and more consistent and equitable emission
reduction strategies.
However, there needs to be a proper balance between national
,
consistency and appropriate measures applied to local problems.
Thi s is
best done by EPA offices that are closer to the problem.
The EPA Regi onal
Offices can tailor the strategy for each area as they work with local
sources, officials, and interest groups.
Legal defensibility and
strategy credibility are more likely to be achieved when these activities
are properly and effectively carried out.
In addition. a practical
consideration is that there must be a distribution of the work load if
many areas need FIP's developed simultaneously.
The EPA Regions, with contract ural assistance. would perform all of
the FIP developmental work, conduct necessary "interactions." draft
regulations and plan documentation, hold public hearings, and prepare
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111-2
Federal Register packages for publication.
There is a general assumption
that EPA would have to promulgate the FIP, but in the development phase
EPA would solicit input from State and local agencies especially where
these agencies may be later involved in the implementation phases of the
FIP's.
The major activities in developing a FIP would be similar to the
steps which occur under SIP-based programs.
These activities include the
following:
(1) development of procedural and technical guidance; (2)
training of air agency and other staff; (3) interaction and coordination
among the agencies involved in planning and implementing the plan
requirements; (4) development of appropriate data bases, primarily emission
inventories and air quality monitoring data; (5) analytical modeling of
the ozone problem to determine the emission reduction requirement; (6)
identification and evaluation of alternative measures and selection of a
control strategy; (7) development of the actual plan, including a
demonstration of attainment and any regulations needed; and (8) providing
opportunity for review and comment on the plan and then adoption by
appropriate authorities.
These activities and their associated resource
requirements under a FIP scenario are discussed below.
Each planning
activity is described and then followed by a discussion of the assumptions
for the FIP scenario.
Following this discussion is the analysis and
estimate of resource requirements for each activity.
A summary of the
resource requirements is given in Table III-I.
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I II-3
TABLE III-1
FIP PLANNING
NATIONAL RESOURCE SUMMARY*
EPA Requirements
St ate Time
HQ RO Contractor Other costs requirements requi rements
Act i vity (work-yrs) (work-yrs) _-L$OOO) - _J $000)__- (work-yrs, $000) (months)
o Develop guidance 30 1 5,000 10 1 6-9
o Training 2 1 150 50 1 , $50 6-9
o Interaction with State 1 90 2,000 12
and local agencies and
officials
0 Data base development 1 60 5,640 500 30 9-12
o Modeling 5 30 200 1,000 3-12
o St rategy selection 5 80 8,500 9-12
o Plan development 2 60 4,500 100 9-12
o Plan review and 30 176 1,500 200 15 12-18
adoption ---- -- ---- ----
TOTAL 76 498 25,490 3,860 47 , $50 (not
additive)
*Based on a total of 60 FIP's.
Fractions have been raised to the nearest whole number.
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II 1-4
Guidance Development
Historically, one of the first steps in a State implementation
plan (SIP)-based approach to implementing a new control effort has been
for EPA Headquarters to develop appropriate guidance for States and EPA
Regional Offices to follow in preparing and reviewing plans containing
the new requirements.
This gudiance has been to provide technical assistance,
promote consistency among control plans, and ensure (as best as possible)
that the resulting plans were able to achieve the desired objectives.
Under a FIP scenario, guidance would still be needed for the same reasons;
however, the "audience" for the guidance would generally be EPA Regional
Offices and, to a much lesser degree, States in some cases.
Additional
guidance (discussed later) would also be needed to assist Regional Offices
and State agencies in implementing the requirements of the FIP's.
Guidance would be needed in the following areas of plan development:
(1) procedures and schedules to follow in developing the plan and
administering sanctions; (2) data bases, analyses~ and other technical
content regarding the evaluation of the ozone problem and the determination
of corrective or additional measures needed; and (3) the form of the FIP,
including appropriate documentation of the plan's technical and legal
soundness.
The FIP guidance would build on existing SIP guidance where
possible, but considerable new guidance would be needed regarding the
administration of sanctions and the evaluation of various control measures.
Also, FIP guidance would be needed to ensure that up-to-date policies and
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111-5
guidance are used in developing new Federal regulations and identifying
and correcting existing SIP deficiencies.
Guidance regarding procedures and schedules would focus on the
sequence of events that would occur in administering sanctions, preparing
the FIP's and submitting them for approval, and promulgating the FIP's
after appropriate review.
The guidance would describe for Regional
Offices the steps to follow to ensure that sanctions achieve their intended
effect (e.g., no new major sources are permitted during the construction
ban).
The use of additional sanctions that might be needed to accomplish
the planning activities would also be discussed, and the actions needed
to invoke (and remove) them would also be described.
The schedule for
developing the technical content of the FIP would be outlined; major
milestones and submittal dates and procedures would be specified for
important activities.
The procedures and schedules for obtaining
appropriate review and comment on the FIP would also be described.
The
procedures would cover any needed Office of Management and Budget
(OMB) review of FIP's as well as public hearings and other review by
State and local agencies and officials.
Guidance would specify who
(e.g., which State or local agencies) should be contacted at what points
in the plan development process regarding comments or suggestions on the
plan content.
The schedule for developing the FIP would conclude with promulgation,
as represented by the final Federal Register notice for the plan.
Although
the final Federal Register notice would represent completion of the
development of the FIP, important events related to litigation might
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II 1-6
extend the schedule of activities needed to resolve problems with specific
sources or control measures.
Guidance would also be needed on schedules
and procedures to follow in addressing such litigation.
The most extensive guidance would be needed in developing the
technical content of the F1P, i.e., the necessary data bases, the modeling
analyses, and the evaluation of possible control measures.
This guidance
would describe in detail how to analyze an area's ozone problem and
determine the measures that should be implemented to resolve that problem.
Guidance in this area of F1P development would be particularly important
since historical procedures and agency roles for accomplishing these
activities would not apply under the F1P scenario.
[In other words, EPA,
particularly Regional Offices, would be taking a much greater role in
evaluating the ozone problem, investigating alternative control measures,
and selecting appropriate measures for implementation.
The FIP guidance for emission inventories would specify which data
elements should be collected from which sources for purposes of establishing
the emission reduction target and tracking future emission levels.
Si nce
States may not provide emission data as in the past [e.g., through the
National Emissions Data System (NEDS) or other State inventory efforts],
Regional Offices may have to take more involved roles in developing the
desired information.
Appropriate guidance could help ensure that consistent,
efficient procedures are used and that the resulting inventories can be
confidently used in developing the control strategies and tracking progress
toward attainment.
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Guidance regarding air quality data would specify the monitoring
network needed to adequately characterize the ozone problem and the
procedures to be followed in collecting such monitoring data.
Again,
since Regional Offices may be assuming responsibilities historically held
by States, appropriate guidance would be needed to ensure that consistent
and efficient procedures are used to collect and compile the desired air
quality data.
These would be based largely on existing monitoring guidance
for ozone, nonmethane organic compounds (NMOC), and oxides of nitrogen
(NOx).
Guidance on appropriate modeling procedures to calculate the emission
reduction requirements would also be based mostly on existing guidance;
however, different procedures may apply depending on whether EPA-Headquarters
or EPA Regional Offices take the lead in performing the analyses.
Considering
new guidance would be needed on the possible measures to be included in
the FIP control strategies.
Many of these measures would be quite different
from earlier measures in terms of what sources they affect and how they
could be implemented.
Instructions would be needed on how to calculate
the benefits, costs, and other impacts of these measures in the particular
area where they are implemented.
One of the most important areas for guidance development would be in
the area of evaluating and selecting control measures for a particular
area.
Although EPA has provided guidance to States in the past in regard
to determining the emission reduction potential and costs of many control
measures, little guidance has been developed on weighing the "pluses and
minuses" of the control measures before selecting which ones are a part
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I II-8
of the overall strategy.
Under the FIP scenario, EPA Regional Offices
would be primarily responsible for designing the "best" strategies
for their areas.
In determi ni ng these "bes t" strategi es, several factors
would be considered, such as reduction potential, costs, social impacts,
technical feasibility, political feasibility, time to implement, etc.
Measures to remedy any problems or deficiencies in existing State regulations
and programs would also have to be developed.
Guidance would be needed
in each of these areas to assist Regional Offices in these important
evaluations and decisions.
The final area where guidance on FIP development would be needed is
in regard to the form of the FIP, i.e., the actual content of the plan.
The major elements (e.g., demonstration of attainment, impacts analysis,
regulations, etc.) would be described to ensure that all FIP's contained
adequate documentation of the analyses and decisions leading to the selected
control strategies.
Assumed FIP Scenario - The EPA Headquarters has worked closely in
the past with Regional Offices, States, local air agencies, and various
governmental and industrial groups to develop guidance to implement new
programs.
Agencies outside EPA have been particularly helpful in providing
broad perspectives and other important input to the development of guidance
for planning and implementing the new programs.
In addition, considerable
work has often been done through the use of contractors to collect and
analyze information related to a particular topic.
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With FIP's, 'EPA would probably take a more singular role in developing
guidance, not only to expedite the process to develop guidance but also
because States may be less inclined to offer support since they may be
less involved in deciding plan content and implementing some of the plan
requirements.
The FIP scenario assumes that EPA would develop all of the
necessary guidance and have only 1 imited consultation with States [say,
through the State and Territorial Air Pollution Program Administrators/
Association of Local Air Pollution Control Officials (STAPPA/ALAPCO)].
The EPA would still rely significantly on contractors to produce and
analyze certain information, particularly on possible control measures,
although procedural and administrative guidance would probably be developed
largely by EPA staff.
The EPA Headquarters would draft all of the initial
guidance and, with periodic consultation and coordination with Regional
Offices. produce the final guidance.
Analysis of.Resource and Time Requirements - Development of new
guidance can take from 1 to 3 years (and longer). depending on the type
and availability of information that might need to be gathered. the
analysis required of the information or options, and the form the guidance
will take.
Guidance for developing a plan generally should take less
time than. say, guidance for a new control technique, which involves
considerable data collection and interaction among various groups.
Guidance for developing a FIP could probably be prepared within a year,
since some of that guidance will draw on existing guidance regarding SIP's.
However, a minimum of 9 to 12 months would still be required to prepare
the appropriate reports or documentation and obtain at least some review
within and outside E~A.
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The level of effort required to develop guidance also depends on the
type of guidance.
The procedures and schedules for preparing, submitting,
and promulgating F1P's and administering any sanctions would probably
require about 3 to 6 work-months (wk-mos) of effort.
[More general
guidance would require a level of effort near the lower end of the range,
while more specific instructions would necessitate an effort near the top
of the range, or even beyond.]
Development of the technical guidance for the analysis of the ozone
problem and the determination of control measures that are needed would
require the most extensive resources. About 6 to 9 wk-mos would be
required for EPA Headquarters staff to develop appropriate guidance for
Regional Offi ces to follow in collecting, compiling, and submitting
emission inventory information.
Similarly, about 3 wk-mos would be
required at Headquarters to develop guidance for air quality monitoring
networks and procedures.
Guidance already being developed for States
regarding post-198? nonattainment could probably serve as a base for the
monitoring guidance to the Regional Offices.
The modeling guidance could
also build substantially on previous and current work.
Still, the model ing
guidance would require about 12 wk-mos to adequately address topics such
as transport and use of models other than the empirical kinetic modeling
approach (EKMA) (i .e., the use of photochemical dispersion models).
Guidance for Regional Offices to follow in evaluating and selecting
measures for the control strategies would require a substantial effort.
Appropriate information on how to calculate the benefits, costs, and
other effects for some measures may need to be developed from "scratch,"
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since little information may exist now.
Guidance on the decision-making
process, including how to weigh the different factors, would represent
essentially a new effort.
Developing the guidance for evaluating the
reductions, costs, and other effects of the measures (including measures
to improve existing State regulations) and selecting those for the control
strategies would require from 18 to 24 wk-mos at EPA Headquarters.
[Developing detailed information on each measure is discussed below.]
Coordination and interaction with Regional Offices regarding guidance
would probably require a total of about 9 wk-mos of Regional Office
effort.
Given adequate staff, all of the above guidance should be able
to be developed within the 9- to 12-month time .frame described earlier.
Limited consultation with State and local agencies (probably through
STAPPA/ALAPCO) would probably require a total of about 6 to 9 wk-mos of
State/local effort.
Travel costs for this coordination with Regional
Offices and STAPPA/ALAPCO plus printing costs for guidance material would
be about $10,000.
Preparing technical guidance for individual control measures would
require the single largest amount of additional resources.
Although
considerable work could be done through contractor support, about 6
wk-mos would be needed for each measure to develop and monitor any contractor
work and use the results in preparing an appropriate guidance report.
The contractor effort would be expected to cost from $75,000 to $200,000
per measure depending on the nature of the measure (e.g.. innovative area
source measures would cost more to be evaluated).
For certain mobile
source measures, substantial resources would be required to evaluate
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reduction potential and program design and implementation options.
Assuming that as many. as 50 measures may need such guidance, total contractor
support (based on $100,000 per measure) would cost $5 million, and EPA
staff requirements (at Headquarters) would be about 25 work-years.
The final area of guidance development for FIP planning would be in
regard to the form of the plan.
About 6 wk-mos at EPA Headquarters would
be required to prepare a document describing the organization and content
of the FIP.
Training
Training is the major mechanism for providing the guidance developed
for FIP planning (as well as other pertinent guidance) to those who will
be carrying out the various planning activities.
Essentially all of the
areas for which guidance would be developed could be the subject of
training efforts.
These training efforts could come in the form of
workshops, special training courses, or additions or modifications to
existing training courses.
Historically, State and local air agencies and other agencies [e.g.,
State and local Department of Transportations (DOTls), planning boards,
etc.] along with EPA Regional Offices have had important foles in developing
ozone control plans.
Training efforts on the various aspects of plan
development have been directed at all of these agencies.
With FIP's, the
EPA Regional Offices will carry out most of the planning functions,
although coordination and communication with State and local agencies and
officials will still occur to the extent possible (see next section,
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111-13
"Interaction With State and Local Agencies and Officials").
Most of th e
training, therefore, will be directed at EPA Regional Offices, with some
training expected for State and local agencies.
The primary form of training would be Regional workshops.
Wo rkshops
would generally provide the guidance and instructions related to FIP
planning in the most expeditious manner.
In general, the sooner the
guidance or other FIP instructions are explained to appropriate Regional
staff (and certain State/local staff), the sooner development of the
FIP's can begin.
Training courses may be more appropriate for providing
guidance and instructions regarding implementation of the plan requirements.
Although training should cover essentially all of the items for which
guidance is developed, the major topics would be technical analyses (e.g.,
development of emission inventories, modeling, evaluation and selection
of measures, etc.) and form and content of the FIP.
Besides the formal
workshops, other mechanisms would be used to provide training.
In
particular, EPA Headquarters would develop guidance memos (IIQ'S and A's")
to provide information on specific topics.
These types of products would
provide quick information on important topics to Regional Offices.
. Assumed FIP Scenario - The EPA Headquarters has been responsible
in the past for developing and providing training material to Regional
Offices and State and local agencies in regard to preparing air pollution
control pl ans.
State and local agencies and EPA Regional Offices have
provided input by reviewing training material, evaluating workshops or
training courses after completion, and providing suggestions or comments
on training needs through formal (e.g., National Air Audit System) and
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informal mechanisms.
Under the FIP scenario, EPA Headquarters would
d~velop most of the training material and provide workshops to Regional
Offices and, for some topics, to State and local agencies.
Regional
Offices would indicate their training needs and consult with State and
local agencies to assess their training needs.
For example, a local
transportation department may want to provide the mobile source emission
inventory, but it needs training in the most up-to-date techniques and
factors for making the calculations.
A minimum of three workshops would
be expected to be needed in each Region to provide the necessary training.
Analysis of Time and Resource Requirements - An important consideration
affecting the time required to develop training will be the availability
of guidance material.
Since much of the training material would be based
on FIP guidance documents, these documents would need to be largely
complete before the training material could be developed.
Guidance
documents would be expected to take from 9 to 12 months to be developed.
Training material could probably start to be developed between 6 to 9
months into the guidance development effort.
Developing the training
material for three workshops would take from 6 to 9 months from that
point.
The EPA Headquarters would probably hire contractors to develop the
training material and organize it in a workshop format.
About $25,000 to
$50,000 would be required for each of the three workshops for a total of
$75,000 to $150,000.
About 9 wk-mos of EPA Headquarters staff would be
required to organize, coordinate, and review the contractor effort (3 wk-mos
per workshop).
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Actual presentation of the workshops would require EPA Headquarters
and Regional Office time and travel dollars.
Similar resources would be
required of State and local agencies who participated in the workshops.
With three (2- to 3-day) workshops in each Region, about $50,000 in
travel and printing costs would be incurred.
Staff requirements would be
9 wk-mos for EPA Headquarters and 12 wk-mos for Regional Offices.
Assuming
that State and local agencies would attend at least one of the workshops,
additional resource requirements for these agencies would be $50.000 for
travel and 9 wk-mos.
Other less formal training/guidance efforts (e.g., Q's and A's)
could distribute important but limited amounts of additional information.
Resource requirements for these efforts would be relatively low on a "per
item" basis, but added together they could be significant.
About 2 to 3
wk-mos from EPA Headquarters would be required to respond to questions or
specific concerns in this manner.
Interaction With State and Local Agencies and Officials
A variety of State and local agencies and officials have been involved
in the past in the development of ozone control plans.
Besides the State
and local air agencies, other agencies such as the transportation depart-
ments, planning boards, engineering departments, economic development
boards, and public health commissions have been closely involved in
analyzing an area's ozone problem and evaluating and selecting alternative
solutions.
Many of these agencies and officials have provided vital
input to understanding the feasibility. benefits. and costs of various
measures to reduce ozone levels.
Much of this input has been readily
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provided by the appropriate agencies, whereas, if EPA had had to provide
the information, substantial resources could have been required.
Under
the FIP scenario, even though EPA will be primarily responsible for
evaluating and selecting the control strategy, the input from these
agencies and officials would be crucial to developing effective and
reasonable strategies that would have a high likelihood of successful
implementation.
Therefore, EPA would make a concerted effort to work
with these agencies and officials in the planning stage to develop effective
control strategies.
Assumed FIP Scenario - With SIP's, the State air agencies have taken
the lead in working with other State agencies and local agencies and
officials to develop and implement control strategies.
Under the FIP
scenario, the State air agency could continue to coordinate and interact
with local agencies and officials and provide their input to EPA.
On the
other hand, it could decide to withdraw entirely from the planning effort
and place the responsibility of interaction with these agencies and
officials totally on EPA.
Between these extremes, the State could work
with some agencies to obtain input while EPA worked with others.
~r
example, the State air agencies might work with State and local transportation
departments to develop baseline emission inventories for mobile sources
while EPA works with the local planning board to investigate area source
emissions and possible control measures.
The State air agency generally
has well-established lines of communication with other State and local
agencies, whereas EPA may have to use considerable time and resources to
establish its own communication channels.
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This analysis assumes that EPA would have to assume most of the
interactive and coordination role the State air agencies had under SIP's.
The EPA would still encourage the air agency to participate, but it is
possible that the agency would choose to playa minor role in developing
the FIP.
Almost all of the interaction with the State and local agencies
would be carried out by Regional Offices.
The EPA Headquarters staff
could be involved at times on technical details or policy issues.
~r
example, staff from Headquarters might meet with the Regional Office and
certain States to discuss treatment of transport in a particular modeling
analysis.
Analysis of Time and Resource Requirements - Throughout the period
for developing the FIP (probably about 1 year), 18 wk-mos of effort would
be required of Regional Offices for interacting with the State and local
agencies and officials in ~ach FIP area.
Most of this effort would be
related to meetings with local staff officials (as many as 25 to 50 could
be expected).
Extensive travel would be required to support the coordination
effort.
Travel costs would be about $2,000,000 primarily for Regional
Offices.
A total of about .6 wk-mos would be required from Headquarters staff
to meet with agencies in some areas or possibly prepare material concerning
higher management meetings (e.g., local transportation or planning board
meeting with Administrator).
This estimate could be much larger if State
and local officials in several areas wanted to discuss their situations
with the upper EPA management.
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Data Base Development
The two most important data bases in developing an ozone control
plan are the volatile organic compound (VOC) emissions inventory and the
ozone air quality monitoring data.
The emission inventory is critical in
two ways:
(1) it characterizes an area's emissions, and (2) it provides
an overall baseline.
By characterizing an area's emissions, that is, by
showing what sources emit how much, the inventory is an initial indicator
of where additional reductions should be achieved to make significant
progress towards attainment.
This information must then be evaluated in
light of reductions that have already occurred or have been required at
that source category.
For example, petroleum storage tanks in a particular
area may account for a large portion of the emission inventory; however,
these sources may have already reduced their uncontrolled emissions
significantly (say, 80 percent).
Further reductions from these sources
may be difficult and not equitable considering efforts from other sources
in the area.
The emission inventory also provides an important baseline.
The
'adequacy of the ozone control plan is based on its ability to reduce that
baseline by a certain percentage (determined through modeling).
If a
more complex approach of assessing the adequacy of the plan is used (i .e.,
photochemical dispersion model), an even more detailed inventory is needed
as input into a model to simulate emissions and meteorological processes.
The major steps in developing emission inventories are to identify
sources, collect basic data on production or activity level, apply emission
factors, review/quality assure calculations, and compile results.
The
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I II-19
steps are somewhat different from source category to source category and
from stationary to mobile sources; however, these basic steps generally
apply.
Uncertainty and error can enter into almost any step of the inventory
process.
Data on production is not always readily available; appropriate
records are not always maintained; emission factors may be based on loose
extrapolations or questionable assumptions; not all sources may be
inventoried; handling of the data (key punching, tabulating, hand
calculations, etc.) may cause errors.
Procedures and programs have been
established over the years to promote consistency and quality in the
emission inventories, but it is still a difficult and time-consuming
process.
The process is made even more difficult with VOC inventories
which require information from a large number of small sources that are
generally less familiar with air pollution rules and reporting than are
1 arger sources.
The NEDS has provided the framework for a national inventory for
years.
Under NEDS, States generally have give detailed questionnaires to
their sources concerning processes, fuel use, control equipment, production
rates, etc.
The data from sources has then been combined with emission
factors to calculate emissions.
Major changes in production rates,
equipment, fuel use, etc., are supposed to be submitted to NEDS.
State
and local agencies, some of whom have their own inventory systems, have
followed the NEDS reporting requirements inconsistently (partly due to
the low priority assigned by EPA and States).
And since NEDS is directed
at major sources (i.e., those emitting over 100 tons per year), less
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I II-20
attention has been given to developing high quality emission estimates
for the smaller sources.
But roughly a fourth of the total VOC emissions
come from smaller sources.
For SIP emission inventories, State or local agencies have supplemented
or substituted NEDS related work with special efforts for the nonattainment
areas.
Because of their familiarity with local sources, State and local
agencies have been able to carry out this more concentrated inventory
effort, sometimes even conducting surveys of sources or gathering inventory
data during source inspections.
Also in these areas, detailed transportation
network information has been provided by State and/or local transportation
departments.
Using this network information and current mobile source
emission factors from EPA, States have developed detailed emission
inventory information for the transportation sector.
The above discussion
illustrates that States and local agencies have played major roles in
developing emission inventories, often with limited resources for those
activities.
With FIP's, EPA would be faced with considerable resource
requirements since it might not be able to IIpiggy-backll even a portion of
the inventory effort.
Not only is current emission inventory information collected in
developing a control plan, but inventories expected in future years are
calcul ation.
These future inventories show what emissions will occur
given proj ected growth and current regul at ions (incl udi ng those bei ng 0 r
expected to be implemented).
The difference between these future inventories
and an lIattainmentll inventory (the inventory level if the required emission
reduction is achieved) indicates the need for additional control measures.
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States have been.able to develop these future inventories based on individual
source growth estimates and areawide factors (e.g., population projections,
motor vehicle use patterns, etc.).
The other major data base needed in ozone control plans is air
quality monitoring data.
Ozone air quality data are needed to determine
the magnitude and nature of the ozone problem.
The monitoring data
provide a direct indication of the ozone levels the public is exposed to.
Analysis of the data can determine the degree of emission reductions
needed and where those emission reductions should occur.*
Other air quality monitoring is also important in characterizing the
.ozone problem and determining emission reduction requirements.
Monitoring
data for NMOC and NOX must be available for input into the modeling
analysis.
An extensive network of monitors has been established to measure
ozone concentrations, especially in and around urban areas.
State and
local air agencies have generally taken the responsibility of maintaining
these monitoring networks, collecting and compiling the measurements, and
submitting the results to EPA.
Procedures and schedules have been
established at the Federal, State, and local levels to ensure that the
data collected is reported in a timely manner and the data are of high
quality.
These procedures range from a State's own laboratory procedure
to check the function of monitoring equipment to audits by EPA to ensure
that appropriate steps are being taken throughout the collection and
submission of the data.
*Analysis of the data may indicate a need for reductions in distant areas
since transport ma~ cause some or a large part of the problem.
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Similar types of procedures exist for monitoring NOx. and State and
local agencies have taken the responsibility for operating the NOx
monitoring network.
However, the NOx network is much more limited, and
many of the sites may not be suitably located to provide input for the
modeling analysis.
For NMOC, monitoring efforts have been even more
limited and short-term.
State and local agencies are generally not as
familiar with the operating and reporting methods for monitoring NMOC.
Recent changes in the monitoring protocol for NMOC mean that even fewer
States are probably familiar with the operating and reporting methods.
Assumed FIP Scenario - State and local agencies have considerable
experience and have made substantial investments (both for equipment and
personnel) in their programs to maintain emission inventories and operate
air quality monitoring networks.
Direct responsibility for inventories
and monitoring provides them first-hand knowledge of the sources and
location of pollution and the levels of pollution their citizens are
exposed to.
It is likely that under a FIP scenario, they would want to
continue at least some of their current activities and responsibilities
in these areas.
With emission inventories, the FIP scenario assumes that States
would collect and provide emission inventory information at least for
their large stationary sources [i .e., sources emitting more than 100 tons
per year (tpy) of VOC].
The EPA Regional Offices would inventory smaller
stationary sources, which would probably require a survey in each area to
identify the sources and collect the necessary information.
In addition
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II 1-23
to the survey of-small stationary sources, EPA would also want to review
and check the inventory of the larger sources because of their importance
to the overall inventory and the potential problems alluded to in the
earlier discussion.
This review and check of the inventory would involve
comparing the State data with other available inventories (e.g., Department
of Energy, trade associations, etc.) or contacting individual large
sources to "spot check" the State data.
For mobile sources, the assumption in the FIP scenario is that State
or local transportation departments would provide current traffic data
and the transportation networks for the areas in question.
The EPA would
then input these data into its own models to calculate mobile source
emissions.
This assumption is critical.
If EPA had to develop traffic
data and networks for each area, the expense would be extremely large:
probably $200,000 to $500,000 per area.
Time requirements would also be
significant.
An average of 1 year might be required to produce the
information, depending on the availability of other important data,
traffic counts, speed studies, origin and destination studies, etc.).
The growth projections for large stationary sources would be provided
by the State or local air agency, as part of its inventory effort, and
projections for mobile source growth would be provided by the transportation
departments.
The EPA would have to develop estimates for area source
gro~th, based on population projections and other available data.
States would be even more likely to continue their air quality
monitoring activities because of their equipment and personnel investment
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and the importance of knowing public exposure to air pollution levels.
For this analysis. it is assumed that States would continue to collect
and provide all of the ozone and NOx monitoring data.
For NMOC. however.
the assumption is that EPA would have to do all of the collection and
analysis of data.
At least two sites would be needed in each area during
an ozone season.
Because of the limited network for NOx. it is assumed
that additional NOx monitoring would be required in each area.
TheN~
monitoring sites would be colocated with the NMOC monitoring sites.
Analysis of Time and Resource Requirements - For States. the collection
of emission inventory information for large sources and operation of the
ozone and NOx monitoring networks would be included in their continuing
inventory and monitoring efforts and. therefore. would be covered through
their current grant programs.
The determination of growth projections
could be an additional effort of about 6 wk-mos per area.
For EPA. additional resources would be required to inventory smaller
sources and monitor NMOC levels in each nonattainment area.
The EPA
Regional Offices would probably rely on contractors to inventory the
small sources as well as check the State's data on large sources.
Contractor
costs would be about $75.000 - $125,000 per area, depending to a large
degree on the number of sources in the area.
Administering the contract
and collecting and reviewing all of the stationary source inventory
information would require from 6 to 9 wk-mos for each area.
For the
Regional Office to collect and code the mobile source data and run
appropriate models for current and future years, about 3 wk-mos per area
would be required.
About one work-year of effort would be needed at EPA
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Headquarters to receive emission inventory and air quality data submittals
from the Regions.
Developing the current and projected emission inventories would
probably take about 9 to 12 months.
The timing could be affected
significantly by the selection of the base year and the point where the
State is currently at in its inventory process.
State and local air agencies should be able to provide the ozone
monitoring data as part of their current monitoring and reporting
activities.
If the time frame for reporting the data is accelerated, an
additional 1 wk-mo of effort per area would be required.
Additional personnel and equipment would be needed to monitor NMOC
and NOx* in all areas.
Probably two NMOC monitors and two NOx monitors
would be needed in each area.
NMOC monitors would cost about $5,000
each, and (assuming contractor support) about $20,000 would be needed to
operated each monitor and compile the data.
For NOx, the equipment would
cost about $10,000 with operating costs of about $12,000 (per monitoring
site) .
About $500,000 would be needed to support computer processing of
the emission inventory and air quality data bases and a 1 imited amount of
travel.
Modeling
A critical step in the planning process is the determination of the
emission reduction target; that is, how much do current VOC* emission
levels have to be reduced to attain the ozone ambient standard.
Various
*A few areas may have adequate NOX monitoring networks as part of their
current monitoring programs.
