Jnucd Stales
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-452/R-93-002
March 1993
Air
EPA
GUIDANCE FOR GROWTH FACTORS,
PROJECTIONS, AND CONTROL
STRATEGIES FOR THE
15 PERCENT
RATE-OF-PROGRESS PLANS
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Guidance for Growth Factors,
Projections/ and Control
Strategies for the 15 Percent
Rate-of-Progress Plans
Ozone/Carbon Monoxide Programs Branch
U.S. Environmental Protection Agency
Office of Air Quality Planning and
Standards
Research Triangle Park, NC 27711
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ADDENDUM TO "GUIDANCE FOR GROWTH FACTORS, PROJECTIONS, AND
CONTROL STRATEGIES FOR THE 15 PERCENT RATE-OF-PROGRESS PLANS"
The purpose of this addendum is to provide information on
the status of issues that have been raised regarding the
15 percent rate-of-progress plans. These issues are divided into
three categories: clarification of resolved issues, status of
previously identified issues, and identification of new issues.
Clarification of Resolved Issues
Inspection/Maintenance (I/M)
Section 4.2 of the document titled Guidance on the Ad-justed
Base Year Emissions Inventory and the 1996 Target for the
15 Percent Rate-of-Progress Plans. EPA-452/R-92-005, discussed
the credit that can be allowed for improvements to I/M programs.
As indicated in that discussion, credit can be allowed for
improvements in I/M programs that go beyond EPA's basic I/M
requirements or the program that was approved in the SIP at the
time of enactment, whichever is more stringent. Therefore,
States can not get credit for bringing an I/M program up to the
basic I/M standards, even where EPA never issued a pre-enactment
SIP call to correct the I/M program and where the I/M program had
been approved in the SIP. This interpretation is based on the
language in sections 182(b)(1)(D)(iv) and 182(a)(2)(B)(i) of the
Act.
Reid Vapor Pressure (RVP)
Several questions have been raised concerning what RVP
States should use in developing the 15 percent plan, particularly
for areas that had an actual RVP less than 9.0 psi in 1990. The
reductions that must be subtracted from the "rate-of-progress
base year inventory" are calculated exactly as discussed in
Guidance on the Adjusted Base Year Emissions Inventory and the
.1996 Target for the 15 Percent Rate-of-Progress Plans, page 13.
This means that in determining the reductions that would be
achieved by the FMVCP and RVP requirements, all areas, including
areas that had an actual RVP less than 9.0 psi in 1990, should
use the actual RVP for the- 1990 case and the allowable RVP
(9.0 or 7.3 psi) for the MOBILES.0 run that will be used to
calculate the 1990 adjusted base year inventory. Although rhis
might at first appear to result in a target that is more'
difficult to meet, in reality it does not. The reductions that
are subtracted to get the adjusted base year inventory are later
added to other reductions to get- the total required reductions.
The effect of subtracting a smaller number from the rate-of-
progress inven€ory is compensated by adding a smaller number to
the total reductions.
0.0.1
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Nonroad Mobile Source Emissions Factors
A number of States have questioned the accuracy of the
nonroad mobile source emissions factors and emissions provided by
the Office of Mobile Sources (QMS). Although the factors are
higher than previous estimates, QMS believes that they are more
accurate. They have indicated that they are willing to work with
any State that has identified problems regarding activity factors
related to distribution and/or usage of equipment.
Status of Previously Identified Issues
Waivers
Issue:
Status:
Issue:
Status:
-ssue:
What does "all measures that can feasibly be
implemented...in light of technological achievability"
include? [Section 182(b)(1)(A)(ii)(III)]
One interpretation of the Act is that "all measures
that can feasibly be implemented...in light of
technological achievability" includes only those
measures that are achieved in practice in nonattainment
areas of the next higher classification. The EPA is
still considering whether this is the preferred
interpretation.
If a State is granted a waiver, based on the fact that
it has submitted a plan•that includes all measures that
can feasibly be implemented, is the State still
required to submit contingency measures? If so, what
would be available as contingency measures?
If the interpretation above is used, other measures
such as those achieved in areas of even higher
classification will be available as contingency
measures. For an area classified as severe, there
would be no measures readily identifiable since there
is -only one classification above severe, although these
areas are still required to submit contingency
measures. If a more stringent interpretation- is used,
EPA will have to consider whether it is reasonable to
require contingency measures.
In determining the feasibility of I/M for the purposes
of a waiver, can a State consider the population of an
area?
Status: This issue is still under review by- QMS..
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RVP
Issue: What RVP should be assumed for projecting 1996
emissions?
Status: This issue is under review by QMS. They are evaluating
whether there is justification for allowing States to
assume that actual emissions are expected to be less
than future allowable emissions.
Federal Measures
Issue: Will EPA approve 15 percent plans that are based on
commitments to adopt new CTG RACT rules and/or
forthcoming national rules (e.g., auto refinishing)?
Status: The EPA will be providing guidance to the States
concerning the credit that can be allowed from these
programs.
Vehicle Miles Traveled (VMT) Growth Projections
Issue: Can States use more recent estimates or actual VMT
growth rates where available?
Status: The QMS has indicated that areas may be able to show
that regionally-specific factors may be more
appropriate in some circumstances, and plans to provide
clarification of this issue.
Nonroad Mobile Sources
Issue: How much credit can be allowed for the use of
reformulated gasoline in nonroad engines?
Status: The QMS plans to provide guidance to the States on how
to determine credit for use of reformulated gasoline in
nonroad sources.
