United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/4-80-026
October 1980
Air
Methodology To Conduct
Air Quality Assessments
of National Mobile Source
Emission Control
Strategies
Final Report

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                                   EPA-450/4-80-026
Methodology To Conduct Air Quality
   Assessments of National Mobile
 Source Emission Control Strategies

                Final Report
             Energy and Environmental Analysis, Inc.
                  1111 North 19th Street
                 Arlington, Virginia 22209
                 Contract No. 68-02-3371
              EPA Project Officer: Warren P.G. Freas
            U.S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Air, Noise, and Radiation
            Office of Air Quality Planning and Standards
            Research Triangle Park, North Carolina 27711

                    October 1980

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This report was furnished to the Envfronmental  Protection Agency by
Energy and Envfronmental Analysis, Incorporated, 1111  North 19th Street,
Arlington, Virginia  22209, in fulfillment of Contract No. 68-02-3371.
The contents of this report are reproduced herein as received from
Energy and Environmental Analysis.  The opinions, findings and conclusions
expressed are those of the author and not necessarily those of the
Environmental Protection Agency,
             Publication No,  EPAT<450/4-80^026
                              ii

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                            TABLE OF CONTENTS
                                                                 Page
1   INTRODUCTION   ...                           .1-1
    1.1  Purpose of this Report	1-1
    1 2  Past Applications of Rollback and EKMA	1-2
    1.3  Report Organization	1-4
2.  APPLICABILITY OF ROLLBACK AND EKMA	            .2-1
    2.1  Assumptions and Limitations	2-1
         2.1 1  Rollback Assumptions     ...                . 2-1
         2.1.2  Rollback Limitations	2-4
         213  EKMA Assumptions         	   .  .    . 2-5
         2.1.4  EKMA Limitations	2-6
         2.1 5  Applications of EKMA to Ozone Strategies .... 2-8
    2.2  Use in Nationwide Studies	2-11
         2.2.1  Carbon Monoxide	     .... 2-11
                2.2.1.1  Applicability of Rollback  	 2-12
                2 2.1.2  Comparison of Results Using Rollback
                         and the Indirect Source Guidelines. .   . 2-14
         2.2.2  Ozone	2-15
         2.2.3  Nitrogen Dioxide 	 2-16
3.  SUGGESTED METHODOLOGIES FOR COMPILING MODELING DATA. .    .   . 3-1
    3.1  Emission Inventories	3-1
         3.1.1  Ozone.  . .     	3-1
         3.1.2  Carbon Monoxide	3-9
         3.1.3  Nitrogen Dioxide 	 3-10
    3.2  Design Values	3-14
         3.2.1  Carbon Monoxide.   	     .   . 3-17
         3.2.2  'Ozone	3-17
         3.2.3  Nitrogen Dioxide 	 3-18

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                     TABLE OF CONTENTS (Continued)
                                                                Page
   3.3  Growth and Retirement Rates  	 3-20
        3.3.1  Stationary Sources  	 3-20
        3.3.2  Mobile Sources	3-23
   3.4  Control Effectiveness  	 3-30
        3.4.1  Mobile Sources	3-30
        3.4.2  Stationary Sources  	 3-32
   3.5  Source Contribution Factors  	 3-40
        3.5.1  Ozone	3-41
        3.5.2  Nitrogen Dioxide  	 3-42
        3.5.3  Carbon Monoxide	3-42
    3.6  Transportation  Control Factors	3-51
4.  STRATEGY EVALUATION  CRITERIA  	 4-1
    4.1  Percentage Change  in Pollutant  Concentration	4-1
    4.2 Number of Exceedances of the NAAQS	4-2
    4.3 Number of Regions  with Ambient  Levels Greater than
         the Standard	4-4
    4.4  Other Strategy Evaluation Criteria	4-5
    4.5  Conclusion	4-5

5.  SUMMARY AND CONCLUSIONS	5-1
    5.1  Applicability of Rollback and EKMA	5-1
    5.2  Suggested Methodologies  for Compiling Modeling Data .  .  5-3
         5.2.1  Emission Inventories 	  5-3
         5.2.2  Design Values	5-4
         5.2.3  Growth and Retirement Rates	5-4
                5.2.3.1  Stationary Sources	5-4
                5.2.3.2  Mobile Sources	5-5

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                  TABLE OF CONTENTS (Continued)
                                                             Page
     5.2.4  Control Effectiveness	5-5
     5.2.5  Source Contribution Factors	5-6
     5.2,6  Transportation Control Factors 	  5-7
5.3  Strategy Evaluation Criteria	5-7

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                          1.   INTRODUCTION
1.1  PURPOSE OF THIS REPORT
The purpose of this report is to (1) review and evaluate current proce-
dures ,  and suggest new procedures when warranted for applying modified
rollback modeling assumptions and the Empirical Kinetic Modeling Approach
(EKMA)  to national strategy assessments, and (2) to compile national
data bases for CO, 0~, and NO- for use in future nationwide mobile
source  studies.  Both modified rollback and EKMA are simple models which
do not  require extensive data bases.  As such,  they are most useful for
analyzing the impact of an emission control strategy on air quality in
nationwide studies where a number of alternative control strategies must
be analyzed in a great many areas.   While these models may not estimate
absolute concentrations in each modeling region with great accuracy,
they are useful for predicting the relative impacts of a number of
alternative emission control scenarios on a nationwide basis.

The rollback model is based on the assumption that a change in pollutant
emissions will result in a proportional change in the pollutant's ambient
concentration.  In its simplest form, rollback assumes that the concen-
tration of a pollutant at any point is equal to its background concentration
plus some linear function of the total emission rate of that pollutant
in the  area which impacts the concentration at that point.  However, the
version of the rollback equation discussed in this report provides for
different assumptions to be included for each of a number of source
categories which comprise the total emission rate of a pollutant.  For
instance, growth in new sources, control efficiencies, and a typical
source-receptor relationship can be specified for each source category
of interest.  The source-receptor relationship is especially important,
because it is what differentiates rollback from other more sophisticated
air quality models.
                                   1-1

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EKMA is a procedure for using an isopleth diagram to estimate the effec-
tiveness of volatile organic compounds (VOC) and/or NO  controls on
                                                      A
ozone concentrations.  The isopleths depict the sensitivity of maximum
hourly afternoon ozone to changes in non-methane organic compounds
(NMOC) and oxides of nitrogen (NO ) under meteorological conditions
                                 A
conducive to ozone formation.  The EKMA curves have been generated using
a chemical kinetic model validated and calibrated with smog chamber data
(U.S. EPA, 1977).

1.2  PAST APPLICATIONS OF ROLLBACK AND EKMA
One of the first uses of rollback was to set goals for the emission
reductions needed from automobiles in order to meet the National Ambient
Air Quality Standards on a nationwide scale (Earth, 1970).  Since that
time, projection analyses using rollback.and EKMA have been performed to
evaluate the relative air quality impacts of revisions to the automotive
emission standards,  inspection and maintenance programs for autos,
alternative truck regulations, alternative motorcycle emission control
strategies, and high altitude emission standards.  The results of these
analyses have been  used  in  environmental impact  statements for EPA
mobile  source regulations and to supply Congress and the Administration
with an assessment  of the air quality impacts of alternative automotive
emission standards.   The most recent  important applications of rollback
and  EKMA to nationwide  studies have been the EPA regulatory analyses
conducted  in association with the  review of ambient standards for 0- and
CO  (U.S. EPA, 1979  and EEA,  Inc. 1979).

Past mobile source  air  quality assessments  have been performed using a
sample  of  Air Quality Control Regions (AQCR's) that have ambient monitoring
data which indicates either present NAAQS violations or the potential
for  future NAAQS violations for  CO, N02, or 0  .  The monitoring data, or
design  values, used to  choose the AQCR's with the highest pollutant
levels,  are used as  the  base year air quality concentrations in the
                                   1-2

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rollback equation.  Data on current emission levels are usually  taken
from the U.S. EPA National Emissions Data System  (NEDS) or from  emission
inventories prepared by State or local air pollution control agencies.
NEDS is typically used because of the consistency of data collection
among regions.  These data are grouped into source categories which have
similar growth patterns and anticipated control potential.  Assumed
growth rates and control efficiencies for each source category are then
applied to estimate future year emissions.  The relationships between
emissions and pollutant concentrations typically observed at design
value monitors for each source category are taken into account in the
rollback formulation so that sources that have tall stacks or are usually
located far from urban area monitors are assumed to have less impact  on
design value monitors than mobile or other ubiquitous sources.  For
instance, in the recent CO regulatory analysis, point source emitters
were found, through modeling, to generally have no impact on monitored
CO levels in urban areas, due to monitor placement (EEA, Inc., 1979).

Assuming that the relationship between air quality and emissions observed
in the base year remains the same in future years, projected emissions
are used to estimate ambient pollutant levels for the year of interest.
Indicators such as average percentage change in concentrations, number
of cities with projected ambient levels above the NAAQS, and the total
number of violations are then used to characterize how air pollutant
levels are expected to change.  Typically, alternative emission control
options are compared using these indicators.

The EKMA isopleth curves were incorporated into the nationwide analysis
procedure in 1977.  These curves depict the sensitivity of maximum
hourly ozone to changes in non-methane organic compounds (NMOC) and
oxides of nitrogen (NO ) under conditions assumed to be conducive to
                      X
ozone formation.  Past EKMA analyses performed on a nationwide basis
                                 1-3

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assumed that the NMOC/NO  ratio is 9.5:1 in all areas, and that the
                        X
effects of natural background ozone concentrations on maximum afternoon
ozone levels for an urban area are offset by diminishing levels of
transported ozone into the areas as controls are implemented upwind.  It
has also been assumed in the nationwide study applications of EKMA that
NO  levels remain constant in future years.
  x

The information presented in this report draws most heavily from the
recent regulatory impact analyses for the National Ambient Air Quality
Standards (NAAQS) for CO, 0_, and NO..  The CO rollback analysis was
performed by SRI International for mobile and stationary area sources
(Siddiqee, Patterson, and Dermant, 1979).  The CO point source analysis
using the model PTMAX was performed by EEA, Inc. as well as the cost and
economic analysis for all significant .CO sources (EEA, Inc., 1979).  The
0» regulatory analysis used both rollback and EKMA to forecast which
areas would have 0~ levels higher than various alternative ambient
standards (U.S. EPA, 1979).  The NO  regulatory work is still in progress.

1.3  REPORT ORGANIZATION
This report is organized in four sections in addition to the Introduction.
Section 2 discusses the applicability of using rollback and EKMA in
nationwide studies.  The assumptions and limitations of the models are
presented and their use in nationwide studies is discussed separately
for CO, O.j, and NO^.  Section 3 presents suggested methodologies for
compiling modeling data for use in rollback and EKMA.  Section 4 critiques
the evaluation criteria typically used to compare different model runs.
A summary of the entire report is presented in Section 5.
                                 1-4

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                         REFERENCES FOR SECTION 1
Barth, D. S.  1970.  "Federal Motor Vehicle Emission Goals for CO,  HC,
and NO  Based on Desired Air Quality Levels".   J.  Air Poll.  Control
Assoc.  Volume 20.

Energy and Environmental Analysis,  Inc.   December 28,  1979.   Regulatory
Impact Analysis for the National Ambient Air Quality Standards for
Carbon Monoxide.  Arlington, VA.

Siddiqee, W., Patterson, R.  and Dermant, A.  December 1979.   Methodologies
to Conduct Regulatory Impact Analysis of Ambient Air Quality Standards  for
Carbon Monoxide.  (EPA-450/5-80-006).  SRI International,  Menlo Park, CA.
(Prepared for U.S. EPA, RTP, NC).

U.S. Environmental Protection Agency.  February 1979.   Cost  and Economic
Impact Assessment for Alternative Levels of the National Ambient Air
Quality Standards for Ozone.  (EPA-450/5-79-002).   Research  Triangle
Park, NC.

U.S. EPA.  November 1977. Uses, Limitations and Technical Basis of Procedures
for Quantifying Relationships Between Photochemical Oxidants and Precursors.
(EPA-450/2-77-021a) Research Triangle Park, NC.
                                 1-5

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                  2.  APPLICABILITY OF ROLLBACK AND EKMA
Section 2.1 presents a discussion of the assumptions and limitations of
rollback and EKMA and how these models compare with alternative air
quality modeling approaches.  Section 2.2 discusses the use and applica-
bility of rollback or EKMA in nationwide studies of CO, 0., and NO,,
concentrations.  Each pollutant is discussed separately in Section 2.2.

2.1  ASSUMPTIONS AND LIMITATIONS

2.1.1  Rollback Assumptions
Air quality dispersion models are mathematical constructs that attempt
to represent, with varying degrees of sophistication, the relationship
between pollutant emissions and the resulting concentration of that
pollutant in the ambient air.  If only nonreactive pollutants are considered,
i.e., those that do not undergo rapid chemical transformation to some
other species, then the relationship between emissions and air quality
concentrations can be represented very simply as:
          X  =   2  R.Q.  +  B                                   (2-1)
           o     iii

      where:
          X  = Base year air quality concentration.  It should ideally
               be a measured concentration which is representative of
               the air quality in the region of interest during the base
               year.  This "design value" is usually chosen to be con-
               sistent with the form of the air quality standard for the
               pollutant being modeled.
          Q  = Base year emission inventory for source category i.  The
               inventory should be accurate and complete for all signif-
               icant sources of the pollutant being modeled.  It is
               usually expressed in tons/year.
                                 2-1

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          B =  Ambient  background concentration in an area  (defined  as
               the  sum  of  the  contributions from natural emission  sources
               within the  study area and the anthropogenic  and natural
               sources  outside the study area affecting concentrations
               in the study area) given in the same units as X  .
          R. = Function that relates the emission rate  (Q ) to the
               pollutant concentration (X ).
For example, if the Gaussian or bivariate normal equation is assumed to
be representative of the behavior of the pollutant after it is emitted,
the R. takes on the familiar form given in the traditional  Gaussian
     i
models.  As such, R. is characterized as a function of  source-receptor
distance, atmospheric stability, windspeed and the effective height  of
release (stack height plus buoyant rise).  An important feature  of the
formulation, that will be  employed later in this discussion, is  the
linear dependence of the pollutant concentration on the pollutant  emission
rate, i.e., for any given set of meteorology and source-receptor configurations
R. is a constant which does not depend on changes in emissions.

When the data are not available to evaluate the function R  , or  are  im-
practical to assemble,  such as in the case with an analysis of nation-
wide scope, then a simplifying assumption is usually made that  reduces
R. to an arbitrary constant (K).  If this is done, Equation (2-1)  reduces
to the form:
          XQ =  K 2 Q   +  B                                      (2-2)

where, as before, X  and Q  are  the base year air quality and  emission
rate  (for category i) respectively, and B is the background concentra-
tion.  An alternate  form would be to set R  = kS..  Then,
          XQ = k SQ^  +  B                                      (2-3)

where  the  factor S   is  introduced because  it  is not desirable  to totally
discard  the effect  of height  of  release  and distance  on the rate of
dispersion and consequently on  concentration  estimates.
                                      2-2

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Air quality projections for some calendar year j can be made with  suit-
able adjustments to the emission rates for each source category ±  to
account for growth (G.,), change in emission factors (F..) resulting
from imposition of controls, dispersion characteristics (S.) and the
implementation of transportation control measures (T  ) .  The future
year projection for year j then becomes:

          x  - k                   + B                           (2-4)
     where :

          X. = Projected air quality concentration for calendar year j.

         G  . = Growth factor for source category i in year j .  This is a
           *"   measure of the expected annual growth in the activity
               level for each source category.

         F . . = Emission factor ratio for source category i in year j .
           ^   An emission factor ratio is a ratio of the emission
               factor of an average source in some future year to the
               emission factor of an average source in the base year.
               It is indicative of the amount of control on a source
               category.

          S . = Source contribution factor for stationary source category
               i.  This factor accounts for the relative effect of
               emission height and distance from the source to the
               receptor on ground level air quality.  An elevated source
               would be expected to contribute less to ground level air
               quality than a ground level source under most meteorolog-
               ical conditions.

         T  . - Transportation control factor, if applicable, for mobile
               source category i in year j .  This factor is used only to
               account for measures designed to reduce vehicle miles
               traveled in an urban area.

It has also been assumed that future background concentrations are the
same as in the base year and the proportionality constant (k) is unchanged,

The assumption on background invariance is not necessary and a different
background estimate could be used.
                                   2-3

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The projected air quality can be estimated simply by  solving  Equation
(2-3) for the unknown constant k and substituting that  result into
Equation (2-4).  The resulting expression for "modified"  rollback then
bee omes :
                                                                  <2-5)
It is clear from Equations (2-4) and (2-5), that  once  the  functional
form of R  is chosen (in this case kS.) and evaluated,  all  strategy
evaluations for nonreactive pollutants become  rollback analyses.   Projected
air quality estimates are made by adjusting emission rates  appropriately
to reflect the desired emission revisions.  Note  also,  that the rollback
formulation is inherently designed to estimate  changes  in  air quality
concentrations based on current air quality and assumed background
levels resulting from emission changes.  As such  it can only be used in
the relative rather than the absolute sense.