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methods have been used in the past to estimate the reduction target, but
the currently-accepted procedure is a mathematical model, usually EKMA.
Use of EKMA requires city-specific input primarily for ozone, NMOC,
and NOx ambient concentrations, VOC and NOx emission inventory information,
and meteorological data.
The EKMA analysis will produce the percent
reduction needed in VOC* emissions to attain the standard.
This percent
is then compared with the percent change expected between the baseline
(current) inventory and a future inventory level which takes into account
growth and existing regulations and programs.
For example, if EKMA
indicates a VOC reduction of 40 percent is needed to attain the standard
and existing regulations and programs are expected to reduce the current
emission inventory by 10 percent (even after accounting for the effects
of industrial and population growth), an additional reduction of 30
percent is needed to attain the ozone standard. .It is the primary objective
of the control plan to identify the additional measures which should be
implemented to achieve this 30 percent reduction.
There are also more complex models that can be used to estimate the
reductions needed to attain the standard.
Some of these models perform a
more rigorous assessment of the effects of upwind emissions, for example,
those in another urban area, county, or State.
Others simulate pollutant
emissions and meteorological processes to estimate resulting ozone levels
under various control strategies.
With these simulation models (e.g.,
*NOx reductions can sometimes augment or supplement VOC reductions in
particular cases. Only a small number of ozone nonattainment areas
would be expected to consider NOx reductions in their strategies.
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111-27
AIRSHED), the control strategy is adjusted until attainment of the ozone
standard is predicted so that an overall emission reduction target is not
actually necessary.
Both the transport models and the simulation models
require extensive data input and computer processing.
Most States and Regional Offices have experience with the use of
"city-specifi c" EKMA to determi ne emi ssi on reduction targets.
EKMA was
essentially used in all ozone extension areas (those with approved plans
for attainment by the end of 1987) in their plan submittals in 1982.
Areas which projected attainment by the end of 1982 used either EKMA or a
simpler roll-back technique based on ozone design values and total
emissions.
Few areas are experienced with photochemical dispersion
models.
States have generally performed the modeling analyses, although
Regional Offices have assisted or performed their own analyses to check
results.
Assumed FIP Scenario - City-specific EKMA would be used in most
areas to determine the emission reduction targets.
For the areas in
the northeastern United States, a model to more comprehensively address
transport issues would probably have to be used as a substitute or in
addition to EKMA.
Transport is generally recognized to be a valid concern
in the northeastern part of the country.
Because of the time and expense
involved in using photochemical dispersion models, EPA would not plan to
use these although a State or local area could undertake such an analysis
on its own.
Either EPA Headquarters or the Regional Offices could perform the
modeling analyses.
An "economy of scale" might be realized by having all
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111-28
analyses performed at Headquarters.
On the other hand, it may be more
important for Regional Offices to be fully involved in all aspects of
plan development, including determination of reduction targets, since
they would be responsible for practically all interaction with State and
local agencies and officials, industries, and the general public.
This
analysis assumes, therefore, that all EKMA type analyses will be performed
by the Regional Offices.
The more specialized modeling analyses required in the northeast to
address transport issues would probably require both Regional Office and
Headquarters staff.
State agencies might also want to be involved,
especially since important assumptions or decisions could significantly
affect the determination of reduction targets for various areas.
Analysis of Time and Resource Requirements - The major effort in the
modeling analysis involves the collection of the required input data:
pollutant ambient concentrations, emission inventories, meteorological
conditions.
One to 2 wk-mos of Regional effort would be needed to
collect the data and run the model for each FIP area.
The EPA Headquarters
requirements would be about 3 to 6 wk-mos mostly for the comprehensive
analysis in the northeast.
Additional contractor support of about $200,000
may also be needed in the northeast for data collection and model runs.
Probably 1 to 2 work-months per area would also be needed in Headquarters
to support Regional Offices in the modeling activities.
work-years is estimated for Headquarters.)
(A total of 5
Under this FIP scenario, significant resources for States would not
be required.
A State wishing to run a photochemical dispersion model on
its own could spend nn the order of $500,000.
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111-29
Assuming that the required data are readily available, possibly from
previous activities (e.g., emission inventory development), the modeling
analysis could be completed within 3 months.
The analysis in the northeast
would take from 9 to 12 months.
Regional Offices could not perform the
EKMA analysis until the emission inventory work had been completed.
The
time shown for the Northeast analysis assumes a period of time for data
collection, including emission inventories.
Computer costs for modeling
activities could be about $1,000,000.
Strategy Selection
The primary objective of the ozone control plan is to specify the
additional measures that are needed to achieve the emission reduction
target and, thereby, attain the ozone standard.
Determination of these
measures in the past has involved both EPA and State and local agencies.
The EPA has specified basic plan requirements and provided guidance on a
number of possible measures.
For required measures (e.g., motor vehicle
inspection and maintenance), EPA has provided considerable detail on how
States should design their programs and what performance criteria should
be used to judge the adequacy of the measure.
Similarly, EPA has determined
the reasonably available control technology (RACT) requirements for
certain stationary source categories [i .e., control technology guidelines
(CTG's)] and presented broader guidance on RACT for other sources.
States, on their part, have developed their plans to include all
reasonably available control measures needed to show attainment of the
standard.
For stationary source measures, States have generally relied
on the CTG's to develop their regulations, although industry concerns or
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II 1-30
comments t State regul atory procedures and formats t and other factors have
caused some variation in the RACT requirements for various source
categories.
The variation in States' regulations has been even more
apparent-where there is no EPA guidance or where the guidance is quite
general.
For mobile sources [except for inspection and maintenance (11M)
programsJt States have had considerable freedom in determining which
control measures should be implemented.
The EPA has provided guidance on
many measures (ranging from mass transit programs to bicycle lanes) t but
States have generally had the responsibility of identifying and evaluating
alternative measures and selecting those needed for attainment.
Within the Statet there have been many important participants in the
process of evaluating and selecting measures.
Affected industries have
exerted strong pressure on State air agencies regarding the specific
requirements of possible regulations.
State and local agencies and
officials and the general public have provided considerable input on
mobile source measures.
Much of the input from these "nonair" agencies
has been particularly important since often it would be these agencies
who would actually implement and administer some of the mobile source
measures.
In evaluating possible control measures for Slp.s, several factors
are often considered.
Some of these factors include emission reduction
potential, costs, technical and administrative feasibilitYt and social
and pol Hical impacts.
The various decisionmaking processes in State and
local agencies consider these and other factors to varying degrees,
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111-31
resulting in strategies that are tailored for the particular nonattainment
areas.
State air agencies generally have numerous meetings with other
agencies. government officials, industries, and public organizations in
this process of evaluating and selecting control measures.
Sometimes, considerable upfront work is needed to develop or design
a control measure at least to a point where sufficient detail is available
to use in evaluating the feasibility and effects of the measure.
For
example. a "generic" mass transit system would not provide a sufficient
detail to enable planners to determine the expected with resulting emission
reductions, costs, and other effects.
A study of transit options would
have to be performed to look at possible routes, transit modes, support
systems (e.g., bus routes), and other variables to develop emission
reductions, costs, and other information for a recommended system or
range of alternatives.
Assumed FIP Scenario - In the past, States have had the responsibility
for evaluating and selecting control measures, as long as they satisfied
the minimum requirements EPA established for an approvable plan (which
included demonstrating attainment by a certain date).
The degree to
which States considered the various factors like costs or political
feasibility was really up to them, since EPA's major concern was with the
predicted emission reductions and the enforceability of the plan.
With FIP's, EPA would be assuming the lead responsibility for
evaluating and selecting the control measures for an area.
The EPA woul d
take a rigorous and consistent approach in identifying, evaluating, and
selecting control measures.
It is likeTy that a more thorough upfront
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111-32
evaluation of alternative control measures would enhance the chances of
overall success of the control strategy.
The EPA would investigate each
measure in regard to at least the following factors:
emission reduction,
costs to industry, costs to public. technical and administrative feasibility,
time to implement, and social and political impacts.
Contractors could
be used to obtain basic information on control measures, particularly
where .upfront design or developmental work is needed.
This upfront design
work is assumed to be required in five areas.
The EPA would rely on State and local transportation departments,
metropolitan planning organizations, and others involved with motor
vehicles or the transportation planning process to provide input and
review concerning possible mobile source control measures.
Many of
the possible mobile source measures would not be feasible without the
participation of these agencies.
The resource requirements discussed
earlier in "Interaction With State and Local Agencies and Officials" are
assumed to cover the resource needs for this activity.
The EPA would also be determining those measures needing to improve
existing State regulations or programs.
The first step in this process
would be for Regional Offices to identify deficiencies or loopholes in
State regulations using primarily guidance developed earlier by Headquarters.
With these problems identified, Regional Offices would specify the
corrective actions States needed to take to improve the effectiveness of
their current regulations and programs.
Where States would not take
corrective action, EPA would promulgate changes to the regulations.
This
FIP analysis assumes that half of the States adopt and implement the
corrective measures jdentified by EPA.
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111-33
It is also assumed that in some areas there will be strong pressure
to base the overall control strategy on NOX reductions, by themselves or
in conjunction with VOC reductions.
Considerable time and EPA resources
could be involved in negotiating this issue, even in only a few areas.
This FIP analysis assumes that NOx control will be an issue in three
areas.
Analysis of Time and Resource. Requirements - Most of the resources
for this activity would be required to evaluate possible control measures.
About 9 to 12 wk-mos of Regional Office effort would be required for this
evaluation process in each area.
From $75,000 to $100,000 in contractor
support would be required in most areas, and an additional $300,000 to
$500,000 would be required in the worst (5) ozone areas for upfront
development of certain control measures.
Most of the work of Headquarters
regarding evaluation of measures would have been done earlier in guidance
development, which described how to obtain information on the evaluation
factors and consider these in selecting measures for the plan.
St i 11 , a n
average of 1 wk-mo per area would probably be required to work with
Regional Offices on specific problems or details in the control strategy.
Regional Offices would require about 3 wk-mos per area to review
existing State regulations and programs to identify deficiencies or other
problems and determine corrective measures needed.
For those areas (half)
where States would not adopt and implement the corrective measures,
another 2 wk-mos would be required to promulgate those measures as Federal
rules.
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111-34
A minimum of 6 months would be required to perform the evaluations
of control measures.
However, the interaction required with State and
local agencies and others and the need for some contractor studies would
probably raise this minimum to 9 to 12 months.
Additional time (6 months
assumed) would be required in areas where considerable discussion of an
NOX-based control strategy occurs.
An additional 3 wK-mos of Regional
Office effort and 2 wK-mos of Headquarters effort would be required in
each of these areas.
Plan Developmen~
All of the information gathering and analyses activities in developing
the ozone control plans (for Slp.s or FIP's) must be organized and presented.
in a report.
This report is the plan for attaining the ozone standard
and it documents for others (e.g., government agencies and officials,
industry, general public) the data and rationale which led to the plan
requirements.
The plan is organized in a format which clearly describes
the major activities which led to the development plan, the results of
those activities, and the anticipated activities to implement the plan.
The major elements presented in the plan are summaries of emission
and air quality data, the modeling analysis, the evaluation and selection
of control measures, the demonstration of attainment, new or modified
regulations, and responsibilities and commitments.
These elements combine
to describe the basic planning process of gathering data, analyzing the
problem, identifying and evaluating alternatives, and selecting a solution.
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111-35
The emission inventory summary describes the distribution of emissions
in an area, that is, what portion of the emissions come from large sources
(by type) and how much comes from smaller, areawide sources, how much
comes from stationary sources vs. from mobile sources, etc.
The summary
also indicates the temporal distribution of the emissions which is an
important input in the modeling analysis.
The summary shows what level
of control has already been achieved by various source categories, which
illustrates the degree of further control that may be possible.
The
techniques used in collecting and compiling the emission information are
also described.
The air quality data contained in the plan represent the results of
ambient monitoring activities and show the severity of the ozone problem.
Both for air quality data and emission inventory information, sufficient
detail is needed to show the key inputs into the modeling analysis (e.g.,
early morning emissions, upwind ozone levels, etc.).
The discussion of
the modeling analysis shows other important input and also provides the
reasoning for use of a particular model or any assumptions in the analysis.
The plan summary of the evaluation and selection of control measures
addresses both the process used and the results.
If major upfront studies
were performed or if a series of public workshops were held to investigate
control measures, these activities would be summarized in the plan.
The
plan then shows the effects (i .e., emission reductions, costs, administrative
feasibility, social impacts, etc.) expected from the various alternatives.
The selection of control measures leads into probably the "heart" of the
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111-36
ozone pl an:
the' demonstration of attainment.
Th e d erno n s t rat ion 0 f
attainment combines the emission and air quality data, the modeling
analysis, and the selection of measures to show that the plan is capable
of achieving the standard by the prescribed date.
In general, the
demonstration shows that the emission reduction target, identified in the
modeling analysis, will be achieved through implementation of the selected.
measures.
Along with the demonstration are the necessary commitments
(e.g., for a local transportation department responsible for implementing
a ride-share program) to ensure effective implementation of the plan.
The final element of the plan is the regulations needed to implement
the various requirements.
Some regul at ions can be developed from "scratc h"
while others may be available from existing EPA guidance (e.g., CTG's).
Any variances or unique circumstances are addressed in the regulations,
and compl iance schedules are developed for the different source categories.
In the past, these compliance schedules often have resulted after extensive
interaction with industries in the affected source categories.
Although EPA has developed guidance on the form and content of SIP's,
States have been almost totally responsible for the actual preparation
of the plan.
Several State and local agencies have been involved in
preparing the plans, sometimes through providing discussions of analyses
and results for a specific plan element or obtaining appropriate documents
of commitments to various measures.
Often, obtaining review and comment
or commitments from agencies and officials within the State or area can
be a time-consuming process.
Some of these agencies also work with the
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111-37
State air agency to design and document specific implementation and
enforcement programs for new measures (e.g., some of the mobile source
measures like ride-sharing or parking restrictions).
The ozone plan under a FIP approach would generally require the same
elements that have been included in SIP's.
In addition, the FIP would
also need to contain or be accompanied by a technical support document*
which details all of the analyses, both air quality and impacts analyses.
The greater detail and documentation would be needed since FIP's may come
under intensive scrutiny from various groups or agencies, including
industrial associations, economic development agencies, and even State
environmental agencies and boards.
Assumed FIP Scenario - The EPA would develop all of the ozone control
plan under the FIP scenario.
Much of the work in preparing the plan
would involve summarizing earlier activities and analyses, such as emission
inventory development and modeling analysis.
Additional work at this
stage would involve developing appropriate regulations to implement the
requirements.
Each Regional Office could develop its own regulations,
possibly tailored for each area, or EPA Headquarters could develop generic
regulations needing minor modifications to apply to specific areas.
~r
this analysis, it is assumed that Headquarters would develop example
*The technical support document could also be included in the FIP as
expanded discussion of the analyses and the results.
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II 1-38
regulations for most of the source categories to be regulated under the
FIP's.
Regional Offices would rely on these example regulations to
develop specific regulations for their areas.
Regional Offices would
develop regulations for unique source categories, with some interaction
with Headquarters.
The Regional Offices would develop technical support documents
(TSD's) for each of the FIP areas.
These TSD's would describe all of the
technical analyses and the results, with particular emphasis on the
impacts of th~ alternative measures.
Contractor support would probably
be used to develop the TSD's.
Analysis of Time and Resource Requirements - Most of the resources
needed to prepare the ozone control plan (i .e., the FIP) would be for
developing regulations to implement the FIP requirements.
The EPA Regional
Offices and. to a lesser degree. Headquarters could be involved in a
number of negotiations with States and industry groups to "fine-tune" the
regulatory requirements.
Unique industries or circumstances may require
considerable effort to negotiate alternative requirements and compliance
schedules.
These negotiations could take 3 months and, possibly, much
longer depending on the difficulty of the problem or the determination of
the State or local agency or the affected industry to press for alternative
requi rements.
About 9 to 12 wk-mos per area would be required for the
Regional Offices to develop regulations and negotiate variances or
alternatives with State or local areas or specific industries.
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I II-39
The EPA Headquarters effort for new regulations would occur mostly
in the guidance development stage, where example regulations would be
produced.
However, an additional 2 work-years would probably be needed
to assist Regional Offices in developing regulations for specific areas,
particularly where several alternative compliance schedules or requirements
are proposed by the State or industries.
Documentation of the technical analyses (including the impacts of the
analyses of alternative control measures) would probably be done through
a contractor.
About $50,000 to $75,000 per area would be needed to
provide this contractor support.
An additional 6 to 9 months would be required to compile the remaining
portions of the plan.
This effort would include coordination and
interaction with other agencies that may be providing input into the
plan.
For example, several discussions or meetings with a local transportation
board may be required to design a transportation control measure selected
for inclusion in the plan.
About $100,000 would be needed for printing
and related activities.
Plan Review and Adoption
The final phase in the development of an ozone control plan involves
the review of the plan by various groups and the formal approval and
adoption of the plan.
This phase provides the opportunity for those
concerned with the ozone problem or the proposed control measures to
express their comments or questions on the various aspects of the ozone
control plan (i.e., the SIP or FIP).
These comments and questions are
then considered in preparing the plan for final review and adoption by
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111-40
the appropriate agency or body.
Formal adoption of the plan represents
the final step in the development of the plan and the first step in
implementation of the plan.
With SIP's, this phase in the development of the plan generally
includes review by concerned groups, modification to plan based on
comments, State approval and adoption, and EPA review and approval.
With
FIP's, essentially the same activities occur except that State approval
and adoption is not required and review by other agencies (e.g., OMB) may
be required before final adoption (or promulgation) by EPA.
The review by concerned groups can take several forms ranging from
meetings and workshops to formal public hearings.
The objective is to
explain the purpose and content of the control plan and receive comments,
questions, and suggestions concerning the plan.
Various groups may want
to participate:
industry associations as well as specific industries,
government agencies and officials, environmental or public interest
groups, and the general public.
States must follow their own administrative procedures as well as
Federal requirements in obtaining review and comment on their SIP's.
Generally, these requirements result in a newspaper announcement in the
affected area some minimum time period before a formal public hearing(s),
followed by the public hearing, and then another time period in which
additional comments may be submitted.
These are the minimum requirements,
and often States take special efforts to obtain public review and comment
particularly on major or controversial proposals.
States might use
newspaper advertisements, public service announcements, direct mailings
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111-41
to those interested in environmental rulemaking, and other methods to
notify people about the control plan and how they can review and comment
on the plan.
Copies of the plan are made available for review at various
locations, and individual copies of the plan (in total or in part) can
usually be obtained for the cost of duplication.
In addition to the
formal public hearing(s), workshops or meetings are sometimes held to
discuss the control plan and receive public comment.
In development SIP's, States then review the comments and determine
whether changes in the control plan are warranted.
The plan may be
modified to accommodate various concerns, as long as the control requirements
(e.g., 11M, RACT on selected sources, attainment by specified date, etc.)
are still satisfied.
The modified plan is then presented to a State
environmental board or commission for approval and adoption.
Approval
and adoption of the plan make the requirements and the regulations
enforceable under State law.
The State plan is then submitted to EPA for its review and approval.
The EPA Regional Offices have generally been closely involved in the
development of the SIP and are familiar with the plan features and
requirements.
Following considerable analysis and discussion among the
Regional Office and Headquarters, a position is reached on the approvability
of the plan.
The proposed action on the plan (i .e., approval or disapproval)
is published in the Federal Register to receive public review and comment.
Generally, considerable discussions occur between EPA and the State during
this process, particularly if a problem exists.
Final approval of the SIP
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III-42
by EPA makes the " plan federally enforceable.
Disapproval of the plan
indicates that several actions (e.g., sanctions) may be taken to pressure
the State to submit an approvable plan.
Under the FIP scenario, EPA would also take steps to obtain pUblic
review and comment on the Federal plans.
Under the Administrative
Procedures Act, EPA would be required at a minimum to publish a summary
of each FIP (either individually or collectively), provide a time period
in which comments would be received, hold formal public hearings, and
respond to comments in developing the final FIP's (also published or
summarized in the Federal Register).
The EPA could also employ other
methods to develop a public awareness of the FIP's and receive public
comment and review.
Examples of these methods include press releases,
workshops, meetings, public information campaigns, and other elements of
an overall communication strategy.
The EPA could also have to satisfy additional review requirements
not generally associated with SIP's.
As major Federal actions, FIP's
would have to be reviewed by OMB.
The OMB review could be for each FIP
individually or possibly the overall package of FIP requirements.
Assumed FIP Scenario - The EPA would be responsible for obtaining
public review and comment on the FIP's.
The review of each FIP could
take place individually, or the proposed FIP's could be published in the
Federal Register all at once.
National public hearings could be held, or
hearings at the Regional or nonattainment area levels could be conducted.
An overall communication strategy could be implemented by EPA Headquarters
or each Regional Office could conduct its own communication activities.
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111-43
This analysis assumes that the Regional Offices would be responsible
for obtaining public review and comment on each of the FIP's.
Regional
Offices would draft the Federal Register notices for the FIP proposals
and the final promulgations.
Headquarters would be involved Jointly with
the Regional Offices in preparing summary and briefing material for upper
EPA management regarding the FIP proposals and final promulgations.
Regional Offices would conduct at least one public hearing in each
nonattainment area.
Primarily, Regional Offices with some Headquarters
support would prepare responses to the comments.
Headquarters would
develop a "generic" communication strategy which Regional Offices would
use to interact with various industrial and environmental or health groups
and the general public.
Headquarters and Regional Offices would jointly prepare summary and
briefing material for the OMB review.
It is assumed that OMB would review
each one of the FIP's individually rather than all of the FIP requirements
as a whole.
Analysis of Time and Resource R~irements - Review of the FIP's
would take between 9 to 12 months, including time for preparation of the
Federal Register packages, conducting the public hearings, preparing
responses to the comments, and briefing EPA management.
Revi ew by OMB
would take another 3 to 6 months.
Most of the additional resources would be needed in Regional Offices.
About 1 to 3 wk-mos would be required to prepare for and conduct each
public hearing, and about 6 wk-mos would be required to respond to comments.
Contractor support (about $25,000) might also be needed in each area to
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111-44
respond to comments.
Two wk-mos would be required to develop the final
For each FIP, a total of 6 wk-mos of Headquarters
Federal Register notice.
effort would be required to work with the Regional Office, particularly
in preparing the final Federal Register notice and briefings for OMB.
Printing and publication costs would be about $200,000.
A broader communication strategy (i .e., besides just a public hearing)
would require 18 to 24 wk-mos in each Regional Office.
The communication
effort could also call on State and local agencies to assist in contacting
the various groups that might be interested in or affected by the FIP.
State resources would probably be about 3 wk-mos for each area.
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IV.
FIP IMPLEMENTATION
After an ozone control plan (SIP or FIP) has been developed. it can
only achieve emission reductions through effective implementation.
The
major elements of implementing an ozone control program effectively are
source permitting. source testing and inspection. enforcement activities.
and program evaluation.
In implementing the ozone control programs outlined in the Flp.s.
EPA would consult with State and local agencies to determine the specific
roles of each.
Unlike the FIP planning process. which would require that
EPA assume responsibility for almost all activities. the implementation
process would be best facilitated by shared responsibilities among EPA
and State and local agencies.
While EPA could not legally require another
agency to implement control measures in the context of a FIP. it does
expect that many State and local agencies would want to be involved in
the implementation of the FIP.
The EPA recognizes that there would be
certain FIP elements, such as air quality monitoring, that these agencies
would want to continue to implement. as well as others, such as inspection
and maintenance (11M) and TCM's, that would be more effectively implemented
at the local level rather than the Federal level.
The EPA does not
foresee any legal problems with delegating these types of responsibilities
to State and local agencies.
However, as discussed later, enforcement
actions would probably be carried out at the Federal level because sources
would be operating under Federal. rather than State, permits.
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IV-2
The resource requirements associated with implementing the FIP would
tend to be one-time, upfront requirements for certain activities, such as
guidance development and training, and annual requirements for the others,
such as inspection, enforcement, overview, etc.
The resource requirements
for guidance development and training can be discussed somewhat generically;
however, the resource requirements for other implementation activities
greatly depend on the nature and number of control measures in the
strategy.
Therefore, the implementation resource requirements will vary
from one FIP to anouther, depending on the components of the FIP's.
Thi s
analysi s has est imated resource requi rements for an area wi th a IImoderatell
ozone problem.
Multiplying the resource requirements for this area
generally by the total number of FIP areas is considered to provide a
reasonable approximation of total resource requirements.
In the discussion which follows, the activities of guidance development
and training under FIP's are described along with their implications for
resource requirements.
Following that discussion, the types of mobile
source controls and stationary source controls that would probably be in
FIP's are described with particular emphasis on the resource requirements
that would be associated with implementing these measures.
The resource
requirements associated with overall program evaluation and auditing are
then discussed, followed by a discussion of the requirements related to
modifying the FIP or other supplemental planning activities.
Table IV-l summarizes the resource requirements for the various
implementation activities.
The resource requirements listed in the table
are based on an assumed implementation scenario in which attainment of
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IV-3
TABLE IV-1
FIP IMPLEMENTATION
NATIONAL ANNUAL RESOURCE SUMMARya
Activity
EPA-HQ
(work-yrs)
6b
EPA-RO
(work-yrs)
EPA-otherd
( $1000)
State
(work-yrs)
Contractor
- ($1000)
l,ooob
450b
300
o Deve~op guidance
o Training
6b
2
8
60
141'
4
185
70b
20
]b
2
200,000 b,c
199,OOOc
o Mobile source controls
925
o Stationary source
controls
9
300
9,750
1,450
300
o Transportation control
measures
3
345
7,000
1,725
300
o Program evaluation
and audit
7
40
450
200
90
o FIP modifications and
supplemental planning
5
120
600
TOTALe
34
994
216,500
4,920
752
1,484
aBased on a total of 60 FIP's and control strategy for medium area.
bCosts are one-time only, not annual.
CAssumes that costs of enhanced 11M programs cannot be recovered by vehicle inspection fees.
11M needs to be initiated in only 20 areas and operated in 40 areas.
dOther costs include primarily travel costs. For most activities, the travel costs are based
EPA RO work-year and $2000 per State work-year.
eTotal includes all annual costs, not one-time only costs.
State-othe rd
( $1000)
14b
4
120
580
600
180
Al so assumes
on $5000 per
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IV-4
the standard is athieved in all areas as expeditiously as practicable
(AEAP).
The AEAP requirement means that attainment dates for some areas
(i .e., the worst ozone areas) would likely be further into the future
than the attainment dates for other areas.
If all areas, including the
worst ozone areas, were forced to attain by a specific near-term date
(say, 1992), the implementation requirements would be different, depending
on which measures had to be dropped (because of long lead times for
implementation) and which ones had to be added or modified to achieve the
shortfall in emission reductions.
For example, measures depending on a
turnover in the vehicle fleet (e.g., methanol conversions) could ont be
implemented and have their intended effect in the near-term.
Guidance Development
In order to effectively implement any ozone control program, guidance
is needed on how the control measures should be designed, what procedures
should be followed to ensure compliance, how should the effectiveness of
the measures be calculated, and what other technical and procedural
requirements should be applied.
This would be particularly important in
the case of ozone FIP's because they would probably require nontraditional
control measures and close cooperation among many different agencies.
Historically, ozone has been reduced by controlling large stationary
sources of volatile organic compound (VOC) and automobile tailpipes.
However, it appears that further reductions in ozone levels would require
greater control of smaller sources, consumer product formulations, and
gasoline consumption.
Since these types of controls have not been imple-
mented to a great extent in the past, new guidance would have to be
developed.
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To ensure national consistency in the interpretation and application
of FIP requirements, EPA Headquarters would issue guidance for the 30 to
50 control measures which could be needed in the various nonattainment
areas.
The guidance would provide specific instructions and schedules on
source permitting, source testing and inspections, enforcement activities,
and program evaluation.
To the extent possible, EPA would also define
the roles of the various implementing agencies.
The EPA could use contractor assistance for all, some, or none of
the implementation guidance development.
Since the guidance would require
input from several different groups within EPA (e.g., regulation developers,
planners, permitters, and enforcers), it is assumed that the most
expeditious approach to developing the guidance would be to rely heavily
on contractor support.
For each control measure, the estimated average
contract cost would be $30,000 and the required EPA resources to administer
the contract and coordinate development of the final guidance document
would be about 2 wk-mos.
A total of $1 million and 6 wk-yrs of effort
from EPA Headquarters is assumed to be needed to produce the guidance.
Each project would take between 3 and 5 months to complete; however, they
could be done concurrently rather than consecutively.
]raining
In addition to issuing technical and procedural guidance, EPA
Headquarters would provide training opportunities to improve implementation
capabilities of the appropriate staff and ensure consistent interpretation
of guidance.
The training program would include a near-term effort to
instruct implementation personnel on the general requirements of each
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control measure tn the FIP's.
The program would also address implementation
issues on specific control measures on a longer-term basis through
correspondence courses and workshops.
Supplemental to the formal training
program, Headquarters staff would be available for consultation in their
respective areas of expertise on an as-needed basis.
The near-term training effort would consist of three separate workshops
conducted in each of the ten EPA Regions.
The workshop material would
cover the implementation of mobile source controls (including transportation
control measures) and stationary source controls.
The mobile source
workshop would include instructions on implementing vehicle tailpipe
controls and gasoline volatility controls.
An extra session on 11M
procedures. may be conducted in Regions with areas that need to initiate
an 11M program.
The workshop on stationary sources would include information
on new categories of point and area sources. as well as instructions on
how to improve and enforce regulations on currently controlled sources.
A specific workshop would be held for transportation control measures
(TCM's) to discuss the roles of EPA and State and local planning agencies
in implementing programs that would improve driving patterns or reduce
vehicle-miles traveled (VMT).
Estimated developmental costs for each of the three types of workshops
would be $150.000 in contract money and 24 work-months (wk-mos) for EPA.