2.1.2  Rollback Limitations
The limitations of simple rollback have previously been described (deNevers
and Morris, 1975) but will be reiterated here  for completeness along
with additional limitations specific to air quality assessments of
national mobile source emissions strategies.   Obviously, rollback is an
attractive methodology to employ because of its computational and resource
economy.  The most significant limitations are:
   1.  Lack of model validation.
   2.  The assumed linear relationship between  emissions and air
      quality.  Deposition, agglomeration  and  chemical reaction
      could invalidate the  linear  assumption.
                                    2-4

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  3.  Estimates can only be made at existing monitoring  sites.   If
      the existing monitoring data have not detected  the "true"
      maximum concentrations, then projected air  quality estimates
      may be understated.
  4.  The growth factor used assumes all other parameters  remain
      unchanged, i.e., all sources grow equally and their  spatial
      distribution remains constant.
  5.  Simple and "modified" rollback assume that  the  meteorological
      conditions occurring when the design value  was  measured are
      the same in the projection year.
  6.  Very simplistic treatment of source-receptor relationships.
  7.  Simple rollback assumes all sources emit at the same height
      and "modified" rollback assumes sources within  certain cate-
      gories emit at the same height.

2.1.3  EKMA Assumptions
While the rollback model has been widely used as  a method for estimating
changes in air quality levels due to changes in CO emissions and N0?
area source emissions (see Section 2.2.3), the relationship between
ozone concentrations and hydrocarbon emissions is very complex  and
renders the linear relationship invalid.  (This is discussed further  in
Section 2.1.5).  Hence, the EPA is currently recommending a different
modeling methodology called the EKMA.  Because EKMA has  been described
in detail (EPA, 1977) only a brief discussion follows.

EKMA utilizes a set of ozone isopleths which depict maximum afternoon
concentrations of ozone downwind from a city as a function of initial
(i.e., morning) concentrations of NMOC and NO , NMOC  and NO  emissions
                                             xx
occurring later in the day, meteorological conditions, reactivity  of the
precursor mix, and concentrations of ozone and precursors transported
from upwind areas.
                                    2-5

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EKMA is best used to determine the sensitivity of maximum hourly ozone
concentrations observed within or downwind of a city to changes in
ambient levels of NMOC and oxides of nitrogen (NO ) precursors.  EKMA is
                                                 A
most suitable for addressing questions like, "How much reduction in
local prevailing precursor levels would be needed to attain  the 0.12 ppm
standard for ozone" or, "What reduction in ozone levels is likely to
accompany a specified reduction in precursor levels?"  The method is not
suitable for estimating the impact of strategies which result in substan-
tial changes in source configurations or for questions about what the
impact of controlling a single or small group of sources would be.  As
such, EKMA can be used in nationwide studies for the same scenarios as
rollback.

There are two variations of EKMA.  The first involves the use of city-
specific ozone isopleths.  The second utilizes a standard set of ozone
isopleths in which  fixed assumptions have been made about sunlight
intensity, atmospheric dilution rate, reactivity and diurnal emission
patterns.  Because  of  their ease  of use in  a nationwide study,  the
standard set of  ozone  isopleths was used in the ozone regulatory analysis
 (EPA,  1979).  The application of  EKMA used  in the  ozone NAAQS regulatory
analysis assumed the  same NMOC/NO ratio for all cities.  Based on  an
                                  A
examination  of data from a number of monitoring sites a median  ratio  of
9.5:1  was chosen.   In addition, it was assumed that NO  emissions remain
                                                      a
constant between the  base year and  the projection  year.  The EKMA standard
isopleth curves  are illustrated in Figure 2-1.  A  line depicting the
9.5:1  NMOC/NO  ratio  is shown for reference.
             A

2.1.4   EKMA  Limitations
For several  reasons,  isopleth diagrams are  most properly  interpreted
when used  in a relative rather than an absolute sense.  First,  the
absolute position  of  the  isopleths  depends  upon a  number  of  underlying
assumptions  concerning meteorological conditions and emission patterns.
                                  2-6

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Unless the meteorological conditions and emission patterns  corresponding
to those assumed in deriving the isopleths are similar to those  occurring
in the city of interest on days with high ozone concentrations,  there  is
no reason to expect the absolute position of the isopleths  to be correct.
The relative positions of the isopleths, however, should be  less sensi-
tive to these differences.  Sensitivity tests have indicated that pre-
dicted control requirements for emissions of volatile organic compounds
(VOC) are not very sensitive to changing dilution rates, solar intensity,
diurnal emission patterns and changes in reactivity when the isopleths
are applied in a relative sense (Dodge, 1977).  One advantage to beginning
with the observed design value of CL as input to the EKMA is that this
parameter inherently reflects the local prevailing meteorology on that
day.  In this respect, the standard isopleth approach is area-specific.
It is crucial, of course, that the 0  monitoring data have been  collected
at sites likely to record the maximum 0_ concentration in the region.

A second reason for applying the isopleths in a relative sense is that
they reflect the behavior of one fixed mixture of automotive exhaust.
Relative positions of the isopleths are less sensitive to the mix of
ozone precursors assumed.  Third, simulations in which the kinetics
model was used to derive the standard EKMA isopleths did not include
allowance for any injection of precursors after 8 a.m. LDT.   A sensitivity
test conducted with the model indicated that the maximum ozone concentra-
tion formed on the first day of the simulation is increased by post-8
a.m. precursor emissions (Dodge, 1977).  However, this same sensitivity
study indicated that estimated control requirements (using the isopleths
in a relative manner) were generally insensitive to the post-8 a.m.
emissions.  It is important to point out that in the sensitivity studies,
post-8 a.m. emissions were reduced in proportion to reductions in initial
NMOC concentrations.  Thus, in using the standard isopleths, proportional
reductions in all emissions (both 6-8, a.m. and post-8 a.m.)  must be
assumed in order for the curves to be applied properly.  No distinction
                               2-7

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                                                   FIGURE 2-1
-^1
ftt
                                    ISOPLETH CURVES FROM SMOG CHAMBER EXPERIMENT
                                                 Oa ,

                                 .00 .12  .16 .20   .24  .20
.32     .36
                                                0,0       1.0       1.2


                                                     MM! 1C ppm C
                1.4
i.a
i.a
20

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can be made between 6-9 a.m. emissions and other emissions with the
standard isopleths.  Fourth, it should be kept in mind that the isopleths
have been primarily validated against smog chamber data.  Smog chambers
represent a simplification of the urban atmosphere in that several
contaminants which may have a potential impact on maximum CL may have
been excluded from either the chamber or the model or both.  Finally, a
limitation in this method, as well as in linear rollback or any other
empirical technique, is that there will always be some uncertainty about
whether the maximum ozone concentration is measured.   On any given day
it is unlikely that the ozone monitor is at the precise location experiencing
the maximum ozone concentration.

In the Los Angeles basin, standard EKMA tends to underestimate changes
in ozone concentrations observed between the mid-1960's and the mid-1970's
(Trijonis and Hunsaker, 1978).   Studies are currently underway to
compare both city-specific and standard versions of EKMA with more
recent trends observed in the Los Angeles basin.  Results of the 1978
Trijonis and Hunsaker study, as well as the more recent studies, indicate
that the agreement between EKMA and Los Angeles trends is sensitive to
the NMOC/NO  ratio assumed to prevail in the mid-I960's.
           A

Applying EKMA to a nationwide study by assuming the same NMOC/NO  ratio
                                                                A
in all AQCR's will produce some errors.  Therefore, area specific ratios
should be used whenever available.  However, if the variance about the
default 9.5:1 ratio is not large, then indicators like average percentage
change in 0. concentration and number of areas above the ambient standard
should be meaningful for comparing control strategies.

2.1.5  Applications of EKMA to Ozone Strategies
For the rollback relationship to hold for ozone, there must be a single
proportionality constant between VOC emissions and maximum ozone.
Re-examining Figure 2-1 shows that this is not always the case.  Even if
it were assumed that the isopleths in Figure 2-1 are not absolutely
                                   2-8

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correct, the proportionality "constant" between NMOC and 0_  depends on
(1) the prevailing level of NO  and (2) the changes in NO  accompanying
                              X                          A.
hydrocarbon control strategies.  For example, for 0^ =  .28 ppm,  ac-
cording to Figure 2-1, the proportionality "constant" can be anything
from 0.36 to 0.14.  Proceeding from the 0« =  .28 isopleth down to the
0  = .08 ppm isopleth at a constant NMOC/NO   ratio of 9.5:1,  one finds
proportionality constants between NMOC and 0. varying between .26 and
.50.
As noted previously, control estimates are usually  based  on the scenario
where transported ozone (from upwind areas) is  diminished concurrently
with implementation of local emission control programs.   Ideally,  this
reduction would result in ozone transported to  downwind  cities being
reduced  to  levels approaching natural background.   Because transport and
natural  background affect maximum ozone via a similar  mechanism (i.e.,
from aloft),  to be consistent, natural background should  be ignored if
transport is  ignored.  For ozone design values  in the  range 0.15 to
0.16, the scenario in which  transport is  actually reduced, ignoring both
transport and natural background results  in calculated control requirements
that are within ±5% of those in which reasonable estimates of both
transport and natural background are considered. Hence,  this approach
may be  considered adequate given the general uncertainty  of the levels
of  present  and future transport in  many areas and the  long time frame
often considered  in  regulatory analyses.

An assumption in  rollback is that the amount of VOC emission controls
needed  to  attain  the  ozone standard is  independent  of  the prevailing
NMOC/NOx ratio.   However, smog chamber  experiments  suggest that the
 lower  the  ratio,  the  more effective the VOC reduction  is in reducing the
                                     2-9

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                               TABLE 2-1

                   NATIONWIDg EMISSION ESTIMATES, 1977
                         (10  metric tons/year)
Source Category
NO
VOC
                                                                    CO
Transportation
  Highway Vehicles
  Non-highway vehicles

Stationary fuel combustion
  Electric utilities
  Industrial
  Residential, commercial, & institutional

Industrial processes
  Chemicals
  Petroleum refining
  Metals
  Mineral products
  Oil & gas production & marketing
  Industrial organic solvent use
  Other processes

Solid waste

Miscellaneous
  Forest wildfires & managed burning
  Agricultural burning
  Coal refuse burning
  Structural fires
  Miscellaneous organic solvent use

TOTAL
                                            9.2
                                            6.7
                                            2.5

                                           13.0
                                            7.1
                                            5.0
                                            0.9

                                            0.7
                                            0.2
                                            0.4
                                            0
                                            0.1
                                            0
                                            0
                                            0

                                            0.1
 0
 0.
 0
 0
 0
 0
23.1
         11.5
          9.9
          1.6

          1.5
          0.1
          1.3
          0.1

         10.1
          2.7
          1.1
          0
          0
          3.1
          2.7
          0.3

          0.7
   1
   1
 4
 0
 0
 0
 0
 3.7
28.3
                                                                    85.7
                                                                    77.2
                                                                     8.5

                                                                     1.2
                                                                     0.3
                                                                     0.6
                                                                     0.3

                                                                     8.3
                                                                     2.8
                                                                     2.4
                                                                     2.0
                                                                     0
                                                                     0
                                                                     0
                                                                     1.1

                                                                     2.6

                                                                     4.9
                                                                     4.3
                                                                     0.5
                                                                     0
                                                                     0.1
                                                                     0

                                                                   102.7
NOTE:  A zero indicates emissions of  less than 50,000 metric tons/year.
SOURCE:  U.S. EPA, National Air Quality, Monitoring, and Emissions Trends
         Report, 1977  (EPA-450/2-78-052), Research Triangle Park, N.C.,
         December, 1978.
                                 2-10

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maximum ozone formed.  Thus,  at very low NMOC/NOx ratios, rollback may
underestimate the effectiveness of VOC controls.  Conversely, at high
ratios, estimates obtained with rollback may be overly optimistic.   With
the prevailing ambient conditions which appear to be typical  in many
cities, the net effect of rollback assumptions is to estimate that  less
control is needed to attain the ozone standard than would be  implied by
the EKMA.  Under the ambient conditions which apparently prevail  in most
cities, rollback is  likely to differ most from predictions  of kinetics
models during the period in which initial control increments  are  exercised
 (i.e, when the NMOC/NO  ratio is still relatively high).  Thus, for
                      X
 example,  if VOC emission reductions of 30 percent were  implemented  in a
 city  experiencing moderate (9.5:1) NMOC/NOx  ratios, the  corresponding
 improvement  in maximum ozone concentrations  may be  considerably  less
 than  the  30  percent  predicted with rollback.  The risk  in  relying on
 rollback  is  that when the  corresponding  30 percent  reduction in ozone
 levels failed  to materialize,  questons may arise  about  whether  con-
 trolling  volatile  organic  compounds will ever be  effective in reducing
 ambient ozone.  Many of  these  questions  would arise because a model
 which is not based directly  on cause-effect  relationships  between ozone
 and its precursors is used.  Therefore,  use  of  rollback for estimating
 VOC reductions needed to attain the ozone standard  is not  recommended.

 2.2  USE IN NATIONWIDE STUDIES

 2.2.1  Carbon Monoxide
 Concentrations of CO vary with time,  season, and geographic  location.
 These variations often follow predictable trends.  In most cities,  CO
 levels peak at 7 to 9 a.m.,  4 to 7 p.m., and 10 p.m.  to midnight.   The
 first two peaks arise from automobile traffic coupled with meteorological
 conditions.  The midnight peak can be primarily attributed to calm  wind
 conditions which result in a reduced dispersion of CO emissions.
                                  2-11

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The highest CO levels tend to occur in the fall and winter.   In  the fall
and winter seasons, the tendency toward colder ambient  temperatures
results in increased production of CO emissions from  cars,  in addition
to CO emitted from other fuel burning sources.  Also, the more stable
atmospheric conditions and low wind speeds which occur  during winter and
fall result in decreased dispersion of CO emissions and contribute  in
substantial part to the occurrence of high ground  level CO concentrations

Carbon monoxide is commonly understood to be a mobile source  problem
with wide variations in concentrations within an urban  area.   As  can be
seen from Table 2-1, transportation sources emitted more than 80  percent
of the anthropogenic CO emissions in the U.S. in 1977.  Some  cities  show
that mobile sources emit even a higher proportion  of  CO than  80 percent.
For instance, the  Denver SIP estimates that 93 percent of all CO emis-
sions in 1978 were from motor vehicles in that region.

2.2.1.1  Applicability of Rollback
A recent study performed by SRI International (Shelar, Ludwig, and
Shigeishi, 1979) for EPA's Office of Mobile Source Air Pollution Control
studied CO source/receptor relationships in four urban areas.  These
areas were San Jose, Seattle, Phoenix, and Chicago.  One of the purposes
of this study was to identify the contribution of  CO  from local versus
regional sources at sites where violations of the  8-hour CO standard are
likely.  The site chosen for study in San Jose was near a congested
suburban intersection in a commercial area.  The Seattle and  Chicago
sites were in heavily congested downtown areas.   The site studied in
Phoenix was downtown near government office buildings where parking  lots
filled and emptied during rush hours in the morning and evening.  All  of
the sites were chosen because they were considered likely to  have viola-
tions of the CO standard during the one week monitoring period.  Both
"local" and "background or regional" monitors were used at each site.
                                    2-12

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The results of the monitoring in these four cities illustrate  two  situa-
tions that can produce CO 8-hour standard violations.  The first situa-
tion is where high traffic density and congested conditions produce
excessively high CO emissions which cause high ambient levels.  This
situation is characterized by diurnal CO patterns which closely follow
traffic level variations.  The second situation is where an inversion
forms to limit vertical mixing, and emissions during  the time  the  inver-
sion is in place build up to produce peak CO levels.  CO violations
during this time can be widespread in an urban area.  However, there  is
no  evidence to 'suggest that CO is transported from any distance during
the inversion.  If this is true, "local" emissions are responsible for
high observed CO levels.

Because CO has been labeled as a "local" problem with variations  in con-
centrations thought to be due to nearby traffic densities, little  work
has been done to characterize how CO concentrations can reach  peak
 levels during periods when emissions are low.  Therefore,  there is
 considerable  uncertainty in identifying which sources or types of  sources
 are contributing to high nighttime levels of CO.  For an application of
 rollback  to be valid, it is important that  the mix of sources  contributing
 to  the problem be  accurately known.  This issue is discussed further in
 Section 3.

 In  the CO  Regulatory Analysis, the rollback equation  was applied  to
 estimate  the  number of counties that would  have CO levels  exceeding
 alternative  ambient standards  for CO in future years. Because of  the
 different  nature  of mobile and stationary source CO  emission problems,
 and the  location  of the  existing monitoring network,  it was concluded
 that  recorded violations in CO nonattainment areas are due primarily to
 mobile  sources  and localized area sources.  Therefore, only mobile
 source  and other  area source emissions were included  in the  emission
 inventories  used  in the  rollback analysis.  An analysis of large  stationary
                                   2-13

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(point) sources was conducted and it indicated that stationary source
emissions had negligible effects on existing urban monitor sites.  Thus,
the analysis assumed for existing problem areas that all reductions
would come from controlling mobile and other area source emissions.  The
regulatory analysis assumes that 100 percent of all mobile source emissions
in a county and 20 percent of all area source emissions affect concentrations
at design value monitors.  However, the mix of sources used in the CO
regulatory analysis is not applicable for cases where high CO levels are
measured during nighttime or early morning hours.