About five Regional personnel and two or three State or local personnel
are expected to participate in each workshop.
Total Regional Office
effort is assumed to be about 14 wk-yrs. and State effort would be an
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additional 7 wk-yrs.
Travel related to the workshops would be about
$70,000 for EPA and $14,000 for States.*
The longer-term aspect of the training program would include more
specialized courses and workshops on implementing the different components
of the FIP.
For example, if EPA Regional personnel encountered difficulties
in implementing or enforcing a particular regulation, then Headquarters
would organize and present further instructions on that regulation.
Through ongoing dialogue with the Regions, Headquarters would assess the
specific needs (e.g., test methods, enforcement issues, definitions,
etc.) and address them as thoroughly and expeditiously as possible.
An
estimated budget of $300,OOO/yr would be needed to develop additional
training opportunities.
Headquarters would operate the training program
at a level-of-effort of 24 wk-mos/year.
Assuming that each Region would
require about 20 person-weeks of training each year, a total resource
effort of 4 wk-yrs would be devoted to training.
Simi 1 arly, State and
local agencies would need about 100 person-weeks of training which implies
a resource need of about 2 wk-yrs.
The EPA travel and other costs would
be $20,000 per year and an additional $4,000 would be needed for State
travel.
*Travel costs are assumed to be $5,000 for each EPA Regional Office
work-year and $2,000 for each State work-year. This same assumption
applies to estimates of resource requirements for implementation
activities.
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Other long-term act ivit i es to suppl ement the formal trai ni ng program
would include periodic newsletters, policy and guidance memorandums, and
Headquarters staff available to answer questions on their areas of
expertise.
No resources have been estimated for these activities because
they would not involve any new responsibilities for the Office of Air
Quality Planning and Standards staff.
Mobile Source Control Program
Mobile source emissions comprise about 50 percent of the total
emissions inventory for nonattainment areas.
Although substantial emission
reductions have already been achieved through the Federal Motor Vehicle
Control Program (FMVCP) and an 11M program, the FIP's would include
measures to achieve considerable reductions in mobile source emissions.
The types of mobile source-related controls that might be included in a
FIP are more stringent tailpipe controls, an enhanced 11M program, a
limit on gasoline volatility, refueling (Stage II) controls, and conversion
of fleets to methanol-powered vehicles, and transportation control measures
(TCM' s).
These controls are discussed in greater detail in the following
chapter on strategy selection.
This chapter focuses on implementation
requirements.
For each EPA Regional Office wk-yr, about $5,000 would be
needed to cover "other" costs, primarily for travel.
Similarly, each
State wk-yr would need $2,000 to cover other costs.
FMVCP (Tailpipe Controls) - Currently, motor vehicle manufacturers
are required to equip automobiles and light-duty trucks with air pollution
control devices to comply with Federal emission standards.
These control s
have reduced total motor vehicle emissions of hydrocarbons (Vac's) by
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about 30 percent"since their implementation.
It is possible to achieve
even greater emission reductions from automobiles by reducing IIcold
startll emissions through the use of a heated catalyst.
Simi 1 arly, 1 i ght-
duty truck emissions could be reduced to the same level (per vehicle) as
automobile emissions as, in fact, they already are in many models.
Motor vehicle tailpipe controls are implemented in the following
manner.
First, EPA promulgates the emission standard and indicates the
test procedure that manufacturers are required to perform on each vehicle
model as adequate to the emission standard.
Proper manufacturing procedures
are verified by EPA spot-checks on the assembly line.
Fi nally, the
integrity of the air pollution control equipment is checked by random
checks of privately-owned automobiles.
Major problems with control
equipment may prompt a recall of the affected vehicles.
Whil e thi s type
of program cannot ensure that every vehicle meets the EPA emission standard,
it is a cost-effective way to evaluate manufacturing trends and correct
deficiencies if necessary.
Implementing more stringent tailpipe controls may involve some
administrative costs; however, general program implementation would not
require any additional resources because the program structure is already
in p 1 ac e .
Thus, no additional resource or time requirements are listed
here.
It is important to note, however, that increasing the stringency
of the motor vehicle standards may require legislative action.
11M Programs - There are currently about 40 11M programs operating
throughout the country to control VOC emissions.
The programs range in
size from 100,000 to 13,000,000 vehicles.
11M has been generally successful
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in reducing hydrocarbon emissions, but not all of the local programs are
as effective as they could be.
Under a FIP scenario, in addition to
requiring 11M programs in all other nonattainment areas, EPA would impose
a more stringent standard that may require upgrades of existing programs.
The EPA would implement centralized, enhanced 11M programs in the 20
nonattainment areas not currently operating 11M programs.
A central i zed
program is one in which high-volume inspection stations are operated,
usually by a contractor, for the sole purpose of testing tailpipe VOC
emissions and checking for tampering.
The inspectors would test each
motor vehicle biennially and issue a certification form for any vehicle
that meets the "enhanced 11M" emi ssi on standard.
Working with the State
Department of Transportation (DOT), EPA would enforce the 11M program by
requiring the certification form to be submitted with the application for
State license tag renewal.
Implementation of 11M programs would require large capital expenditures
for land and facilities.
It is estimated that a representative area with
1,000,000 automobiles would require about 40 inspection stations at a
total start-up cost of $10,000,000.
For 20 areas, the total capital cost
would be $200,000,000.
The potential costs of program upgrades in the
other 40 areas are not included.
The EPA assumes that about one-third of the nonattainment areas will
choose to continue operating their present 11M programs without further
assistance from EPA.
The remaining 40 areas will be operated by Federal
contractors for a cost of about $4/car.
For 40 representative areas,
the total operating costs would be $160,000.000/yr.
Ordinarily, capital
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and operating costs are recovered by the individual vehicle inspection
fees.
However, more than likely this would not be possible for an 11M
program administered by the Federal government.
The oversight of each 11M program is expected to require resources
of about 12 wk-mos to audit the inspection stations, 4 wk-mos to analyze
the data submitted, and 4 wk-mos for contract management activities.
It is assumed that States would be involved in as much as 25 percent of
these activities throughout the country and the EPA Regional staff would
perform the remaining 75 percent.
The total effort for EPA Regional
Offices would be 20 wk-yrs; for States, 10 wk-yrs.
In some areas, the
data analysis activities may include research-oriented analyses that
ultimately may be used to improve the effectiveness of 11M programs in
many areas.
Headquarters oversight would require about 24 wk-mos for all
areas.
Gasoline Volatility - Controlling the volatility of gasoline would
significantly reduce refueling and evaporative emissions from motor
vehicles.
Implementation of this control measure could occur at various
stages in the gasoline marketing chain, but the most effective point of
control would be the refinery.
To implement volatility controls, EPA would hire a contractor to
locate all the refineries in the nonattainment area and mail them
information on the new volatility standard.
The contractor would also
mail each source a permit application form, which the source would be
required to complete and submit.
The testing and inspection program
would consist of an annual test and inspection at each refinery and random
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spot-checks at various service stations.
(Service stations should be
inspected to ensure that no alcohol or butane is added to the gasoline at
the pump.)
Finally. EPA would follow-up with any enforcement activities
necessary to bring all sources into compliance.
It would take about 4 years to implement full volatility control
programs in each nonattainment area.
Resource requirements for each area
are estimated to be the following:
$50,000 for a contractor to locate
sources and prepare and send information; 4 wk-mos for EPA or States
to review permit applications; 10 wk-mos for EPA or States and $250,000
for a contractor to perform testing and inspections and 2 wk-mos for
contract management activities.
It is assumed that Stats will be involved
in about 25 percent of these activities.
Headquarters oversight and
enforcement procedures will require about 24 wk-mos.
Stage II - Controlling refueling emissions from automobiles by means
of Stage II controls will achieve significant VOC emission reductions in
the near-term.
Implementation efforts for Stage II controls would be
directed solely at the service stations and would, for the most part,
follow the same scenario as volatility controls.
First, a contractor
would be hired to locate all service stations in the nonattainment area
and mail them appropriate information on the newly promulgated control
requirements.
Each source would be required to complete and submit a
permit application.
The EPA would then set a schedule to inspect each
source at least biennially.
No testing would be done due to the large
number of sources and the assumption that the standard would require
use of certain equipment rather than a certain emissions level.
Finally,
EPA would conduct enforcement activities as necessary.
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This control measure could be implemented within 2 to 3 years of
promulgation.
Associated resource requirements for each nonattainment
area that does not yet have Stage II controls are about $100,000 for a
contractor to locate sources and prepare and send information, 6 wk-mos
for EPA to review all permit applications, 12 wk-mos for EPA and $250,000
for a contractor to perform source inspections (which may be conducted in
conjunction with volatility inspections), and 2 wk-mos for contract
management activities.
States are expected to be involved in about 25
percent of these activities.
It will require about 24 wk-mos for EPA
Headquarters to carry out necessary oversight and enforcement procedures.
Transportation Control Measures (TCM's) - TCM's are intended to
reduce the vehicle miles of travel in an area and thereby reduce mobile
source emissions.
Historically, TCM's have not been a major component of
ozone control strategies due to their high social impacts and relatively
low emission reductions.
TCMls, such as ridesharing, high occupancy
vehicle lanes, right-hand turn lanes, etc., are also difficult, if not
impossible to enforce at the Federal level.
Under the FIP scenario, the
primary TCM's considered for implementation would be gas taxes, vehicle
taxes, and a combination of ridesharing, work schedule changes, and
parking taxes.
The taxes may be collected by the States and used to fund
the development or improvement of public transit systems.
The implementation
requirements of each are discussed below.
(a) Gas Taxes - Any gas tax imposed as part of a FIP would be
administered in the same way as current gas taxes.
Implementing a
gas tax involves interaction and cooperation with various State agencies,
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but the Regional Offices will be primarily responsible for implementation
activities.
To be fully effective, a gasoline tax would be administered as far
"Up the pipeline" as possible, preferrably at the refinery.
In addition,
it might be applied over a large area, even nationwide, to discourage
vehicle owners from driving to attainment areas to buy gasoline.
It is
estimated that the administration of this program would require about 180
wk-mos per EPA Region.
Approximately 12 wk-mos of EPA Headquarters
resources would be required for accounting and tracking purposes.
(b) Vehicle Taxes - Implementation of vehicle taxes would require
State involvement.
The most convenient way to apply and enforce a vehicle
tax on cars in addition to primary family cars would be to include it in
the annual license tag renewal process.
In this way, all registered
automobiles would be reviewed for applicability.
Unfortunately, most
States do not currently have a system for determining how many cars are
owned by each family.
Assuming that all States have some type of computer-
ized data base, EPA would hire a contractor to upgrade the data base
format so that only one car per address could be 1 i sted as a "primary
famil y car. II
This would cost an average of $200,000 in each of the 35
States that would be in the program.
The States' role in implementing a vehicle tax program would be to
process the necessary forms in conjunction with the license tag renewal
process, collect the tax, and report any violations to EPA.
Thi s woul d
require an average of 36 wk-mos for each nonattainment area.
The E PA
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IV-IS
will be responsible for tracking the collection of taxes and initiating
any necessary enforcement procedures.
This will require about 15 wk-mos
per area for Regional personnel and 12 wk-mos for Headquarters.
(c) Ridesharing, Work Schedule Changes, and Parking Taxes - Of
the three TCM's considered for inclusion in the FIP's, this measure would
be the most difficult to implement.
The only feasible method of implementa-
tion would be to develop a cooperative effort among companies employing
more than 50 people, State or local transportation agencies, and EPA
Regional Office staff.
Companies would be required to hire one program
coordinator for every 200 employees.
This person would be responsible
for coordinating carpools, ensuring that employees are all on compressed
work-schedules (e.g., 4-10 hour days/week or 8-9 hour days followed by
1-8 hour day and a day off). and overseeing the parking facilities and
associated fees.
Agency personnel would work with the company coordinators to ensure
that the programs meet EPA requirement, perform spot-checks at parking
lots to ensure proper administration of parking fees, and keep an account
of all taxes collected.
These tasks would probably require an average of
48 wk-mos per area.
It is assumed that the nationwide resources required
to implement this measure would be divided evenly between EPA and the
State or local agencies, although the exact split would vary in each
area.
Approximately 12 wk-mos of EPA Headquarters resources would be
needed for program coordination.
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Stationary Source Control Program
Control of large stationary sources has always been an integral
component of the VOC control program.
Under the FIP scenario, EPA would
expand the scope of these controls to include other categories of large
point sources not previously regulated, smaller point sources, and area
sources.
In addition, EPA would revise or clarify existing reasonably
available control technology (RACT) and new source review (NSR) regulations
so that further emission reductions could be achieved from categories that
are already regulated.
The specific control measures to be applied are
discussed in detail in the following chapter on strategy selection.
In
this section, only general implementation requirements for point and area
sources are addressed.
Point Sources - The program for implementing controls at stationary
point sources would be similar to the present program, in that it would
include permitting, inspection, and enforcement activities.
It is assumed
that the regulation of 20 to 30 new categories of existing stationary
sources, including treatment, storage, and disposal facilities (TSDF's) for
hazardous wastes, would result in about 50 additional point sources needing
to be controlled in each nonattainment area.
The improvement of existing
RACT regulations may result in five more sources per area needing to be
controlled, and improvements in existing NSR procedures may result in an
additional increase of five sources per area.
Tightening existing regulatory
limits may add five more sources per area to the list of sources needing
to be controlled.
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In determining resource requirements for the stationary point source
control program, EPA assumes that State and local agencies would continue
their existing programs, supported by their own legislatures and the
section 105 air program grants.
In addition, it is assumed that States
would want to participate in about 50 percent of the implementation
activities for the new point source controls.
Thus, EPA would be responsible
for the remaining half of the permitting permitting, inspection, and
enforcement activities only at those facilities not presently regulated.
It is estimated that reviewing permit applications wo~ld require about 36
wk-mos per nonattainment area.
Testing and inspection activities in each
area will require about $150,000 in contract money and 60 wk-mos per
year.
A total of 84 wk-mos of Headquarters resources would be required
for oversight and interaction with the Regions (12 wk-mos, cleaning up
existing regulations; 24 wk-mos, first set of new regulations; 12 wk-mos,
TSDF's; 12 wk-mos, tightening existing regulations; 24 wk-mos, second set
of new regulations).
Area Sources - The FIP control strategy would focus more heavily on
the control of area sources such as architectural coatings, consumer and
commercial solvent-based products, and adhesives than past SIp.s have.
Controlling these categories presents certain implementation problems,
though.
The large number of small sources (e.g., a single can of house
paint or adhesive) do not lend themselves easily to control or inspection.
Therefore, it is assumed in the FIP scenario that controls on area sources
would be impl emented as far "upstream" as possibl e (i .e., at the manufacturer
and/or wholesaler) to centralize the implementation activities.
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To implement area source controls, EPA would need to interact extensively
with the appropriate manufacturers during and after development of the
regulations.
There are many types of products that would be regulated,
and EPA would need to work with the manufacturers in reviewing product
formulations and establishing compliance schedules.
Next, EPA would
initiate a certification program in which any product that is formulated
to meet the solvent content limit is certified for sale in nonattainment
areas.
Manufacturers would indicate this certification in some conspicuous
place on their products' labels.
Estimated resource requirements for the
reformulation and certification procedures are about $750,000 in contract
money and 15 wk-mos for EPA Headquarters to oversee the project.
Inspection activities would occur at the manufacturer, wholesaler,
and retailer.
The EPA would conduct spot-checks at the manufacturing
facilities to ensure that the products are formulated according to EPA
standards.
Inspection at wholesale and retail facilities would be to
ensure that only EPA-certified products (i .e., only products with EPA's
certification on their labels) are offered for sale in nonattainment
areas.
These activities would require about 24 wk-mos annually per area
to be divided evenly between EPA Regional Offices and State or local
agencies that want to participate.
Any violations in the manufacture or sale of area source products
would be addressed by EPA Headquarters, due to the national scope of this
control measure.
Appropriate enforcement activities would require about
9 wk-mos per year, on the average.
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Overall Program Evaluation and Audit
Program evaluation and audit is critical to successful implementation
of a FIP.
As was discussed earlier, a FIP would rely heavily on the use
of nontraditional control measures such as TCM's and area source controls.
Because previous control, tracking, and auditing efforts typically have
been aimed primarily at large point source controls, there is a need to
develop and use nontraditional evaluation and auditing systems to determine
the success of these new types of control measures.
Developing such
systems would not be an easy task because of the large number of small
sources that require control under the FIP strategy and the corresponding
need for each control measure to be implemented with full effectiveness.
However, the nature of the control strategy only strengthens the need for
a systematic means of evaluating whether each source is actually achieving
its expected emission red~ctions and what the resulting impacts are on
air quality. To assist Regional Offices in identifying problems that may
be hindering program effectiveness, Headquarters will periodically audit
each program.
Evaluation of Emissions Reductions - The effectiveness of the control
program outlined in the FIP can be measured, in part, by the extent to
which the expected emission reductions have actually been achieved.
To
determine whether the FIP is being implemented effectively, emissions
reductions would be tracked closely in each nonattainment area for
stationary (point and area) and mobile sources.
For stationary sources,
the most recent inspection reports would be evaluated and the emissions
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inventory updated.
For mobile sources, the transportation network and
estimated VMT would be revised so that "MOBILE3" could be used to model
the current emissions and the emissions inventory could be updated.
In evaluating the updated emissions inventories, EPA would assess
which sources or source categories need further attention in terms of
guidance, training, or implementation.
The results of this review may be
used by Headquarters personnel to address specific problems in the context
of the long-term training program.
The results may also be used by
Regional personnel to determine corrective measures that should be taken
to bring noncomplying sources into compl iance.
In general, the emissions
inventory updates would be used to give EPA an accurate assessment of the
current VOC emissions and to provide a basis for targetting future
implementation efforts.
Tracking emission reductions would be an ongoing process requiring
cooperation among several agencies.
Options for assigning specific tasks
to EPA and State and local agencies include the following:
1.
EPA tracks and analyzes stationary source emission reductions,
updates the National Emissions Data System (NEDS) inventory, and prepares
input for and runs MOBILE3.
2.
State or local air agency tracks emissions reductions, updates
NEDS, and works with the appropriate DOT to prepare input for MOBILE3;
and EPA analyzes emissions inventory and runs MOBILE3.
3.
State or local OOT prepares input for MOBILE3; and State or
local air agency tracks and analyzes stationary source emissions reductions,
updates NEOS, and runs MOBILE3.
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The EPA assumes that option No.2 is most likely to occur.
Following
the scenarios described in earlier sections, the State or local air
agencies would be responsible for inspecting both stationary and mobile
sources, and the OaTis would continue tracking changes in the local
transportation network.
It would be a logical extension of these
responsibilities to update the NEDS inventory based on results of the
inspections and provide information on the transportation network structure
and VMT to EPA for use in MOBILE3.
The estimated costs of enacting this scenario in each nonattainment
area would be as follows:
5 wk-mos for the State to evaluate inspection
reports and determine emissions reductions, 3 wk-mos for the State to
update the NEDS inventory, 4 wk-mos for the State to revise MOBILE3
input information, 2 wk-mos for EPA to run MOBILE 3, and 3 wk-mos for EPA
to assemble the total revised inventory.
About 12 wk-mos of Headquarters
resources will be required for evaluation of the 60 inventories.
Evaluation of Air Quality - The primary objective of a FIP is to reduce
ambient ozone to a level below the national ambient air quality standards
(NAAQS).
Through tracking annual changes in ambient levels of ozone and
its precursors [nonmethane organic compound (NMOC) and nitrogen oxides
(NOx)], EPA could evaluate the air quality impact of implementing a FIP in
a particular area and establish whether the area is progressing toward,
or has already attained, the ozone NAAQS.
If an area's emissions or air quality data have changed substantially
since the FIP was developed but the area is still not in attainment, it
may be desirable to establish a new emissions reduction target for the
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area.
The most recent air quality data, as well as current emissions
data, will need to be used as inputs to the empirical kinetic modeling
approach (EKMA) computer model that establishes the percent reduction
target for an area.
A satisfactory air quality network consists of three to five ozone
monitors and one to two NMOC/NOX monitors, depending on the population
and design value of the urban area.
Most of the air quality networks are
sufficient to adequately characterize the ozone situation; however, EPA
has identified some areas where additional monitors would be needed to
meet basic requirements.
For example, New Orleans and Atlanta both need
more extensive ozone networks.
In addition, many areas need an additional
NMOC/NOx monitor.
Upgrading these networks should bring the deficient
areas up to a satisfactory level of monitoring.
The EPA expects that State and local air agencies would want to retain
the responsibility of operating their existing air quality networks.
Upgrading the existing networks would require an average of one new monitor
per area.
Assuming that States would choose to operate the new monitors
as well, EPA would need to fund $20,000 per monitor for data analysis
and 6 wk-mos for State personnel to track the air quality data in each
area.
About 2 wk-mos per area of Regional resources and 12 wk-mos of
Headquarters resources will be needed for data analysis and evaluation.
Auditing - To understand how well the overall control program
has been designed and implemented, EPA Headquarters would conduct annual
or biennial audits in conjunction with the National Air Audit System
(NAAS).
The audits would consist of a written survey and file review
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pertaining to the elements of FIP implementation discussed in previous
sections.
Through the audit, EPA would seek to uncover areas of program
deficiency and suggest practical means of correcting them.
In addition,
EPA Regions would have an opportunity to express their needs for further
assistance in permitting, testing, inspection, and enforcement of both
mobile and stationary source control measures.
The following questions would be addressed for a number of regulations
in the written survey component of the audit:
(1) Is the regulation
effectively written? and (2) Is the regulation effectively enforced?
The
first question would be answered by specific analyses of whether the
regulation contains the necessary components, whether the intended emission
reductions can be achieved from source compliance with the enforceable
emission 1 imit, and what types of variances and exemptions have been.
granted to specific sources.
Answering the second question would require
information on whether all sources in the category have been identified,
what proportion of applicable sources are inspected, how compl iance
determinations are made, and what type of follow-up is conducted at
sources found to be violating the regulation.
The file review that EPA conducts would seek answers to the following
questions for the same regulations addressed above:
(1) How effectively
are sources complying with the regulations? and (2) What emission reductions
are achieved as a result of the regulation?
In reviewing source permits
and inspection reports, EPA would hope to gain insight on the compliance
rates of selected source categories in order to answer the first question.
In calculating emission reductions resulting from the regulation, EPA
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Headquarters would review the Region's updated emissions inventory and
compare it to the projected emission reductions for that source category.
The audit procedure, from development through analysis, would take
between 6 and 9 months to complete.
Development of the audit would require
about 12 wk-mos of EPA resources to formulate the surveys and plan the
f i 1 e rev i ews .
The audit would be distributed as part of the NAAS, so
associated resources (for copying, mailing, etc.) are considered to be
absorbed in the overall budget for that activity and are not reported
here.
The EPA Regional Offices would need about 2 wk-mos to complete the
survey for each nonattainment area.
The file reviews would be conducted
by a contractor for an estimated cost of $7,500 each.
The results of the
entire audit would then be analyzed by EPA Headquarters personnel at a
total estimated level-of-effort of 48 wk-mos.
FIP Modifications and Supplemental Planning
Realistically, it is unlikely that the original FIP developed for an
area would be "perfect" and not need to be revised in the future.
A
particular FIP could require changes or revisions as EPA identifies
problems and possible solutions.
Results of the program evaluation and audit, the development of new
types of TCMls, and the identification of long-term adverse impacts are
some of the factors that may influence whether a FIP needs to be modified.
These factors may indicate the need for an area to remove certain control
measures from its FIP due to implementation difficulties, and/or add
other measures to make up for deficiencies in emission reductions being
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IV-25
achieved.
Other modifications that may be made include revisions to the
implementation schedule, emissions inventory, projected emission reductions,
and modeling analysis.
Some supplemental planning may need to be performed. particularly if
there are changes in the roles of State and local planning agencies or
funding for specific control measures.
Supplemental planning may take
the form of changes in enforcement practices, redefinitions of agencies.
roles, or reprioritization of control measures.
FIP modifications and supplemental planning efforts for each area
would require EPA Regional resources of as much as 24 wk-mos annually,
depending on the extent to which revisions need to be made.
These resources
would support the following types of activities:
analysis of the evaluation
and audit process results to determine what type(s) of modifications
should be made, analysis of impacts created by a particular modification,
development of plans and schedules for making the suggested modifications.
and interaction with State and/or local planning agencies to discuss
changes in roles or funding caused by the suggested modifications.
Most
of the functions would be performed by Regional personnel, with some input
or review by Headquarters at a total level-of-effort of 60 wk-mos.
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V.
SELECTION OF MEASURES
Introduction
This chapter describes the types of measures likely to be contained
in Federal implementation plans (FIP's) and the process used in this
analysis to select a set of measures for three example areas.
Prior to
selection of measures, a simplified modeling analysis employing limited
data was used to estimate the level of emission reduction needed to
achieve attainment in each nonattainment area.
This modeling is far less
detailed than the modeling which would occur in an actual State implementa-
tion plan (SIP) or FIP and it provides only an approximation of the
reductions necessary for attainment.
More reliable estimates of attainment
targets would come from intensive data collection effort and detailed
modeling that would take place in development of a real FIP.
However,
for this study, approximate estimates are prerequisite to selecting
control measures which might provide for attainment by a specific date.
Consistent with the short time deadline, the measures presented in
this chapter have originated through a quick process of "brainstorming"
rather than a more deliberate and lengthy analysis.
Measures easi ly
implemented nationally and other measures considered reasonable [Federal
Motor Vehicle Control Program (FMVCP), Reid vapor pressure (RVP) control,
inspection and maintenance (11M), and certain point and area source
measures or policies] were assumed to apply in all post-1987 areas.
11M
is assumed to be one of these measures based on the Act requirement of
this measure in all areas unable to show attainment by 1982, and EPA's
current Ipost-1982" policy presumptively requiring 11M in any post-1982
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V-2
area unable to attain by 1987 without it.
Additional stationary source
and mobile source measures and transportation control measures (TCM's)
are obviously needed in many areas if attainment is to be reached.
Wh i 1 e
estimates of cost and feasibility for these additional measures have been
attempted for most measures, these should be taken as "ballpark" estimates
rather than reliable data.
Their purpose is to present estimates of what
the measures might achieve and at what cost relative to one another.
Estimates of the contents of a FIP have not been made for each of
the 73 metropolitan areas exceeding the ozone national ambient air quality
standards (NAAQS).
Rather, three generic areas needing low (25 percent),
medium (50 percent), and high (75 percent) percent emissions reductions
have been selected to represent the other areas.
The contents of a FIP
for individual areas can then be compared to the contents of the nearest
generic area.
Generic strategies were developed for short-term (1992)
and longer term (1995, 2000, and 2010) attainment deadlines.
Modeling Analysi~
To estimate the emissions reductions needed to attain, the Office of
Mobile Sources (OMS) performed simplified modeling of individual metropolitan
areas using the Empirical Kinetic Modeling Approach (EKMA).
The modeling
provides approximate estimates of city-specific emission reduction
percentages based on a 1983 emission inventory.
(The modeling used the
Dodge chemical mechanism*, which EPA is in the process of replacing with
the more accurate carbon bond 4, or CB-4, mechanism.
The CB-4 mechanism
*A chemical mechanism automatically simulates ozone formation.
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V-3
reflects the most current thinking regarding chemistry of ozone formation
in urban plumes and would be used in actual FIP modeling.)
Data - The modeling uses ambient ozone data from the period 1982-
1984.
The ozone data come from monitors located within the boundaries
of the metropolitan areas.
This study does not consider ozone measured in
a downwind area and originating in another metropolitan area.
It also
does not consider more than one upwind area contributing to violations at
a downwi nd site.
Considering such situations would likely increase the
design values and reduction targets for certain major urban areas (Chicago,
New York, etc.) and decrease the design values and reduction targets
results in smaller areas downwind (Atlantic City, Allentown, etc.).
Unlike a real SIP or FIP which would model the highest five ozone
days in a 3-year period, this simplified analysis modeled only the day on
which the fourth highest ozone value was measured.
Although this simpli-
fication reduced the amount of time needed to perform the modeling, the
assumption is made that the fourth highest reduction target occurs on the
day of the fourth highest ozone.
Although this occurs frequently in
actual SIP's, it is not a reliable assumption.
In actual FIP modeling,
the fourth highest reduction target could occur on any of the five highest
ozone days.
Model inputs for mixing height and solar intensity were determined
from data for just three cities:
Los Angeles, Denver, and St. Louis.
Each of the 73 metropolitan areas was assigned to one of these three
c it i es .
Model inputs for these data for each city were then selected
accord i ng to it s city "type. II
Most cities fell into the St. Louis category.
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V-4
Table V-I shows nonmethane organic compounds (NMOC) and nitrogen
oxides (NOX) data taken from measurements during 1984 and 1985. Table
V-I includes 26 of the 73 metro areas listed in Table II-I.
NMOC/ NOx
ratios for the 47 cities not measured during the 2-year study were set to
a median value of 11.6:1 derived from the cities participating in the
study.
TABLE V-I
MEDIAN NMOC/NOx RATIOS (1984-1985)
1 . Ak ron, OH
2. Atl anta, GA
3. Baton Rouge, LA
4. Beaumont, TX
5. Bi rmi ngham, AL
6. Boston, MA
7. Charlotte, NC
8. Chattanooga, TN
9. Cincinnati,OH
10. Cleveland, OH
11. Clute, TX (Brazoria)
12 . Da 11 as, TX
Fort Worth, TX
13. El Paso, TX
14. Houston, TX
15. Indianapolis, IN
16. Kansas City, MO
17. Lake Charl es, LA
18. Memphis, TN
19. Miami, FL
West Palm Beach, FL
20. Philadelphia 1, PA
Philadelphia 2, PA
21. Portland, ME
22. Ri chmond, VA
23. St. Louis, MO
24. Texas City (Galveston)
25. Washington, DC
26. Wilkes Barre, PA
1984
12.8
10.4
1985
Metro Area
25.3
11.7
10.4
16.7
9.1
14.9
53.2
7.6
23.7
16.0
11.5
15.1
12.9
10.9
9.9
12.9
13.3
14.2
7.5
24.6
11.8
11.8
11.9
8.5
23.7
11.6
10.5
37.7
9.3
14.3
6.5
9.5
11.2
9.6
28.7
8.7
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V-5
Transport -For this analysis, default estimates of present ozone
transport were based on samples collected upwind of cities selected from
Table V-I.