2.2.1.2  Comparison of Results Using Rollback and the Indirect Source
         Guidelines
In past uses of rollback for analyzing the impact of nationwide control
programs on CO concentrations, it has been assumed that although CO is
largely thought to be a "hot-spot" problem, that if the county or AQCR
inventory used in the modeling accurately reflects the source contri-
butions at the design value monitor, that rollback was appropriate for
estimating future year CO concentrations.   By comparing the technique
for estimating the impact of changing localized emissions on nearby CO
concentrations described in the Indirect Source Guidelines (U.S.  EPA,
1978) with the rollback equation, the validity of this assumption can be
tested.  The difference in the procedure used to estimate future year CO
concentrations using the Indirect Source Guidelines versus using rollback
is only in the way the design value is chosen.  The Indirect Source
Guidelines use the HIWAY model along with traffic characteristics to
estimate local CO contributions.   (Background CO should be added to
obtain a total concentration.)  Rollback uses measured CO values in the
urban area.  Both methods use variations in emission rates due to changes
in emission factors, vehicle miles traveled, and vehicle speed to estimate
future year concentrations.  Therefore, both methods of estimating
future concentrations assume the basic relationship that emission changes
result in proportional changes in air quality.
                                   2-14

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In any city where high CO concentrations are a localized phenomenon,
rollback can be used instead of the Indirect Source Guidelines to esti-
mate future year CO concentrations if (1) the monitor measuring the
design value is in a location representative of the highest CO in the
city, if (2) the emission sources affecting the monitor are well charac-
terized, and if (3) the same meteorological conditions are assumed to
prevail in the future.  Then, the only difference between rollback and
ISG predicted future CO concentrations is that monitored versus estimated
concentrations, respectively, are used as design values.

2.2.2  Ozone
Ozone, a secondary pollutant, results from the reaction of non-methane
organic compounds  (NMOC) and oxides of nitrogen (NO ).  Ambient ozone
                *                                   a
concentrations occur as the result of two processes.  One is a physical
process involving  dispersion and transport of the precursor emissions.
The  second  is a chemical process involving reaction of the precursors
under  the  stimulus of sunlight.  Obviously, then, meteorological conditions
are  an important factor in determining ambient ozone  levels.  Atmospheric
dilution and transport affect ambient pollutant levels and the geographic
relationship between  source areas and corresponding ozone problem areas.
Solar  radiation  and ambient temperature  affect the chemical processes.

Because meteorological conditions influence ozone formation to such  a
great  extent,  they tend to obscure both  the absolute  and relative effects
of the emission-related factors  to degrees that vary  by geographic
 location and  season.  However, because nationwide analyses are the
principal  application for the modeling procedures described in this
 document,  the  average predicted  changes  in concentrations should not be
unduly biased  by yearly meteorological variations in  a few cities.

 In previous nationwide studies it has been informative to use both EKMA
 and rollback to  produce  separate estimates of expected ozone concentration
                                    2-15

-------
re'ductions in future years.  However, EKMA is regarded as a more theoretically
sound approach for estimating the effects of VOC reduction on ozone
concentrations, and the use of rollback is no longer recommended.

2.2.3  Nitrogen Dioxide
The formation of NO- in the atmosphere is a highly complex process.  NO,
formed primarily as a result of fuel combustion, can be converted to NO-
through oxidation with atmospheric oxygen, ozone or various organic
compounds.  Only about five percent of the NO  in the combustion products
is in the form of NO-.  Production of NO- by oxidation with atmospheric
oxygen is immediate for NO concentrations greater than about 100 ppm and
significant 0^ concentrations.  Such high concentrations of NO only
occur very near the point of exhaust, however.   As the NO is diluted to
concentrations below 100 ppm, the rate of conversion by oxygen decreases
to a point where at 1 ppm, the direct reaction with 0- becomes unimportant.
For the most part, the NO to NO- conversion through this mechanism is
limited to roughly ten percent of ambient NO  concentrations.
                                            A

Oxidizing agents such as ozone produce a rapid conversion of NO to NO-.
The degree of conversion, under certain conditions, is directly propor-
tional to the level of ozone present.  In the absence of photochemical
activity, N0_ formation due to 0- is on a one-to-one basis.   In the
presence of ultra-violet light, an equilibrium set of reactions between
NO- and ozone result.  On days with high solar radiation, NO-  levels are
set by these competing reactions.  The presence of organic pollutants
(e.g., NMOC) may, in some cases, shift this equilibrium.  In spite of
these very complex chemical processes, some success in applying rollback
in NO  control strategies has been achieved, as will be shown in the
     X
following discussions.

Measured violations of the current annual average NAAQS for NO- are
generally believed to be caused by area, especially mobile,  sources.
                                   2-16

-------
Therefore, only area source emitters of NO  are  typically included in
                                          X
applications of the rollback model to NO- regulatory  analyses.   This
approach is supported by recent studies on the relative impact  of mobile
and stationary sources on high NO- concentrations.  One study analyzed
NO , CO, and SO- data from the Welfare Island monitoring site in New
York City  (Iverach, 1978).  It assumed that ambient SO  can be  used as a
surrogate  for stationary source emissions and ambient CO can be used as
a surrogate for mobile source emissions.  Therefore,  the concentrations
of CO and  SO  during periods of high NO- should  show  which source type
predominates. 'The conclusion of the analysis was  that on annual basis
for the area around the Welfare Island, NY site, NO   emitted from mobile
and other  area sources is more likely to result  in high measured NO
than NO   emitted from point sources.
       x

Other studies also tend to suggest that mobile and area sources of NO
are the primary contributors to the levels occuring at ambient  monitoring
sites.  First, it has been shown (Chang, Norbeck,  and Weinstock, 1980) ,
using LA  Basin data, that high one-hour N0? resulted  mainly from vehicular
sources.   An examination of the NO /CO and SO-/CO  ratios shows  that a
                                  X           £»
significant  impact of elevated NO  sources on high N09 occurs rarely.
                                 X                    t»
In  fact,  a stationary (both ground level and  elevated) source contribution
of  greater than  10 percent was rare at the LA Basin  sites examined.  The
only  exception to  this would be a case where  stationary sources with low
stacks  were near a monitor.

Chang,  Norbeck,  and Weinstock  also concluded  that  rollback calculations
that  assume high hourly N02 concentrations are  proportional to the total
 tonnage of NO  emissions  from  all sources will  greatly underestimate the
             X
 improvement in N02 air quality to be  expected from a  reduction in vehicle
N0x emissions  in the LA  Basin.  Therefore, source  contribution factors
must  be used to  discount  the  effect  of  emissions from stationary sources
on observed N02  levels.   See  Section  3.5  for  a  further discussion of
 source contribution  factors.
                                    2-17

-------
A recent study by SRI International (Martinez and Nitz, 1979) examined
high (greater than 0.20 ppm) hourly NCL levels at 48 monitoring sites in
California during 1975-77.  Approximately 1800 site-days when N02 exceeded
0.20 ppm were reviewed.  It was found that mobile source emitters predo-
minated at all stations.  Point-source effects linked to high hourly N0_
were infrequent.

In addition, Martinez and Nitz found that high hourly NO- levels in
Southern California coincide with increased emissions from stationary
area sources of NO .   The diurnal variations of the high N00 levels at
	              x                                        2
the California monitors were associated with the traffic cycle.   There-
fore, some combination of mobile and stationary area sources contributes
to peak NO- levels.

As noted above, these studies tend to support the contention that high
measured NO- concentrations are attributable to mobile or other area
source impacts and, thus point source emissions can be neglected.  Therefore,
although ambient concentrations of N0_ are created by a mix of emissions
from point and area sources, it is suggested that for regulatory analyses
only area sources be  modeled using rollback. This is a reasonable approach,
particularly if, as appears true from the available evidence, most
monitors in urban areas are sited to reflect contributions primarily
from area sources of  NO  emissions.
                       A
                                   2-18

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                         REFERENCES  FOR SECTION 2
Chang, T.Y.,  Norbeck,  J.M.,  and Weinstock,  B. February 1980.  "NO  Air
Quality — Precursor Relationship:   An Ambient Air Quality Evaluation in
the Los Angeles Basin".  J.  Air Poll. Control Assoc. Volume 30, No. 2.

deNevers, N.  and Morris, J.R.   1975.  "Rollback Modeling:  Basic and
Modified," J. Air Poll. Control Assoc^  Volume 25, No. 9.

Dodge, M.C. June 1977.  Effect of Selected Parameters on Predictions of
a Photochemical Model.  EPA-600/3-77-048.U.S. EPA.Research Triangle
Park, N.C.

Energy and Environmental Analysis,  Inc.  December 28, 1979a.  Regulatory
Impact Analysis for the National Ambient Air Quality Standards for
Carbon Monoxide.  Arlington, VA.

Iverach, D. August 1978.  "A Technique for Estimating the Relative
Impact of Mobile and Stationary Sources on N02 Concentrations".  J. Air
Poll. Control Assoc. Volume 28, No.  8.

Martinez, J.R. and Nitz, K.C.  August  1979.  Analysis of High NO,, Concentrations
in California,  1975-1977  EPA-450/4-79-034a.  SRI International.  Menlo  Park,  CA.
(Prepared for U.S. EPA, RTP, NC).

Shelar,  E., Ludwig, F.L., and  Shigeishi, H.  May 1979.  Analysis  of
Pollutant and Meteorological Data Collected  in the  Vicinity  of Carbon
Monoxide "Hot  Spots".   Draft.  SRI  International, Menlo  Park, CA.
(Prepared  for  U.S. EPA, Ann Arbor,  MI.)

Trijonis, J.,  Peng, T., McRae, G. and  Lees,  L.  January  1976.   "Emissions
and  Air  Quality Trends in the  South Coast Air Basin," EQL Memo No.  16
Environmental  Quality Laboratory, California Institute of Technology,
Pasadena,  CA.

Trijonis,  J. and  Hunsaker, D.   February  1978.  Verification of  the
Isopleth Method for Relating  Photochemical Oxidant  to Precursors.
EPA-600/3-78-019.  Published  by U.S. EPA,  Research  Triangle Park, NC.

 U.S. Environmental  Protection Agency.  November  1977.  Uses, Limitations
 and Technical  Basis  of Procedures for Quantifying Relationships  Between
 Photochemical  Oxidants and  Precursors.  EPA-450/2-77-021a.   Research
 Triangle Park, NC.
                                    2-19

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U.S. EPA.  September 1978.  Guidelines for Air Quality Maintenance
Planning and Analysis Volume 9 (Revised):   Evaluating Indirect Sources,
EPA-450/ 4-78-001 (OAQPS No. 1.2-028R).   Research Triangle Park,  NC.

U.S. EPA.  February 1979.  Cost and Economic Impact Assessment for
Alternative Levels of the National Ambient Air Standards for Ozone.
EPA-450/5-79-002.  Research Triangle Park, NC.
                                2-20

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        3.  SUGGESTED METHODOLOGIES FOR COMPILING MODELING DATA
This section discusses potential methodologies for compiling modeling
data for use in a nationwide analysis of CO, 0-, or NO- concentrations.
Procedures for estimating emission inventories, design values, growth
rates, retirement rates, control effectiveness, source contributions,
and transportation controls will be presented.

3.1  EMISSION INVENTORIES
The first step in compiling modeling data for use in applying rollback
or EKMA is to collect an emission inventory for each region of interest.
For each pollutant to be modeled, there are two key questions that must
be answered before inventorying can begin.  They are:
  •  What size area should be inventoried?
  •  Within this area, which source categories have a significant
     effect on monitored concentrations?

The first question can be answered by determining how large a source area
typically affects design value concentrations of the pollutant being
modeled.  The design value and the emission inventory should be within a
common boundary.  Emission patterns and ambient air quality data are
reviewed for each pollutant for a sample of urban areas to answer this
question.  To answer the second question, ambient data and modeling
studies are examined separately for CO, 0_, and N0_.
                                         •3        £»

3.1.1  Ozone
In order to determine an appropriate source area for ozone, studies in a
number of cities were reviewed.  The first such study examined here was
performed during the summer of 1977 in Tulsa, Oklahoma.  (Eaton et al.,
                                 3-1

-------
1979)  Ozone was monitored at 10 sites; NO/NO  at eight  sites;  non-
                                             2v
methane hydrocarbons at four sites; wind speed and direction at four
sites; and solar radiation at one site.  An airborne  program measured
ozone, NO/NO , temperature and other variables for seven days during the
            X
study period.  This data base is useful in determining  the  spatial
distribution of ozone and the relationship between major emission sources
and  observed maximum concentrations.

On three of the four days that the aircraft measured  a  distinct ozone
plume, the maximum ozone concentration was measured approximately 48 km
 (30  mi) north of the center of Tulsa.   (Aircraft monitoring flights were
only made on days with consistent southerly winds).   On the remaining
day, the maximum ozone concentration was measured approximately 32 km
 (20  mi) downwind.  It is interesting that the urban ozone plume did not
experience a significant amount  of spread in traveling  the 64 km (40 mi)
 to the location of the aircraft  final horizontal traverse.   The average plume
spread on all horizontal traverses was approximately  34 km (21 mi).  The
city of Tulsa is approximately 26 km (16 mi) wide  in  the east to west
 direction.   Therefore, the  ozone plume  from Tulsa was only slightly
wider  than Tulsa and did not widen appreciably in  traveling the 64 km
 downwind.

 The  morning  ozone  precursor concentrations at  the  downwind sites were
 generally very  low compared to those measured  in the  city.   Therefore,
 ozone synthesis from local  sources at  the downwind  sites probably repre-
 sents only  a small contribution  to the  maximum ozone  concentrations
 measured  at those  sites.  This means that a  large  percentage of the
 ozone measured  at  those  sites is from  precursors which originated in the
 Tulsa metropolitan area.

 In addition, during  the  study,  three sites were  considered to be simul-
 taneously under urban  influence  on 39  days.  The maximum ozone con-
 centration  in the  network was measured  at Vera (34 km downwind) on 49
                                    3-2

-------
percent of those days, at Ochelata (48 km downwind) on 32 percent of
those days, and at Sperry (14 km downwind) on 8 percent of those days.
This points out the widespread nature of high ozone levels, and the
necessity of modeling a large enough area to include both the monitor
with the highest 0_ levels and all sources affecting readings at that
monitor.

Project Da Vinci II involved ambient monitoring aloft of ozone and
precursors near and downwind of St. Louis (Decker et al., 1977).  During
this study, ozone concentrations measured aloft above the radiation
                                               3
inversion remained in the range 230 to 290 pg/m  from 1700 on June 8
until the flight was ended the next day.  These measurements strongly
suggest overnight transport of ozone aloft with minimum dilution and/or
destruction,  (i.e., <20 percent).  In addition, the occurrence of high
                               3
ozone concentrations (>250 (Jg/ffl ) on tne morning of June 9, 1976,  in a
rural area in southwest Indiana was attributed to long range transport
of ozone from St. Louis.  These measurements suggest that a large source
area should be modeled for ozone analyses.

Ozone data collected during the St. Louis RAPS study are also useful for
determining the appropriate source area for ozone.  Table 3-1 shows
monthly maximum ozone values for July, August, and September for 24
sites in and near St. Louis.  They are classified by their distance and
directional location with respect to the St. Louis Central Business
District (CBD) .  The outermost sites are as much as 50 km from the CBD.
A map of these sites is shown in Figure 3-1.  The monthly maxima in
Table 3-1 show no discernable pattern.  At least one value greater than
the 0.12 ppm hourly standard was measured during these three months at
every site.  Therefore, it is likely that a large source area contri-
butes to the design value monitor in St. Louis.  At the least, it can be
concluded that a large area (AQCR) must be inventoried to ensure in-
clusion of all of the significant emissions affecting each site.
                                 3-3

-------
                              TABLE 3-1

   MONTHLY MAXIMUM HOURLY OZONE FOR RAPS SITES IN ST. LOUIS  (1976)
                        CONCENTRATIONS IN PPM
                           Distance from
Site Clusters
1.

West of CBD
125
Center City

50-60
(km)


July

0.145
August

0.168
September

0.106
2.  Western Edge of CBD
119
120
121
Central Business District
101
102
105
106
107
111
112
113
Downwind Edge of CBD
103
104
110
114
118
Downwind 10 km
109
115
116
117
Outer Periphery
122
123
124
10-20
10-20
20-30

0
<0
SO
SO
SO
SO
SO
10-20

SO
50
SO
10-20
10-20

10-20
20-30
20-30
10-20

50-60
30-40
40-50
10-20
10-20
20-30
.126
.155
.126
.160
.176
.187
.107
.146
.109
0
SO
SO
SO
SO
SO
SO
10-20
.151
.107
.122
.155
.154
.107
.154
.179
.145
.149
.180
.169
.152
.134
.134
.158
.092
.249
.098
.110
.090
.108
.188
.108
SO
SO
SO
10-20
10-20
.158
.112
.141
.223
.144
.202
.152
.146
.177
.143
.248
.087
.120
.132
.154
10-20
20-30
20-30
10-20
.159
.169
.167
.137
.180
.192
.180
.166
.120
.132
.124
.107
50-60
30-40
40-50
.148
.141
.160
.190
.010
.111
.126
.109
.153
                                 3-4

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             FIGURE  3-1




RAMS MONITORING SITES  IN ST.  LOUIS
                  £RSEYVILU
                           ©122
                                               • RAPS CENTRAL



                                               « RAMS STATIONS
                                                E7HALTO
                                                  EDWARDSVILLE

-------
Most, if not all, of the available evidence suggests that VOC inven-
tories to be used in a nationwide rollback or EKMA modeling approach
should be compiled on an AQCR basis.  The only evidence presented here
that suggests otherwise is the situation in Los Angeles, where  it is
suggested that a county inventory covers the source area affecting
maximum ozone (Trijonis and Hunsaker, 1978).  In order to estimate  the
error involved in using an AQCR inventory where a county inventory  is
appropriate, a sample of regions was used to compare the distribution of
sources in a county versus an AQCR.  Data for this comparison were  taken
from the National Emissions Data System (NEDS).  Chicago, Washington,
Los  Angeles, Philadelphia, Baltimore, Detroit, Pittsburgh, and  Houston
were the cities  used in the comparison.  The results of this comparison
are  shown in Table 3-2.  The only area with a significant difference
between the distribution of sources is Washington, DC.  The percentage
of mobile source emissions in the District of Columbia is much  lower
than it is in the remainder of the AQCR.  Because of the way NEDS calcu-
lates mobile source emissions, the miles traveled in DC by vehicles
registered and fueled in the neighboring States of Maryland and Virginia
are  probably not included  in the DC totals.  Therefore, it is  likely
that in actuality,  the  distributions of emissions in the District of
Columbia  alone and  in the  entire AQCR are approximately equal.

Because  the  source  distributions are roughly the same in counties and  in
 the  AQCR's  that  encompass  those counties, if AQCR inventories  are used
 in all  areas, when  in some cases a  county inventory is appropriate, the
resulting errors will be minor.

It is  recommended  that  VOC inventories  for  use  in nationwide  analyses  be
compiled  using the  source  categories listed in  Table 3-3.  These cate-
 gories  are  essentially  the same as  those recommended by EPA for use in
 preparing VOC  emission  inventories  (U.S. EPA, 1977).  Therefore, they
 correspond  closely  to  the  inventories  included  in the SIP's.   National
                                  3-6

-------
                                              TABLE 3-2

              DISTRIBUTION OF VOC SOURCES FOR COUNTY VERSUS AQCR INVENTORIES FROM NEDS
                           PERCENTAGE OF ANNUAL EMISSIONS IN EACH SOURCE CATEGORY
Source Categories
AQCR 216  Harris  AQCR 197  Allegheny  AQCR 123   Wayne
 Houston  County  SW Penn    County    Detroit   County
AQCR 115   Baltimore
Baltimore    County






1. Petroleum Refineries
2. Storage, Transportation and
Marketing of Petroleum
Products
3. Industrial Processes
4. Organic Solvent Evaporation
5. Stationary Combustion Sources
6. Mobile Sources
Source Categories
1
2
3
4
5
6
. Petroleum Refineries
. Storage, Transportation and
Marketing of Petroleum
Products
. Industrial Processes
. Organic Solvent Evaporation
. Stationary Combustion Sources
, Mobile Sources
.07
.18
.31
.19
.01
.24
AQCR 047
National
Capital
0
.05
0
.37
.01
.57
.03 0
.24 .05
.19 .09
.23 .41
.02 .01
.29 .44
AQCR 067
D.C. Chicago
0 .01
0 .10
0 .03
.64 .48
.01 .02
.35 .37
0 .01 .02 .01
.04 .05 .05 .04
.12 .02 .03 .04
.37 .54 .50 .45
.01 .02 .02 .02
.47 .36 .38 .44
AQCR 045 Philadel-
Cook Philadel- phia AQCR 024
County phia County Los Angeles
0 .03 .01 .05
.04 .19 .04 .06
.01 .04 .01 0
.54 .37 .42 .45
.01 .01 0 .04
.40 .36 .51 .39
.03
.04
0
.50
.01
.42
Los Angeles
County
.06
.07
0
.49
.04
.34

-------
                               TABLE 3-3

             VOLATILE ORGANIC COMPOUND EMISSION INVENTORY
                           SOURCE CATEGORIES
Stationary Sources

     1.  Petroleum Refineries

     2.  Storage, Transportation and Marketing of Petroleum Products

     3.  Industrial Processes

     4.  Industrial Surface Coating

     5.  Other Solvent Use

     6.  Other Miscellaneous Sources



Mobile Sources

     7.  Light-Duty Gasoline Vehicles

     8.  Light-Duty Diesel Vehicles

     9.  Light-Duty Trucks

     10. Heavy-Duty Gasoline Trucks

     11. Heavy-Duty Diesel Trucks

     12. Other Transportation Sources
                                 3-8

-------
Emissions Data System (NEDS) data can also be easily structured into
these source categories.  Light-duty diesel numbers are not readily
available at this time from NEDS, however.

3.1.2  Carbon Monoxide
CO concentration patterns across a city relate primarily to nearby
traffic levels and meteorological conditions.   The most important
meteorological variables are wind speed, atmospheric stability, and
mixing height.  CO concentrations usually vary greatly within an urban
area, so it is important to characterize only those emissions near the
design value monitor.  However, two meteorological conditions, occurring
simultaneously or separately, can occur to produce widespread high CO
levels.  One is thermal circulation, such as sea-land breezes, lake-land
breezes, drainage winds, or mountain-valley winds, that is caused by
differential heating of topographic features.   These winds generally
flow in one direction during the day, then in the opposite direction at
night.  As a result, an urban area can experience "blowback" of CO
emissions emitted during the day resulting in higher CO concentrations
at night.  The second meteorological condition that can lead to wide-
spread high CO is inhibited vertical mixing caused by high atmospheric
stability or presence of a shallow mixed layer.   An important example of
limited vertical mixing occurs as the result of a "surface" or "radiative"
inversion.  Such conditions usually occur at night, with light winds and clear
skies.  The surface inversion usually persists for hours and, because it
typifies stable atmospheric conditions, it can lead to high and rela-
tively widespread CO concentrations.

Presence of a shallow mixed layer may often occur as the result of a
subsidence inversion, caused by the adiabatic  warming of a descending
atmospheric layer.  The subsidence inversion usually persists on the
order of days and tends to contribute to high urban background CO concen-
trations.
                                   3-9

-------
Because CO problems seem to be predominantly related to microscale
emission levels,  and occasionally more widespread emissions  (in  the
presence of adverse meteorological conditions), the recommended  inventory
area is a county.  While in many cases, nonattainment areas  for  CO  are
smaller than a county (sometimes they include only a few blocks  in  a
downtown area) for practical purposes a county inventory is  the  most
reasonable approach for a nationwide study.  This is true  because the
NEDS summaries are available only down to the county level.

Table 3-4 lists  the source categories suggested for compiling  county
emission inventories for use in a nationwide analysis.  These  categories
are recommended  based on the assumption that stationary sources  of  CO do
not significantly affect concentrations measured at design value monitors,
and the source categories typically used in NEDS are sufficient  (see
Section 3.5 for  a more complete discussion of source contributions).

3.1.3  Nitrogen  Dioxide
Observed concentrations of NO- result primarily from chemical  reactions
in the ambient air involving NO and other pollutants.  The principal
mechanisms  leading to high NO- levels are photochemical synthesis and
the reaction  of  NO with ozone  (titration).  Photochemical  synthesis
occurs when NO and NMOC react  in the presence of sunlight  to form NO .
Site  locations which primarily experience high NO- concentrations due to
photochemical synthesis are usually within 1-4 hours travel  time of
where heavy NO   and VOC emissions occur.  The titration reaction of NO
              X
with  ozone  to form N02 occurs  very rapidly in the atmosphere,  much
faster  than the  photochemically driven synthesis.
                                    3-10

-------
                     TABLE 3-4

              CARBON MONOXIDE EMISSION
             INVENTORY SOURCE CATEGORIES
Mobile Sources

     1.  Light-Duty Gasoline Vehicles

     2.  Light-Duty Diesel Vehicles

     3.  Light-Duty Trucks

     4.  Heavy-Duty Gasoline Trucks

     5.  Heavy Duty Diesel Trucks

     6.  Other

           Off-Highway

           Rail

           Aircraft

           Vessels



Stationary Sources

     7.  External Combustion

           Residential

           Industrial

           Commercial-Institutional

     8.  Solid Waste Disposal

     9.  Misc el laneous

-------
                                                                       FIGURE 3-2
                              1977 N02 CONCENTRATIONS  IN THE LOS ANGELES AIR QUALITY CONTROL REGION
CO
 I
                                                                                                                  	_AQC|l_Baindlli|
           A •


           B-Ami	


           C-Burtunk...
.109


..121


 IM
           D-Cimlllo	43


           E-GuUNea	M1
          MONITORING SITE AND READINGS


F • Li Habn	1W1          K • Los Angles Ct)	105


G • Lenxu	122           \_ • Lymnod	120


H-LontBudi	Ul           M-Nnilull	M


I -Los Antfln	IK           H-P>»d«*	163


J • Los Annl«,	1*           0-Poun	134
P-Redtandi	(0


fl • KuKdon	M'


R-SwBetui4iiu	Si


S-Smll Balkan	ft'


T-HMttiM	I3«
1977 ARITHMETIC MEAN

1  MuswedbySiltaunColoiinUiclMiod

2  Hun fcmtd Iroa l«ss than 75toMoljl
  possible obunatigns
                                                                                                                  HUES

-------
Therefore, a monitor with high N02 readings produced  by  a reaction with
ozone is most likely near significant NO sources.

Because the highest annual average NCL concentrations will be  measured
at less than four hours travel time, and oftentimes immediately  downwind,
of significant NO  sources, it seems appropriate to compile NO  inventories
                 X                                             X
for nationwide studies on a county basis.  This conclusion can be  judged
further by examining spatial variation patterns of ambient N0? data.

Few areas have enough N02 monitors to allow spatial variation  patterns
to be determined.  The Los Angeles Basin and the St. Louis area  do have
sufficient data; Los Angeles through regular monitoring  and St.  Louis
from the RAPS study.  Figure 3-2 shows isopleths of annual average NO
in the Los Angeles Basin from 1977 data.  Based on the Los Angeles data,
for an analysis of annual mean NO., it is probably appropriate to  use  a
county inventory.

During 1976, 18 individual stations monitored hourly NO-  concentrations
in St. Louis as part of the RAPS study.  The site locations are  shown  in
Figure 3-1.  Site 101 is in the city center.  If the other sites are
grouped with respect to their distance from site 101, conclusions  can  be
made about the spatial variation in N02 concentrations in  the  vicinity
of St. Louis.

   Site Distances from          Number of            Annual Average
  the City Center (km)            Sites                 N02 (ppm)
            0                       1                      .028
           0-4                      3                      .027
           4-10                     5                      .027
          10-20                     7                      .015
          20-30                     2                      .012
                                    3-13

-------
The annual averages in the above table are averages of  the  1976  annual
means at all of the sites in each group.  While the annual  averages
within 10 km of the city center are relatively constant  at  .027-.028
ppm, there is a considerable drop in the annual average  at  sites more
than 10 km from site 101.  Therefore, it seems reasonable to  assume  that
a county rather than an AQCR-wide emission inventory  is  appropriate  for
characterizing the sources contributing to the design value concen-
trations in St. Louis.  This is consistent with the findings  in  Los
Angeles.

NO  emission inventory source categories recommended  for use  in  nation-
wide studies are shown in Table 3-5.  Point sources are  aggregated into
one category because it was found that point sources  do  not significantly
impact NO. concentrations at the present set of continuous  NO monitors.
They can be used in emission projections, however.  Source  contributions are
discussed further in Section 3.5.

3.2  DESIGN VALUES
The design value is defined as  the  concentration  that must  be reduced to
the  level of the standard for an area to be in attainment.  In using
ambient monitoring data  in national strategy assessments, design values
are usually chosen to correspond to the form of the standard  for each
pollutant.  In addition, design values can be chosen  from a time period
consistent with the emission inventory.  Therefore, recommended  techniques
for determining design values are presented separately  for  CO, 0-, and
N02.   The EPA  Storage and Retrieval of Aerometric Data  (SAROAD)  System
is the source  of monitoring data typically used to determine  design
values for  use in nationwide studies.  SAROAD is  simply a compilation of
ambient  air  quality data from air monitoring operations of  State,  local,
and Federal networks.
                                    3-14

-------
                      TABLE 3-5

             OXIDES OF NITROGEN EMISSION
             INVENTORY SOURCE CATEGORIES
Mobile Sources

     1.  Light-Duty Gasoline Vehicles

     2.  Light-Duty Diesel Vehicles

     3.  Light-Duty Gasoline Trucks

     4.  Heavy-Duty Gasoline Trucks

     5.  Heavy-Duty Diesel Trucks

     6.  Other Mobile Sources

           Off-Highway

           Aircraft

           Vessels

           Locomotives (Rail)


Fuel Combustion (Area Sources)

     7.  Residential Oil/Gas

     8.  Comm/Inst. Coal

     9.  Comm/Inst. Oil/Gas

     10. Industrial Coal

     11. Industrial Oil/Gas

     12. Other
                       3-15

-------
        TABLE 3-5 (Continued)
Solid Waste
     13. S.W. Disposal
Point Sources
     14.  Point Sources
                       3-16

-------
3.2.1  Carbon Monoxide
There are currently two NAAQS for carbon monoxide;  an eight-hour standard
of nine ppm and a one-hour standard of 35  ppm.  As  a  result  of  the
review and revision of the health criteria, EPA has recently proposed to
lower the one-hour standard to 25 ppm  (45  FR  55066).   For  the most part,
the eight-hour standard is more stringent; therefore,  all  of the design
values used in this study are for an eight-hour averaging  time.

Under the present form of the standard, design values  are  determined  by
choosing the second highest monitor reading (non-overlapping) in any
year.  Thus, the highest second high in the three year period encompassing
the emission inventory base year should be chosen as  the design  value.

While this technique for choosing a design value is acceptable given  the
current deterministic form of the standard, a change  to a  statistical
standard has been proposed.  A daily interpretation of exceedances of
the CO NAAQS has been proposed which is consistent  with the  interpreta-
tion of exceedances for the ozone NAAQS.

3.2.2  Ozone
The ozone NAAQS contains the phrase "expected number of days per calendar
year."  This differs from the previous NAAQS for photochemical oxidants
which specifies a concentration "not to be exceeded more than once per
year."  Although the new standard form appears to be complicated,  the
basic principle is relatively straightforward.  In  general,  the  average
number of days per year above the level of the standard must be  less
than or equal to one.  The simplest method for determining compliance
with the standard is to record the number of exceedances at  each site
each year and then average this number over the past  three years to
determine if it is less than or equal to one.   Adjustments can be made
for incomplete monitoring data and year to year variations in emissions
and meteorology.  (U.S. EPA, 1979a).
                                   3-17

-------
Because the choice of a design value is primarily influenced by  the  few
highest values in a data set, it is possible to construct a simple table
look-up procedure to determine a design value (U.S. EPA, 1979a).  To use
this tabular approach, it is only necessary to know the total number of
daily values and a few of the highest values.  For example, if  there are
1,017 daily values, then the ranks of the lower and upper bounds  obtained
from Table 3-6 are 3 and 2.  This means that an appropriate design value
would be between the third-highest and second-highest observed values.
In using this table, the upper bound should be used as the design value.

For data sets that are 75 percent complete, but still have less  than 365
days of data, the maximum observed concentration may be used as  a tenta-
tive design value as long as the data set was 75 percent complete during
the peak times of the year.

For a  complete discussion of this table look-up procedure and other
alternative methods  for estimating ozone design values, refer to the
Guideline  For the Interpretation Of Ozone Air Quality Standards  (U.S.
EPA,  1979a).

3.2.3   Nitrogen  Dioxide
Annual average NO   design values can be simply determined by  choosing
 the highest annual  average  from the past three years.  However,  care
 should be  taken  to  ensure  that only valid annual averages are  considered
 in choosing a design value.  SAROAD uses the criterion  for calculating
 annual means  from continuous observations with sampling  intervals of
 less  than 24  hours  that  data must  reflect a minimum of  75 percent of the
 total number  of  possible  observations  for the applicable year.   Criteria
 for  noncontinuous observations with sampling intervals  of 24 hours  or
 greater are as  follows:
                                  3-18

-------
                                TABLE 3-6

                   TABULAR ESTIMATION OF DESIGN VALUE
Number of Daily
   Values
Rank of Upper
    Bound
Rank of Lower
    Bound
Data Point Used
     for
 Design Value
365 to 729
730 to 1094
1095 to 1459
1460 to 1824
1825 to 2189
1
2
3
4
5
2
3
4
5
6
highest value
second highest
third highest
fourth highest
fifth highest
SOURCE:  U.S.  EPA.  January 1979.   Guideline for the Interpretation
         of Ozone Air Quality Standards.EPA-450/4-79-003.OAQPS
         No, 1.2-108.  Research Triangle  Park,  NC.
                                3-19

-------
  •  Data representing quarterly periods must reflect a minimum of
     five observations for the applicable quarter.  If there are no
     measurements in one of the three months of the quarter, each
     remaining month in that quarter must have no less than two
     observations reported.
  •  Data representing annual periods must reflect four quarters of
     observation that have satisfied the quarterly criteria.
3.3  GROWTH AND RETIREMENT RATES

3.3.1  Stationary Sources
Changes in stationary source activity levels are accounted for  in  the
rollback model by a combination of growth and retirement rates.  This  is
done because regulations affecting new sources differ from those af-
fecting existing sources.  Therefore, different control assumptions are
identified for each.  Growth rates and controls are applied to  estimate
new source emissions.  Retirement rates are applied to estimate how
emissions from existing sources will decrease.