These estimates of transported ozone for 1983 were 0.07 ppm
for all areas.
Transported NMOC and N~ were assumed to be zero in this
analysis.
Future levels of transported NMOC, N~, and ozone would be estimated
when modeling for real SIP's or FIp.s.
Although the preferred approach
for estimating future NMOC, N~, and ozone is to utilize a regional scale
model (e.g., ROM, RTM) , results from regional scale models may not be
available until 1991.
An alternative approach is to estimate future
ozone transport levels from EKMA curves and typical NMOC/NOx ratios.
Future NMOC and NOx transport levels are assumed to be reduced in proportion
to upwind reductions in NMOC and N~ emissions.
In this simplified analysis, however, it was not possible to use
either of the above procedures.
Instead, this study utilized the curves
in the current guidelines on the use of city-specific EKMA.
These curves
resulted in future transported ozone equal to present default levels of
transported ozone (0.07 ppm).
Future transported NMOC and N~ are assumed
to be zero.
Role of NOll - In past EPA policy regarding SIP attainment demonstration,
substitution of N~ control for VOC control has not been allowed.
This
appeared reasonable due to the relatively low NMOC/N~ ratios (less than
10:1 in most cities) and the desire for the application of nationally
consistent VOC control technology.
Recently, NMOC/N~ ratios have
increased, due mainly to improved accuracy in the measuring devices, and
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V-6
NOx control in some cities may be more effective than previously believed.
Small cities with high VOG reduction targets and high NMOC/NOx ratios
such as Beaumont, Texas, may benefit from a primarily NOx control strategy,
assuming that controllable NOx sources can be found.
It was decided early on in this study that NOx control strategies
were too complex for consideration by this short-term FIP study.
Becaus e
NOx reductions can either increase or decrease ozone depending on the
NMOC/NOx ratio, detailed modeling and city-specific analyses are required
to support a control strategy emphasizing NOx reductions in place of VaG
reductions.
There is also controversy (e.g., Los Angeles) over whether
NOx reductions are needed in addition to the VOG reductions to reach
attainment.
However, generally there is little dispute over whether the
VOG reductions are needed.
Therefore, the authors of this study have
assumed that attainment will be achieved if the VOC reduction target is
met.
It is further assumed that any changes in NOx emissions that occur
by the date when the VOG reductions are met do not significantly alter
the VOG reduction target.
Emission Reduction Targets - Approximate reduction targets based o~
the simplified EKMA modeling are given in Table V-2.
The use of defaul t
NMOG/NOx ratios and transport values artificially gives the same reduction
targets to cities with the same design values.
In real SIP's or FIP's,
use of city-specific data would create a greater variation of targets
among cities with common design values.
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V-7
TABLE V-2
APPROXIMATE REDUCTION REQUIRED IN 1983 VOC EMISSION INVENTORY
TO ATTAIN OZONE NATIONAL AMBIENT AIR QUALITY STANDARD
IN 73 METROPOLITAN STATISTICAL AREAS> 0.12 PPM (1982-84)
1983 Attai nment
Design Reduction Total Le vel Reduct ion
MSA or CMSA Value Ta rget Inventory Inventory Required
1982-84 1000 TPY 1000 TPY 1000 TPY
----------------- ------- --------- -------- -------- --------
1 BEAUMONT-PORT A.TX* 0.21 87% 162 21 141
2 LOS ANGELES CA 0.36 72% 1,026 290 736
3 HOUSTON TX 0.25 70% 377 114 262
4 GREATER CONN. CT 0.23 64% 255 91 165
5 NEW YORK METRO NY 0.23 64% 942 335 608
6 LAKE CHARLES LA 0.15 61% 82 32 50
7 SACRAMENTO CA 0.18 60% 112 44 68
8 OXNARD-VENTURA CA 0.21 60% 42 17 25
9 CHICAGO METRO IL 0.20 60% 614 247 366
10 BATON ROUGE LA 0.17 59% 75 31 44
11 SAN 01 EGO CA 0.20 59% 170 70 100
12 ATlANTIC CITY NJ 0.19 57% 26 11 15
13 BOSTON METRO MA 0.19 57% 363 157 207
14 N EW BE OF OR 0 MA 0.19 57% 19 8 11
15 SPRINGFIELD MA 0.19 57% 74 32 42
16 EL PASO TX 0.17 56% 40 18 22
17 PHILADELPHIA PA 0.18 54% 441 201 240
18 BALTIMORE MD 0.17 51% 186 91 95
19 GALVESTON TX 0.17 51% 48 24 24
20 MILWAUKEE WI 0.17 51% 119 58 61
21 DALLAS-FT.WORTH TX 0.16 51% 332 163 169
22 SAN FRANCISCO CA 0.17 50% 405 204 201
23 ATLANTA GA 0.17 48% 191 100 91
24 BAKERSFIELD CA 0.16 46% 54 29 25
25 FRESNO CA 0.16 46% 45 25 21
26 PROVIDENCE RI 0.16 46% 56 30 26
27 ST. LOUIS MO 0.17 44% 253 141 113
28 PHOENIX AZ 0.15 40% 117 70 47
29 SALT LAKE CITY UT 0.15 40% 87 52 35
30 BIRMINGHAM AL 0.15 38% 68 42 26
31 ALLENTOWN-BETH. PA 0.15 38% 59 36 22
32 LONGVIEW-MARSH. TX 0.15 38% 49 30 19
33 LOUISVILLE KY 0.15 38% 97 60 37
34 MODESTO CA 0.15 38% 22 14 9
35 NEW ORLEANS LA 0.15 38% 77 48 30
36 PORTLAND ME 0.15 38% 27 17 10
37 WASHINGTON DC 0.16 38% 205 127 78
38 CINCINNATI MET. OH 0.15 32% 149 101 48
*Although an 87% target is shown for Beaumont-Port Arthur, TX, a VOC strategy
is unlikely to be as effective as a NOx strategy due to high (up to 50:1)
NMOC/NOx ratios.
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V-8
TABLE V-2 (cont.)
APPROXIMATE REDUCTION REQUIRED IN 1983 VOC EMISSION INVENTORY
TO ATTAIN OZONE NATIONAL AMBIENT AIR QUALITY STANDARD
IN 73 METROPOLITAN STATISTICAL AREAS> 0.12 PPM (1982-84)
1983 Attai nment
De si gn Reduction Total Level Reduction
MSA or CMSA Value Ta rget Inventory Inventory Required
1982-84 1000 TPY 1000 TPY 1000 TPY
----------------- ------- --------- -------- -------- --------
39 DENVER-BOULDER CO 0.14 29% 180 127 52
40 BRAZORIA TX 0.14 27% 38 28 10
41 DETRO IT MI 0.14 27% 360 263 97
42 HUNTINGTON-ASH. WV 0.14 27% 34 25 9
43 LANCASTER PA 0.14 27% 37 27 10
44 MUSKEGON MI 0.14 27% 17 12 4
45 PITTSBURGH PA 0.14 27% 130 95 35
46 SAN ANTONIO TX 0.14 27% 85 62 23
47 VALLEJO-FAIRFLD CA 0.14 27% 32 24 9
48 VINE LAND-MILL. NJ 0.14 27% 16 12 4
49 WORCESTER MA 0.14 27% 53 39 14
50 RICHMOND-PETERS.VA 0.14 26% 73 54 19
51 SANTA BARBARA CA 0.15 25% 28 21 7
52 STOCKTON CA 0.13 25% 30 23 7
53 KANSAS CITY MO 0.14 23% 127 .99 29
54 CLEVELAND OH 0.14 19% 137 111 26
55 C HA TT ANOOGA TN 0.13 17% 53 44 9
56 SCRANTON-WILKES PA 0.13 13% 63 55 8
57 MEMPHIS TN 0.13 13% 78 68 10
58 MIAMI-HIALEA . FL 0.13 12% 105 93 13
59 AKRON OH 0.13 12% 64 57 7
60 CANTON OH 0.13 10% 38 34 4
61 DAYTON-SPRING. OH 0.13 10% 84 75 9
62 ERIE PA 0.13 10% 26 24 3
63 GRANO RAPIDS MI 0.13 10% 72 64 7
64 HARRISBURG-LEHI.PA 0.13 10% 61 55 6
65 NASHVILLE TN 0.13 10% 100 90 10
66 PORTSMOUTH-DOV. NH 0.13 10% 21 19 2
67 READING PA 0.13 10% 37 33 4
68 TAMPA-ST. PETE FL 0.13 10% 116 104 12
69 TULSA OK 0.13 10% 66 59 7
70 VISALIA-TULARE CA 0.13 10% 24 22 2
71 YORK PA 0.13 10% 36 32 4
72 INDIANAPOLIS IN 0.13 10% 104 94 11
73 CHARLOTTE-GAST. NC 0.13 10% 86 78 8
WEIGHTED AVG. %REDUCTION = 47% 10,078 5,299 4,780
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V-9
Comparison to Other Modeling Analysis - As a test of the accuracy of
the simplified modeling used in this study, the results can be compared
to recent photochemical grid modeling (using the Airshed model) performed
in New York and Kern County (Bakersfield, California).
Al though
photochemical grid modeling does not produce an attainment reduction
target like EKMA. grid models can evaluate whether a control strategy will
result in attainment and, therefore. can assess the adequacy of a SIP
strategy designed to meet an EKMA target.
Airshed modeling was recently performed in the New York metropolitan
area (New York, New Jersey. and Connecticut) in the OMNYMAP study.
The
1982 ozone SIP for the New York area estimated that a reduction of about
60 percent in 1980 VOC emission levels was needed to attain the standard.
(This FIP study estimates 64 percent reduction in 1983 VOC levels is
needed to produce attainment.
This more stringent target appears to
result from the use of a higher NMOC/NOX ratio.)
The full SIP control
strategy was tested for attainment by the photochemical grid model.
When
submitted, the SIP predicted a reduction of 60 percent in 1980 VOC levels
with full impl ementation of the strategy.
However. due mainly to new
mobile source emission factors, the full SIP strategy now results in an
estimated 40 percent reduction.
Not surprisingly, the grid model found
that this strategy would not produce attainment. although it would lower
peak ozone (from 0.26 ppm to 0.17 ppm) and reduce the geographic coverage
of the problem.
Thus, the grid model supports the EKMA modeling to the
extent that substantially more reduction is needed than is provided by
the current SIP.
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V-10
In Kern County, California (Bakersfield), a proposed strategy
resulting in a 35 percent decrease in 1984 VOC emissions and a 26 percent
decrease in 1984 NOx emissions ~as found by a photochemical grid model to
be inadequate to produce attainment.
The model also found that a reduction
of 51 percent in either vac or NOx would reduce ozone significantly, but
would not result in attainment.
Besides showing support for a combination
VOC/NOx strategy, these grid model results indicate that the target from
this FIP study for Bakersfield (46 percent VOC reduction from 1983 levels)
may be underestimated.
Emission Inventory
A baseline VOC inventory was developed for total mobile and nonmobile
emissions for each of the 73 metropolitan nonattainment areas.
Breakdowns
by source categories were also estimated.
In this FIP study, reductions
from control measures are expressed as a percentage of the total baseline
inventory, facilitating direct comparison to the reduction target.
Therefore, it is not as important to know the absolute size (tons/year)
of source categories as it is to know the relative mix of sources in
proportion to the total.
in Table V-3.
The mix of mobile to nonmobile sources is given
Description - The year 1983 was selected for the baseline year
because it is situated in the middle of the 3-year period 1982-84 during
which the ozone levels were measured.
Mobile source emissions were
calculated using recent MOBILE3 emission factors corrected for higher
gasoline volatility.
These and other changes in mobile source emission
factors result in increases by a factor of two in mobile source emissions
-------
V-ll
compared to recent SIP submittals.
For example, the mobile source
emissions in Table V-3 are 178,000 tons/year for Dallas-Ft. Worth and
104,000 tons/year for Atlanta.
SIP's submitted in 1986, however, show
about half as much mobile source emissions:
96,000 tons/year for Dallas-
Ft. Worth in 1983 and 52,000 tons/year for Atlanta in 1984.
Nonmobile sources were generated from the National Emissions Data
System (NEDS).
Point source emissions were summarized by county.
Area
source emissions were based on national emissions estimates allocated to
metropolitan areas by population, employment, or other parameters.
Nonmobile source emissions are also much higher than SIP estimates.
For
example, nonmobile sources for Dallas-Ft. Worth are 154,000 tons/year
compared to 65.000 tons/year in the SIP submittal.
For Atlanta, the
figures are 87,000 tons/year compared to 37,000 tons/year in the SIP.
This study has not attempted to explain the difference in these estimates.
Source Mix - A coarse breakdown of VOC emissions in the 73 areas is
given below in Table V-4.
For estimating reductions from control measures,
it was assumed that a source mix in a typical urban area would be similar
to the mix in Table V-4.
This mix was then used for the high, medium,
and low examples in assessing control measures.
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V-12
TABLE V-3
MIX OF MOBILE/NONMOBILE SORUCES IN 1983 VOC EMISSION INVENTORY
73 METROPOLITAN STATISTICAL AREAS> 0.12 PPM (1982-84)
RANKED BY 1983 TOTAL VOC INVENTORY (1000 TONS/YEAR)
MSA or CMSA Mob il e Percent Nonmob; 1 e Percent Tot a 1
----------------- ------ ------- ---------- ------- ------
1 LOS ANGELES CA 541 53% 485 47% 1,026
2 NEW YORK METRO NY 484 51% 459 49% 942
3 CH I CAGO METRO IL 254 41% 359 59% 614
4 PHILADELPHIA PA 196 44% 246 56% 441
5 SAN FRANCISCO CA 236 58% 169 42% 405
6 HOUSTON TX 141 37% 236 63% 377
7 BOSTON METRO MA 196 54% 167 46% 363
8 DETROIT MI 160 45% 199 55% 360
9 DALLAS-FT.WORTH TX 178 54% 154 46% 332
10 GREATER CONN. CT 108 42% 148 58% 255
11 ST. LOUIS MO 110 43% 143 57% 253
12 WASHINGTON DC 123 60% 82 40% 205
13 ATLANTA GA 104 55% 87 45% 191
14 BALTIMORE MD 94 50% 92 50% 186
15 DENVER-BOULDER CO III 62% 68 38% 180
16 SAN DIEGO CA 92 54% 78 46% 170
17 BEAUMONT-PORT A.TX 21 13% 140 87% 162
18 CINCINNATI MET. OH 67 45% 82 55% 149
19 CLEVELAND OH 68 50% 69 50% 137
20 PITTSBURGH PA 74 57% 56 43% 130
21 KANSAS CITY MO 65 51% 62 49% 127
22 ru LWAUKEE WI 59 50% 60 50% 119
23 PHOENIX AZ 78 67% 39 33% 117
24 TAMPA-ST. PETE FL 76 66% 40 34% 116
25 SACRAMENTO CA 70 63% 42 37% 112
26 MIAMI-HIALEA FL 66 63% 39 37% 105
27 INDIANAPOLIS IN 52 50% 53 50% 104
28 NASHVILLE TN 40 40% 60 60% 100
29 LOUISVILLE KY 45 46% 52 54% 97
30 SALT LAKE CITY UT 56 65% 31 35% 87
31 CHARLOTTE-GAST. NC 43 50% 43 50% 86
32 SAN ANTONIO TX 57 68% 27 32% 85
33 DAYTON-SPRING. OH 42 50% 42 50% 84
34 LAKE CHARLES LA 8 9% 75 91% 82
35 MEMPHIS TN 40 51% 39 49% 78
36 NEW ORLEANS LA 41 53% 36 47% 77
37 BATON ROUGE LA 22 30% 53 70% 75
38 SPRINGFIELD MA 28 37% 47 63% 74
39 RICHMOND-PETERS.VA 34 47% 39 53% 73
40 GRAND RAPIDS MI 25 35% 46 65% 72
41 BIRMINGHAM AL 39 57% 29 43% 68
42 TULSA OK 39 59% 27 41% 66
43 AKRON OH 28 44% 36 56% 64
44 SCRANTON-WILKES PA 28 45% 35 55% 63
45 HARRISBURG-LEHI.PA 24 40% 37 60% 61
46 ALLENTOWN-BETH. PA 27 46% 32 54% 59
47 PROVIDENCE RI 25 45% 31 55% 56
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V-13
TABLE V-3 (cont.)
MIX OF MOBILE/NONMOBILE SOURCES IN 1983 VOC EMISSION INVENTORY
73 METROPOLITAN STATISTICAL AREAS> 0.12 PPM (1982-84)
RANKED BY 1983 TOTAL VOC INVENTORY (1000 TONS/YEAR)
MSA or Cr~SA Mobile Percent Nonmobile Percent Total
----------------- ------ ------- ---------- ------- ------
48 BAKERSFIELD CA 31 57% 23 43% 54
49 WORCESTER MA 20 37% 33 63% 53
50 CHATTANOOGA TN 21 39% 32 61% 53
51 LONGVIEW-MARSH. TX 10 21% 38 79% 49
52 GALVESTON TX 12 25% 36 75% 48
53 FRESNO CA 30 66% 16 34% 45
54 OXNARD-VENTURA CA 25 61% 16 39% 42
55 EL PASO TX 27 68% 13 32% 40
56 BRAZORIA TX 9 22% 30 78% 38
57 CANTON OH 21 56% 16 44% 38
58 LANCASTER PA 15 41% 22 59% 37
59 READING PA 14 38% 23 62% 37
60 YORK PA 16 45% 20 55% 36
61 HUNTINGTON-ASH. WV 14 41% 20 59% 34
62 VALLEJO-FAIRFLD CA 21 66% 11 34% 32
63 STOCKTON CA 22 71% 9 29% 30
64 SANTA BARBARA CA 16 58% 12 42% 28
65 PORTLAND ME 11 40% 16 60% 27
66 ER IE PA 11 42% 15 58% 26
67 ATLANTIC CITY NJ 12 45% 14 55% 26
68 VISALIA-TULARE CA 16 67% 8 33% 24
69 MODESTO CA 15 67% 7 33% 22
70 PORTSMOUTH-DOV. NH 7 32% 15 68% 21
71 NEW BEDFORD MA 11 60% 8 40% 19
72 MUSKEGON MI 8 46% 9 54% 17
73 VINELAND-MILL. NJ 7 46% 9 54% 16
4,940 49% 5,139 51% 10,078
Source: U.S.EPA National Emission Data System (NEDS)
Mobile source emissions estimates based on MOBILE3 factors.
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V-14
TABLE V-4
VOC EMISSIONS IN 73 METROPOLITAN AREAS - 1983
Category
1000-!p'Y
4,940
1.
Mobile sources
- Includes Stage II and off-highway
vehicle
2.
Other solvent use
2,495
- Degreasing, dry cleaning, adhesives,
graphic arts, solvent extraction,
other
3.
Miscellaneous area sources
956
- Combustion, solid waste, etc.
4.
5.
Petroleum storage
604
Industrial processes
Industrial surface coating
459
415
6.
7.
209
Petroleum refining
--
TOTAL
10,078
Percent
49
25
9
6
5
4
2
100
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V-15
Projections and Growth - To show prospects for expeditious attainment
under a strict interpretation of the Act, short-term projections were
made to 1992 (5 years after 1987).
For a somewhat more practical time
frame, longer term projections were also made to 1995, 2000, and 2010.
The more distant years (2000 and 2010) allow the vehicle fleet to turn
over and offer additional mobile source measures such as onboard refueling
controls, tighter tailpipe standards, and methanol substitution.
Nationally, urban vehicle miles traveled (VMT) is projected to
increase by about 27 percent by 1995 and by 60 percent by 2010.
The
increase in urban VMT between 1983 and the projection years are listed
below.
Urban VMT
(billion)
1983
853
1992
1024
1995
2000
1176
2010
1367
1081
Percent increase
from 1983:
20%
27%
38%
60%
Growth in mobile source emissions was calculated after the effect of
the FMVCP has occurred.
For example, in 1992, the FMVCP would have
reduced 1983 VOC emissions by about 25 percent if the VMT had not changed.
The mobile source emissions in 1983.were 50 percent of the total.
Therefore,
the 1992 emissions would be 25 percent of the total.
By 1992, VMT is
projected to increase by 20 percent and the 1992 emissions would be 25
percent times 1.20 or 30 percent.
The emissions increase due to growth
is 30 percent minus 25 percent, or 5 percent.
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V-16
Growth in point and area source categories is projected according to
EPA-450j4-80-026 Methodology to Conduct Air Quality Assessments of National
Mobile Source Emission Control Strategies - Final Report, October 1980.
The growth estimates in the document were made by the Bureau of Economic
Analysis (1977).
These growth projections include new sources, retirement
of existing sources, and replacement sources.
As opposed to the calculation of growth in mobile source emissions,
growth in point and area source emissions are calculated before, instead
of after, controls.
This is because growth will occur before long-term
control is applied to many of the point and area source categories (solvent
prohibition, application of stringent regulations, relocation of major
emitters, etc.).
Based on estimates by EPA new source review staffers, it is assumed
that 40 percent of the total growth in nonmobile source emissions will
occur in new sources or major modifications.
This growth could be
controlled through modest tightening of existing new source review policy.
Definition of Factors Used in Selection of Measures
Description of Measures - Measures can have two principal objectives:
reduction of emissions or reduction in the level of an emission-producing
activity.
The first category includes emissions-control devices (e.g.,
catalytic converters, carbon adsorbers, incinerators, etc.) and process
changes or product modifications (e.g. water-based or high-solids coatings,
fuel conversion, etc.).
The second category includes measures where the
activity itself is not changed, but the number of repetitions of the
activity is reduced.
This includes:
TCM's that reduce vehicle miles
-------
V-17
traveled, production caps, and prohibition of certain high-polluting
activities.
The measure description will include a description of the source
category of which the measure is controlling, modifying, or reducing the
activity.
To the extent possible, the source category's proportion of
total emissions in the IIgenericll areas will be defined.
The description
includes a discussion of any options considered and why the measure was
selected over the rejected options.
The description of the measure also
includes a technical description of the selected measure and a discussion
of the number of sources to which the measure would apply.
Finally, there is a discussion of the means by which the measure
would be implemented in a FIP scenario.
For example, the measure might
be implemented by prohibition, taxes, or Federal regulation.
Implementation Date - Time is needed to develop new control measures
or to identify the sources to be controlled.
Of course, the measures
easiest to implement will generally have the shortest implementation
times.
If the measure involves new tailpipe or other on-board vehicle
controls, time for the entire vehicle fleet to turn over must be included
before the measure can be considered to have been fully implemented.
Emission Reduction - Since it is estimated that many areas will
need massive emission reductions to achieve attainment, the reduction in
baseline emissions from the application of the measure is a main factor
in selection of measures.
The two key elements in determining emission
reductions are by when and how much?
The IIby whenll part was determined
above under Implementation Date.
The IIhow muchll part assumes some
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V-18
estimate can be made of the in-use effectiveness of the measure.
Thi s
estimate may be much less than the required reduction in the regulation
or than a tested reduction from an individual control device.
For example,
although new cars perform better than the Federal 0.41 gram per mile
tailpipe standard at the factory, a typical in-use emission rate can be 2
to 3 times the standard after 60,000 miles.
Because emissions are generated by various activities, estimates of
future emissions and associated reductions must take account of growth or
decline in the activity levels.
However, since this study is looking at
three generic areas, growth will be accounted for separately.
Fo r the
purposes of this study, growth in the VMT rate is assumed to be offset by
the TCM's required in an area.
If an area is growing at a 2 percent per
year rate, this would result in a VMT increase of 40 percent by the year
2000.
The FIP would therefore set the stringency level of TCM's at a
rate sufficient to produce a 40 percent reduction of the VMT projected to
occur by the year 2000.
It should be noted that this is not the same as
a 40 percent reduction from baseline VMT levels. This means that short-term
TCM's are required to produce less drastic VMT reductions than the long-term
TCM'.s.
Costs - Costs are borne by the regulated industry and by the public
through purchase of affected goods.
The costs incurred by industry
include the cost of control equipment or product reformulation, monitoring
and recordkeeping, permits, etc.
This assumes that the industry can
afford the costs and remains in business, or that the emissions from the
particular industry are not prohibited as part of a FIP strategy.
For
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V-19
the purposes of this study, the costs to industry of the Federal construction
ban have not been estimated.
Costs to the public may take the form of
fees, taxes, pass-through costs of goods or services, the cost of inconvenience,
etc.
If costs are those incurred in adding more control to an existing
control, such as tightening reasonably available control technology
(RACT) to usuper-RACT,u such costs are described as uincremental" costs.
These costs may also include expanding the applicability of controls to
sources not previously covered, or the eclipse of a short-term measure by
a long-term measure.
Costs are expressed on a $/ton basis.
These figures are derived
from the annual cost of operation and maintenance, and the annual cost of
capital.
These costs are then divided by the annual emission reduction
to arrive at the $/ton figures.
Capital costs for stationary source
controls are assumed to be amortized over a 10-year period at 10 percent
interest.
Social Impacts - If large emission reductions are to be achieved
in large cities. there is no alternative to severe cuts in emissions from
mobile and area sources.
If attainment is to be reached, people may have
to accept a lifestyle with more mass transit, restrictions or taxes on
the use of the private automobile, high parking fees, prohibition of the
sale or use of gasoline and other solvents, etc.
The impacts of these
changes can be spread out over, say, a 20-year period, but the measures
cannot be effective unless accepted by the public.
Unequal effects may
fall on certain social classes.
For example, low-income people needing
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V-20
to use their vehicles may pay high percentages of their income relative
to other classes in the form of gas and parking taxes.
Feasibility - For the purposes of this study, four types of feasibility
are discussed with respect to each measure or group of measures: institu-
tional, legal, technical, and pol itical.
In some cases, technical feasi-
bility is separated out and the other types are discussed as a group.
Institutional feasibility means the "willingness" of government,
mainly the Federal government, to pursue and adopt a measure.
If changes
in attitude or institutional structure are needed to facilitate the
adoption or implementation of a measure, these are identified.
Legal feasibility means the ability of government to adopt or require
a measure within existing laws.
If laws must be changed to allow a
measure, these changes will be identified.
Technical feasibility means that the technology either exists or can
be developed within a workable time frame, usually the implementation
date.
If the technology must be developed, the main requirements or
obstacles are described.
Political feasibility means the willingness of elected officials to
support the measure, or conversely, to accept a measure as a "necessary
evil."
Although public support for a measure generally indicates political
acceptance, special considerations must be made for measures affecting
jobs, increasing taxes, or opposed by powerful interest groups.
Efforts
to enlist the support of State and local officials adopting or implementing
elements of the FIP should improve the effectiveness of most measures.
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V-21
Selection Process (i .e."concept")
Since the main objective of IFIP's" would be to bring about attainment
as rapidly as possible, any measure is a candidate for a FIP regardless
of its cost or difficulty of implementation, if attainment cannot be
achieved without it.
Obviously, certain measures are easier to develop,
adopt, and implement than others.
For exampl e, a transportation control
measure which attempts to force a major segment of the population into a
mass transit system will take years and will be extremely difficult to
accomplish, but such a measure may be necessary to counteract the effects
of growth and sprawl.
These effects might make attainment impossible if
1 eft unchecked.
However, before extreme measures are taken, many other
measures can and should be tried.
Certain measures are likely to be common to all areas, regardless of
the area's ozone problem.
There are several reasons for this.
The
measure may be implemented nationally throughout the country.
The new
car and truck tailpipe standards and RVP controls on commercial gasoline
are examples of such measures. Or, the measure may be well established,
within reasonable cost 1 imits, and previously required in other areas.
In a post-1987 setting, such measures might include standard (i .e., RACT)
vehicle inspection/maintenance or Stage II refueling controls.
And, some
measures make good sense.
For example, improvements to certain existing
. SIP rules and certain national policies or procedures make sense in
almost all areas, but especially in post-1987 nonattainment areas.
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V-22
Because such measures are obvious candidates for virtually all
post-1987 areas, a selection process is not necessary.
When ranked against
other measures on a scale of implementation difficulty, such measures are
generally among the least difficult to adopt and implement.
Additional measures must be selected if all areas, especially those
with high reduction targets, are to achieve attainment.
The objective of
this selection process is to rank the measures starting with those which
can be implemented with the least difficulty or cost and proceeding to
those of higher difficulty or cost, along the lines of the outline shown
in Figure V-l.
In general, this is the process EPA would expect to
follow if the Agency was to develop FIP's.
It is understood that, at the higher reduction targets, some measures
will have high costs and high social or political impacts relative to
those of current controls.
Although costs are to be considered in the
process, no measure will be assumed too costly if the nonattainment
problem is continued or substantially delayed because of failure to adopt
the measure.
No level of cost is considered "too high."
Fi gure V-1
RANKING OF MEASURES
Order of Incfeasing Difficulty to Adopt or Implement
-SIP Rule Improvement
-National Mobile Source Measures
-Stationary Point Source Measures
-Local Mobile Source Measures
-National Policy/Procedural Changes
-Stationary Area Source Measures
-Short-Term Transportation Control Measures
-Long-Term Transportation Control Measures
-Stringent Stationary Point Source Measures
-Stationary Source Growth Restrictions, Heavy
Production Caps
-Severe Mobile Source Measures
Offset s ,
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V-23
In the selection process, choices between alternative measures must
be made at some point.
For example, if mobile sources must be reduced to
very low levels relative to current emissions, a decision must be made
between (1) further tightening of the tailpipe standards, (2) drastic VMT
reductions through TCM's, or (3) converting the entire vehicle fleet from
gasoline to an alternate fuel such as methanol.
Such a decision depends
on knowledge of the costs and implementation problems associated with
each option, neither of which are well known.
Besides identifying the
choices required, this study makes some rough cost and feasibility estimates,
and attempts to provide enough information to determine whether each
alternative is viable.
Improvements in Existing SIP Regulations
Stationary Source RACT Regulations - An important aspect of the FIP
will be provisions for ensuring that existing SIP's fully conform with
the intent of EPA's guidance on stationary source control as expressed in
control technique guidelines (CTG's) and various guidance memorandums.
Although most SIP regulations have met the terms of EPA's requirements
for Part D SIP's, EPA has inadvertently approved some SIP's containing
rules that do not meet those requirements.
Some State regulations to control vac emissions are being implemented
in a manner that does not conform with EPA requirements and policies and
can, in certain cases, significantly interfere with the effectiveness of
those regulations.
These implementation problems appear to be caused by
incorrect to ambiguous definitions, variable interpretation, or the lack
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V-24
of key provisions (e.g., compliance times, test methods, etc.), or specific
provisions in State regulations that are inconsistent with current EPA
po 1 i ci es .
In some cases, these problems can interfere with the States'
ability to (1) secure their expected emissions reductions from stationary
source RACT regulations or (2) control emission growth through their
new source review (NSR) regulations.
The EPA will identify these problem
areas and provide training, guidance, and other technical support to
ensure that RACT and NSR regulations are effectively implemented.
The
EPA will focus its efforts on the RACT and NSR issues and problem areas
discussed below in its effort to ensure that existing regulations conform
with the intent of EPA's previous guidance.
The existing RACT regulations were developed as a major component of
the SIP strategies to achieve VOC emission reductions.
The foll owi ng
describe the areas where RACT regulations have been written and/or
implemented on an inconsistent basis.
RACT Regulation Exemptions - Many of the CTG's that EPA issued in
the late 1970's recommended that States exempt from their RACT rules only
those sources falling below certain size or throughput cutoffs.
at her
CTG's recommended no such cutoffs.
Some of the RACT regulations now in
the SIP's, however, establish exemptions wider than those recommended in
the CTG's or provide exemptions so ambiguous as to be susceptible to
abuse.
The EPA would amend each of these rules to ensure that these
exemptions conform to the CTG recommendation in all cases except those
for which the State provides adequate justification that the CTG level
would impose unreasonable requirements in that State.
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V-25
Definition of 100 Tons Per Year Source - The EPA guidance has called
on SIP's for extension areas to require RACT for sources with the potential
to emit more than 100 tons per year (tpy), but that do not fall into a
CTG category.
Although EPA intended the definition of source for this
purpose to be the entire plant, some SIP's are susceptible to an
interpretation requiring RACT only for individual emissions units emitting
more than 100 tpy with controls.
The EPA intended, however, to apply
RACT to non-CTG sources emitting more than that amount without controls.
Therefore, EPA intends to amend VOC rules that do not clearly reflect
EPAls intent.
RACT-Level Control on Non-CTG Sources - The EPA has noticed that
decisions on what constitutes RACT for various types of non-CTG sources
often vary within a source category from State to State.
To minimize
this, the Agency proposes to review non-CTG determinations to ensure
. consistency and, where necessary, to amend those rules for States with
insufficiently stringent RACT rules for these sources.
Other Issues - Existing VOC rules contain a variety of other
ambiguities and exemptions that may impede efforts to achieve full RACT-
level reductions.
Although some of the affected State or local agencies
currently interpret these rules consistently with EPA policy, courts will
frequently turn to the actual words of the rules to decide the legal
obligations of the affected sources.
For that reason, EPA believes it is
essential to amend these rules to state clearly what is required.
Un t i 1
these rules are changed, the Agency will continue to interpret them
consistently with EPA's intent when it approved them and will encourage
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V-26
the relevant State or local agencies to do the same.
Examples of these
deficiencies are described generally below.
o Emission Limit Units - vac rules incorporating limits expressed
as pounds of VaG per gallon (lbs VaG/gal) of coating should also list the
equivalent lbs VaG/gal of solids emission limit.
It will be acceptable
but not mandatory to totally replace pounds of VaG per gallon of coating
units with units of lbs VaG per gallon of solids.
vac rules should state
that units of lbs VaG/gal of solids be used for all calculations involving
bubbling, cross-line averaging, and determining compliance by add-on
control equipment such as incinerators and carbon adsorbers.
If exempt solvents are used as part of the coating formulation, the
rule should State that exempt solvents are treated as water in VaG
calculations, i.e., subtracted along with water where "less water" is
part of the emission limit units.
Some people might object that while lbs VaC/gallon solids might be
more rigorously correct to use in calculations, it will be a lot of
trouble to change and that the benefits to be gained will not be worth
the effort.
an the contrary, the magnitude of emission reductions that
potentially can be achieved is shown below to be significant and, thus,
worth the effort of modifyi ng the regul at ions.
To see what the magnitude of this change might be, look at web
coating lines such as paper, fabric, and film coaters.
Uncontrolled
national VaG emissions from such sources are estimated to be:
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V-27
Paper, film, and foil
Tapes and labels
Flexible vinyl and urethane
Magnetic tape
Fabric coating
TOTAL
Tons/yr
192,500
495,000
25,300
8,800
77,000
798,600
The VOC reduction intended by the CTG for these sources is 81 percent
or a reduction of 646,800 tons/yr.
A source using an incinerator or other add-on control device, may
perform the emission reduction calculation incorrectly using lbs VOC/gallon
coating and decide that a 49 percent reduction is all that is needed.
If
this reasoning was applied uniformly to the whole industry only, 391,600
tons/yr would be reduced.
This means that (646,800 - 391,600) tons/yr or 255,200 tons/yr of VOC
emissions would be controlled by requiring the correct calculation
procedure that would not be controlled using the incorrect calculation
procedures.
It is not true to say that all web coating sources will
control using add-on controls, nor is it true that all sources are doing
the calculations incorrectly, so this overstates the reduction achievable.
However, if we assume that only half of web coating sources will control
with add-on controls and that only half of these are performing the
calculation incorrectly, the emission reduction attained by correcting
the calculation procedure is still 63,800 tons/yr nationally or about
32,000 tons per year in nonattainment areas.
This reduction simply from
using appropriate units and correct calculation procedures for web coating
is as large as the total reduction obtained from controlling some complete
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V-28
industries.
For example. solvent use in automobile assembly plants
coating operations is around 70,400 tons/yr.
Correcting calculation
procedures for the web coating industries alone could give emission
reductions comparable to controlling all auto assembly plants.
o VOC Definitions - These definitions should define VOC as all
organic compounds except those that EPA has listed as negligibly photo-
chemically reactive in its Federal Register notices.
Many VOC definitions
incorrectly contain a vapor pressure cutoff that effectively exempts some
photochemically reactive compounds (such as butyl dioxito1, a paint
solvent, and certain mineral oils) from control.
The following definition
is a model for use:
Volatile Organic Compound (VOC) - Any organic compound which
participates ~atmospheric photochemical reactions; that is, any
organic compound other than those which the Administrator designates
as having negligible photochemical reactivity. VOC may be measured
by a reference method, an equivalent method, an alternative method,
or by procedures specified under 40 CFR Part 60. A reference method,
an equivalent method, or an alternative method, however, may also
measure nonreactive organic compounds. In such cases, an owner or
operator may exclude the nonreactive organic compounds when determining
compliance with a standard.
o Other definitions - A variety of other definitions in VOC
rules are inconsisten~ with EPA's CTG's.
The EPA would identify these
deficiencies and remedy them.*
*For example, definitions of IIcoating 1inell should not exempt from
control coating lines that do not have bake ovens. Also, definitions of
IIrefinishingll in miscellaneous metal coating rules should make clear
that lIin-1inell or IIfinal off-linell repair by original equipment manufacturers
is not refinishing. Refinishing should be defined as the repainting of
used equipment. The definition of paper coating should be refined to
make clear that the paper coating regulations cover coating on plastic
film and metallic foil as well as paper. Paper and fabric coating
should cover saturation operations as well as strictly coating operations.
Vinyl coating definitions should make clear that organiso1 and plastisol
coatings (which traditionally have contained little or no solvent)
cannot be used to bubble emissions from vinyl printing and topcoating.
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V-29
o Iransfer Efficiency - Some States have attempted to provide
particular sources with relaxations of solvent content limits in return
for improvements in the efficiency with which the sources apply paint
solids to their products ("transfer efficiency.I).
Some of the affected
VOC rules, however, do not mention this type of substitution.
Still
others mention it but do not prescribe an acceptable method for determining
the baseline from which the transfer efficiency improvements are to be
calculated.
The EPA would require that, regardless of whether transfer efficiency
is mentioned in the applicable SIP rule, a source may use improved transfer
efficiency as a substitute for meeting the SIP solvent content limit only
if this substitution receives EPA approval as a sourcespecific SIP revision.
Such a revision must establish a baseline transfer efficiency equal to
that type of sourcels RACT transfer efficiency at the time the State
adopted the solvent content limit and set forth a method for calculating
the improved transfer efficiency.
o Compliance Periods - VOC rules should describe explicitly the
compliance time frame associated with each emission limit (e.g.,
instantaneous or daily).
However, where the rules are silent on compl iance
time, EPA will interpret it as instantaneous.
The rules could include
periods longer than 24 hours only in accordance with the memorandum from
John OIConnor, Acting Director of the Office of Air Quality Planning and
Standards, dated January 20, 1984, and only as source-specific SIP
revisions.
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V-30
o Recordkeeping - The EPA will amend State VOC rules to require
explicitly that sources keep records needed to assess compliance for the
time frame specified in the rule.
Records must be commensurate with
regulatory requirements and must be available for examination on request.
The SIP must give reporting schedules and reporting formats.
For example,
these rules must require daily records if the SIP requires daily compliance.
If a company is bubbling its emissions on a daily basis, the rules must
require daily records to determine compliance.
If units of lbs VOC/gallon
solids in calculations are required for daily compliance, the source must
record gallons of solids used per day and pounds of VOC emitted per day.
The rules should also require sources to list separately the amount of
diluents and, where relevant to determining compliance. wash and clean-up
VOC.
Beyond that, they should require sources to document (1) that the
coatings manufacturer used either EPA Method 24 or an EPA-approved State
method to calculate the amount of VOC per gallon of coating (less water
and exempt solvents) and (2) what method the manufacturer used to calculate
the volume percent solids content of the coatings.
o Test Methods - The EPA will amend State VOC rules to require
the use of the most current test methods to determine the VOC content of
coatings (e.g., EPA Reference Method 24 or equivalent ASTM Methods).
The
method used to determine volume percent solids should be specific and
should be an EPA-approved method (see "Procedures for Certifying Quantity
of Volatile Organic Compounds Emitting by Paint, Ink. and ~her Coatings."
EPA-450/3-84-019, December 1984).
The procedures in outdated ASTM methods
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V-31
and the Volume II CTG are generally no longer acceptable.
Procedures
should specify that EPA or States may verify test data submitted by
'companies with independent tests and that EPA or State conducted tests
will take precedence.
The EPA also will amend State vac rules to state the procedures the
relevant agencies would use to measure capture and control device
efficiencies.
For example, the rules for some types of sources or control
systems should require the use of temporary enclosures, rather than
material balances, in "capture efficiency systems" or "maximum reasonable
capture" should be replaced with specific control requirements.
o ~~ent Leak Components - The EPA would require equipment
leak SIP regulations to be strengthened according to the intent of the
CTG's.
For example, sources that have previously been exempt from
monitoring requirements due to line size or the use of plug and ball
valves should become subject to the SIP requirements.
In addition, the
FIP would delete exemptions of unsafe and inaccessible valves from all
periodic monitoring requirements.
The EPA believes that inaccessible and
unsafe-to-monitor valves should be monitored as often as practicable
because of the potential for finding leaks and reducing emissions.
For natural gas plants, RACT should apply to equipment that contains
or contacts a process stream with a vac concentration of 1.0 percent by
weight or more.
Equipment with process streams containing relatively low
percentages of vac (i.e., between 1.0 and 10.0 percent) contributes a
significant portion of total emissions from natural gas plants and,
therefore, is subject to RACT requirements.
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V-32
o Exemptions and Variances - Although many SIP's contain
provisions giving the State authority to ~rant variances, exemptions and
alternative means of control strategies, the FIP will require SIP's to
make clear what must be submitted as a revision to the SIP.
Summary of Impacts of Policy Conformity Efforts for RACT Regulations -
The measures described above for ensuring conformity of stationary source
RACT regulations in existing SIP's with EPA policy will make VOC control
efforts in all nonattainment areas more consistent, will result in easier
enforcement, and will give increased VOC reductions.
It is difficult to
quantify the VOC reductions achieved by such measures.
Some analysts
have estimated that measures to ensure conformity of SIP's with EPA
guidance could result in as much as 200,000 tons per year VOC reduction.
Such an estimate, however, covers such measures as improved ambient air
monitoring, improved compliance provisions, and some other programs that
are really outside the scope of strictly stationary source control
regulations which are being discussed in this section.
A more conservative
estimate is given by the VOC reduction expected from correcting calculation
procedures by using units of lbs VOC/gallon solid.
In an earlier section,
this was shown to give a 32,000 tons/year emission reduction in nonattainment
areas.
The EPA manpower to specify these changes will not be great, if
guidance can be given on a blanket basis because the major inconsistencies
have already been identified in general.
However, if each individual SIP
has to be evaluated for inconsistencies and a correction guidance be
tailored to each SIP, then the process will take much more manpower.
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V-33
New Source Review (NSR) Regulations - The primary focus of
the NSR regulations is to evaluate the emissions impact of new or modified
source projects before construction commences on the projects.
The basi c
requirement for a new source of air pollution is to ensure that its
emissions do not cause any new nonattainment situations or exacerbate any
existing nonattainment problems.
All sources must "prove" that they do
not cause or contribute to any nonattainment problem.
For maj or new
sources and major modifications wishing to locate in designated nonattain-
ment areast the applicant must also show that the most stringent pollution
control equipment is being installed [lowest achievable emission rate
(LAER)Jt that all other sources owned by the applicant within the State
are in compliance (Statewide compliance), and that the emission increases
are either offset or taken into account with an approved growth allowance
(emission offsets).
These requirements are listed in the Clean Air Act
in sections 172 and 173.
The wording in some State NSR regulations has allowed or has the
potential to allow certain sources to avoid some or all of the intended
requirements of new source review.
The EPA believes that appropriate
guidance and technical support can help ensure that States implement the
new source review regulations in conformance with EPA policy; however,
EPA may need to correct or clarify some State regulations to avoid possible
applicability or enforcement problems that may arise under new source
review.
The following areas should be the focus of efforts to achieve
conformity with EPA policy.
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V-34
_E x~"p-~i.~ _. .
o Penmit Conditions - Federal requirements state that only
federally enforceable permit conditions may be used to exempt a source
from the requirements for major sources.
Examples of nonfederally
enforceable permit conditions include State operating permits, State
consent decrees, and construction penmits which have not undergone public
comment.
o State Nonattainment Designations - The EPA will not permit a
State to exempt sources located in nonattainment areas that the State has
designated "attainment" without EPA approval.
Similarly, States will not
be permitted to use attainment demonstrations that have not received EPA
approval to detenmine whether an offset or netting transaction is consistent
with reasonable further progress (RFP).
o General - The FIP will revise State regulations to remove any
regulatory provisions that could be used to exempt any source from any
major NSR requirements except the exemptions contained in the Federal
definitions of major stationary sources [40 CFR 51.18(j)(1)(iv)] or major
modifications [40 CFR 51.18(j)(1)(v)].
No source type (e.g., cotton
gins, resource recovery facility) or source class (e.g., reactivated
sources) may have a blanket exemption from any new source review requirement.
This is a problem even if "one" individual exempted source, by itself, is
usually under the major source and major modification thresholds since
the NSR provisions require that all emission increases be accumulated for
applicability purposes.
For example, the cotton gin may be a minor source
while four cotton gins located on one piece of land, would be equivalent
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V-35
to a major source or major modifications.
States may retain exemptions
from minor source permitting requirements if (1) there exists a federally
approved growth allowance to mitigate resulting increases in emissions
and (2) State regulations expressly prohibit the use of the exemptions to
exempt any major source or major modification from major NSR requirements.
o Clea~~~~Exemption - As a result of the August 1980 rulemaking
which was done as part of the Alabama Power court settlement, State
regulations cannot contain provisions that exempt a source from major new
source review requirements because the source does not IIsignificantly
cause or contribute to a violation of a national ambient air quality
standard.1I
The August 1980 requirements subject any major source or
major modification located in an EPA designated nonattainment area to the
major NSR requirements regardless of the ambient impact of the source.
~ffset/Netting Requirements -
o Offset - The EPA requires State regulations to contain
enforceable and specific criteria on the credibility of emission reductions
as offsets.
These provisions shall include a specific, well-defined
baseline for emission increases and decreases, a requirement that all
emission reductions used for offset be federally enforceable (see section
on permit conditions above), certain restrictions on the use of emission
reductions caused by prior shutdowns and curtailments as offsets, and the
prohibition of the use of any emission reductions already included in a
State attainment demonstration.
The reasoning behind the restrictions on
prior shutdowns and curtailments is that the reductions from these
processes would have occurred anyway and, therefore, should be used to
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V-36
assist the area to show attainment rather than assist new source growth.
The last requirement listed is to ensure that a State does not use a
reduction twice, i.e., once for attainment purposes and once for mitigation
of new source growth.
o Netting - The EPA requires State regulations to contain
specific and enforceable criteria if a State wishes to allow a source to
"net out" of major NSR review.
A source "nets out" of major new source
review by securing emission decreases within the source to mitigate
increases from the same source, resulting in an "insignificant" emissions
increase on a sourcewide basis.
The Federal regulations require the
following criteria for netting:
(1) an II actua 1" basel i ne; (2 ) health and
welfare equivalence between the emission increases and decreases; (3)
Federal enforceability of emissions decreases (see section on permit
conditions above); (4) a specific contemporaneous time frame (up to 1a
years); and (5) the prohibition on the use of any reductions already
incorporated in a State's attainment demonstration (see discussion on
offsetting above).
The health and welfare equivalence for an ozone
nonattainment area focuses on relative reactivities of the VaG species.
The State should not allow a netting transaction that causes an increase
in a reactive VaG and a decrease in a negligibly reactive vaG even if the
absolute amount of VaG emitted does not increase significantly.
The
contemporaneous time frame is needed to ensure that increases are
accumulated over a reasonable period of time, to discourage construction
projects exempting themselves from NSR, and ensure that decreases are not
so old as to already be taken into account in attainment demonstrations.
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V-37
Also, if a reduction occurred a very long time ago, that reduction should
go towards assisting an area to show attainment rather than assisting a
source to avoid major NSR requirements.
Definitions -
o VOC - NSR regulations should use a VOC definition that defines
VOC as all organic compounds except those that EPA has listed as negligibly
photochemically reactive in its Federal Registe~ notices.
definition in RACT regulations above.)
(See VOC
o Other - The FIP will require that NSR regulations contain
clear definitions, consistent with Federal requirements, for the following
terms:
stationary source; actual emissions; allowable emissions; fugitive
emissions; commence or begin construction building, structure, or facility;
and major stationary source.
State regulations that do not contain good,
concise definitions that meet the Federal requirements risk treating
sources inequitably because of various interpretations of the definitions,
even beyond what occurs using Federal definitions.
For example, minor
variations in the LAER definition could allow a source to avoid installing
proven technology by arguing that it costs too much.
The definitions
must provide a framework to make decisions replicable among sources.
Mobile Source Controls
On the average, mobile sources are responsible for about one-half of
the VOC emissions.in most urban areas.
Although emission controls have
reduced tailpipe and evaporative emissions per vehicle substantially
since the advent of controls in the late 1960's, the sheer numbers of
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V-38
vehicles and mi1"es driven per vehicle cause mobile source emissions to
remain at high levels.
Mobile sources are also prone to high growth rates, since increases
in population not only add more drivers and trips, but result in urban
sprawl which increases the length of each trip, not to mention congestion.
Traditional mobile source controls such as tailpipe standards or 11M
programs, while reducing the emission rate per vehicle, do not affect
growth.
Traditional transportation control measures such as ridesharing,
parking fees, mass transit incentives, etc., generally have resulted in
very small VMT changes. To offset large projected VMT increases, more
effective TCM's are needed.
FMVCP - By far, the FMVCP has reduced urban VOC emissions more than
any other measure or combination of measures.
Even though offset by
substantial VMT growth, national VOC emissions from transportation sources
declined by 30 percent from 1975 to 1984, due to the FMVCP and a few 11M
programs.
However, the FMVCP is expected to "bottom out" in the 1995-2000
time frame, because by that time almost all of the vehicle fleet will be
equipped with the same controls that are on the new cars.
Unl ess further
mobile source reductions are achieved, vehicle emissions will begin to
increase due to increased VMT and deterioration of controls on older
vehicles.
(For the possibilities of further tightening of the existing
tailpipe standards, see "New Tailpipe Standards" below.)
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V-39
The FMVCP, without 11M, is projected to reduce total emissions by
about 17 percent between 1983 and 1995, assuming a mobile source share of
about 50 percent.
From 1995 to 2010, mobile source emissions will increase,
resulting in an increase of about 4 percent of the total 1983 baseline
emissions.
New Tailpipe Standards - It is technically possible to reduce new car
tailpipe emissions further through a more stringent hydrocarbon exhaust
standard and improved "durability."
With these changes, exhaust emissions
would be reduced to the lowest levels believed possible on gasoline
engines.
The current exhaust emission standard for 1977 and later passenger
cars is 0.41 grams per mile.
The same standard appl i es to 1979 and 1 ater
1 ight-duty trucks up to 4000 pounds.
Recent advances in emission control
technology such as electronic fuel injection have caused the average new
car emission rates to be significantly below the 0.41 g/mi level.
Accord i ng
to the Cal ifornia Ai r Resources Board and or~s, a 0.25 g/mi hydrocarbon
standard is possible.
Because many new cars already outperform the 0.41 standard, a reduction
of 0.16 g/mi by going to a 0.25 standard is not likely.
that the reduction might be 0.10 g/mi.
or~s estimates
Additional reductions are bel ieved possible through improved durability
which would require the manufacturer to demonstrate full life compliance
of the emission control system.
Although current emission standards are
based on an average life of 50.000 miles, the actual life is about 100.000
mi 1 es .
This half-life compliance allows exceedances of the standard
during the second 50,000 miles.
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V-40
Improved durability requirements would effectively extend the manufacturer's
responsibility for meeting emission standards to 100,000 miles and result
in lower in-use emissions.
OMS estimates that such improvements might be
able to gain another 0.10 grams per mile reduction.
In combination, the lower tailpipe standard and improved durability
requirements could potentially achieve a reduction of 0.20 g/mi.
This is
equivalent to a reduction of about 2.5 percent of 1983 baseline emissions.
It is assumed that manufacturers might be allowed to 1995 for time to
develop and produce the first vehicles capable of meeting such new standards.
Thus, the reductions might be achieved by about 2005, allowing 10 years
for the new improved cars to effectively replace the existing fleet.
The cost of these new standards is estimated to be reasonable,
perhaps $150 per car or lower.
Gasoline Volatility The volatility (evaporation rate) of commercial
gasoline is measured by the RVP.
Since the 1970's, the volatility outside
California has steadily- increased from 9 RVP to about 11.5 RVP as suppliers
added butane.
The substitution of cheaper butane enabled more gallons of
gasoline to be produced from each barrel of oil.
California has controlled gasoline to about 9 RVP in Los Angeles and
San Francisco since the mid-1970's.
(However, in a nationwide program,
California would also be required to control further, achieving a reduction
equivalent to the 2.5 psi reduction of other States.)
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V-41
The emissions affected most by gasoline volatility are not tailpipe
emissions, but excess evaporative losses from the vehicle's carbon canister.
which controls evaporative emissions from the carburetor during the "hot
soak" period after engine shutdown.
Because the canister was sized at the
factory to meet Indolene test fuel (9 RVP) it becomes saturated at
some point due to the higher RVP in commercial gasoline and the excess
vapors evaporate as VOC emissions.
These excess emissions are about 15
percent of the 1983 mobile source emissions. or about 7.5 percent of the
1983 total VOC emissions.
There are two ways to reduce these excess evaporative emissions. One
way is to increase the size of the canister to handle the RVP in commercial
gasoline.
The other way is to reduce the RVP in commercial gasoline to 9
RVP. but to keep the canisters at the present size.
A combination approach
has also been suggested. where the canisters would be increased and the
gasoline RVP would be lowered. so that both the auto manufacturers and
the petroleum industry would share the cost.
For the purposes of this study. the option achieving a reduction in
gasoline RVP was selected. for a couple of reasons.
First, this option
can quickly achieve emission reductions. whereas the canister option
cannot produce full reductions until the fleet has "turned over." a
period of about 10 years.
Second. reducing gasoline volatility causes
reductions in VOC emissions throughout the gasoline marketing system
(bulk plants and terminals, tank trucks. service stations. etc.), whereas
the canister option only controls emissions from the vehicle.
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V-42
Limits on commercial gasoline volatility resulting in a 2.5 psi RVP
reduction could be accomplished by about 1992.
Such a reduction would be
accomplished by removal of butane at the refinery.
This would require
some additional refining and the use of more gasoline per gallon of
product.
The cost of the 2.5 psi RVP reduction is estimated at about 120
million to 180 million dollars per year nationwide outside California.
The emission reductions expected at full implementation are about 1,460,000
tons/year nationwide outside California.
Of this total, 577,000 tons/year
are in the 61 non-California MSA's measuring ozone above the 0.12 ppm
standard.
The remaining 882,000 tons/year are in attainment areas.
These figures include reductions from both vehicles and gasoline marketing
operations.
For cost-effectiveness calculations, a $250/ton benefit (credit) is
assumed to apply in attainment areas, based mainly on crop damage estimates.
Using this credit and the above costs and reductions, the calculated cost
effectiveness for nonattainment areas ranges from about a $70/ton credit
to a $40/ton cost.
RVP control of commercial gasoline is technically feasib}e.
Some
capital expenditure by refineries both in and out of California must be
made and resistance may be high, particularly from small refiners.
The
reaction of politicians, government officials, and the public is presumed
to be supportive.
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V-43
Vehicle Refueling (Stage II) - Air sitting above gasoline in an automobile
gas tank contains gasoline vapors.
Gasoline pumped into the tank displaces
these vapors and creates additional vapors which escape from the fill
pipe as VOC emissions.
These emissions can be captured and controlled by
either a device on the vehicle (onboard controls) or a vapor return line
attached to the gas pump hose (Stage II).
Stage II systems have been
operating in California since the mid-1970's, and later in Washington,
D.C.
St. Louis, Missouri, recently required that Stage II controls be
put in place by the end of 1987.
developed to date.
Onboard vehicle controls have not been
Refueling emissions represent about 2 percent of emissions from all
sources.
Stage II controls are reported to achieve about 85 percent
reduction in California, while onboard controls are estimated to obtain
about 90 percent reduction.
Additional reductions are potentially possible
from Stage II through more stringent enforcement and lower cutoff sizes.
Although the Clean Air Act (CAA) prohibits EPA from applying Stage II to
independents this provision would exempt few marketers and, therefore,
would not interfere with the assumption of 85 percent reduction from
Stage II controls.
This study has assumed that Stage II controls would be implemented
under a FIP scenario because of the 2-3 year implementation timetable for
Stage II compared to the approximate 10-year turnover time for onboard
controls.
Stage II could be implemented through Federal promulgation of
rules for selected areas and Federal enforcement.
It is presumed that
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V-44
Stage II could be implemented by the end of 1990 for post-87 areas that do
not already have such a requirement.
As sumi ng an 85 percent II i n-use" reduct i on for Stage II, and a 2
percent share of all emissions for refueling, the calculated reductions
would be about 1.7 percent of the total baseline emissions.
The cost-
effectiveness of Stage II controls has been estimated at about $600/ton.
Other than some inconvenience for certain self-service users, social
effects are assumed to be insignificant, based on acceptance of this
measure in California.
Stage II technology is proven and significant
improvements in the equipment have occurred in recent years.
Although Stage II has been controversial in the past, much of the
controversy has centered around EPAls procrastination on the Stage II vs.
onboard issue.
Under a Federal promulgation of Stage II, particularly
where more stringent controls are also part of the FIP, it is presumed
that there would be little political resistance to this measure.
Enhanced Ins~ection/Maintenance (11M) - 11M programs reduce tailpipe
VOC (and CO) emissions by repairing or replacing emissions-related equipment
(air filters, spark plugs, vacuum lines, EGR valves, PCV valves, etc.)
and by deterring tampering and misfueling.
As of February 1987, there
are 59 operating 11M programs, 54 of which test for VOC.
The average
program consists of a tailpipe test at idle, with no tampering or misfueling
inspection.
Based on EPAls audits, almost all programs are achieving VOC reductions
in excess of EPAls minimum requirements (approximately 25 percent reduction
in tailpipe emissions from gasoline-powered passenger vehicles, as calculated
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V-45
from the appropriate mobile emissions model, currently MOBILE3).
The
average emission reduction from a typical 11M program is about 4 percent
of total emissions, assuming a 50 percent mobile source share.
Enhanced 11M consists of a tailpipe test and various checks for
tampering and misfue1ing.
There are several operating enhanced 11M
programs which check for VOC-re1ated tampering or misfue1ing.
The best
of these programs (e.g. New Jersey, Arizona) can produce about half again
as much emission reductions as the average program, or another 2 percent
of total emissions.
Since 11M is required in the Act for areas unable to show attainment
by 1982 (extension areas), it is assumed that additional 11M requirements
should be required for post-1987 ozone nonattainment areas.