The most recent industry-by-industry projections of growth applicable  to
an air pollution analysis are those performed by the Bureau of  Economic
Analysis (BEA, 1977).  They are shown in Table 3-7.  These growth  rates
were calculated based on earnings and, therefore, are assumed to repre-
sent net growth for an industry.  In other words, retirement of existing
sources is taken into account.  Retirement rates for existing sources
are shown in Table 3-8.  These estimates of plant retirement rates were
developed for EEA by Data Resources, Inc. (U.S. DOE, 1979) in support  of
EEA's ISTUM model development.

The equation which should be used to incorporate the data in Tables 3-7
and 3-8 is as follows:
                                 3-20

-------
                               TABLE 3-7

     STANDARD INDUSTRIAL CLASSIFICATION  (SIC) ANNUAL GROWTH RATES*
Industry                                   SIC

Agriculture                                1-7
Forestry and Fisheries                     8-9
Metal Mining                               10
Coal Mining                               11-12
Oil and Gas Extraction                     13
Mining and Quarrying                       14
Contract Construction                     15-17
Food and Kindred Products                  20
Textile Mill Products                      22
Apparel and Other Textiles                 23
Lumber and Furniture                      24-25
Paper and Allied Products                  26
Printing and Publishing                    27
Chemicals and Allied Products              28
Petroleum Refining                         29
Primary Metal Industries                   33
Fabricated Metal Products                  34
Machinery, Except Electrical               35
Electrical Machinery                       36
Transportation Equipment                   37
Miscellaneous Manufacturing Industries     39
Railroad Transportation                    40
Motor Freight Transportation               42
Transportation Services                    47
Communication                              48
Electric, Gas and Sanitary Services        49
  Average Annual
Growth (1977-2000)

        0.6
        1.7
        1.3
        3.1
        2.2
        1.5
        3.6
        1.2
        2.4
        2.0
        2.3
        2.7
        2.3
        3.1
        1.9
        2.4
        2.5
        2.6
        2.9
        1.5
        3.3
        0.2
        3.2
        2.9
        4.9
        3.5
                                  Population Growth Rate
        0.8
SOURCE:  Bureau of Economic Analysis, 1977.

*  Based on projected earnings by industry, calculated in 1967 dollars.
                                 3-21

-------
                             TABLE  3-8

                    INDUSTRIAL  RETIREMENT RATES
Industry
Agricultural Production
Agricultural  Services
Forestry
Fishing, Hunting, and Trapping
Metal Mining
Anthracite Mining
Bituminious Coal and Lignite Mining
Oil and Gas Extraction
Mining and Quarrying
Building Construction
Construction Other than Buildings
Construction - Special Trade
Food and Kindred Products
Tobacco
Textile Mill Products
Apparel
Lumber  and Wood  Products
Furniture and Fixtures
Paper and Allied Products
Printing and Publishing
Chemicals and Allied  Products
Petroleum Refining
Rubber  and Miscellaneous Plastics
Leather and Leather Products
Stone,  Clay, Glass and Concrete
Primary Metal  Industries
Fabricated Metal Products
Machinery,  Except Electrical
Electrical Machinery
 Transportation Equipment
Miscellaneous  Instruments
Miscellaneous  Manufacturing Industries
 Railroad  Transportation
 Interurban Transit
 Motor Freight Transportation
 U.S. Postal Service
 Water Transportation
 Air Transportation
 Pipe Lines, Except Natural Gas
 Transportation Services
 Communication
 Electric, Gas and Sanitary Services
 General Government,  Except Finance
 Justice, Public Order,  and Safety
 Public Finance and Taxation
                                                         Average Annual
                                                        Retirement Rates
                                           01
                                           07
                                           08
                                           09
                                           10
                                           11
                                           12
                                           13
                                           14
                                           15
                                           16
                                           17
                                           20
                                           21
                                           22
                                           23
                                           24
                                           25
                                           26
                                           27
                                           28
                                           29
                                           30
                                           31
                                           32
                                           33
                                           34
                                           35
                                           36
                                           37
                                           38
                                           39
                                           40
                                           41
                                           42
                                           43
                                           44
                                           45
                                           46
                                           47
                                           48
                                           49
                                           91
                                           92
                                           93
  26
  26
  26
  26
  26
  26
  26
  26
  26
  26
  26
  26
4.56
3.35
  20
  18
3,
3,
6.37
  ,68
  .13
4.92
5.07
4.48
2.97
  ,09
  ,93
  ,97
3.23
4.10
4.61
4.09
4.83
4.41
4.26
4.26
4.26
4.26
4.26
4.26
4.26
4.26
4.26
4.
4.
4.
   26
   26
   26
 4.26
SOURCE:  U.S.  Department of  Energy,  1979

-------
QQ = QQ {[(1 + G.)t - 1] FQ + (1 - Ri)t Fe +  [1 -(1  - R^] Fn}        (3-1)
     where:
          Q  = emissions in projection year
          Q  = emissions in base year
          R. = retirement rate
           i
          F  = emission factor ratio for existing sources
          G. = growth rate
          F  = emission factor ratio for new sources
           n
The first term in the equation represents new source growth and controls,
the second term accounts for retirement and controls for existing sources,
and the third term accounts for replacement source controls.  It should
be noted that the G. term in equation (3-1) represents net growth.  If a
total growth rate (G.') is used, the first term in equation (3-1) should
be changed to [(1 + G.' - R.)1" - 1] F .  (Estimates for F  and F  are discussed
       6      lv     i    i'     J  n                   en
in Section 3.4.)

In order to facilitate use of the growth and retirement rates in Tables 3-7
and 3-8 in a nationwide analysis, Tables 3-9 and 3-10 are included.
They present the data in Tables 3-7 and 3-8 for 15 different stationary
source category groupings commonly used in nationwide analyses.  Annual
percentage ranges in growth and retirement along with the applicable SIC
category are shown in the tables.

3.3.2  Mobile Sources
One of the most difficult and important variables to project for future
years is growth in vehicle miles traveled (VMT) which is used as a
surrogate for mobile source emissions growth.   Growth in VMT is difficult
to predict for two reasons.  One is the uncertainty in how changes in
fuel prices will .affect demand for gasoline and travel.   The second is
                                   3-23

-------
                               TABLE 3-9




                STATIONARY SOURCE ACTIVITY LEVEL GROWTH
     Source Categories




1.   External fuel combustion




2.   Internal fuel combustion




3.   Chemical manufacturing




4.   Food/agriculture industry




5.   Primary metal products




6.   Mineral products




7-   Petroleum industry




8.   Wood products




9.   Industrial solvent evaporation




10.  Other industrial processes




11.  Solid waste  disposal




12.  Petroleum storage & transport




13.  Gasoline service stations




14.  Area  source  solvent evaporation




15.  Mi sc ellaneous
1975-1995
Annual
Percentage
Change
3.5
3.5
3.1
0.6
2.4
1.3
1.9
2.3
3.3
3.3
0
1.9
1.9
0.8
0
As sumed
SIC
49
49
28
20
33
10
29
24
39
39
-
29
29
population
—
 SOURCE:   BEA,  1977.
                                 3-24

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                              TABLE 3-10




                  STATIONARY SOURCE RETIREMENT RATES
1.   External fuel combustion




2.   Internal fuel combustion




3.   Chemical manufacturing




4.   Food/agriculture industry




5.   Primary metal products




6.   Mineral products




7.   Petroleum industry




8.   Wood products




9.   Industrial solvent evaporation




10.  Other industrial processes




11.  Solid waste disposal




12.  Petroleum storage and transport




13.  Gasoline service stations




14.  Area source solvent evapoation




15.  Miscellaneous
Annual
Percentage
Change
4.3%
4.2
5.1
4.6
5.0
4.9
4.5
6.4
4.4
4.4
0
4.5
4.5
0
0
Assumed
SIC
49
49
28
20
33
10
29
24
39
39
-
29
29
-
^
SOURCE:  U.S.  DOE,  1979.
                                3-25

-------
identifying how VMT will change in the areas that specifically  affect
high pollutant levels.  For instance, growth in VMT in central  business
districts may vary from that in outlying areas.  VMT is an  important
variable to estimate accurately because the rollback or EKMA  predictions
are sensitive to the value assumed, especially if projections are made
more than 10 years into the future.

On a nationwide basis, VMT has historically grown at a rate of  slightly
over four percent per year (Congress, 1979).  Immediately prior to the
1973-1974 oil embargo, annual growth reached nearly five percent.  After
a rapid drop during the embargo, VMT gradually increased again  to a four
percent annual rate.  However, recent events suggest that fuel  prices
will continue to rise, and VMT may not increase as rapidly  as historical
trends indicate.  Gasoline consumption fell by five percent in  1979 and
is down eight to nine percent so far this year (1980) .   (With recent
fuel economy gains, changes in gasoline consumption do not  track directly
into VMT  changes).  Until the elasticity of gasoline demand with respect
to price  can be quantified, it is  only speculation how VMT  will change
in future years.

The California Transportation Department determined that weekend traffic
on State  highways  declined by 11 percent last December  (1979) from a
year earlier.  However, weekday traffic increased by four percent.  It
is important  to make  this differentiation when performing an  air pollu-
tion analysis, because  the traffic affecting the periods  of highest
concentration are  of  interest.  Assuming that most high  concentrations
are observed  on a  week  day, growth in travel during that  period should
be used.

Although  one  response to  rising gasoline prices  is reducing the number
of trips, work  trips  are  not  likely  to be reduced as much as  trips for
other  purposes.  These  are  the  trips that contribute most  to  high pollutant
levels.   Therefore, in  estimating  future VMT growth rates,  it is important
not to use  total VMT  changes  when  weekday travel  is of  interest.
                                    3-26

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The second major issue regarding VMT growth  estimates  is that only the
VMT specifically affecting the design  value  concentrations  should be
considered in growth projections.   This means  that  SMSA growth rates are
not always applicable.  If the nonattainment area is the central  business
district, then expected growth in VMT  in  that  area  alone should be
included in the projections.  In addition, if  a  specific time period of
the day is of interest, e.g., 6-9 a.m., then VMT changes for that period
should be accounted for as much as  possible.

Despite the fact that in most analyses the same  growth  rate is used  for
all mobile source categories, it is appropriate  to  use  a separate growth
rate for each vehicle type if possible.   Therefore, the nationwide
average growth rates presented in Table 3-11 are specific to each vehicle
type.  The 1977 market share for diesels  is negligible  when compared
with 1990.  Therefore, total VMT estimates are shown for both years.

In cases where nationwide average growth  rates do not apply and it is
necessary to estimate how VMT growth on urban  roads (especially within
the CBD) is likely to change in future years,  it is useful  to consider
how roadways are designed.  Rather  than build a  road to  handle  the
maximum volume likely to travel on  it during a year, traffic  engineers
either measure or estimate the hourly distribution of traffic volume
during a year, pick an hourly traffic volume along that  distribution,
and build the roadway with the chosen capacity.  This is  done because it
is uneconomical to provide for the extreme hourly volumes of  traffic
that may occur but a few times during a year.  Based on  the  relationship
between the peak hourly flows and the annual average daily  traffic, it
has been determined that the ratio of benefit to expenditure  is near its
maximum at the thirtieth highest hourly traffic  volume  (Wohl  and Martin,
                                     3-27

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                               TABLE 3-11

                       MOBILE SOURCE GROWTH RATES*
A,  Highway Vehicles

    1.  Gasoline
B
        a.  Light-Duty Vehicles
        b.  Light-Duty Trucks I
        c.  Light-Duty Trucks II
        d.  Heavy-Duty Trucks
        e.  Motorcycles
    2.  Diesel
        a.  Light-Duty Vehicles
        b.  Light-Duty Trucks I
        c.  Light-Duty Trucks II
        d.  Heavy-Duty Trucks
    Off-Highway Vehicles

    1.  Gasoline

    2.  Diesel

C.  Locomotives

D,  Aircraft

E.  Vessels
                                        Annual
                                      Percentage
                                        Change
                                          0.5%
                                          2.3
                                          6.2
                                         -2.0
                                          2.5
5.0



2.3

2.3

0.2

2.7

2.7
                                                     1977
                                                      VMTq
                                                    (x 10*)
                       1990
                        VMTq
                      (x 10*)
                                                      1.23
                                                      0
                                                      0
                       201.79
                        32.19
                        33.65
     Light-duty vehicle  and  light-duty  truck growth are estimated from
     data presented  in McNutt, Dulla, and Lax,  1979.   Heavy-duty truck
     growth rates  are taken  from U.S. EPA,  1979b.   Growth for motorcycles
     is  assumed to be 2.5%,  which  is  FHWA's latest  estimate of expected
     growth in VMT for the vehicle fleet as a whole.   For off-highway
     vehicles, growth rates  are estimated from  projections of growth in
     earnings by industry  (BEA, 1977).
                                  3-28

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1967).  Hence, for most cases, the thirtieth highest hourly volume  for
the year is generally a reliable criterion of the needed capacity for
which it is most practical to design.

This design criterion, if commonly used, has important implications for
analyzing future VMT growth.  If peak hour traffic is of interest, and
roadway capacity is typically reached an average of 30 times per year,
then even if VMT grows during off-peak periods, mobile source contribu-
tions to peak pollutant levels are unlikely to change.  However, this
conclusion is dependent on the averaging time of the standard being
examined.

A question that has been raised a number of times with respect to nation-
wide studies is whether area specific growth rates should be used for
mobile sources.  In order to test the sensitivity of rollback results to
the use of area specific growth rates, a test case was run using the
data from the CO regulatory analysis.  The results are shown in the
table below:
            Average Percentage Changes in CO Concentrations
                           (1976 Base Year)
                           Projection Years
 Growth
Scenarios                1982      1985      1987      1990      1999
No Growth
1% Growth
3% Growth
Area Specific
  Growth                  -17       -33       -40       -46       -40
The above table shows that rollback predictions are sensitive to the
assumed growth rate, but that area specific growth rates are roughly
-28
-25
-16
-46
-41
-32
-54
-49
-39
-61
-56
-45
-65
-58
-39
                                 3-29

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equivalent to using a three percent VMT growth assumption  for  the  whole
country.  The indicators of "number of cities above the standard"  and
"the total number of expected violations" are also essentially equiva-
lent for the three percent and the area specific growth assumptions.
The area specific growth rates are based on DOT-FHWA projections from
1975-1990.  These projections were all submitted by the individual
States and may be derived from differing assumptions.

In summary, it is recommended that the point estimates of  mobile source
growth  in Table 3-11 be used in analyses where nationwide  average  VMT
growth  rates are needed.  Because there is considerable uncertainty in
predicting how VMT will change in future years, upper and  lower bound
growth  rates should be included in the analysis in addition  to the point
estimate.  In adjusting the Table 3-11 growth rates to run sensitivity
analyses, it is probably appropriate  to assume that growth increases  or
decreases proportionately  for all vehicle categories.

3.4   CONTROL EFFECTIVENESS

3.4.1  Mobile Sources
The  effectiveness  of future  controls  for mobile sources  can be estimated
using EPA's mobile source  emission factor program  (MOBILE2).  This
program accounts  for both  expected future emission  levels  by model year
by vehicle  type  and the rate  of  retirement  of existing vehicles from the
present fleet.   For use in a nationwide study, MOBILE2 emission factors
 for  the base  year  and  the  projection  year are calculated and used  to
 determine an emission  factor ratio.   This emission  factor  ratio is
 simply expressed as:

           Emission Factor Ratio  = Projection Year Emission Factor
                                      Base Year  Emission  Factor
 This emission factor ratio is calculated  separately for  each motor
 vehicle type.
                                     3-30

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Despite slight differences  in emission  standards  for California and high
altitude areas, the technologies  applied  to  reduce  mobile source emis-
sions are the same throughout the country.   California and high altitude
emission factors should be  used where appropriate,  however,  using emission
factor ratios computed from 49-state emission  factors  in  a nationwide
analysis will yield nearly  the same results  as using California specific
emission factors.

The MOBILE2 emission factors program is used to account for  controls
mandated by the Federal Motor Vehicle Emission Control Program  (FMVECP).
If an estimate of the potential effectiveness  of  an inspection  and
maintenance (I/M) program is needed, the MOBILE2  program  (U.S.  EPA,
1978) can be used to generate this estimate.  Because  the emission
factors including I/M credits are calculated within the MOBILE2 program,
the effect of an I/M program is accounted for in  rollback by changing
the emission factor ratios.

I/M programs are required by the  Clean Air Act Amendments (1977)  if
SIP's for ozone and/or CO cannot  demonstrate attainment of the  NAAQS by
1982. The original timetable for  implementation of  I/M programs was as
follows (U.S. EPA, 1978):
     June 30, 1979            Legal Authority for I/M Programs  Required
     December 31, 1981        Decentralized I/M Programs  in Place
     December 31, 1982        Centralized I/M Programs in Place

Although not all states met the June 30, 1979 deadline for enabling
legislation, as of September 1,  1980,  only two of the 29  states required
to have I/M legislation did not have it.  Taking into consideration the
                                   3-31

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fact that several areas  already have  operating I/M programs, it is
reasonable to assume that on a  nationwide average, all areas projected
to not attain the CO and/or the 0_  standard by December 31, 1982 will
have an I/M program operating beginning in 1982.