Based on the
public acceptance existing enhanced 11M programs, it is presumed that
FIP's would promulgate enhanced 11M programs in all post-1987 areas.
Enhanced 11M can be implemented within about 2 years after legal
authority is established.
Therefore, assuming promulgation of an 11M
rule in 1988 for post-1987 areas, the enhanced 11M program is presumed to
begin operation in 1990.
The cost-effectiveness of enhanced 11M if
implemented in an area with no 11M program is estimated at $2100/ton if
biennial and $3300/ton for annual.
These figures can be reduced by
half if CO benefits are included.
Perhaps no other VOC control measure has seemed as much of an invasion
of privacy to the average citizen as 11M.
Politicians have won and lost
elections supporting or (usually) opposing this issue.
Few measures have
been delayed for as long, and no issue has brought on sanctions as 11M
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V-46
has.
Nonetheless, 11M is effective. and given the major reductions in
vac emissions needed to attain. enhanced 11M is a necessary feature of an
ozone attainment strategy.
Some of the old political opposition can be expected. especially
from those areas new to 11M or from those areas that believe that the
public will not support any enhancements to an existing program. However,
public acceptance of enhanced 11M must be won or more drastic transportation
control measures will not be accepted.
Methanol Fuel - Gasoline. either unburned (evaporative emissions) or
as a product of combustion (exhaust emissions), is known to be highly
photochemically reactive. or smog-producing.
However. other automotive
fuels are less reactive and may result in the formation of lower ozone
1 eve 1 s .
If part or all of the gasoline-fueled vehicles were replaced
with vehicles burning less reactive fuel, a potential exists for the
reduction of ozone.
Methanol is not nonreactive. It is more reactive compared to ethane.
the suggested nonreactive "standard."
However, the reactivity rate over
time for methanol is more than two times less than butane (a gasoline
additive; see discussion on gasoline volatility above) and much less than
other gasoline components.
This suggests that replacing gasoline with
methanol should reduce. or at least delay. the formation of ozone.
Methanol is also much less volatile than gasoline and. if the fuel economy
of methanol vehicles can be improved, evaporative emissions from both
vehicles and the gasoline marketing systems could be reduced in a methanol
substitution scenario.
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V-47
With current technology, VOC emissions from methanol and gasoline
vehicles are about the same.
However, because of the difference in
reactivity, EPAls Office of Mobile Sources predicts that substitution of
methanol fuel for gasoline in current technology vehicles would generate
20 percent to 51 percent less ozone than gasoline vehicles.
For "advanced
technology" methanol vehicles (lean burn engines, improved catalysts,
etc.), OMS estimates a reduction of 84 percent to 94 percent in the
"ozone generating" rate of methanol compared to gasoline vehicles.
This
is comparable to a potential reduction of VOC emissions from vehicles by
84 percent to 94 percent.
If this is true, substitution of gasoline with
methanol may lead to attainment of the ozone standard, even in Los Angeles.
The above studies have only looked at first day ozone generation.
No
studies have shown what the levels of second day ozone or ozone transported
downwind would be.
This is a major unknown problem for methanol as an
ozone control measure, since it is possible that methanol may react to
form ozone either in multi-day ozone episodes in the urban area, or in
downwind areas as the result of transport.
Additional modeling of multi-day
episodes and regional transport is needed to determine whether methanol
reduces ozone under these conditions.
Based on several fleets currently using methanol, the technology
appears to be practical and cost-effective.
Even the advanced technology
is anticipated by OMS to cost no more than $200 above an equivalent
gasoline vehicle.
The projected cost-effectiveness is estimated to be no
more than $2500/ton.
However, a significant unknown factor is the cost
of methanol fuel.
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V-48
Implementatio'n of an all-methanol vehicle fleet involves producing
new vehicles capable of burning methanol efficiently and producing sufficient
methanol fuel.
To manufacture new methanol vehicles is expected to be
less difficult than it will be to produce methanol in the quantities
needed.
According to some estimates, the current United States methanol
capacity must be increased 100 times if all vehicles were to switch from
gasoline to methanol.
Much of this new capacity must come from coal.
For this study, however, it has been assumed that methanol would be
substituted for gasoline only in California, utilizing the existing Title
II emission standards provision in the Clean Air Act.
It is also assumed
that manufacturers would begin production of methanol vehicles in 1995
and that a 15-year period would be given to achieve the full effect of
methanol throughout the fleet and the fuel marketing system.
Thus, by
2010, the California cities would see the benefits of methanol conversion.
To encourage new car buyers, a tax on gasoline vehicles could be
imposed and the funds could be used to give a discount sales of new
methanol vehicles.
To encourage production of methanol, a gas tax could
be imposed and the funds used to provide capital to methanol producers.
Other than the effects of taxes, the social impacts from methanol
conversion are not assumed to be great.
However, this presumes that the
technology is well demonstrated through fleet conversions and that sufficient
fuel supplies exist at a reasonable price.
Political support cannot be expected to be won easily for such a
major change.
The science of ozone reductions through methanol substitution
will have to be proven.
Some important public figures must champion
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V-49
methanol and fight off the petroleum companies which will certainly
'resist the virtual elimination of gasoline.
The government will have to
be willing to use taxes or other means to create the necessary incentives.
Transportation Control Measu!es - Most TCM's do not reduce vehicle
emissions directly.
Instead, these measures reduce either the number of
vehicles on the road or the number of miles each vehicle travels.
Some
measures (e.g., coordinated signals) increase vehicle speed thereby
reducing emissions.
Except in the largest cities, the traditional trans-
portation control measures (ridesharing, mass transit improvements,
parking management, etc.) have not produced large VOC reductions, perhaps
due to their generally unenforceable nature.
This study will look at only those TCM's that can offer a significant
reduction in the number of vehicles on the road or the number of miles
each vehicle travels.
The indicator used is VMT.
As projected by OMS's
MOBILE3 Fuel Consumption Model, urban VMT is estimated to increase almost
2 percent annually, growing 26 percent by 1995 and 60 percent by 2010
from 1983 levels.
Because these are averages, individual cities may be
growing at higher or lower rates, with the rate inversely proportional to
city size.
Despite these high growth rates, the FMVCP (in conjunction
with 11M) continues to produce reductions in mobile source emissions in
most cities through about 1995.
Beyond that date, however, mobile source
emissions begin to increase due to growth.
For cities with high VOC reduction targets in combination with high
mobile source shares, it has to be assumed that attainment is possible
only if mobile sources are reduced to the lowest possible levels.
Unless
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V-50
methanol substitution of gasoline is capable of the extreme potential
reductions projected earlier, TCM's must playa role in reducing the
projected VMT growth rate.
Some TCM's considered in this study are designed to increase, perhaps
drastically, the cost of all trips, thereby reducing as much as possible
the "unnecessary" trips.
Three means of doing this are considered: gas
taxes, vehicle taxes, and parking taxes.
Taxes are preferred as opposed
to gas rationing, for example, because taxes are difficult to avoid
through a "bl ack market" and can be appl i ed uni formly.
Gasoline Tax - A gas tax resulting in, say, a three-fold increase of
the price of gasoline, is thought to have a chilling effect on excessive
vehicle use.
Although it may shift vehicle use toward the rich and those
who have no choice but to pay the tax, the tax could fund mass transit
systems, methanol fuel production, etc.
The tax might even be palatable
if it was designed as a temporary measure to be lifted or reduced when
the goal of the funded program was achieved, for example. the opening of
the mass transit system.
As described in Appendix B, a 10 to 15 percent reduction in gasoline
."
usage could be achieved within the first year by a gasoline tax increasing
the price by 50 to 75 percent.
Given the elasticities assumed in the
Appendix. even less tax appears to be needed to maintain the same reduction
in usage over the longer term.
Even with a temporary tax, the effect at
the right amount should potentially result in a sizable interim reduction
in unnecessary vehicle trips.
It has been assumed in this study that a
gas tax would be set at a level necessary to meet a required VMT reduction.
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V-51
Even if temporary~ the effect of a gas tax at the right amount should
result in a sizable interim reduction in unnecessary vehicle trips.
Vehicle Tax - Vehicle taxes might place a progressive tax on the
second, third, fourth, etc., vehicles owned by a family, and a tax increasing
with the age of all registered vehicles.
However, the number of vehicles
owned by a family cannot be determined from the registration data, and
would be difficult to enforce.
It is assumed that the gas tax would be
sufficient to deter the use of too many vehicles anyway, making a number-
of-vehicles tax unnecessary. A vehicle age tax, however, could serve to
advance the turnover of newer vehicles, especially if the tax funded a
discount on new car sales. This tax might encourage sales of new methanol-
fueled vehicles, for example.
Parking Taxes - Parking taxes would be designed to encourage the use
of ridesharing or mass transit on work trips, by making single drivers
pay a heavy penalty for parking privileges relative to high-occupancy
vehicles.
This tax might also fund mass transit systems or alternate
fuels and also might be made temporary.
The tax might be collected by
the employer through wage tax withholding each year.
Implementation of these taxes might involve several years to allow
time for establishment of tax authority, voter referendums, resolution of
lawsuits, etc.
A 5-year period is therefore assumed for implementation
of the above taxes.
Thus, the full effect on projected VMT could be
realized by 1995.
In a city with an average growth rate of 2 percent
per year, a 30 percent reduction in the projected 1995 VMT could reduce
the 1995 VMT levels to what they were before 1980.
This is comparable to
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V-52
reducing mobile so.urce emissions by 30 percent in 1995 and is equivalent
to a reduction of about 9 percent from 1983 baseline emissions from all
sources.
A gas tax increasing the price of gasoline from $1.00 to $3.00 per
gallon might cost the consumer using 400 gal/year an additional $800.
age tax might be assumed to cost up to $500 per vehicle covered by the
An
tax.
The parking tax, if it tripled the parking cost per vehicle, might
cost an extra $50/month, or $600/year.
At the most, then a person with
an old car. driving it to work alone, might pay another $1900 per year.
Although technically feasible, none of these taxes can be expected
to be politically, socially, or institutionally accepted without resistance.
To be successful, they must be viewed as necessary and as a means to a
goa 1 .
The goal should be concrete and within sight:
mass transit system,
methanol fleets, etc.
The temporary use of taxes for a legitimate purpose
may stand a chance of ultimately being accepted.
Other TCM's are designed to reduce VMT through prohibition of certain
actions.
Two means of doing this are considered:
gas rationing and
alternate drive days.
Gas Rationing - Although gas rationing is subject to evasion through
a IIblack market ,II it is potentially capable of major VMT reductions.
Because such a program would upset everyday life, gas rationing is
anticipated only in those cities with high reduction targets and high
mobile source shares.
Although rationing at any level is theoretically
possible, excessive reduction of available gasoline would unnecessarily
disrupt the economy.
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V-53
If attainment is required in the short term (by 1992), gas rationing
or gas taxes are the only TCM1s capable of major VMT reductions over a
short time frame.
The tight attainment deadline would require VMT
reductions on the order of 25 to 50 percent.
If attainment can be extended
to a later date, gas rationing may be needed only if programs such as
methanol fuels do not achieve the expected reductions.
Ga so 1 i ne taxes
would be more preferable ways of reducing VMT, and might be substituted
for gas rationing at the 25 percent VMT reduction level.
In a typical urban area with national average growth rates, a 25
percent VMT reduction by 1992 would offset completely the VMT growth
which would have occurred by that year.
A 50 percent VMT reduction would
achieve additional reductions.
Alternate Drive Days - Using police powers, this measure would
restrict some portion of the vehicle fleet to driving on certain days
("drive-days") .
Driving on "no-drive days" would be prohibited for this
part of the fleet.
To produce sizable VMT reductions, several days per
week must be declared "no-drive days."
This study assumes that the program would alternate drive and no-
drive days every other weekday, so that half of the participating drivers
would be dirving on any given weekday.
It is also assumed that only half
of all vehicles participate in the program.
The other vehicles are
assumed to be required for everyday use (police, service, sales, and
other "must-d ri veil wo rkers) .
The participating vehicles are assumed to
comply with the alternate drive day restriction 80 percent of the time,
and a 20 percent VMT increase on the drive day is assumed as these drivers
"make-up" tri ps not taken on the no-drive day.
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V-54
A typical VMT reduction from the program described above would be
about 16 percent.
However, to allow for poor compliance, poor participation
or lax enforcement, this study has assumed a conservative 10 percent VMT
reduction.
Stationary Source Controls
Point Source Controls - There are a number of stationary
point source categories which are still uncontrolled and which are large
VOC emi tters .
Several of these have been identified for which regulation
development should take place immediately for all nonattainment areas
which contain these sources.
These sources. control of which should be
in "common" to all nonattainment areas. have been identified because of
large emissions, feasible control technology. or low cost of control.
The following table identified these "common" sources:
TABLE V-5
RECOMMENDED SOURCE CATEGORIES
EPA Regul at ion
Potential Reduction, Tons Percent Control Cost Development
So_urce Category Jin Nonattainment Areas) Reduct i on $/Ton Cost ($000)
---
SOCMI Distillation 66,000 85 1,800 75
Petrol eum Waste-
water 11,000 0 75
socrn Reactor
Processes 12,000 80 75
Plastic Parts
Coating 16,000 80 0 75
Metal Rolling 7,000 60 100 125
SOCMI Batch Process 38,000 35 225
Web Offset
Li thography 30,000 80 600-1800 100
Electronics Mfg. 4,000 70 125
Ai rcraft Coating 3,000 60 100
Coke Oven By-
Product Pl ants 91,000 97 100 100
TOTAL 279,000
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V-55
Each of the source categories in Table V-5 can be briefly described as
follows:
Synthetic organic chemical manufacturing industry (SOCMI) distillation,
SOCMI batch processes, and SOCMI reactor processes refer to operations
that take place in the synthetic organic chemical manufacturing industry.
Work has already been done in developing a new source performance standard
for SOCMI distillation so the technology and costs for this are well
known.
More development work will have to be done on reactor processes
and batch processes.
Reactor processes refer to emissions from chemical
reactors and these usually have a continuous flow of products through the
reactor.
Batch processes refer to emissions which are emitted from tanks
which are used to carry out chemical reactions in a "batch" or one at a
time basis as contrasted with continuous feed.
Batch operations in the
chemical industry are similar to batch operations in the pharmaceutical
. industry for which some controls have been installed.
Batch operations
vary so widely from operation to operation, it is difficult to quantify
costs of control for these operations.
Petroleum wastewater is similar to other wastewater separator
operations for which a CTG already exists, but certain processes were not
covered in the previous CTG.
The previous eTG showed money could be
saved by covering wastewater separators to prevent VOC from flashing off.
Plastic parts coating would cover the coating of a wide variety of
parts.
Already plastic parts coatings for business machines is covered
by a proposed new source performance standard.
Regulations should be
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V-56
extended to existing sources and industries other than business machines.
Business machines account for only about one third of all plastic parts
coating.
Plastics for automobile parts is another large segment of this
industry.
Metal rolling refers to the lubricating oil which is used when
aluminum and other metallic foil is rolled from thicker sheets of metal.
The kerosene-like lubricating oil is driven off when the metal is heated
in an annealing oven.
Higher molecular weight lubricating oils are
available which show about a 60 percent emission reduction.
Sc rubbers
are also available which can reduce emissions by 90 percent, but their
cost is much higher around $9,000/ton of VOC removed.
Lub ri cant reformu1 at ion
is the recommended control.
Web offset lithography is a form of printing that uses an ink application
roller whose image area is neither recessed (as in rotogravure) or elevated
(as in letter press or f1exography).
This applicator is chemically
treated so that ink adhers only to the image area.
To maintain this
condition, the ink roller must be continually wetted by a water-alcohol
mixture.
The isopropyl alcohol from this wetting solution evaporates
into the atmosphere, but low alcohol wetting solutions have been developed.
Also, a kerosene-like solvent evaporates from the drying oven when the
ink is dried.
This VOC emission can be controlled at reasonable cost
with an incinerator.
Electronics manufacture refers to solvent use in manufacturing computer
chips and microelectronic circuits.
Solvent containing coatings are
applied to the chip surface at various stages in the etching process to
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V-57
ensure that only selected areas of the chips are affected.
Later, these
coatings are removed, again often by organic solvent using processes.
Solvents are also used in manufacturing circuit boards.
These solvent
emissions can be collected in hoods and directed to a carbon adsorber.
Several electronic plants are using this control technology.
Aircraft coating is similar to other types of miscellaneous metal
coatings except that airplanes are exposed to somewhat severe weather
conditions.
There are already regulations covering airplane coatings in
some areas of the country.
There is already a national emission standards and hazardous air
pollutant (NESHAP) being developed for coke oven by-product plant emissions.
This NESHAP will soon be available and will serve to control emissions
from this source.
Since the technology to control these sources seems available at
reasonable prices and the general public is not directly affected by
regulating these emission sources, the social impacts of controlling
these sources is low.
It will take 18 months to 2 years to develop
Federal regulations for these industries and to develop appropriate
background technical support.
should be completed sooner.
The NESHAP already under development
There has been identified a group of other uncontrolled large vac
emission sources in addition to those identified above.
These are listed
separately because various technical problems or current lack of data for
these sources means that more effort will have to go into developing the
background support for these so there will be a longer lead time in
-------
V-58
implementing regul"ations for these.
This list of sources is shown in
Table V-6.
TABLE V-6
ADDITIONAL SOURCE CATEGORIES
Potential EPA
Reduction, Tons Regul at ion
(in Nonattainment Percent Control Cost Development
Source Category Areas) Reduction $/Ton Cost {$OOQl
Wood furniture
coating 25,000 60 0 150
Autobody
refinishing 53,000 60 0 125
TSDF 330,000 50 0-55,000
Bakeries 27,000 80 1800-5500 150
POTW's 33,000 60
Fabric printing 10,000 80 400 100
Clean-up solvents 41,000 50 200
Paint manufacturing 35
Ink manufacturing 35
TOT AL 519,000
This set of source categories has 1 arge emission reduc t ion potential,
but there are various problems involved with each of these.
Wood furniture coating emissions may be reduced by up to 80 percent
by use of waterborne coatings.
Such coatings have been developed by
paint companies and demonstrated in EPA research projects.
However,
these coatings have received very limited use in production.
Currently,
we know of no large furniture company who is using these on a full time
basis.
Many industry representatives claim that waterborne coatings do
not give as superior a finish as high solvent conventional microcellulose
coatings, but this is debatable.
Other techniques which could give small
reductions, include electrostatic spray and use of high solids polyester
coatings and acid catalyzed higher solids topcoats.
Use of air assisted
-------
V-59
airless spray may give some reduction by improving paint transfer efficiency,
but due to lack of transfer efficiency data, it is unclear how much.
Although waterborne coatings do not cost more than conventional
coatings, the wood furniture industry is strongly opposed to regulation
requiring waterborne coatings, even though many in EPA believe that
waterborne coatings have been adequately demonstrated.
The industry
would also oppose being forced to use catalyzed high solid topcoats.
use of air assisted airless spray would probably not be opposed since
The
this is fairly cheap to install and allows the same coatings to be used,
but it is doubtful that this measure will get large emission reductions.
The use of add-on controls such as incinerators is not at all cost-effective
in this industry due to the large volume of air and the low VaG concentration
in spray booth exhaust air.
Autobody refinishing has been difficult to control because low-
solvent coatings have not been well demonstrated for this industry.
The
same low VaG coatings used to paint the car at the auto assembly plant
cannot be used to repaint the car since the original body paints are
baked at a high temperature to cure.
A refinished auto cannot be baked
at a high temperature as this would damage the rubber and plastic parts
of the car.
Low temperature cure catalyzed urethanes have been developed
which give a satisfactory finish, but this catalyzed coating gives off
toxic fumes before curing which would be hazardous to the paint sprayer.
Add-on controls are not feasible because of the high cost/ton of VaG
cont roll ed .
Many auto refinish shops are small businesses whose owners
-------
V-60
would have trouble raising money to buy such equipment.
One possible
control technique that might be easy to apply would be to ban solution
lacquers and encourage instead the use of dispersion lacquers.
The higher
solids dispersion lacquers would give a 60 percent reduction compared to
the low solids solution lacquers.
Higher solids enamels could also be
used to give reductions.
A problem with enforcing such a regulation is
that many small businesses would be involved and it would be difficult to
monitor compliance.
TSDF refers to treatment, storage, and disposal facilities.
VOC
emissions are emitted from a variety of facilities handling wastewater
and solids.
Such facilities include:
Surface impoundments
Waste piles
Wastewater treatment plants
Landfills
Land treatment
Transfer, storage, and handling
Pretreatment
operations
The EPA is currently involved in a large scale study of emissions from
TSDF sources which can be controlled under the Resource Conservation and
Recovery Act (RCRA).
Because the control costs and technology varies
widely depending on which segment of TSDF is being addressed, regulation
of some segments will be more feasible and more quickly developed than
others.
Regulations on industrial wastewater and municipal landfills
will probably be developed first.
POTW refers to publically owned treatment works.
Volatile organic
compounds can be mixed with water in various industrial and commerical
facilities and this wastewater dumped into a municipal sewer.
This VOC
-------
V-61
can evaporate from the water in the water treatment plant.
The most cost-
effective way of preventing this would be to not put VaG's in the wastewater
in the first place, and regulations may be able to prevent this.
If it is
difficult to prevent VaG's from getting into wastewater, the wastewater
can be treated before being discharged into the public sewer.
This can
be done with carbon adsorbers or by steam stripping the VOG's from the
wastewater.
This can be quite expensive.
One study indicated costs as
high as $50,000/ton of VaG removed could be reached.
Evaporation of
VaG's from the treatment plant itself could be achieved with covers and
treatment devices.
This treatment at the POTW itself will probably be
quite high also, but EPA has not yet done a thorough cost analysis of
this.
Bakeries are a VaG source because of ethyl alcohol which forms in
bread dough as a result of yeast fermentation processes.
This ethanol is
released when the dough rises and is baked.
One study estimated that 0.57 lb
of ethanol is emitted per person per year from bakery products in the
United States.
Large urban areas usually have several bakeries which each
may emit over 100 tons/year of ethanol.
Not all bread uses the same
types of dough so emissions will vary from bakery to bakery.
The most
obvious way to control these emissions is by adding an incinerator to the
bakery oven exhaust and burning the ethanol.
This has never yet been
done at any bakery, and bakery operators are afraid that adding the
incinerator will upset the air flows within the ovens and give unevenly
cooked bread.
The cost of incineration is estimated to vary from $2,000
to $6,000 per ton of VaG removed.
The higher costs would be for smaller
-------
V-62
ovens for baking rolls and for whole wheat bread dough or other types of
dough which emit less ethanol.
Fabric printing refers to printing of decorative patterns on fabric
for use chiefly in clothing.
The printing ink contains organic solvent
especially in the roller printing segment of the industry.
Roller
printing is basically a rotogravure printing process.
While much of the
fabric printing industry has gone to waterborne inks, the roller printing
segment uses mostly high VOC containing inks because this type of ink is
supposed to give more brilliant colors and a softer feel to the cloth.
These VOC emissions. which are often over 100 tons/year per plant. can be
controlled with add-on incinerators or carbon adsorbers.
The industry
will have some trouble affording these controls since it is a low profit
segment of the textile industry and faces sharp foreign competition.
Carbon adsorbers will allow solvent to be recovered and reused. thus
"making a profit for the printing plant.
Carbon adsorbers are thus a
viable control option for this industry.
Clean-up solvents are solvents used for cleaning various machinery.
especially coating type machinery such as paper coaters or printing
presses.
Although CTG's now exist for many of these industries. clean-up
solvent is not covered by existing regulations or CTG's even though this
accounts for sizable emissions.
The problem with developing a standard
for clean-up solvents is that there is no simple way this type of standard
could be written (such as expressing the emission limit in lbs VOC emitted
per gallon used).
Rather. the standard would most likely be a detailed
work practice type standard which would be difficult to write, difficult
-------
V-63
to enforce, and dtfficult to determine the effectiveness of.
Such a
standard might be similar in form to some of the Occupational Safety and
Health Administration (OSHA) work practice standards which are very
unpopular with industry.
However, because the estimated emissions are
large, such a standard might give significant VOC reductions.
Paint manufacturing and ink manufacturing are similar types of
industries.
Resins, pigments, solvents, and various other additives are
blended in large tanks.
Agitation of the tank contents by stirers give
rise to solvent emissions.
Resins are cooked in large kettles and volatile
material is given off from these operations.
In addition, these are
numerous solvent storage tanks and solvent pumping operations, all of
which emit solvent.
Right now EPA does not have a good national inventory
for these types of plants, but many such plants are located in large
cities (there are over 1000 different paint manufacturing companies,
. although probably 80 percent of all paint is made by the top ten companies).
The emissions from a single paint plant may be well over 100 tons per year
so the total emissions in nonattainment areas is large.
The problem with
regulating such sources is that there is no one large emission source to
control such as an exhaust of a baking oven in paper coating, for example.
Rather, there are dozens or even hundreds of small sources.
In fact,
each kettle, mix tank, and storage tank becomes a source.
Larger resin
cooking kettles and heated mix tanks could be exhausted through cold
water jacketed condensers which is a cost-effective way to collect solvent.
Smaller room temperature tanks could just be required to have covers.
Such a standard would end up being largely a housekeeping standard for
-------
V-64
which it will be d"ifficult to determine the real reductions achieved.
However, since these plants are large, significant reductions may be
achieved.
Regulations for controlling paint manufacturing facilities
already exist in the Los Angeles Air Quality Management District (AQMD)
and in Mi ssouri .
Due to the technical difficulties involved in this second grouping
of industries, it is expected that about 36 months will be needed to
fully develop the technical background document and Federal regulation
for each of these categories.
The EPA's cost of development will be on
the order of $100,000 to $200,000 for each industry category.
TSDF ,
because it actually involves many subcategories, will cost much more to
develop regulation for, but much of this money is currently budgeted and
is now being spent.
It will take perhaps 2 years after the technical background documents
and regulations are prepared to actually implement the regulations in
all areas of the country where they must apply.
Therefore, the "total
time from the start of the development program until all the industries
in Tables V-5 and V-6 comply will be 5 years.
Some aspects of TSDF regulations
""
are expected to be developed by the end of 1988 since work has been
ongoing in this area for some time.
Tightening of Existing Control Levels - Table V-7 shows a list of
emission source categories with 1983 emissions for nonattainment areas in
tons per year.
This 1 ist is taken from EPA's NEDS (National Emissions
Data System) which consists of emissions data on existing sources reported
by States to EPA's computerized system.
Table V-7 shows those source
-------
V-65
categories for which nonattainment area emissions of over 1,000 tons per
year are reported.
The 174 source categories on this list show total
emissions of 1,231,574 tons/year.
If source categories with emissions of
less than 1000 tons per year are included, the list would grow to about
800 different categories for a total of 1,426,210 tons/year emissions.
It is apparent that source categories with emissions of over 1,000 tons
per year give the bulk of emissions.
Many individual emission sources from the categories in Table V-7
are already controlled.
The column ElOC (existing level of control)
gives a weighted average level of control for sources reported in NEDS
for each category.
Even greater levels of control requirements have been
identified in certain areas of the country (usually in California).
This
maximum level of control is identified in the column labeled MAXSIP
(which stands for maximum level of SIP requirements).
-------
TABLE V-7
Ranked by SCC Category
SCC
Major
Category
--------
-----------------
30100305 Chemical Mfg
30100308 Chemical Mfg
30100504 Chemical Mfg
30100509 'Chemical Mfg
30100601 Chemical Mfg
30101401 Varnish Mfg.
30101801 Plastics Production
30101802 Plastics Production
30101807 Plastics Production
30101812 Plastics Production
30106099 Pharmaceuticals
30112599 Chemical Mfg
30113299 Chemical Mfg
30117401 Chemical Mfg
30119701 Organic Chemicals
30119705 Organic Chemicals
30119799 Chemical Mfg
30120201 Chemical Mfg
30125101 Chemical Mfg
30125405 Chemical Mfg
30125801 Chemical Mfg
30125810 Chemical Mfg
30125899 Chemical Mfg
30183001 Chemical Mfg
30188801 Chemical Mfg
30199999 Chemical Mfg
30201003 Food/Agriculture
30299998 Food/Agriculture
30299999 Food/Agriculture
30300302 Iron/Steel
30300308 Iron/Steel
30300813 Iron/Steel
30400110 Sec. Aluminum
30400199 Sec. Aluminum
30501204 Mineral Prod
30599999 Mineral Prod
30600103 Petrol Refinery
30600104 Petrol Refinery
30600201 Petrol Refinery
30600503 Petroleum Refining
30600504 Pelroleum Refining
66
POTENTIAL STATIONARY SOURCE EMISSION REDUCTIONS
Minor
Category
---------------
Ammonia Feed Desulfurization
Ammonia C02 Regenerator
Carbon Black-Furnace Vents
Carbon Black-Furnace Fug.
Charcoal-Gen,
Bodying Oil-General
Polyvinyl chloride
Polypropylene-Gen
HD Polyethylene Prod.
LD Polyethylene Prod.
General-unclassified
Organic Chem-organohalogens
Organic Acids Prod-Misc
Organic Chem-ethylene oxide
Olefin-Ethylene Prod.
Olefin-Propylene Prod.
Olefin Prod-Unclassified
Organic Chem-phenol
Organic Chem-glycols
Organi~ Chem-acrylonitrile
Organic Chem-benzene
Organic Chem-p-xylene
Organic Chem-Aromatic-Misc
Organic Chem Stg/Transfer-Misc
Fugitive-Unclassified Tons
Misc-Unclassified Tons
Whiskey Aging
Misc-Unclass. Tons Input
Misc-Unclass. Finished Tons
Coke By-Product/Oven Charging
Coke By-Product/Oven Door Leak
Sintering-Wind Box
Foil Roll ing
Misc-Unclassified
Wool Fiberglas Forming
Misc-Unclassified
Oil-fired Proc Hlrs 1000Gal
Gas-fired Proc Htrs MMcuft
Fluid Cat Cracker
Process Drains
Process Drains
1983
Emission
TPY
--------
2,310
1,122
6,258
6,488
5,900
6,,954
18,097
8,989
9,200
9,295
3,867
1,070
1,243
1,759
17,951
1,812
1,475
1,030
1,100
7,276
1,790
1,914
3,004
6,647
2,620
26,550
4,255
3,206
1,801
17,819
3,886
6,495
2,732
2,085
1,502
2,715
1,150
43,405
14,714
30,956
18,324
Potential
Reduction
TPY
--------
6,220
8,409
3,395
17,592
1,581
26,638
15,639
(lOOe TPY CUTOFF/CATEGORY)
Total
Cost
$ MM
$0.06
($2.20)
$0.65
$30.96
$1. 16
$19.90
$14.80
$/Ton
($262)
$191
$1,760
$734
$747
$946
ELOC
$9
67.50%
38.30'
0.00%
0.00%
1.88%
9.00%
9.40%
85.10%
0.00%
63.20%
59.00%
86.80%
80.20%
79.60%
0.00%
84.30%
95.80%
32.50%
0.00%
0.00%
93.98'
0.00%
99.70%
66.90%
92.20'
97.30'
0.00%
3.10%
46.80%
55.30%
24.30%
0.00%
16.10%
2.98%
34.80%
14.90%
10.30'
24.30%
95.90%
53.40%
61.10%
MAXLOC
67.50%
38.30%
0.00%
0.00'
1.88%
90.40'
9.40%
85.10%
91. 40%
63.20%
95.00%
86.80%
80.20%
79.60'
98.00%
98.00%
95.80%
32.50%
0.00%
0.00%
93.98%
0.00'
99.70%
66.90%
92.20%
97.30%
0.00%
3.10%
46.80'
55.30'
24.30%
0.00%
16.10%
2.98%
34.80%
14.90%
10.30'
24.30%
95.90%
93.50%
94.30%
MAXSIP
0.00%
0.00%
0.00%
0.00%
0.00%
90.00%
0.00%
0.00%
95.00%
0.00%
95.00%
0.00%
0.00%
0.00%
98.00%
98.00%
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%
90.00'
90.00%
-------
TABLE V-7
67
POTENTIAL STATIONARY SOURCE EMISSION REDUCTIONS
(1000 TPY CUTOFF/CATEGORY)
Ranked by SCC Category
SCC
Major
Category
Minor
Category
--------
-----------------
---------------
30600505 Petroleum Refining Wastewater Treatment
30600506 Petroleum Refining Wastewater Treatment
30600602 Petroleum Refining Vacuum Dist.(Vac. Feed)
30600603 'Petroleum Refining Vacuum Dist. (Ref. Feed)
30600701 Petrol Refinery Cooling Tower MMGal Water
30600702 Petrol Refinery Cooling Tower 1000Bbl Feed
30600801 Petroleum Refining Fugitive-Pipeline Valves
30600802 Petroleum Refining Fugitive-Vessel Rlf Vlvs-'Vlvs
30600803 Petroleum Refining Fugitive-Pump Seals
30600804 Petroleum Refining Fugitive-Compressor Seals
30600805 Petroleum Hefining Fugitive-Purge/Sampling
30600812 Petroleum Refining Pipeln valves It liq gas strm
30600822 Petroleum Refining Fugitive-Vessel Rlf Vlvs-Feed
30601101 Petrol Industry Asphalt Blowing-Gen.
30688801 Petrol Industry Fugitive-Unclassified 1000Bbl
30688803 Petrol Industry Fugitive-Unclassified 1000Bbl
30699999 Petrol Industry Misc.-Unclassified Bbls
30800799 Misc. Rubber Prod Unclassified Tons
30800799 Fab. Plastic Prod Misc.-Unclassified Tons
30999999 Fabricated Metals Misc.-Unclassified Tons
30999998 Oil/Gas-Nat Gas Prod Unlisted
31000204 Oil/Gas-Nat Gas Prod Unlisted
31000299 Oil/Gas-Nat Gas Prod Unclassified
39999999 Industrial Processes Unclassified Tons
40100102 Drycleaning Stoddard Solvent-gen.-clothes
40100103 Drycleaning Perc-Tons solv.
40100104 Drycleaning Stoddard Solvent-gen.-solv.
40100201 Degreasing Open Top-Stoddard
40100202 Degreasing Open Top- 1-1-1 Tri
40100203 Degreasing Open Top- perc
40100204 Degreasing Open Top-Meth. Chloride
40100205 Degreasing Open Top-trichloroethylene
40100299 Degreasing Open Top- Unclassified
40100399 Cold Cleaning Unclassified Solvent
40101722 Sfc. Coating Can Coating-Interior Spray
40188801 Organic Solvent Fugitive-Unclassified Tons
40188898 Organic Solvent Fugitive-Unclassified Gal.
40200101 Sfc. Coating Sol v-based Paint-Gen. Tons
40200110 Sfc. Coating Solv-based Paint-Gen. Gal
40200301 Sfc. Coating Varnish/Shellac-Gen. Tons
40200401 Sfc. Coating Lacquer-Gen. Tons
1983
Emission
TPY
--------
4,512
6,710
18,754
5,571
4,072
2,076
8,777
1,123
1,623
1,753
II ,052
3,418
2,963
17,215
3,556
8,152
33,697
3,127
2,432
1,068
1,738
1,738
2,271
20,721
4,491
1,159
3,332
4,604
8,232
6,853
l,8ll
5,008
13,581
4,336
1,768
1,055
2,060
57,218
2,020
7,444
28,978
Potential
Reduction
TPY
--------
3,482
6,039
18,371
5,460
7,879
1,010
1,431
1,571
9,915
3,076
2,667
3,932
480
2,995
2,445
3,404
3,026
978
2,604
7,160
1,503
1,073
Total
Cost
$ MM
$3.30
$4.50
$3.15
($0.90)
$7.50
$0.58
$0.71
$0.95
$8.60
$3.60
$1.90
$1. 01
$0.83
$0.18
$2.30
$3.20
$2.90
$0.94
$2.48
$7.50
($0.07)
$1.88
$/Ton
$948
$745
$171
($165)
$952
$574
$496
$605
$867
$I, 170
$712
$257
$1,729
$60
$941
$940
$958
$961
$952
$1,047
($45)
$1,752
BLOC
20.30'"
0.00'"
2.00'"
0.00'"
32.70'"
O.OO~
8.10'"
5.90~
15.50'"
3.80~
13.50'"
0.00'"
0.00'"
85.50'"
59.30'"
0.00'"
41.70'"
13.08~
71. 40'"
77.00'"
0.00'"
O.OO~
0.00'"
74.60'"
13.30~
58.00'"
1.00'"
1.90'"
65.90~
23.00~
0.00'"
25.00~
II . 80'"
25.00~
9.70'"
50.70'"
o.oo~
32.80'"
21.80'"
0.70~
11.50~
MAXLOC
81. 80'"
90.00~
98.00~
98.00'"
32.70'"
O.OO~
90.60~
90.50~
90.00'"
90.00~
91.10~
90.00~
90.00~
85.50'"
59.30'"
O.OO~
41.70'"
13.08~
71. 40~
77.00~
O.OO~
O.OO~
0.00'"
74.60~
89.20'"
75.40'"
90.00~
54.00~
80.00~
57.00'"
54.00'"
64.00~
58.30~
51.00'"
64.50~
50.70'"
0.00%
32.80~
21.80'"
0.70~
11 . 50%
MAXS IP
90.00'"
90.00'"
98.00%
98.00%
0.00%
0.00%
90.00%
90.00%
90.00'"
90.00~
90.00'"
90.00'"
90.00'"
O.OO~
0.00'"
O.OO~
0.00'"
0.00'"
0.00%
0.00'"
0.00%
0.00'"
0.00'"
0.00'"
90.00'"
50.00'"
90.00'"
54.00'"
54.00'"
54.00~
54.00'"
54.00'"
54.00'"
51. 00'"
61.00'"
O.OO~
0.00'"
O.OO~
0.00%
0.00%
0.00'"
-------
68
TABLE V-7 POTENTIAL STATIONARY SOURCE EMISSION REDUCTIONS (1000 TPY CUTOFF/CATEGORY)
Ranked by SCC Category
1983 Potential Total
SCC Major Minor Emission Reduction Cost
Category Category TPY TPY $ MM $/Ton ELOC MAXLOC MAXSIP
-------- ----------------- --------------- -------- --------
40200410 Sfe. Coating Lacquer-Gen. Gal 5,267 39.75% 39.75% 0.00%
40200501 Sfe. Coating Enamel-Gen. Tons 34,689 8.40% 8.40% 0.00%
40200510 Sfe. Coating Enamel-Gen. Gal 1,403 0.05% 0.05% '0.00%
40200601. Sfe. Coating Primer-Gen. Tons 6,147 9.60% 9.60% 0.00%
40200610 Sfe. Coating Primer-Gen. Gal 2,153 0.00% 0.00% 0.00%
40200701 Sfe. Coating Adhesive-Gen. Tons Coated 2,754 22.50% 22.50% 0.00%
40200706 Sfe. Coating Adhesive-Solvent Mixing 12,942 0.00% 0.00% 0.00%
40200710 Sfe. Coating Adhesive-Oen. Gal. Coated 1,054 0.00% 0.00% 0.00%
40200801 Sfe. Coaling Coating Oven-Oen. Tons Coating 24,070 47.60% 47.60% 0.00%
40200802 Sfe. Coating Coating Oven-Dried<175 deg 1,102 12.80% 12.80% 0.00%
40200803 Sfe. Coating Coating Oven-Baked>175 deg 2,750 57.70% 57.70% 0.00%
40200901 Sfe. Coating Thinning Solv-Unelassified 31,214 41. 80% 41. 80% 0.00%
40200902 Sfe. Coating Thinning Solv-Aeetone 2,713 3.10% 3.10% 0.00%
40200910 Sfe. Coating Thinning Sol v-Ethyl Alcohol 1,264 15.80% 15.80% 0.00'
40200918 Sfe. Coating Thinning Solv-MEK 3,730 38.09% 38.09% 0.00%
40200922 Sfe'. Coating Thinning Sol v-Toluene 5,653 0.18% 0.18% 0.00%
40201101 Sfe. Coating Fabric Coating 3,871 2,166 ($0.04) ($18) 77.98% 90.30% 85.00%
40201301 Sfe. Coating Paper Coating 11,175 7,473 $8.76 $1,172 68.00% 89.40% 85.00%
40201606 Sfe. Coating Auto/Lt.Truek Top Coat 1,794 1,073 $4.30 $4,007 0.00% 59.80% 75.00%
40202501 Sfe. Coating Misc. Metal-Coating 6,349 5,390 $8.60 $1,596 4.70% 85.60% 85.00%
40202531 Sfe. Coating Misc. Meta1-Convr Single Flow 928 882 $1. 40 $1,587 0.00% 95.00% 95.00%
40299998 Sfe. Coating Mise-Gal. 28,253 60.26% 60.26% 0.00%
4.0299999 Sfe. Coating Mise-Tons 8,115 52.83% 52.83% 0.00%
40300101 Fixed Roof Tanks Gasoline-Breathing Loss 2,805 1,843 ($0.38) ($206) 86.00% 95.20% 95.00%
40300102 Fixed Roof Tanks Crude Breathing Loss 2,376 2,198 $0.58 $264 44.00% 95.80% 95.00%
40300103 Fixed Roof Tanks Gasoline-Work ing Loss 8,628 7,328 ($1.52) ($207) 78.10% 96.70% 95.00%
40300104 Fixed Roof Tanks Crude Working Loss 14,943 12,994 $3.40 $262 81.60% 97.60% 95.00%
40300107 Fixed Roof Tanks Dist Fuel Breathing 2,288 81. 08% 81. 08% 0.00%
40300152 Fixed Roof Tanks Dist Fuel Working 1,666 53.00% 53.00% 0.00%
40300161 Fixed Roof Tanks Toluene Working Loss 1,598 24.98% 24.98% 0.00%
40300198 Fixed Roof Tanks Unclassified-Breathing Loss 2,206 1,761 $1.70 $965 77.70% 95.50% 95.00%
40300199 Fixed Roof Tanks Mise-Working Loss 6,912 6,045 $10.30 $1,704 72.10% 96.50% 95.00%
40300201 Floating Roof Tanks Gasoline-Standing 23,519 15,197 $16.30 $1,073 93.50% 97.70% 95.00%
40300202 Floating Roof Tank Product-Working Loss 8,949 4,606 $4.60 $999 93.20% 96.70% 95.00%
40300203 Floating Roof Tank Crude-Standing Loss 6,917 4,427 $0.53 $120 97.50% 99.10% 95.00%
40300204 Floating Roof Tank Crude-Working Loss 6,779 4,519 $4.52 $1,000 87.70% 95.90% 95.00%
40300302 Var. Vapor Sp Tanks Gasoline Working Loss 1,748 91. 76% 91.76% 0.00%
40301001 Fixed Roof Tanks Gasoline-Breathing 67k RVP13 1,691 1,598 ($0.36) ($225) 9.50% 95.00% 95.00%
40301007 Fixed Roof Tanks Gasoline-Working RVP13 1,233 1,163 $0.26 $224 42.00% 96.70% 95.00%
40301008 Fixed Roof Tanks Gasoline-Working RVP10 1,574 378 ($0.06) 98.67% 98.99% 95.00%
40301010 Fixed Hoof Tanks Crude RVP5 14,398 13,671 $0.57 $41 0.99% 95.00% 95.00%
-------
TABLE V-7
SCC
Ranked by SCC Category
--------
40301012
40301019
40301097
403fH099
40301101
40301102
40301105
40301107
40301108
40301109
40301110
40301198
40301199
40388801
40399999
40400101
40400108
40400110
40400111
40400116
40400199
40400210
40500101
40500201
40500301
40500305
40500311
40500312
40500401
40500501
40500511
40500599
40600101
40600126
40600131
40600133
40600136
40600141
40600236
40600240
40600243
40600253
Major
Category
-----------------
Fixed Roof Tanks
Fixed Roof Tanks
Fixed Roof Tanks
Fixed Roof Tanks
Floating Roof Tank
Floating Roof Tank
Floating Roof Tank
Floating Roof Tank
Floating Roof Tank
Floating Roof Tank
Floating Roof Tank
Floating Roof Tank
Floating Roof Tank
Petrol Storage
Petrol Storage
Blk Term. Fxd Rf
Blk Term. Fxd Rf
Blk Term. Fltg. Rf
Blk Term. Fltg. Rf
Blk Term. Fltg. Rf
Printing/Publishing
Blk Plants-Fltg Rf.
Printing/Publishing
Printing/Publishing
Printing/Publishing
Printing/Publishing
Printing/Publishing
Printing/Publishing
Printing/Publishing
Printing/Publishing
Printing/Publishing
Printing/Publishing
Tank Cars/Trucks
Tank Cars/Trucks
Tank Cars/Trucks
Tank Cars/Trucks
Tank Cars/Trucks
Tank Cars/Trucks
Marine Vessels
Marine Vessels
Marine Vessels
Marine Vessels
69
POTENTIAL STATIONARY SOURCE EMISSION REDUCTIONS
Minor
Category
---------------
Crude Working Loss RVP5
Dist. FueU2-Breathing 67K
Misc. Liq.-Breathing Loss
Misc. VOL-Working
Gasoli~e RVP13-Standing 67K
Gasoline RVPIO-Standing 67K
Gasoline RVPIO-Standing 250K
Gaslne RVP13/10/7-Withdraw 67K
Gasln RVP13/10/7-67K Withdraw
Crude RVP5-Standing-67K
Crude RVP5-Standing 250K
Unclassified-Standing 67K
Misc-250K Standing Loss
Fugitive-Unclassified
Misc-Unclassified
Gasoline-Breathing Loss RVP 13
Gasoline-Working Loss RVP 10
Gasoline-Standing Loss RVP 13
Gasoline-Standing Loss RVP 10
Gasoline-Withdraw RVP 13/10/7
Drier-General (Gallons)
Gasoline-Withdraw RVP 13/10/7
Dryer-Gen (Tons)
Letterpress-Gen (Tons Ink)
Flexographic-Gen (Tons Ink)
Iso. Alcohol Solvent
Flexographic-General (Solvent)
Flexographic-Gen (Gals Ink)
Lithographic-Gen (Tons Ink)
Rotogravure-general
Rotogravure-general
Ink Solvent
Gasoline-Splash Load
Gasoline Submerge Load
Crude Oil-Submerge Load
Jet Naptha-Sub Load
Gasoline-Splash Load-Nml Svc
Gasoline Submerge Load-Balance
Gasoline Ship-Unclean Tank
Gasoline Barge-Avg. Tank
Tanker Crude Loading
Tanker Crude Ballasting
1983
Emission
TPY
--------
1,263
7,563
1,573
9,771
4,656
2,767
1,185
1,008
4,780
5,443
1,232
1,040
6,353
5,146
11,375
1,810
3,619
2,992
2,961
2,725
10,206
1,398
13,856
9,427
6,024
8,203
1,304
1,014
5,201
16,045
7,095
12,307
2,023
4,834
8,383
1,144
5,270
2,616
1,392
3,576
2,258
1,779
Potential
Reduction
TPY
--------
1,187
1,487
8,905
4,405
2,321
1,126
958
4,295
5,125
1,170
824
5,828
1,648
3,404
2,353
2,764
2,585
6,358
1,328
5,704
7,178
1,239
963
14,526
6,628
11 ,060
961
4,143
7,009
4,995
1,682
(1000 TPY CUTOFF/CATEGORY)
Total
Cost
$ MM
$0.05
$1.43
$8.60
($1.07)
($0.56)
($0.27)
$0.95
$4.29
$1.28
$0.29
$1. 25
$9.10
$0.68
$1.40
($0.18)
($0.22)
$1. 82
$2.60
$0.94
$32.10
($0.75)
$6.96
$0.92
$13.90
$6.36
($0.73)
$0.68
$1.23
$4.99
$1. 47
$1. 20
$/Ton
$40
$962
$966
($243)
($241)
($240)
$992
$999
$250
$244
$1,517
$1,561
$413
$411
($76)
($80)
$704
$409
$708
$5,628
($104)
$5,617
$955
$957
$960
($66)
$708
$296
$712
$294
$712
BLOC
43.80%
0.00%
8.40~
92.10~
16.60%
69.00%
O.OO~
0.00%
50.70~
14.30%
0.00%
82.20%
40.70~
0.00%
56.80%
46.50%
16.00%
76.60%
55.00%
2.70%
93.90%
O.OO~
39.20'
2.80~
6.00%
60.00%
0.00%
0.00%
8.00%
56.70%
24.10%
50.66%
92.00'
75.50~
75.60%
1.00'
4.30%
93.00%
O.OO~
O.OO~
0.00%
0.00'
MAXLOC
96.60%
O.OO~
95.00%
99.30'
95.50'
95.00'
95.00'
95.00~
95.00~
95.00'
95.00'
96.30'
95.10%
O.OO~
56.80'
95.20~
95.00'
95.00%
97.00~
95.00%
97.70'
95.00'
.39.20'
2.80~
95.00~
95.00'
95.00~
95.00'
8.00%
95.90'
95.00'
95.00%
95.80'
96.50%
96.00'
1.00'
95.00%
97.50~
O.OO~
O.OO~
0.00%
O.OO~
MAXSIP
95.00~
O.OO~
95.00%
95.00'
95.00'
95.00%
95.00%
95.00%
95.00'
95.00~
95.00~
95.00%
95.00%
0.00%
O.OO~
95.00~
95.00~
95.00%
95.00~
95.00~
95.00'
95.00~
O.OO~
O.OO~
95.00%
95.00~
95.00~
95.00%
0.00%
95.00%
95.00~
95.00%
95.00~
95.00~
95.00%
O.OO~
95.00%
95.00~
O.OO~
O.OO~
O.OO~
O.OO~
-------
70
TABLE V-.7
POTENTIAL STATIONARY SOURCE EMISSION REDUCTIONS
(1000 TPY CUTOFF/CATEGORY)
Ranked by SCC Category
1983 Potential Total
SCC Major Minor Emission Reduction Cost
Category Category TPY TPY $ MM $/Ton BLOC MAXLOC MAXS II>
-------- ----------------- --------------- -------- --------
4~q00302 Servo Sta.-Stage I Sub Fill No Control 2,332 398 $0.06 37.30' 48.00' 46.70'
4 600401 Servo Sta.-Stage II Vapor No Control 6,104 5,680 $3.32 $585 28.00' 95.00' 95.00'
40688801 Petroleum Marketing Fugitive-Unclassified 4,163 75.90' 75.90' 0.00'
49099998' Organic Solvent Misc-Unclassif. Gallons 5,748 78.50' 78.50' 0.00'
49099999 Organic Solvent Misc-Unclassif. Tons Processed 57,886 84. 10' 84.10' 0.00'
50100101 Govt. Solid Waste Mult. Chmbr Munic. Incinerator 2,268 91.00' 91.00' 0.00'
50100102 Govt. Solid Waste Sngle Chmbr Munic. Incinerator 5,848 0.00' 0.00' 0.00'
50300101 Indust. Solid Waste Mul1. Chmbr. Incinerator 1,248 63.80' 63.80' 0.00'
50390006 Indust. Solid Waste Nat. Gas 3,001 0.00' 0.00' 0.00'
------- ------- ------- ------- ------- ------- ------
Totals 1,235,677 394,924 $289.90 $734 Weighted Avg./Ton
NOTES:
Potential Reduction = Incremental emission reduction resulting from MAXLOC relative to BLOC.
(Example: Existing emissions of 10,000 TPY, ELOC of 50'. If MAXLOC is 95', the potential reduction
is the difference between 95' and 50', or 45' of the base uncontrolled emissions, or 20,000x.45=9,000 TPY.
ELOC = Existing Level Of Control, or the weighted average level of control in 1983
MAXLOC = Maximum Level Of Control, or the weighted average amount of control resulting from application olevel of
control to all sources controlled less than MAXSIP in 1983. If some sources are already controlled higher t~a
MAXLOC will be higher than MAXSIP.
MAXSIP = Level of control found in most stringent SIP regulation.
-------
V-71
It can be seen by studying the MAXSIP column of Table V-7, that the
maximum level of control is usually greater than the currently existing
level of control.
If all sources below the MAXSIP level of control are
raised to the MAXSIP level and sources above the MAXSIP level retain
their current high level of control, then the weighted average control
level will be given by the MAXLOC column in Table V-7 (MAXLOC stands
for maximum level of control).
Not all source categories have MAXSIP levels of control which have
been identified as being higher than the existing level of control;
however, a number of source categories do.
For these categories,
significant emission reductions will be achieved by raising the required
level of control for all sources up to the maximum level of control
required in any regulation in the country.
The column headed "Potential
Reduction TPyll on Table V-7 gives the emission reductions for nonattain-
ment areas that can be expected by doing this as 394,924 tons/year, a
significant reduction.
The FIP should require that all existing sources be controlled up to
the level of control required in the most stringent SIP's in the country.
.
This level of control would become a Federal regulation applying to all
nonattainment areas (or at least to nonattainment areas which need a high
percentage VOC reduction to attain).
Federal personnel resources will be
needed to carry this out since a careful evaluation will have to be made
concerning what the maximum level of control really is for each category
and what source categories will be covered.
For example, in Table V-7,
-------
V-72
the MAXSIP level 6f control for printing and publishing is identified as
95 percent.
This is a much higher level of control than exists in previous
Federal guidance, so careful evaluation will be needed to determine if 95
percent is really the level of control specified in the country's most
stringent SIP and if this level of control applies to all types of printing
and publishing.
Table V-7 is a preliminary survey of existing data, and
a more detailed evaluation of each source category could result in a
revision for individual source categories although the overall total
emission reduction is not expected to change much.
It is expected that 3 years will be required to evaluate the Table
V-7 sources and impose the maximum SIP level of control on each of these
sources.
This is expected to take 4 man-years of EPA personnel time.
Generic Control Rules - While most of the large uncontrolled vac
sources are covered by the categories listed in Tables V-5, V-6, and V-7,
there are certain source categories which emit vac but are not well known
to be vac sources.
There may be only a few individual locations for each
type of process, but these individual sources may be large vac emitters
and while not a large part of national emissions may be a significant
source of emissions in local airsheds.
The EPA feels it is reasonable to
control all stack emissions of vac with add-on control equipment such as
incinerators or carbon adsorbers.
Therefore, the FIP will contain the
following generic vac control rule to apply to all vac sources in nonattain-
ment areas which emit over 25 tons/year and are. not covered by another
vac rule written specifically for that source.category:
-------
V-73
a.
All vac sources shall reduce VaG emissions by 8a percent by
collecting emissions and exhausting them through an incinerator,
carbon adsorber, or other equally effective control device.
b.
Alternatively, a VaG source applying coatings may comply by using
coatings which contain no more than 3.5 lbs vaG/gallon of coating
(6.67 lbs of VaG/gallon solids).
Such a generic rule should go into effect 2 years after the FIP is
issued in order to allow time for affected sources to do an engineering
analysis of their situation and to order and install equipment.
The EPA
manpower requirements to write the rule and include it in the FIP will be
small, but much time of EPA personnel could be involved in monitoring
compliance with such a rule.
Any sources which do not comply with this
rule should not be allowed to operate in a nonattainment area.
In addition to measures listed above, there are other measures which
the FIP should impose for areas that are greatly exceeding the standard.
For example, no new sources should be allowed unless vac emissions are
reduced by at least an equal amount from a currently existing source.
ather examples are listed below in increasing order of stringency:
1. Apply RAGT to all sources.
2. Apply LAER to all sources.
3. Apply LAER to all sources plus production caps.
4. Shutdowns or relocations.
Applying RAGT to all sources would be covered by the measures shown
in Tables V-5 and V-6 and by the generic rule (and also by measures to ensure
that existing rules are written to achieve at least the level of stringency
intended by CTG IS). .
-------
V-74
Applying LAER to all sources would mean that each source would apply
the lowest achievable emission rate possible for that source.
LAER is.
usually considered to be either:
1.
represented by the strictest regulation for that source type any-
where in the country or
2.
represented by the best controlled facility of that type identified
anywhere in the country.
The FIP would most likely use the most stringent rule in any SIP to
define LAER.
This is what is done in Table V-7, and the emission reduction
impact is shown to be 394,924 tons/year at an average cost of $734 per ton.
In addition to imposition of LAER, additional control can be achieved
by capping production at historical levels.
For example, for coatings,
the amount of solids applied per given time period can be determined from
records and fixed at this level.
af course, the amount of vac emitted
per gallon of solids will be 1 imited by RACT or LAER.
This type of
approach has already been agreed to by a number of companies as a
surrogate for using monthly averaging rather than daily averaging of
emissions.
The proposed Massachusetts bubble uses a production cap in
this regard.
The most extreme measure would be shutdown or relocations of
large vac sources to outside of nonattainment areas.
This will most likely
take the form of not allowing reconstruction of old facilities (except
for addition of air pollution equipment).
When the facility is obsolete,
it would have to be rebuilt outside the nonattainment area.
-------
V-75
However, if attainment is to be reached quickly in certain areas of
the country that are greatly exceeding the standard, extreme measures may
have to be taken.
These measures could require a shutdown of certain
currently operating solvent using facilities.
This would especially
apply to those facilities which are out of compliance with an industry
specific RACT rule or the generic VOC rule discussed above.
In order to
continue operating, these sources would have to relocate outside the
nonattainment area.
The FIP could order that large solvent using facilities
in an extreme nonattainment area reduce their solvent use by an amount
proportioned to the percent reduction needed to attain the standard.
Those facilities which would be unable to comply with this could be forced
to relocate outside the nonattainment area.
It may even be necessary to
close solvent emitting facilities larger than a certain emission size
cutoff.
This cutoff would be individually determined for each area.
Such a measure will certainly cause economic disruption, but this may be
necessary in order to attain the standard.
Restrictive NSR Measures - Certain new source review policies may be
modified for FIP's applied to nonattainment areas needing large reductions.
Greater offsets than 1 to 1 will be appropriate for new sources or major
new modifications in nonattainment areas needing large reductions.
Offset ratios of 3 to 1 will be appropriate for the most heavily polluted
areas.
Thus, any growth that occurs will contribute significantly to
reductions.
Since such large offsets will often be difficult to achieve,
new sources will be encouraged to locate outside the area.
-------
V-76
Another revision to NSR policy applicable to the most polluted areas
may be a ban on netting.
Theoretically, a source "nets out" of major new
source review by securing emission decreases within the source to balance
the increased emissions from the modification.
However, it often happens
that the emission decreases identified for netting would have occurred in
any case, so if the new source or modification had incorporated LAER, the
total emissions for the source would be lower than if the new source or
modification had been allowed to "net out" and not apply LAER.
Prohibiting
netting in very polluted areas will usually ensure emissions as low as if
netting were allowed and, in many cases, lower, although probabiy at
increased cost to the source.
At any rate, where health-based ambient
air quality standard attainment is concerned, cost is not the primary
consideration.
Area Source Emission Controls - Area sources are vac sources
that are relatively small taken individually, but in aggregate are large,
because there are large numbers of these sources scattered throughout the
popul at i on.
An example would be architectural coatings.
Thousands of
homeowners in an urban area may each use a few gallons of paint per year.
Individually, each user's vac emissions are small but taken together,
because of the large number of individual users, emissions will be large.
A more complete listing of area sources would include:
architectural coatings
traffic paint
industrial maintenance
consumer solvents
adhesives
agricultural pesticides
coatings
-------
V-77
asphalt topping for driveways and parking lots
asphalt roof coatings
asphalt roadways
asphalt sealing compounds
fuel combustion (household, wood stoves)
open burning
small boat repainting
lawn and garden machinery tail pipe and
evaporative emissions
aircraft emissions
off highway vehicles exhaust and evaporative
emissions (construction equipment, trail motocycles)
barge loading
commercial and municipal use of cleaners and solvents
Architectural Coatings - Architectural coatings are coatings used to
paint houses and other buildings and which are used by the general public
and by building and painting contractors and are generally available as
off-the-shelf items at hardware stores and other retail outlets.