If changes in mobile source emission  standards need to be evaluated,
MOBILE2 can again be used to compute  calendar year emission factors to
account for these revisions. To change the emission standards for a
vehicle type, new values for the zero-mileage emission rate and the
emission factor deterioration rate per 10,000 miles must be input to
MOBILE2.  Changes in emission standards can and should be evaluated
separately for each vehicle type.  Again, emission factor ratios are
used to estimate the impact of  mobile source controls.

3.4.2  Stationary Sources
Estimating the effectiveness of stationary source controls  for use in a
nationwide analysis is not as straightforward as it is for  mobile source
controls because there are many more source types to deal with.  Sta-
tionary source categories used in nationwide analyses are usually chosen
so  that source types with common growth rates and control efficiencies
are grouped  together.  Therefore, the control efficiency used in the
rollback or  EKMA model is a weighted average based on control effi-
ciencies for each source type.   This process is further complicated by
the fact that control efficiencies within each  source type  differ based
on  the type  of fuel burned.

Of  the three pollutants being discussed in this report, ozone is the
only  one that has been identified as having a significant stationary
source influence at monitors measuring design values.  Therefore, this
section  concentrates on providing control efficiency estimates for VOC
sources.   In nonattainment  areas, the Clean Air Act Amendments require
new and modified stationary sources to meet the lowest achievable emission
                                   3-32

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reduction (LAER) before a source can be located in an area or modified.
Since EPA has not determined what constitutes LAER for stationary VOC
sources, it should be assumed that new and modified sources will have to
achieve a minimum level of control equal to reasonably available control
technology (RACT).

For areas that fail to attain the standard with mobile source and new
and modified stationary source control, existing sources will also be
required to install RACT.  RACT will vary among industries and may well
vary among sources within an industry.  RACT is defined as the lowest
emission limit that a particular source is capable of meeting by applying
control technology that is reasonably available considering technological
and economic feasibility.  Since economic feasibility is basically
source specific, RACT may vary among sources in an industry.   Since
national assessments generally only consider broad categories of sources
and do not consider the feasibility of RACT on individual sources,  RACT
is broadly defined here as technology available for application in
categories of sources which will lead to adequate levels of control
based solely on technical considerations.  In actual practice, the
reasonableness of technology for particular sources will be determined
by State and local agencies based on technical guidance issued by EPA
and depending upon economic and energy feasibility.

EPA has published guideline documents for VOC sources which assess  the
technology available for these sources.  Based on these documents,
estimates were made of the efficiency of RACT for major VOC sources.
These estimates are shown in Table 3-12.   As of January 1978,  Control
Techniques Guideline (CTG) documents had been issued for 15 stationary
source categories.  Legally enforceable RACT regulations must be sub-
mitted by the states on an annual basis in the January of the year
following the publication of the CTG (Clean Air Act,  1977).  Therefore,
                                 3-33

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                               TABLE 3-12
                ASSUMED EFFICIENCY IDENTIFIED OF RACT FOR
                    VOC STATIONARY SOURCE CATEGORIES

                                                     Efficiency of     Assumed
Source Category and Sources Included*                  RACT (%)          SIC
1.  Chemical Manufacturing                                               28
      •  Organic Chemical Manufacturing Industry
           -  Process Emissions                            90%
           -  Fugitive Emissions                           80%
           -  Storage and Loading Emissions                90%
           -  Secondary Emissions                          75%
      •  Pharmaceutical Industry                           95%
      •  Paint Manufacture                                 90%
      •  Rubber Industry                                   75%
         Weighted Average of RACT**                        82%
         Current Emissions Affected by RACT***             79%
         Emission Reduction in Source                     	
         Category Achievable with RACT                     65%

2.  Petroleum Industry                                                   29
      •  Gas and Crude Oil Production                      90%
      •  Petroleum  Refining
            -  Vacuum Jets                                 100%
            -  Waste Water Separators                       95%
            -  Miscellaneous Sources                        91%
            -  Process Unit Turnaround                      98%
      •  Natural Gas and Gasoline Plants                   96%
         Weighted Average  of RACT**                        95%
         Current Emissions Affected by RACT***             95%
         Emission Reduction in Source
         Category Achievable with RACT                     90%

 3.   Industrial  Solvent Evaporation
     Auto and Light  Duty Truck  Manufacturing               80%
     Flatwood Products                                      80%
                                  3-34

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                         TABLE 3-12 (Continued)
                ASSUMED EFFICIENCY IDENTIFIED OF RACT FOR
                     VOC STATIONARY SOURCE CATEGORIES
                                                     Efficiency of     Assumed
Source Category and Sources Included*                  RACT (%)          SIC

    Paper Coating                                          80%
    Fabric Coating                                         80%
    Wire Coating                                           90%
    Can Coating                                            80%
    Metal Furniture                                        85%
    Industrial Machinery                                   80%
    Commercial Machinery                                   80%
    Coil Coating                                           85%
    Fabricated Metal Products                              80%
    Large Appliances                                       85%
    Small Appliances                                       80%
         Weighted Average of RACT**                        80%
         Current Emissions Affected by RACT***             75%
         Emission Reduction in Source
         Category Achievable with RACT                     60%

4.   Area Source Solvent Evaporation
    Dry Cleaning                                           65%
    Vapor Degreasing                                       55%
    Cold Cleaning                                          50%
    Graphic Arts                                           80%
    Adhesives                                              80%
    Cutback Asphalt Paving                                100%
         Weighted Average                                  75%
         Current Emissions Affected by RACT                39%
         Emission Reduction in Source
         Category Achievable with RACT                     30%

                                 3-35

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                         TABLE  3-12 (Continued)
                ASSUMED EFFICIENCY IDENTIFIED OF RACT FOR
                    VOC STATIONARY SOURCE CATEGORIES
Source Category and Sources Included*
Efficiency of
  RACT (%)
Assumed
  SIC
5.  Petroleum Storage and Transport
    Gasoline and Crude Oil Storage
    Gasoline Bulk Terminals
    Gasoline Bulk Plants
         Weighted Average
         Current Emissions Affected by RACT
         Emission Reduction in Source
         Category Achievable with RACT
                     29
      75%
      95%
      76%
      80%
     100%

      80%
6.  Gasoline Service Stations
    Storage
    Refueling
         Weighted Average of RACT**
         Current Emissions Affected by RACT***
         Emission Reduction in Source
         Category Achievable with RACT
                     29
      90%
      90%
      90%
      83%

      75%
 7.  Fuel Combustion****
 8.   Other  Industrial Processes****
                     49

                     39
 9.   Solid Waste****
 10.  Miscellaneous****
 SOURCES:  U.S. EPA,  1979
          Peterson and  Sakaida,  1978
                                  3-36

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                         TABLE 3-12 (Continued)

                ASSUMED EFFICIENCY IDENTIFIED OF RACT FOR
                    VOC STATIONARY SOURCE CATEGORIES
*     Sources included are those for which screening studies or guideline
      documents are being prepared.  Many solvent evaporation sources
      and other industrial processes are not included because the sources
      have not been identified or control levels have not been defined.

**    Represents weighted average of RACT for sources listed based on
      current national emissions for each category.

***   Represents the proportion of current national emissions for which
      RACT can be applied.  Excludes emissions from source categories
      for which RACT control levels have not been identified and the
      residual emissions from sources which have already controlled to
      the RACT level.

****  RACT has not been identified for these source categories.
                                 3-37

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it is reasonable to assume that unless projections are being  made  for a
year prior to 1982, that the RACT efficiencies in Table 3-12  can be
used.

If the emission inventory in each region is grouped by the  source  cate-
gories identified in Section 3.1, the average emission reduction that
could be achieved with the application of identified RACT must be  deter-
mined for these categories.  To do this, it is first necessary to  derive
the weighted average of the efficiency of RACT for the sources in  each
category for which RACT has been estimated.  This weighted  average takes
into account each sub-category's relative contribution to current  nation-
wide emissions, and the efficiency of RACT for each source.   Therefore,
the total emission reduction in each general source category  is determined
by multiplying the weighted efficiency of RACT for applicable sources by
the percentage of emissions in the general source category  which would
be affected by RACT.  The emissions affected by RACT include  only  those
sources for which RACT has been identified and which have not already
controlled emissions to the RACT level.

As Table 3-12  indicates, emissions from existing VOC sources  can be
reduced by 65  percent from the chemical manufacturing  industry (indus-
trial processes),  90 percent from the petroleum industry,  80  percent
from petroleum storage and transport, 75 percent from  gasoline service
stations, and  60 percent from  industrial surface coating  operations.
However, controls  on identified area source  solvent evaporation sources
will reduce  emissions from the total category by only  30  percent,  since
over half of the emission  inventory results  from sources  which have not
been identified and for which  control levels have not  been  estimated.

Table 3-13 presents stationary source control efficiencies  for CO  and
NO^.  While  they will not  be commonly needed  for nationwide studies
where design values are measured at urban  monitors, they  are  included
                                    3-38

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                               TABLE 3-13




                 STATIONARY SOURCE CONTROL EFFICIENCIES
1.   External fuel combustion




2.   Internal fuel combustion




3.   Chemical manufacturing




4.   Food/agricultural industry




5.   Primary metal products




6.   Mineral products




7.   Petroleum industry




8,   Wood products




9.   Industrial solvent evaporation




10.  Other industrial processes




11.  Solid waste disposal




12.  Petroleum storage & transport




13.  Gasoline service stations




14.  Area source solvent evaporation




15.  Miscellaneous
*  Source:  PEDCo Inc., 1979.




** Source:  U.S. EPA, 1979a.
CO*
RACT
90%
90

RACT
25%
30
NO **
NSPS
33%
30

LAER
90%
60-90
90
99
99
25
30-60  90
                                    3-39

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because they might be useful in emission projections or special studies
where stationary source influences are likely.   CO control efficiencies
in Table 3-13 are assumed to represent RACT.  A wider variety of control
options are available for NO ,  so three levels of control are identified
                            A
for that pollutant in Table 3-13.

While the CO control efficiencies for RACT shown in Table 3-13 are
currently available control technologies, the likelihood of their being
applied to meet the current CO ambient standards is low.  In most cases,
CO SIP's concentrate on controlling mobile soures.
For NO  , there are currently very few nonattainment areas.  Therefore,
      A
RACT controls will only be applied to areas with annual averages greater
             3
than 100 pg/m  .  New Source Performance Standard NO  controls for utility
                                                   A
boilers were originally proposed in 1971 and should affect all boilers
larger  than 73 MW which have begun operation since 1976.  This assumes  a
five year  lag  time between NSPS proposal date and boiler start-up date.
For coal-fired utility boilers, a 0.6 Ib/million Btu NSPS NO  level was
                                                            A
proposed in 1978. Assuming the five year lag time, boilers coming on-line
after 1983 should be meeting the 0.6 Ib/million Btu standard.

The NO  control  efficiencies listed in Table 3-13 for internal fuel
      X
 combustion and petroleum industry sources under NSPS represent levels
that new sources can attain with present control technology rather than
proposed NSPS  levels. Therefore, in a nationwide analysis, it should not
be assumed that  new sources in these categories will control to the NSPS
 levels  shown in  Table 3-13 unless NSPS's for NO  are proposed.

 3.5  SOURCE CONTRIBUTION FACTORS
As noted in the  formulation of modified rollback  (Equation 2-5), a
 source  contribution factor (S±) must be specified for each source category,
 i.e., mobile,  stationary area and stationary point sources.  This factor
                                    3-40

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is to account, in a very simplistic manner,  for  the  effect  of  emission
height and source-monitor separation on the  contribution of that source
category to the measured ambient concentrations.   A  factor  of  1.00
implies that emissions are at or near ground  level and  near the monitor,
and that they will have the greatest impact  on air quality.   Factors
less than 1.00 imply that pollutants are emitted above  ground  level  or
at a considerable distance from the monitor,  and because of  a  better
opportunity for dilution, the emissions have  a lesser impact on air
quality than nearby ground level emissions.   In a national  analysis,
these factors must represent some universal weighting of emissions for a
specific category averaged over all sites.  If sufficient data and
resources were available, then the use of a more sophisticated disper-
sion model would provide these weighting factors directly.   Of course,
such detailed analyses are not usually within the scope  of a nationwide
analysis.  Therefore, estimates of the source contribution  factors must
be based on extrapolations from previous site specific studies  and
engineering j udgement.

3.5.1  Ozone
All sources of volatile organic compounds (ozone precursors) are generally
considered to have a source contribution factor of 1.0 regardless of
their distance from the design value monitor or of the height  of emission.
This assumption is made because ozone is a secondary pollutant  requiring
some time for formation in the ambient air, and is generally characterized
as leading to a pervasive,  as opposed to a "hot spot," air quality
problem.  The complexity of the chemical transformations  (NMOC/NO  to
                                                                 A
ozone), and the large geographic extent of ozone nonattainment  areas,
suggests that all VOC emissions should be considered collectively.  In
addition, height of release is not considered because ozone  levels are
assumed to be more dependent on total atmospheric loadings than on
initial dilution, at the point of emission.  Recall that ozone is  formed
only after photochemical reactions with NMOC and NO  have taken place,
                                                   A
which is generally after the plume has been well mixed in the  atmosphere
and its initial height of release has become inconsequential.
                                    3-41

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3.5.2  Nitrogen Dioxide
Mobile and stationary area NO  sources have traditionally been assigned
                             A
source contribution factors of 1.0.  The rationale for this  selection
follows from similar emission heights of these source categories  and the
annual averaging time imposed by the current NAAQS.  The effect of  the
latter point is to "wash out" the effects of the spatial distribution of
these sources.  Therefore, no support for using a source contribution
factor other than 1.0 is evident, provided that an annual average NAAQS
is under consideration. Conversely, it is unclear what impact  stationary
point sources, which have been shown (see e.g., Chang, et al., 1980a) to
make significant air quality contributions on a short term basis, have
on NO- monitors in the existing network.  However, none of the existing
sites appears to have any significant impact from stationary point
sources; they are dominated by mobile and stationary area sources.   It
follows then, that unless new information becomes available  or new
monitor sites are selected that are dominated by stationary  point sources,
that a source contribution factor of 0.0 should be used for  point sources.

3.5.3  Carbon Monoxide
The selection process for source contribution factors for CO follows,
very closely, that of NO  .  Again, the CO regulatory analysis  has shown
                        X
that, while  stationary point sources can be shown to contribute to
significant  ambient concentrations, none of the CO monitors  that  cur-
rently indicate nonattainment are significantly impacted by  stationary
point sources.  Hence, a weighting factor of 0.0 is assumed  for stationary
point sources.  Note  that the above discussion may not apply to all
monitor sites nor to new  sites.
                                    3-42

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Because of the availability of the SRI work mentioned  in Section 2.2A.I,
an assessment of the relative impact of mobile and  stationary CO area
sources can be made.  Recall that SRI examined,  in  detail,  monitors  in
four areas: San Jose, Seattle, Phoenix, and Chicago.

Monitoring data in San Jose show a correlation between traffic  peaks and
CO levels.  This is illustrated in Figure 3-3 for one  of  the  monitors
closest to the intersection being studied.  There is a sharp  increase in
CO concentration starting at 7 a.m.  Concentrations drop  rapidly after.
9 a.m. and remain relatively constant through mid-day  until they increase
again around 3 p.m.  Peak evening values occur at 8 p.m.  The two sites
most frequently upwind of the nearby roadways show  the least  evidence of
the diurnal cycles.  This is evidence that local contributions  to CO are
important at the downwind sites.  Figure 3-4 shows  the diurnal  pattern of
"local" CO contributions averaged across all monitors  at  the  San Jose
intersection.  The local contribution is determined by subtracting the
background concentration for that hour from the maximum observed concen-
trations.   The local contribution to ambient CO levels  during  periods
when the CO concentration was above 9 ppm (the 8-hour  CO  NAAQS)  ranged
from 62 to 98 percent and averaged 80 percent.