Archi-
tectural coatings may be classified as either waterborne or solventborne
coatings.
In 1983, the national emissions of VOC from waterborne archi-
tectural coatings was 64,000 tons per year.
Even though waterborne
coatings have chiefly water as the volatile portion, they do contain a
small amount of organic solvent.
Due to the large amount of these coatings
used, the VOC emissions are fairly large.
There appears to be no way to
reduce these emissions, however, since these coatings are already waterborne
coatings.
Even though the volume of solventborne paint is much smaller than
the volume of waterborne paint sold, the VOC emissions are much greater
since the volatile portion of this paint is all VOC.
Consequently,
significant VOC reductions can be expected from solventborne architectural
coatings.
The national solvent emissions from solventborne architectural
-------
V-78
coatings in 1983 were 208,500 tons/year.
The emissions in nationwide
nonattainment areas would be about half this.
These emissions can be
reduced by 65 percent by going to waterborne coatings for these solventborne
coatings, a 67,800 tons/year reduction in nonattainment areas.
Several areas in California (including South Coast AQMD) have already
adopted regulations for architectural coatings, although currently there
is a disagreement between South Coast AQMD and EPA Region IX about what
VOC level should be permitted in nonflat (gloss) paints which are particularly
difficult to formulate as waterborne coatings.
Before regulation, the VOC content in most nonflat paints was about
400 to 450 grams per liter.
In 1981, South Coast AQMD adopted Rule 1113
which stated that by August 1985, nonflat paints should have no more than
250 g/1 of VOC.
Before 1985, a limit of 380 g/l was imposed.
In August
1985, the SCAQMD conducted public hearings to evaluate the industry's
progress in meeting the required level.
After receiving testimony that
nonflat paints at 250 g/l VOC content cannot be formulated successfully,
the SCAQMD board granted a 4-year extension of the 380 g/l limit.
The
EPA Region IX refused to approve this 4-year extension.
In 1 ight of the
controversy in California, it will probably take U.S. EPA 3 years to
develop an architectural rule for all nonattainment areas.
The EPA
development cost will be $150,000. Such a rul e wi 11 most certainly be a
part of the F IPs i nce such a rule is already adopted in California and
since these emissions are present in all nonattainment areas roughly in
proportion to population (although number of housing starts per year is
probably a more accurate way to apportion architectural coatings than
-------
V-79
population).
Waterborne architectural coatings cost no more than solventborne
architectural paints, so the cost of conversion is almost nothing.
Traffic Paint - Traffic paint is paint used to paint yellow and
white stripes on roads and parking lots.
The California architectural
coating rule includes traffic paints as an architectural coating, but the
paint industry usually considers traffic paint as a separate category.
The national emissions from traffic paint in 1983 were 65,000 tons per
year.
VOC emissions in nonattainment areas are estimated to be about half
this.
Waterborne traffic paints, which can reduce VOC emissions by 80
percent, have been developed and are successfully being used in a number
of States.
One estimate is that 5 percent of all traffic paints now in
use are waterborne.
Estimates for percent usage in States which use
waterborne traffic paints are:
State
% Use
Al abama
Ma ryl and
Cal Hornia
New Jersey
Vi rg i n i a
New Yo rk
70
70
30
20
10
5
In Alabama and Maryland, the State highway departments have gone 100
percent to waterborne traffic paint, but some counties in these States
have not switched.
Waterborne traffic paint is more expensive than solventborne paint
but is more durable so that it does not have to be applied as often.
This decrease in painting frequency offsets the higher paint cost.
Paint
-------
V-80
spray trucks may need to be modified to use waterborne paints.
Th es e
costs are about $20/ton of VOC removed.
Use of waterborne traffic paint
should allow 26,000 tons/year of VOC to be removed from nonattainment
areas.
Industrial Maintenance Coatings - Industrial maintenance paints are
paints used to paint industrial machinery, bridges, and process equipment
exposed to harsh environments.
Such paints are field appl ied, as opposed
to being applied in a factory where the equipment is manufactured (in
which case the miscellaneous metal parts CTG would apply).
In 1983,
there were 45,000 tons/year national emissions from this source.
It is
estimated that half of these emissions occurred in nonattainment areas.
Low-solvent coatings exist which could cut these emissions by 65 percent
for an emissions reduction of 14,625 tons/year in nonattainment areas.
The main problem with reformulating industrial maintenance paints is
that maintenance paints are often exposed to harsh environments such as
high temperature, acid fumes, and constant outdoor exposure.
Usually,
such paints cannot be baked in an oven as can other harsh environment
coatings such as automobile original coatings.
Therefore, the formulation
problems for making a low-solvent maintenance paint are formidable.
The
EPA believes paints are available, especially catalyzed high solids paints
which can perform satisfactorily in this role.
The cost to switch coatings
is usually around zero on a cost per solids applied basis so the cost in
$/ton of VOC removed should be near zero also.
This is a complex area
for regulation since industrial maintenance paints cover such a wide
variety of substrates, so it will probably take 2 years to develop a
standard for this industry at an agency cost of $125,000.
-------
V-8!
Consumer Solvents - Consumer solvents are volatile organic solvents
which are contained in common household products such as hair sprays,
cleaners, and waxes.
Table V-8 gives a more complete listing of consumer
products which emit VOC's.
Also listed are emissions estimates for the
State of California in tons/year.
Using emission inventories and population
figures, it is possible to arrive at a per capita figure for consumer
solvent emissions per year.
Data indicate that the consumer solvent use
averages about 7 pounds of VOC per person per year.
Multiplying this
figure times the population of the United States (220,000,000 persons)
gives national VOC emissions from consumer solvents to be 770,000 tons
per year.
About half this, or 385,000 tons/year, is emitted in
nonattainment areas.
-------
V-82
TABLE V-8
CONSUMER PRODUCT SUB-CATEGORIES RANKED IN ORDER
OF AVERAGE TOTAL EMISSIONS (FOR CALIFORNIA)
Consumer Product Sub-Category
Total VOC Emissions (tons)
Per Year in California
Paints, primers, varnishes (aerosols)
Hair sprays
All purpose cleaners
Insect sprays
Car polishes & waxes
Room deodorants & disinfectants
Consumer adhesives
Caulking & sealing compounds
Moth control products
Window & glass cleaners
Herbicides, fungicides
Personal deodorants
Auto antifreezes
Carburetor & choke cleaners
Break cleaners
Engine degreasers
Engine starting fluids
Rug & upholstery cleaners
Lubricants and silicones
Metal cleaners & polishes
Waxes & polishes
Tile & bathroom cleaners
Pharmaceutical s
Styl i ng mousse
Windshield deicer
Insect repellents
Starch & fabric finish
Auto cleaners
Floor waxes or polishes
Colognes
Shavi ng 1 athers
Animal insecticides
Aftershaves
Undercoat i ngs
Oven c1 eaners
Shoe polishes, waxes & colorants
Paints-other related products
Perfumes
Spot removers
Waxes & polishes liquids
Hair care products - shampoos
Carpet deodorizers
Suntan lotions
Depilatories
Anti-static sprays
11 ,408
8,095
6,463
5,558
4,625
4,650
3,830
2,380
2,098
1,970
1,803
1,614
1,165
1,051
1,032
1,088
949
930
913
660
621
590
550
543
501
396
365
354
309
303
271
255
205
188
185
183
170
135
127
97
89
69
41
11
3
68,840
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V-83
From Table V~8, the biggest source of consumer solvent emissions is
paints and primers.
This category refers to aerosol spray paints from
aerosol cans.
This is not to be confused with architectural coatings
which are usually sold in gallon pails or with industrial coatings which
are usually sold by the drum.
Several of the other largest categories
from Table V-8 such as hair sprays, cleaners, insect sprays, room deodorants
and disinfectants are also aerosol sprays.
Over half of consumer solvents
appear to come from aerosol products.
Many aerosol products could be
replaced with pump-type sprays which would lessen VOC emissions.
Up to this time, almost all of EPA's efforts in studying consumer
solvent has been in getting accurate estimates of emissions.
Very little
work has gone into studying how consumer solvent emissions can be
control 1 ed.
Based on cursory examination of the problem, it seems likely
that a 20 percent decrease in emissions from consumer solvents could be
achi eved.
This would give a 77,000 tons/year emission reduction in
nonattainment areas.
Since little is known about controlling consumer
solvents and since so many different types of products are covered under
the title "Consumer Solvents ," it will take 3 years to prepare
regulations for this emission source along with adequate technical
background studies.
Once regulations are written, another 2 years should
be allowed to phase in use of the new lower VOC products before full
compliance is reached.
The EPA development cost is estimated at $200,000.
The control technology for consumer solvents will probably be product
substitution, i.e., using low VOC products in place of high solvent
containing products.
Consumers should not have to be denied products
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V-84
they are used to having; rather, the formulation will be changed to give
lower organic solvent content.
This situation will be similar to what
occurred when aerosol products were reformulated to remove chloroflorocarbons.
Most consumers hardly noticed the difference.
There may be some products
which cannot be reformulated.
This is why a relatively conservative
emission reduction estimate of 20 percent is given.
Th e regul at i on
background study will identify those products which can be most easily
reformulated to lower VaG content.
The 20 percent reduction referred to here does not necessarily mean
that every consumer product will have 20 percent less solvent than it now
contains.
Studies may indicate that some products are easier to make in
low VaG formulation than others.
Products for which acceptable low VaG
versions exist may be required to contain less than a specified amount of
solvent, perhaps giving a 90 percent solvent reduction for that particular
product.
Other products may be difficult to make in low-solvent
formualtions.
Possibly, some of these products could continue to be sold
in high solvent formulations, but the entire product mix of consumer
solvents would have to contain 20 percent less solvent.
In some areas of the country which are greatly exceeding the ozone
standard, it may be necessary to reduce consumer solvent emissions by
more than 20 percent, perhaps up to 50 percent.
This may result in some
consumer products becoming unavailable in these areas.
Th i s wo u 1 d mo s t
likely be the case for a product which is marketed nationally whose
manufacturer is unwilling to reformulate to a lower solvent content just
for a few areas of the country.
However, since the cities which most
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V-85
exceed the ozone standard have large populations, it is likely that low-
solvent products especially formulated for this market will be developed,
especially for high volume products which would be most missed if they
were to disappear from the market.
Adhesives - Adhesives are a large user of organic solvents in the
United States.
One estimate of total national emissions from solvents is
766,000 tons per year.
These emissions may be broken into the following
segments:
Market
Na t i ona 1
emissions
per year (tons)
Percent
Construct ion
Transportat ion
Rigid bonding
Packaging
Nonri gid bondi ng
Consumer
Tapes
344,700
53,620
38,300
91,920
22,980
38,300
176,180
45
7
5
12
3
5
23
About half the above tons of emissions would be emitted annually in
nonattainment areas.
Construction includes installation of ceiling panels, floor tile,
wall coverings, wall panels and tile, and carpeting.
Manufacture of
"
prefabricated beams would also be included.
Rigid bondings prevent loosening of mechanical fasteners and would
be used in assemblying wood and metal furniture, appliances, machinery,
and electrical assemblies.
Packaging adhesives are used in laminating multiple-ply package
material and in seam sealing and closures for various kinds of packages,
bags, paper cups, and envelopes.
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V-86
Nonrigid bondings are used in combining fabrics and are used in
manufacture of shoes, carpets, and books.
Consumer adhesives are adhesives sold through do-it-yourself stores,
hobby stores, supermarkets, and model shops and are usually sold in small
containers purchased by the general public.
Tape adhesives are used to manufacture pressure sensitive tapes and
labels.
Of the above adhesive categories, consumer solvent has already been
covered under the category consumer solvent.
Tape adhesives are considered to be stationary source emissions
since the coating operation which is done on paper coating type machinery
is the source of VOC emissions.
(Less than 3 percent of the solvent
remains in the tape to possibly be emitted later.)
Pressure sensitive
tape and label coating is covered in the paper coating CTG and in the
new source performance standards (NSPS) for this industry.
Packaging adhesives would be covered to some degree by the paper
coating CTG since many packaging operations, especially laminating, are
covered done on paper coating type equipment.
Rigid bonding, nonrigid bonding, and transportation adhesives usually
are applied in a manufacturing facility so that they might be more properly
considered stationary point sources rather than area sources.
Howeve r,
since they are not covered by any regulations, we will consider them
here.
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V-87
Construction adhesives can truly be considered an area source.
Although some portion of this adhesive is applied in factories to make
prefabricated beams and other prefabricated parts, most of this adhesive
appears to be field applied.
A 20 percent decrease in emissions from construction adhesives and
also from transportation, rigid bonding and nonrigid bonding seem reasonble
to achieve.
This will be a decrease of 46.000 tons per year in nonattainment
areas.
Due to the wide variety of adhesives used. regulation development
will be complex and will take 3 years with another 2 years necessary to
fully implement regulations.
The cost to EPA to develop these standards
will be $200.000.
Other Stationary Sources - There are a variety of other area VOC
sources (as shown in the introductory paragraph under area sources). but
EPA does have a very good emission inventory on these individually.
~e
large source where data should be available is agricultural pesticides.
number of household pesticides are listed under consumer solvents. but
A
others are used by farmers and crop dusters and would not qualify as
consumer solvent.
Other area source emissions cannot be quantified at
all on an individual basis with current data.
We do, however, have gross
estimates of area source emissions which have been reported into NEDS.
Generalized NEDS data on area sources would include:
Description
Open burning. space heating. and
residential heating
All miscellaneous area sources
National emissions
1983 tons/year
583,831
3.028.864
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V-88
If the area source emissions already discussed here (consumer
solvents, adhesives, etc.) are subtracted from miscellaneous area sources
and these emissions are apportioned to nonattainment areas, the miscellaneous
area emissions remaining in nonattainment areas are approximately 577,700
tons/year.
It seems reasonable that a 20 percent decrease in VOG emissions
can be achieved from open burning, space heating, and miscellaneous area
sources.
This will give a reduction of 174,000 tons per year in
nonattainment areas.
A substantial portion of this reduction can be
attained by reductions in fuel combustion through major energy conservation
measures such as solar water heating.
Fuel combustion is a large source
of VOG emissions, perhaps even larger than indicated by the NEPS data
shown here.
Some estimates for fuel combustion VOG emissions go as high
as 2,300,000 tons per year, about 9 percent of all VOG emissions.
Another control measure that could have wide applicability and which
will reduce VOG emissions from many area sources, as well as many point
sources, is a restriction on bulk solvent purchases.
Such a measure
might involve a solvent tax or surcharge on organic solvents.
By raising
the cost of using solvents, they will be made less attractive, and
.
industrial consumers will have an incentive to use less of them.
Such a
measure would be analogous to an increased tax on gasoline to encourage
reduced vehicle miles traveled.
Other means of rationing solvent might
also be tried.
Another approach might be a solvent rationing scheme,
where users are given an allotment of solvent based on previous usage.
Such a program might be analogous in some respect to the tobacco allotment
program.
Established solvent users would have some advantage in that
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V-89
they coul d obtai n .sol vent, al though in reduced amounts from previ ous ly .
New purchasers of solvent would not have an allotment and would thus be
restricted from solvent purchases, giving them a strong incentive to
locate outside the nonattainment area.
A great many details would have to be worked out to actually implement
such a program.
It is unclear now whether such a program could successfully
be administered on a local area basis or whether such a program would
have to be administered on a national basis, even though solvent restrictions
would not apply in attainment areas.
Currently. 1 ittle study has been made of controlling these miscellaneous
area sources.
Because of this and because of the wide variety of source
types covered, it will take 3 years to develop regulations for these
sources.
An additional 2 years will be needed to fully implement these
The EPA development cost for these regulations is estimated to
controls.
be at least $200,000.
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V-gO
TABLE V-9
SUMMARY OF STATIONARY SOURCE IMPACTS
Source category
FIRST SET:
SOCMI distillation
Petroleum wastewater
SOCMI reactor process
Plastic parts coating
Metal roll i ng
SOCMI batch process
Web offset lithography
Electronics manufacture
Ai rc ra ft coat i ng
Coke oven by-product plants
SECOND SET:
Wood furniture coating
Autobody refinishing
TSDF
Bakeries
POTW I S
Fabric printing
Clean-up solvents
Paint manufacturing
Ink manufacturing
POLICY CHANGES:
Cleaning up existing regs.
Tightening existing regs.
( LA ER )
Generic control rule
Capping production
AREA SOURCES:
Architectural coating
Traffic paint
Industrial maintenance paint
Cons umer solvent
Adhesives
Miscellaneous area sources
TOTAL:
Potent i a 1
reduc t ion, tons*
(in nonattainment
areas)
EPA
development
cost ($000)
Impl ementation
time, years
66,000
11 ,000
12,000
16,000
7,000
38,000
31,000
4,000
3,000
91 ,000
75
75
75
75
125
225
100
125
100
100
25,000
53,000
330,000
27,000
33,000
10,000
41,000
150
125
150
100
200
32,000
395,000
20
120
68,000
26,000
15,000
77 ,000
46,000
174,000
1,631,000
150
125
125
200
200
200
2:"940
*These are emission reductions expected to be achieved by application
of appropriate cont~ol measures, not total emission inventories.
3.5
3.5
4
4
3.5
4
3.5
4
4
2
5
5
5
5
5
5
5
5
5
1
3
2
5
4
4
5
5
5
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V-91
Three Example FIP's (short-term projection:
1992)
For the purposes of this study, three "generic" areas were selected
to represent the range of reductions needed to demonstrate attainment.
This simplification allows analysis of measures based on national
percent reductions instead of city-specific inventories.
Cities with
atypical inventories (i.e., significant deviation from the assumed 50
percent mobile, 30 percent area, 20 percent point source mix) may be
misrepresented by this simplification.
However, at the higher reduction
targets where control of all sources is needed, few sources remain uncontrolled
and the source mix for individual cities becomes less important.
An area representing the low end of reduction targets was assumed to
need up to 25 percent reduction from 1983 levels.
Based on 1982-1984
data, real areas in this range might include Kansas City, Pittsburgh, and
Detroit.
An area representative of the middle range is assumed to need
from 25 to 50 percent reduction.
This could include areas such as Atlanta,
Dallas, and Philadelphia.
The high area is assumed from 50 to 75 percent
reduction.
This could include areas like Houston, Chicago, New York,
and Los Angeles.
Low Reduction Target - The representative area with a low
target (needing up to 25 percent reduction to attain) can reasonably be
expected to achieve this reduction by about 1990.
Many areas in this
range are those which had projected attainment by 1982 in their 1979
ozone SIP's.
These areas did not ask for extensions to 1987 for attainment
and have not been required to implement 11M, Group III CTG's, or RACT on
non-CTG major sources.
The requirements existing in these areas in 1983
consisted of Groups I and II CTG's on major sources.
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V-92
A FIP strategy for an area with a low target would consist of the
standard set of measures shown in Table V-10, plus Groups I and II
CTG's on sources below 100 tons (nonm~or sources), Group III CTG's, and
RACT on non-CTG sources.
This strategy would result in a reduction of
about 34 percent reduction by 1992 with a RACT 11M program, or 31 percent
wi thout 11M.
Medium Reduction Target - Areas with a medium target (defined
as from 25 to 50 percent) can approach the attainment target by 1995 by
applying the standard set of measures.
Medium-type areas need enhanced
11M, Stage II, and some sort of "TCM" giving at least a 25 percent
reduction in VMT.
Here, gas rationing has been assumed; however, a gas
tax or vehicle tax could be substituted if capable of similar VMT
reduct ions.
Because of the 25 percent decline in VMT, a reduction credit
has been taken in the gasoltne storage, marketing, and refining chain due
to lower gasoline production.
Also, additional area source and point
source controls would be needed to achieve a 50 percent reduction target.
Therefore, it has been assumed that existing point source controls would
be revisited and tightened to the most stringent levels found in the
country, and that up to 25 percent of consumer solvents would be prohibited.
However, the total reduction would be short of the 50 percent target
unless other measures are added.
Most areas with a medium reduction target are already subject to the
extension area requirements such as 11M and the Group III and non-CTG
RACT.
However, most of these measures had not been implemented as of
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V-93
1983, so additional reductions from these measures can be assumed from
the baseline.
Table V-10 shows one possible control strategy for a
medium area with the associated emission reductions.
TABLE V-10
THREE EXAMPLE CONTROL STRATEGIES:
Prescribed Attainment Year
Measures
1992 ANALYSIS
Low
(up to 25%)
1992
Med i urn
(25-50%)
1992
Hi gh
(50-75%)
1992
Percent Reductions From Total
VOC Emissions in 1983
------
Mobile Sources & Related
- FMVCP + I/M (without VMT growth)
- VMT growth
- Gasoline volatility
- Enhanced I/r1
- Stage I I
- TCM's (gas rationing with 25-50%
VMT reduction)
Net, mobile sources
Stationary Sources (point and area)
- Implement and cleanup existing rules
- New point source control
(new CTG's, TSDF's, etc.)
- Revisit/tighten existing regs. - most
stringent level in county - incinerate/
convert all solvents at stationary
sources
- Area sources ban or convert up to
50% of all consumer products
with VOC solvents (house paints, etc.)
- Relocation of major emitters (petro-
refineries, large printing and auto
plants)
- Restrictive NSR (ban netting, high offsets)
- Gasoline storage, marketing,
refining (due to gas rationing)
- New source growth
- Existing source growth
Net, stationary sources
TOTAL REQUCTIONS
25%
- 5%
8%
25%
- 5%
8%
2%
2%
5%
28%
37%
4%
5%
4%
6%
3%
3%
2%
2%
3%
- 2%
- 3%
- 2%
- 3%
6%
16%
34%
53%
25%
- 5%
8%
2%
2%
10%
42%
4%
6%
6%
6%
7%
3%
5%
- 2%
- 3%
32%
74%
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V-94
High Reduction Target - Areas needing beyond about 50 percent
reduction will have to make hard choices as to which measures will be the
most feasible and cost-effective.
The control strategy shown for a medium
area will reduce the 1983 mobile source emissions by about one-third.
achieve further mobile source control by 1992 will require a massive
To
reduction in VMT (e.g., through taxes or prohibition of certain activities).
In this example, a 50 percent VMT reduction through gas rationing has
been assumed.
Even if mobile source emissions could be reduced by 100 percent
(i .e., if all vehicles were prohibited), which is obviously not realistic,
further point or area source control would be necessary to achieve a
70-75 percent reduction.
Table V-lO shows one example control strategy
that could bring such an area into attainment by 1992.
In this example, additional control has been assumed for existing
stationary sources representing incineration, conversion, or elimination
of all solvents.
Also, up to 50 percent prohibition of area source
solvent usage (e.g., consumer solvents, architectural coatings, etc.) has
been assumed.
Further reductions are unlikely to be obtained by any other measures
short of plant shutdowns and relocation outside of the problem area.
this example, it has been assumed that attainment by 1992 is such an
In
important objective that permits for large VOC emitters will be revoked
and these sources forced to shutdown before the deadline arrives.
In
addition, the new source review program is assumed to be enhanced to the
point where it is able to offset not only all new source growth, but a
portion of existing 50urce growth.
-------
V-95
Three Example FIPls (long-term projections:
1995, 2000, and 2010)
This long-term projection gives a more realistic projection of
attainment.
The longer deadlines also allow for additional mobile source
measures (tightened tailpipe standards, methanol conversion) that require
turnover of the vehicle fleet.
The disadvantage is that additional VMT
growth more than offsets the reductions available from these programs.
As shown in Table V-11, the long-term analysis assumes that areas
with higher reduction targets will need additional time to implement the
additional measures.
Therefore, the low target area is assumed to attain
by 1995, the medium target area by 2000, and the high target area by
2010.
Even with these relatively near-term dates, the medium and high
target areas will need to offset significant amounts of VMT growth.
Low Target Areas (up to 25 percent reduction)
As in the previous projection for 1992 attainment, the example low
target area is easily projected to meet its target.
And, as in the
previous projection, the same "minimum set" of measures will provide
about 35 percent reduction.
Medium Target Areas (25 to 50 percent reduction)
In thi s exampl e, attai nment in the medi um target area is predicted
to occur by about 2000.
The principal difference between this and the
previous projection of attainment by 1992 is that gas rationing is not
assumed to occur in the long-term projection.
Rather, a combination of
TCMls, with an aggregate reduction of about 20 percent in VMT, has been
assumed.
These TCMls, along with those for the high target area, are
listed separately in Table V-12.
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V-96
As in the previous "medium target" example where attainment was
projected by 1992, stationary and area sources are controlled by tightening
of existing regulations and control of consumer solvents.
In the year
2000 projection, growth in these source categories result in increased
reductions from control in the 2000 time frame.
High Target Areas (50 to 75 percent reduction)
In the high target area, it is assumed that tailpipe standards would
be tightened, that VMT would be reduced by up to 40 percent using the
measures listed in Table V-12 and that half of the vehicle fleet would be
converted to methanol fuel.
These measures would "reduce the mobile source
emissions by about 46 percent and probably represent the limit of control
on mobile sources.
Additional stationary source controls are similar to those assumed
for the high target area in the 1992 projection:
incineration, conversion
or elimination of solvent use; prohibition of up to 50 percent of solvent
in consumer and commercial products; relocation of major emitters and a
very restrictive new source review program.
It has been assumed that by
2010 a small (about 2 percent) amount of VOC reduction could be achieved
.'
through energy conservation measures such as solar water heating replacing
gas or electric water heating.
-------
V-97
TABLE V-II
CONTROL STRATEGIES
LONG-TERM PROJECTION
Potential Attainment Year:
Measures
Mobile Sources and Related
- FMVCP + I/M (without VMT growth)
- VMT growth
- Gasoline volatility
- En hanced I/M
- Onboard
- TCM's (up to 40% VMT red.)
- Tighten tailpipe standards
- Methanol fleet conversions
(50% of fleet, 80% reduction)
Net, mobile sources
Stat ionary Sources
- Implement & clean up existing rules
- New point source control
(new CTG's, TSDF's, etc.)
- Revisit/tighten existing regs. to
most stringent levels in country
- Area sources
-- consumer products-control or ban
up to 50% .
-- commercial solvents-control or ban
up to 50%
- Relocation of major emitters (petro.
refine, large printing plants, etc.)
- Major energy conservation measures
(solar water heating, etc.)
- Restrictive NSR (ban netting, high
offsets)
- Gasoline storage, marketing,
refining due to VMT reduction
- New source growth
- Existing source growth
Net, stationary sources
TOTAL REDUCTIONS
Approximate Emission Reductions
from 1983 by Nonattainment AreaJjye
_Low (25%)
1995
Medium (50%)
2000
28%
- 6%
8%
30%
- 8%
8%
2%
2%
4%
30%
38%
4%
5%
4%
6%
3%
4%
3%
4%
2%
- 3%
- 4%
""5%
35%
- 4%
- 7%
-12%
50%
High (75%)
2010
30%
-13%
8%
2%
2%
8%
3%
6%
46%
6%
6%
6%
7%
4%
3%
2%
11%
4%
- 8%
-12%
20%
75%
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V-98
TABLE V-12
TRANSPORTATION CONTROL MEASURES
Expected percent emission reduction*
from 1983 by nonattainment area type
(i .e., reduction requirement)
Gas tax (10%-15% VMT red) - up
to several $/gal
Low (25%) Medium (50%) High (75%)
1995 2000 2010
2 3
2 2
Projected Attainment Year:
Vehicle use-ownership tax
(10% VMT red) - perhaps
$1000 or more/year/
second car
Mass transit (2% VMT
reduction) - new subway
or light rail system
Rideshare/carpooling (1% VMT
reduction) - perhaps
triple current parking fee
0.4
0.2
0.2
Work schedule changes (1% VMT
reduction) - 20% of workers,
4-day/week
Alternate drive days (10% VMT
reduction) - all cars
every other day
0.2
0.2
2
TOTAL
4.4
7.8
*In this table, a 10% reduction in VMT yields approximately a 2% direct
reduction in emissions. An additional reduction of about 1% in VOC per
10% reduction in VMT is expected from less gasoline throughput in the
marketing chain.
-------
APPENDIX
-------
APPENDIX A
SELECTED EXPERIENCES WITH STATE AND FEDERAL
TRANSPORTATION PLANNING
Ozone State implementation plans (SIP's) with major transportation
control measures have been proposed or promulgated for numerous areas
across the country since 1972. Many of these plans have included
transportation-related controls such as 11M, carpooling, mass transit,
and even gas rationing.
The following is
the SIP proposals and
plans in five cities:
Houston.
a catalog of the history and events associated with
Federal promulgation of transportation control
Los Angeles, Philadelphia, Cincinnati, Boston. and
[Appendix A to be provided later]
-------
APPENDIX B
ELASTICITIES OF GASOLINE DEMAND WITH PRICE
Demand elasticity reflects changes in consumer behavior in response
to changes in price. In this study, price is increased by taxation. As
consumers have time to adjust, the amount of gasoline consumed will change
relative to a given price increase.
As shown in Table B-1, the average short-term (1 year) elasticity of
demand for gasoline is approximately -0.2. This means a price increase
of 100 percent would result in a 20 percent reduction in consumer demand.
The average long-term (up to 10 years) elasticity is reported to be about
-0.7, but is based on speculation. These estimates are from Analyzing
Demand Behavior - A Study of Energy Elasticities by Douglas R. Bohi,
Resources for the Futures, Inc., John Hopkins University Press, 1981.
TABLE 8-1
SUMMARY OF PRICE ELASTICITIES OF DEMAND FOR GASOLINE
Short-run
Long-run
---
Range
-0.11 to -0.41
-0.36 to -0.77
Average
-0.2
-0.7
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