In Seattle, samplers were deployed on a one—way street  in the Central
Business District (CBD).  Because the street was one-way, the bimodal
traffic patterns observed in San Jose were not evident  in Seattle.   As
can be seen from Figure 3-5, CO concentrations rise steadily  through the
day and peak between 5 and 7 p.m.  Apparently, the street where  the
monitors are located is more heavily traveled outbound  during the evening
rush hour period than it is during the morning.  Figure 3-6 shows the
estimated percentage of locally generated CO at the Seattle site.    As
in San Jose,  the maximum local contribution is determined by  subtracting
a background concentration for that hour from the maximum observed
concentration.   Although the local CO contribution usually  ranges between
                                   3-43

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                                  FIGURE 3-3
           DIURNAL VARIATIONS IN CO CONCENTRATIONS OBSERVED BY
             HOUR OF THE DAY AT A SAN JOSE, CA ROADWAY MONITOR*
              MAXIMUM AND MEAN ONE-HOUR AVERAGE MEASURED DECEMBER  8-15,1977
CO (ppm)

30
20-
 15-
 10-
 5-
                                  MAXIMUM
                                 10
I
15
20
        25

HOUR OF DAY
  Hourly values are averages of measurements during the one week monitoring period.
                                      3-44

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                                    FIGURE  3-4
               DIURNAL VARIATIONS IN CO CONCENTRATIONS DUE TO
         LOCALLY GENERATED EMISSIONS AT A SAN JOSE, CA INTERSECTION
          PERCENTAGE OF OBSERVED 8-HOUR (Running) AVERAGE MEASURED DECEMBER 8-15,1977
AVERAGE PERCENTAGE OF
LOCALLY GENERATED CO
100
 80-
 60-
 40-
20-
                                  10
i
IS
20
        25

HOUR OF DAY
  Hourly values are averages of measurements during the one week monitoring period.
                                      3-45

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                                    FIGURE 3-5
          DIURNAL VARIATIONS  IN CO CONCENTRATIONS DUE TO LOCALLY
                 GENERATED EMISSIONS IN DOWNTOWN SEATTLE, WA *
              PERCENT OF OBSERVED ONE-HOUR AVERAGE MEASURED JANUARY 11-18, 1978
AVERAGE PERCENTAGE OF
LOCALLY GENERATED CO
100
 80-
 50-
 40-
 20-
                                   10
15
 I
20
        25

HOUR OF DAY
 * Hourly values are averages of measurements during the one week monitoring period.
                                       3-46

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                                  FIGURE 3-6
          HOURLY VARIATIONS IN CO CONCENTRATIONS DUE TO LOCALLY
                  GENERATED EMISSIONS IN DOWNTOWN SEATTLE
         PERCENTAGE OF OBSERVED 8-HOUR (Running) AVERAGE MEASURED JANUARY 11-18,1978
PERCENTAGE OF LOCALLY
GENERATED CO
100
80-
60-
 40-
20-
          20      40      60     80     100      120      140     160     180     200

                                                                NUMBER OF HOURS
                                   3-47

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60 and 80 percent,  at some hours in Seattle it is much lower.  The
"regional" contribution at times is as high as 70 percent.  Therefore,
the CO problem at these Seattle sites cannot be considered  strictly
"local" in nature.

CO concentration patterns in Phoenix were much different than those in
the previous two cities.  Although the study site in Phoenix was near a
complex of government office buildings in the downtown area with dense
traffic likely from 7 to 9 a.m. and 4 to 6 p.m., the highest CO concen-
trations were observed between 10 p.m. and 2 a.m.; a period with low
traffic volume.  Because high CO was observed at numerous monitors
during this period, it was theorized that a recirculated air mass caused
these readings.   However, based on discussions with the meteorologist
for the State of Arizona Bureau of Air Quality Control, SRI's conclusions
about how these high levels occur may be somewhat misleading.  In the
winter months when high CO concentrations are most likely to be observed
in Phoenix, the following pattern is predominant:
   1. High CO emissions during 6 to 9 a.m. traffic peak.
   2. From 10 a.m. on, upslope  (westerly) winds predominate.  There  is
     intense surface heating which causes instability and promotes  good
     vertical mixing.  Therefore, no CO buildup is likely during the
     day.
   3. High CO emissions during 4 to 6 p.m. traffic peak.
   4. At  approximately 6 p.m. an inversion forms.  Winds continue from
     the west.
   5.  Sometime between 10  p.m.  and midnight the wind direction changes,
      and  downslope winds  bring post  6 p.m. emissions back into the  urban
      area causing high  CO readings.
   6.  The  inversion breaks up by 10 a.m. the next day.

 Given this  weather pattern, then,  locally generated CO emissions
 end  up producing  the high observed values.  The difference  is that  the
                                    3-48

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highest CO emission periods  (morning and  evening  rush hours)  are not the
contributors to the highest  ambient CO.   Because  CO emitted before
6 p.m. is not trapped by the inversion, it  is  unlikely to be  carried
back into the city late at night.  Therefore,  6 p.m.  to midnight emissions
are the most directly related to high CO.

In a city with this type of  situation, rollback is  only applicable if
the mix of sources contributing to the problem is the same as that in
the emission inventory being used.  If an air  mass  leaves and then
returns to the downtown area, it is likely  to  be well mixed (within the
inversion layer).  Therefore, it is more  likely in  a  city like Phoenix
that non-mobile area sources or point sources  can contribute  to CO
concentrations at the design value monitor  if  there is  any transport.

The monitor locations in downtown Chicago were representative of  a
"street canyon" situation, with nearby buildings all  taller than ten
stories.  Figure 3-7 shows that while the local CO  contribution is
typically between 60 to 80 percent, it can  be  as low  as  20 percent.
Diurnal variations in CO concentrations were more evident at  the "local"
monitoring sites than at the "background" sites.  Therefore,  it can be
concluded that to some extent these monitors reflect  "local"  changes in
emissions.  Because there were only two eight-hour  CO standard violations
during the Chicago study period, it is difficult to reach conclusions
based on such a small sample.  However, it  should be  noted that the
"local" contribution to these two violations averaged  86  percent.

The monitoring data collected in Chicago are less representative  of
typical conditions in that city than the data  from  the  other  three
cities.  The CO concentrations observed in  Chicago  during the SRI study
period were much lower than  normal for the  same period  in previous years
                                     3-49

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                                  FIGURE 3-7
              HOURLY VARIATIONS IN CO CONCENTRATIONS DUE TO
             LOCALLY GENERATED EMISSIONS AT A CHICAGO, IL SITE
        PERCENTAGE OF OBSERVED 8-HR (Running) AVERAGE MEASURED FEBRUARY 24-MARCH 3,1978
PERCENTAGE OF LOCALLY
GENERATED CO
100-
 60-
 40-
 20-
           20
40
60
I
80
 i
100
120
140
 I
160
    I
   180      200

NUMBER OF HOURS
                                       3-50

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as measured at a nearby SAROAD site.  Violations  of  the 8-hour standard
occurred approximately one percent of the  time  at the  nearest SAROAD
site in the first quarter of  1975.  Concentrations at  SRI's mobile
laboratory did not even exceed 3 ppm one percent  of  the time during the
test week.  This difference is at least partially attributable to adverse
weather conditions (snow) which reduced traffic during the  study.

Because stationary CO area sources constitute major  contributors  to CO
levels, they pose a perplexing problem.  Based  on emission  height,  they
should probably be weighted the same as mobile  sources.   However,  because
of the short term averaging time of the NAAQS,  averaging  cannot be
easily invoked (as with N0?)  to resolve spatial variability of sources.
Area sources of CO will not,  in general, be as  heavily concentrated
around the nonattaining monitors as mobile sources.  Therefore, a  weighting
factor less than 1.0, but larger than 0.0 should  be  used.   Because
ratios of mobile to area source densities are not available around  each
site, some judgement concerning the level of the  factor must be made.
Traditionally, (see e.g., Chang, et al., 1980b) the  area  source contri-
bution factor has been chosen to be 0.2.  However, the value selected
for this factor is usually not critical because stationary  area souce  CO
emissions consitute only about 7% of the national total mobile and
stationary area source inventory (EPA, 1980).   Thus, an area source
contribution factor of 0.20 can be used for national air  quality assessments.

3.6  TRANSPORTATION CONTROL FACTORS
These factors are used to show the extent to which transportation  control
measures are expected to reduce mobile source emissions.  They should
only be used to account for measures designed to  reduce VMT.   Emission
reductions due to the Federal Motor Vehicle Emission Control Program
(FMVECP) and inspection and maintenance are accounted  for in the mobile
source control factors.
                                    3-51

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Transportation control measures (TCM's) are designed  to  change current
travel patterns via either pricing or service  incentives,  or both.   They
are usually projects which involve a small investment of  capital and
attempt to induce immediate changes in travel  behavior.   Major capital
projects like new freeways and subway systems  which affect long-term
travel are not TCM's.  Through TCM's, an automobile driver may be
induced to:
  •  Eliminate a trip
  •  Reduce the length of a trip
  •  "Double up" by carpooling
  •  Use transit.

Determining potential credits for TCM's  for use in a  nationwide analysis
is difficult because there may be considerable variation in the trans-
portation control plans  among regions.   Therefore, TCM's in one region
may  be  designed to reduce emissions by only a  few percent, while another
region  with a  more extensive set of TCM's may  expect  their program to
reduce  emissions by  10 percent or more.  Because of  this variability, it
is recommended that  any  projection analysis be run using more than one
assumption about TCM credits to test  the sensitivity  of  the results to
changes in this variable.  It  is unlikely  that TCM's  will reduce mobile
source  emissions more than 10  percent, however.

Because transportation control plans  are being continually changed
through the  SIP process, future nationwide  analyses should take these
changes into  account.  To the  extent  that  transportation control plans
are  the same  in different regions, a  point  estimate of TCM effectiveness
can  be  made.   Otherwise, a range of  estimates  should be used.

Determinations of  credits for  TCM's  should  be  based on the most recent guidance
 from EPA's Office  of Transportation  and  Land Use Policy (OTLUP).
                                    3-52

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                        REFERENCES FOR SECTION 3
Bureau of Economic Analysis.  October 1977.  "Population, Personal
Income, and Earnings by State - Projections to 2000."  U.S. Department
of Commerce.  Washington, B.C.

Chang, T.Y., Norbeck, J.M.,  and Weinstock, B.  February 1980a, "NO^
Air Quality-Precursor Relationship:  An Ambient Air Quality Evaluation in
the Los Angeles Basin," J. Air Poll. Control Assoc. 30:157.

Chang, T.Y., Norbeck, J.M.,  and Weinstock, B.  January 1980b, "Urban-
Center CO Air Quality Projections," J.  Air Poll.  Control Assoc.  30:1022.

Congress of the United States.  February 1979.  Changes in the Future
Use and Characteristics of the Automobile Transportation System.   Volume II:
Technical Report.  Office of Technology Assessment.  Washington,  B.C.

Decker, C.E., Worth, J.J.B., Ripperton, L.A., and Bach, W.D.   January
1977.  Ambient Monitoring Aloft of Ozone and Precursors Near and  Down-
wind of St. Louis.  EPA-450/3-77-009.  Research Triangle Institute, RTP,
NC.  (Prepared for U.S. EPA, RTP, NC.)

Eaton, W.C., Decker, C.E., Tommerdahl,  J.B., and Dimmock, F.E. April
1979.  Study of the Nature of Ozone, Oxides of Nitrogen, and Nonmethane
Hydrocarbons in Tulsa, Oklahoma.  Volume II.  Data Analysis and Inter-
pretation.  EPA-450/4-79-008c.  Research Triangle Institute,  Research
Triangle Park, NC.  (Prepared for U.S.  EPA, RTP,  NC.)

McNutt, B., Dulla, R., and Lax, D.  March 1979.  "Factors Influencing
Automotive Fuel Demand."  SAE Technical Paper Series.  No.  790226.
Congress and Exposition.  Detroit, MI.

PEDCo Environmental, Inc.  February 1979.   Control Techniques and Costs
for Carbon Monoxide Emissions.  Interim Report No. 1.  Cincinnati,  OH.

Peterson, P.R. and Sakaida,  R.R. December 1978.  Summary of Group I Control
Technique Guideline Documents for Control of Volatile Organic Emissions from
Existing Stationary Sources.  EPA-450/3-78-120.  Pacific Environmental
Services, Santa Monica, CA.   (Prepared  for U.S. EPA,  Research Triangle Park,
NC)

Trijonis, J. and Hunsaker, D.  February 1978.  Verification of the
Isopleth Method for Relating Photochemical Oxidant to Precursors.
EPA-600/3-78-019.  Technology Service Corporation.  Santa Monica,  CA.
(Prepared for U.S. EPA, RTP, NC.)
                                   J-53

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U.S. Department of Energy.   October 1979.  Industrial Sector Technology
Use Model, Industrial Energy Use in the United States. 1979-2000.
Volume I -Primary Model Documentation.  DOE/FE/2344-1.  Washington, D.C.

U.S. EPA.  December 1977.  Procedures for the Preparation of Emission
Inventories for Volatile Organic Compounds, Volume I.  EPA-450/2-77-028.
RTP, NC.

U.S. EPA.  January 1979a.  Guideline for the Interpretation of Ozone Air
Quality Standards.  EPA-450/4-79-003.  OAQPS No. 1.2-108.  RTP, NC.

U.S. EPA.  December 1979b.   Regulatory Analysis and Environmental Impact
of Final Emission Regulations for 1984 and Later Model Year Heavy Duty
Engines.  Office of Mobile Source Air Pollution Control.  Ann Arbor, MI.

U.S. EPA.  March 1980.   1977 National Emissions Report.  EPA-450/4-80-005.
RTP, NC.

U.S. EPA.  January 1978a.  Control Techniques for Nitrogen Oxides Emmisions
from Stationary Sources-Second Edition.  EPA-450/1-78-001.  Research Triangle
Park, NC.  (Prepared by  Acurex Corporation, Mountain  View, CA) .

U.S. EPA.  August 1978b.  User's Guide to MOBILE1;  Mobile Source Emissions
Model.  EPA-400/9-78-007.  Washington, D.C.

U.S. EPA.  1980.  User's Guide to MOBILE2;  Mobile Source Emissions Model.
 (In press) Ann Arbor, MI.

Wohl, M.  and Martin, B.V.  1967.  Traffic System Analysis for Engineers
and Planners.  McGraw-Hill Book Company.  New York, NY.
                                    3-54

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                    4.  STRATEGY EVALUATION CRITERIA
Indicators like percentage change in concentrations, number of exceedances
of the NAAQS, and number of regions experiencing NAAQS violations are
typically used in nationwide studies to compare the effectiveness of
alternative motor vehicle emission standards or other control programs.
The usefulness of each of these indicators in predicting differences
among control scenarios is discussed in this section.  In addition, some
less frequently used indicators such as concentration frequency distri-
butions, populations at risk, and number of unhealthful days will be
presented and critiqued.  The indicators discussed in this section are
important because they are the criteria by which alternative scenarios
are judged.

4.1  PERCENTAGE CHANGE IN POLLUTANT CONCENTRATION
Calculating the percentage change in air quality between the base year
and the projection year is accomplished using equation (4-1):
     Projection Year A.Q. - Base Year A.Q..Ul_n<,.   _     .     _,        /•/ T\
     	J	Base Ye;r A.Q.	*-100% = Percentage Change   (4-1)

This computation is made for each area in the nationwide sample and then
the specific area values are averaged to determine a nationwide average.

This measure essentially provides a weighted average of the effective-
ness of emission controls.  Emissions are weighted by the source contribution
factors.  The average percentage change in air quality equals  the average
percentage change in emissions if the source contribution factors are
all equal to one, and there is no background.
                                   4-1

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This indicator is useful if the purpose of the analysis is to compare
the effectiveness of different control strategies like different auto
emission standards.  Then, knowing the weighted average effectiveness of
the controls vis-a-vis other source types is important.  It is a good
indicator to use in a nationwide analysis where a sample of regions is
chosen to be representative of the entire U.S.  However, for a regulatory
analysis where attaining/not attaining a standard is of most interest,
its usefulness is limited.

The significance of a percentage decrease in pollutant concentration
depends on the base year ambient levels and their magnitude in relation
to the NAAQS.  For example, a two percent reduction in ambient levels
may be sufficient to bring a region that is already close to the stan-
dard into compliance.  However, in a region with pollutant levels much
higher than the  standard, two percent would be a totally inadequate
reduction.

4.2  NUMBER OF EXCEEDANCES OF THE NAAQS
More than one method  can be used to project the number of exceedances of
the NAAQS.  The  basic procedure is to choose  a frequency distribution
 (e.g., exponential) which has been shown to be representative of the
pollutant in  question and use this distribution to estimate the number
of  violations from the projected concentration for a given sampling
time.  The most  straightforward manner to apply this technique is to use
a single distribution for all areas.  The more complex alternative is to
project a separate distribution for each region.

An example where a distribution was used to predict the number of NAAQS
violations  is  in a past  analysis of alternative automotive emission
 standards.   (U.S.  EPA,  1979).
                                    4-2

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In this analysis, violations of the ambient CL standard were estimated  using
an exponential distribution for CL concentrations.  The exponential
distribution had the form:

          F(C) = 1 - exp (-C/C)                             (4-2)
     where:
        F(C) = the fraction of values less than or equal to the
               concentration C
           C = the mean of the observed concentrations
Hourly 0_ data were used to determine the design value and the mean for
the base year.  These values were then projected to future years using
the rollback model, and used in equation (4-2) to estimate the number of
hours that the standards would be violated.

Other researchers have confirmed the use of the exponential distribution
as a good descriptor of the upper tail of most ambient concentration
distributions (Breiman, Gins and Stone, 1978) (Curran and Frank, 1975).
These references are particularly useful because they concentrate on
predicting peak air pollution concentrations.  In addition, it should be
noted that the one-parameter exponential distribution is readily adapted
to the rollback formulation where only the peak concentration value is
available.

Because this measure compares ambient values to the NAAQS,  it provides
some information on the potential health risk of exposures  to high
pollutant levels.  Presumably,  the greater the number of violations,  the
greater the health risk.  However, there are some uncertainties involved
in estimating the number of ambient standard violations.  One is that
the distribution selected as representative of the data in the base year
is accurate.  Another is whether the distribution of air quality values
in the base year will be the same in future years.   Because control
                                   4-3

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strategies may be focused on the highest recorded  level,  the  distribu-
tions may typically change over time.  However, if the  sample of  cities
used in an analysis is large enough, and the errors  in  estimating the
number of exceedances are randomly distributed between  cities,  the
projected nationwide number of violations should be  a valuable  indicator
for comparing alternative control options.

4.3  NUMBER OF REGIONS WITH AMBIENT LEVELS GREATER THAN THE STANDARD
This is a straightforward number to calculate, but an important measure
to use in comparing control strategies.  It is especially important in
determining the potential control costs to achieve a standard and may be
used as a surrogate for  exposure.  In the recent regulatory analyses,
this indicator was extremely important because a change in the ambient
standards directly affects costs to  industries and consumers  in areas
which must impose controls to meet those standards.  The steps in the
regulatory analyses were:
  •  Use base year monitoring data  to determine design  values
  •  Project  design values to the future year  of interest
  •  Compare  projection  year design  values to  ambient  standards
  •  For areas with values greater  than the standard,  impose
     controls to bring them into compliance
  •  Calculate the cost  of meeting  the ambient standard.
Therefore, estimating whether a region will or will  not comply with an
ambient  standard is crucial in  evaluating needed nationwide control
strategies and their  associated costs.  While  this is  a useful measure
in  a nationwide  analysis,  the use  of rollback  or  the standard EKMA
isopleths to  predict  attainment or  nonattainment by  any single area is
inappropriate.   Control  strategies  in specific areas may be far different
than those assumed  as  a  nationwide  average.
                                  4-4

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4.4  OTHER STRATEGY EVALUATION CRITERIA
The approach used for evaluating the effectiveness of expected emission
reductions in the next 10-20 years by the Council on Environmental Quality
(CEQ, 1976) in its annual reports is somewhat different than that typically
used in projection analyses.  Instead of using a design value to judge
attainment or nonattainment of a standard, the CEQ projects the distribution
of concentrations.  This distribution shows both absolute concentration
intervals and the number of days in a year with maximum concentrations
in those intervals.  This technique assumes a 1:1 relationship between
emissions and air quality reductions.  Essentially, expected reductions
in emissions are accounted for by shifting the distribution downward
according to the percentage reduction in emissions assumed.

Another CEQ indicator for measuring air quality trends is the number of
unhealthful days.  The 1979 CEQ Annual Report uses the Pollutant Standards
Index (PSI) for each city to determine the number of days with unhealthful
air.  In this CEQ report, they use PSI data from 1975-1977 to rank SMSA's
by the number of "unhealthful" and "very unhealthful" days.  For each
county with monitoring data, CEQ multiplies the county population by the
number of days on which the levels of each of the criteria pollutants
exceeded the primary NAAQS.  This yields the number of person-days of
exposure in the county for the year.

The chief advantage of these techniques is that they present more than
just the expected change in the design value for a region.  However,
when considering them for use in a nationwide analysis,  this advantage
is outweighed by the amount of effort to assemble the data for each
region.

4.5  CONCLUSION
The current version of the modified rollback computer program used by
EPA uses three summary statistics as indicators of the nationwide dif-
                                 4-5

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ferences in control options.   They are the projected average percentage
change in air quality,  the number of cities with concentrations  above
the standard, and the total number of violations.  Each one of these
indicators is useful for comparing control options, but some indicators
should receive more emphasis than others depending on  the  type of  analy-
sis being performed.  For example, if different motor  vehicle emission
standards are being compared, the average percentage change in air
quality is probably the most useful.  Alternatively, if a  regulatory
analysis is being performed, the number of cities above the standard  is
the most important indicator because costs for controls are only incurred
in areas that violate the standard.  In\ both cases, the total number  of
violations indicator provides useful additional information about  the
extent of high concentrations in the projection year.

In the CEQ reports, the indicators provide some additional information
when compared with the current rollback output, but with  the exception
of including county population estimates to the data base, they  are only
marginally useful and would be extremely time consumptive  to include  in
a rollback format.
                                  4-6

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                        REFERENCES FOR SECTION 4
Breiman, L., Gins, F. and Stone, C.  November 1978.  Statistical Analysis
and Interpretation of Peak Pollution Measurements.  Technology Service
Corporation, Santa Monica, CA  (Prepared for U.S. EPA, Research Triangle
Park, N.C.)

Council on Environmental Quality-  September 1976.  Environmental
Quality - 1976.  The Seventh Annual Report of the Council on Environ-
mental Quality.  Washington, D.C.

Council on Environmental Quality.  December 1979.  Environmental Quality -
1979.  The Tenth Annual Report of the Council on Environmental Quality.
Washington, D.C.

Curran, T.C. and Frank, N.H.  1975.  "Assessing the Validity of the
Lognormal Model when Predicting Maximum Air Pollution Concentrations"
Paper No. 75-51.3, 68th Annual Meeting of the Air Pollution Control
Association, Boston, MA.

U.S. EPA.  November 1979.  "Data Assumptions and Methodology for Assessing
the Air Quality Impact of Proposed Emission Standards for Heavy-Duty
Vehicles."  OAQPS, RTP, NC.
                                   4-7

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                      5.   SUMMARY AND  CONCLUSIONS
5.1  APPLICABILITY OF ROLLBACK AND EKMA
This study recommends methodologies appropriate  for  evaluating the
nationwide impact of emission control strategies  on  ambient  levels of
CO, NO  and 0_.  These methodologies are not  recommended  for SIP  analyses
      *»      o
of specific urban areas.  They are particularly  appropriate  for evaluating
mobile source control strategies.  Therefore, they apply  to  the mobile
source related pollutants.  These methods use a  sample  of  regions with
ambient data indicating a standards violation or  the potential to exceed
the standard in the analysis.  While emissions and air  quality data
specific to each area are used, other assumptions about control effec-
tiveness, growth in new sources, retirement of existing sources,  and
source contributions are made on a nationwide average basis.

CO and NO  air quality projections are performed  using  the Modified
Rollback Model (de Nevers and Morris, 1975) to relate pollutant emis-
sions and ambient concentrations.  This model assumes that the ambient
concentration of a pollutant is a linear function of pollutant emissions
within a specified geographical area.  Therefore, a  change in  CO  or NO
                                                                      X
emissions is assumed to result in a proportional  change in CO  or  N02
concentrations.

Ozone air quality projections are made using the  Empirical Kinetic
Modeling Approach (EKMA) (U.S. EPA, 1977).  EKMA  utilizes a  set of  ozone
isopleths which depict maximum afternoon concentrations of ozone  down-
wind from a city as a function of initial (i.e.,  morning) concentrations
of NMOC and NO , VOC and NO  emissions occurring  later  in the  day.
              X            X
meteorological conditions, reactivity of the precursor mix,  and con-
centrations of ozone and precusors transported from  upwind areas.
                                 5-1

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However, in the version of EKMA typically used in nationwide  studies,
NO  levels are assumed to remain constant.  Therefore,  only reductions
  x
in VOC emissions are assumed to affect 0  concentrations.  The NMOC/NO
                                        «J                             X
ratio assumed for each area affects the percentage reduction  in  0
attributable to a given reduction in VOC emissions.  Therefore,  area
specific ratios should be used when available.  A default  value  of  9.5:1
is used in areas with no monitoring data.
When comparing models like rollback and EKMA. with  complex dispersion
models, the most important difference is  in determining  the source
contributions.  The extent to which a reduction  in emissions will
produce a reduced pollutant concentration for a  given source cate-
gory depends on source-receptor distance, atmospheric stability,  wind
speed and effective stack height.  The source contribution factors used
in a rollback application are determined  from monitoring and modeling
data.  A source contribution factor is determined  separately for each
source type which contributes significantly to measured  concentrations.
Then, once the source contribution factors are chosen, all strategy
evaluations become rollback analyses.

The main advantage of using rollback is its computational and resource
economy.  There are several limitations associated with  rollback how-
ever.  The most significant are:
      1.   Lack of model validation
      2.   The assumed linear relationship between  emissions and air
          quality.  Deposition, agglomeration and  chemical reaction
          could invalidate the  linear assumption.
      3.   The current base year concentration may  not be known
          based on coverage of  the monitoring network.
      4.   The growth factor used  assumes  all other parameters
          remain unchanged, i.e., all sources grow equally and
          their spatial distribution remains constant.
                                    5-2

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     5.   Simple and "modified" rollback assume  that  the  meteoro-
          logical conditions occurring when the  design  value  was
          measured are the same in the projection year.
     6.   Very simplistic treatment of source-receptor  relationships.
     7-   Simple rollback assumes all sources emit at the same
          height and "modified" rollback assumes sources  within
          certain categories emit at the same height.
     8.   Estimates can only be made for existing monitoring  sites.
It should also be noted that the rollback formulation is inherently
designed to estimate changes in air quality concentrations based on
current air quality and assumed background levels resulting from emis-
sion changes.  Therefore, it should be used to examine relative dif-
ferences between control strategies rather than absolute levels.  Likewise,
EKMA isopleths are most properly interpreted when used in a relative
rather than an absolute sense.

5.2  SUGGESTED METHODOLOGIES FOR COMPILING MODELING DATA

5.2.1  Emission Inventories
The National Emissions Data System (NEDS) is recommended for use in
compiling emission inventories for nationwide studies.  NEDS is the only
source which uses consistent inventorying procedures and compiles data
in a common set of source categories.  NEDS inventories are typically
provided on a county or AQCR basis.  After study of the characteristics
of the three mobile source related pollutants, it is recommended that
county inventories be used for CO and NCL analyses, and AQCR inventories
be used for 0  analyses.  Although CO is predominately a microscale
problem, county inventories are the most detailed included in NEDS, and
it would be impossible to find a consistent inventory area smaller than
a county for which information would be available on a nationwide basis.
                                   5-3

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The source category groupings recommended for use  in  a nationwide study
are shown in Tables 3-3, 3-4, and 3-5.

5.2.2  Design Values
The design value is defined as the concentration that must be  reduced to
the level of the standard for an area to be  in attainment.   In using
ambient monitoring data in national strategy assessments,  design values
are usually chosen to correspond to the form of the standard for each
pollutant and for a time period consistent with the emission inventory.
Design values for the three pollutants considered  in  this  report are
usually chosen as follows:
  •  Carbon Monoxide -
     The highest second high eight-hour average in the  three year
     period encompassing the emission inventory base  year.
                        \
  •  Ozone -
     The one-hour average measured  in the  three year  period encom-
     passing the emission inventory base year which is  expected to
     be exceeded an average  of once per year (See  Table 3-6).
  •  Nitrogen Dioxide -
     The highest annual average measured in  the  three year period
     encompassing the emission inventory base year.

 5.2.3   Growth and Retirement Rates

 5.2.3.1  Stationary Sources
 Future changes  in  industrial activity  can  be accounted for by a combina-
 tion of growth  and  retirement  rates.   Growth and  retirement are differen-
 tiated because  regulations  affecting  new  sources  differ from those
 affecting existing  sources.  Therefore,  different  control assumptions
 are identified  for  each.   Growth  rates  and controls are applied to
 estimate  new source emissions.  Retirement rates  are applied to estimate
 how emissions  from existing sources will  decrease.
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When applying the growth and retirement  rates  listed  in Section 3, it
should be noted that these are national  averages  based  on broad station-
ary source categories, which are judged  to be  sufficient for a national
scale analysis.  They may not be representative of  a  particular urban
area.

5.2.3.2  Mobile Sources
Predicted growth in vehicle miles traveled (VMT)  serves as a surrogate
for estimating the true growth rate in mobile  source  emissions.   However,
growth in VMT is difficult to predict for two  reasons.   One is the
uncertainty in how changes in fuel prices will affect demand for gasoline
and travel.  The second is identifying how VMT will change in the areas
that specifically affect high pollutant  levels.   Therefore,  because  of
the considerable uncertainty in predicting VMT over a 10-20 year period,
it is advisable to use a range of possible growth rates to judge the
sensitivity of the modeling results to changes in this  factor.

It should also be noted that the growth  rates in  Section 3 may  differ
from the area specific VMT growth rates  used in state and local  analyses.

5.2.4  Control Effectiveness
The effectiveness of future controls for mobile sources  can be  estimated
using EPA's mobile source emission factor program (MOBILE2).   This
program accounts for both expected future emission levels by model year
by vehicle type and the rate of retirement of existing  vehicles  from the
present fleet.  MOBILE2 can also be used to evaluate the effectiveness
of I/M programs.

Estimating the effectiveness of stationary source controls  for  use in a
nationwide analysis is not as straightforward as it is  for  mobile  source
controls because there are many more source types to deal with.   Sta-
tionary source categories used in nationwide analyses are usually  chosen
                                     5-5

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so that source types with common growth rates and control efficiencies
are grouped together.  Therefore, the control efficiency used  in  the
rollback or EKMA model is a weighted average based on control  effi-
ciencies for each source type.

Estimates of control efficiencies for stationary sources of VOC detailed
in Section 3 are taken from the Control Techniques Guideline  (CTG)
documents published to date.  As new CTG documents are published,  the
numbers in Table 3-12 can be updated.  Control efficiencies for NO and
CO stationary sources can be updated through new editions of  their
respective Control Techniques Documents (CTD's).

5.2.5  Source Contribution Factors
Source contribution factors are an attempt to account for the effect  of
stack height and source-monitor separation on the contribution of each
source category to measured ambient  concentrations.  A factor of  1.0
implies that emissions from that source category are typically at or
near ground  level and near the monitor measuring the design value.
Factors less than 1.0 imply that pollutants are emitted  above ground
level  or at  a considerable distance  from the monitor, and because of  a
better opportunity for dilution, the emissions have a lesser  impact on
air quality  than nearby  ground  level emissions.

All ozone  precursors are generally considered to have a  source contri-
bution factor of 1.0.  This assumption is made because ozone  is a secondarily
formed pollutant and is  generally characterized as  leading  to pervasive,
as opposed to "hot  spot", air quality problems.  For N0_, point sources
are not significant  contributors to  annual  average  concentrations measured
at urban monitors.   Therefore,  they  are  assigned a  source  contribution
factor of  zero.  Mobile  and other area source emissions  are assumed  to
contribute 100  percent  to ambient N0_.   Similarly  for CO,  it  is assumed
that point sources  have  zero  contribution at  design value monitors.   A
                                     5-6

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source contribution factor of 1.0 is recommended  for  mobile  sources,  and
a 0.2 factor is recommended for stationary area sources.   The  0.2 source
contribution factor is based largely on the  typical distance of  CO area
sources from urban CO monitors in comparison with mobile  sources.

5.2.6  Transportation Control Factors
These factors are used to show the extent to which Transportation Control
Measures (TCM's) are expected to reduce mobile source emissions.   They
should only be used to account for measures designed  to reduce VMT.
Emission reductions due to the Federal Motor Vehicle  Control Program
(FMVCP) and I/M are accounted for in the mobile source control factors.

Determinations of credits for TCM's should be based on the most  guidance
from EPA's Office of Transportation and Land Use Policy (OTLUP).   Because
there may be considerable variation in the transportation control  plans
among regions, it is advisable to model a range of TCM credits rather
than one point estimate.

5.3  STRATEGY EVALUATION CRITERIA
The current version of the modified rollback computer program used by
EPA uses three summary statistics as indicators of the nationwide  differences
in control options.  They are the projected change in air quality, the
number of cities with concentrations above the standard, and the total
number of violations.  Each one of these indicators is useful for  comparing
control options, but some indicators should receive more emphasis  than
others depending on the type of analysis being performed.  See Section 4
for more details about the interpretation of these factors.
                                     5-7

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                       REFERENCES FOR SECTION 5
deNevers,  N.  and Morris,  J.R.   1975.   "Rollback Modeling:
Modified", J. Air Poll.  Control Assoc. Volume 25, No. 9.
Basic and
U.S. Environmental Protection Agency.  November 1977.  Uses, Limitations
and Technical Basis of Procedures for Quantifying Relationships Between
Photochemical Oxidants and Precursors.  EPA-450/2-77-021a.  Research
Triangle Park, NC.
                                    5-8

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                                    TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
   EPA 450/4-80-026
                                                            |3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
   Methodology To  Conduct Air Quality  Assessments of
   National Mobile Source Emission Control  Strateqies
              5. REPORT DATE
               October, 1980
              6. PERFORMING ORGANIZATION CODE
]7. AUTHOR(S)
   James H. Wilson,  Jr. ,
   Mark A. Scruggs
              8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

   Enerqv and Environmental  Analvsis,  Inc.
   Ill  North 19th Street
   Arlington, Virainia   22209
                                                             10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.

                 68-02-3371
12. SPONSORING AGENCY NAME AND ADDRESS

   Environmental Protection Anency
   Research Triangle  Park,  North Carolina   27711
              13. TYPE OF REPORT AND PERIOD COVERED
                 Final
              14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
   EPA Project Officer  -  Warren P. Freas
16. ABSTRACT
           This  report describes a methodology for conducting air quality
      assessments  of national mobile  source emission control  strategies
      using the  Modified Rollback Model  and standard EKMA  isopleths.  Both
      modified rollback and EKMA are  simple models which do not require
      extensive  data bases.  As such,  they are most useful  for estimating
      the impact of an emission control  strategy on air quality in nationwide
      studies where a number of alternative control strategies must be
      analyzed in  a great many areas.   Recommended methodologies and data
      assumptions  are consistent with  those used in the regulatory impact
      analyses for alternative national  air standards for  ozone and carbon
      monoxide.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/Group
  Mobile Sources
  Air  Oualitv Analvses
 8. DISTRIBUTION STATEMENT

  Unlimited
19. SECURITY CLASS (This Report)
   Unclassified
21. NO. OF PAGES
  100
                                              20. SECURITY CLASS (This page)
                                                 Unclassified
                           22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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