Issue: How should States project emissions from nonroad mobile
sources into the future?
Status: The QMS plans to issue guidance on projections for
nonroad mobile sources,
New Issues
The following issues have recently been raised to EPA and we
are trying to resolve these as soon as possible:
To what extent will EPA accept committal SIP's for the
measures necessary to achieve the 15 percent reduction?
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Will SPA accept committal SIP's for the contingency
measures?
• Can the contingency measures be for NOX as well as (or
instead of) VOC?
vi
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CONTENTS
Page
ADDENDUM iii
LIST OF FIGURES x
LIST OF TABLES x
ABBREVIATIONS AND ACRONYMS xi
EXECUTIVE SUMMARY 1
1 .0 INTRODUCTION 5
1.1 Purpose 7
1 .2 Background 8
2.0 GENERAL ASPECTS OF EMISSIONS PROJECTIONS 13
2.1 Use of Emissions Projections 13
2.2 Rate-of-Progress Emissions Projections 13
2.3 Emissions Factor Adjustments 13
2.4 Actual and Allowable Emissions 14
2.5 Effect of Rule Penetration and Rule Effectiveness . 1 7
3.0 ECONOMIC ACTIVITY AND GROWTH 19
4.0 GROWTH PROJECTIONS 21
.4.1 Growth and Retirement Relationships 21
4.2 Emissions Preprocessor System (EPS) 22
4.3 Economic Growth Analysis System (E-GAS) 22
5.0 CONTROL STRATEGIES FOR VOC'S 25
5.1 Stationary Source Controls 25
Add-on VOC Controls 25
Process Modifications and Substitution 26
5.2 Motor Vehicles 27
Federal Motor Vehicle Control Program (FMVCP) ... 27
RVP Limits 27
Stage II 28
Clean Fuel Fleet Program 20
Reformulated Gasoline .... 31
Inspection and Maintenance 21
On-Board Diagnostic Systems 21
Transportation Control Measures (TCM's) 31
5.3 Other Mobile Sources 23
5.4 Control Strategy Documentation for Stationary
Sources . 33
Group I CTG Documents ." 35
Group II CTG Documents 36
Group III CTG Documents 37
Model RACT Rules 37
vii
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New CTG Documents 38
Non-CTG RACT Rules 40
ACT Documents 40
New Source Performance Standards 41
Section 112 Standards 42
Other Federal Control Measures 43
5.5 Rule Effectiveness Improvements 44
Agency Compliance 45
Source 46
Improvements in Technology 46
Education 46
Rules 46
5.6 Quantification of Rule Effectiveness Improvement
Programs 46
6.0 CONTROL STRATEGY DEVELOPMENT PROJECTIONS 49
6.1 Introduction 49
6.2 Purpose and Elements of Emissions Projections ... 50
6.3 Types of Emissions Projections 51
6.4 Methods for Calculating Point, Area, and Mobile
Source 1996 Projection Year Emissions 51
Point Source Emissions Projections 52
Area Source Emissions Projections 66
Mobile Source Emissions Projections 69
Emissions Preprocessor System (EPS) 70
6.5 Effects of Equipment Replacement and New Source
Requirements 72
6.6 Submitting Projection Year Inventories and
Supporting Data 73
7.0 CONTROL STRATEGIES FOR NOX 75
7.1 Stationary Source Controls 75
7.2 Area Source Controls 76
7.3 Mobile Source Controls 76
8.0 ATTAINMENT DEMONSTRATION 77
8.1 Requirements for Moderate and Above Nonattainment
Areas 77
8.2 Requirements for Serious and Above Nonattainment
Areas 78
8.3 Modeling Considerations 78
Empirical Kinetic Modeling Analysis (EKMA) .... ~8
Urban Airshed Model (UAM) ". . ." 78
3.4 Special Air. Quality Situations 78
Areas Requiring Emissions Reductions in Excess of
15 Percent 78
Areas Requiring Emissions Reductions Less Than
15 Percent . 79
Rural Nonattainment Areas 79
Multi-State Nonattainment Areas 79
International Border Areas 80
Vlll
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9.0 CONTINGENCY MEASURES . . . .
9.1 Marginal Areas . . . . ,
9.2 Moderate and Above Areas
9.3 Serious and Severe Areas
9.4 Nonclassifiable Areas . .
9.5 Examples
REFERENCES
APPENDIX A:
APPENDIX B:
APPENDIX C:
81
81
82
85
86
87
89
DEFINITION OF TERMS
REFERENCES FOR CTG AND ACT DOCUMENTS FOR
STATIONARY VOC SOURCES . . . .
A-'
B-1
BACKGROUND INFORMATION DOCUMENTS FOR STATIONARY
VOC SOURCES SUBJECT TO NEW SOURCE PERFORMANCE
STANDARDS (NSPS) AND NATIONAL EMISSION
STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
C-1
APPENDIX D: CONTROL MEASURES FROM THE AIR QUALITY
MANAGEMENT PLAN FOR THE SOUTH COAST AIR QUALITY
MANAGEMENT DISTRICT OF CALIFORNIA D-1
APPENDIX E: CURRENT ACT DOCUMENTS AND OTHER FEDERAL CONTROL
MEASURES E-1
APPENDIX F: PROCEDURES FOR CALCULATING THE 1996 TARGET
LEVEL OF EMISSIONS AND DISCUSSION OF CONTROL
STRATEGY DEVELOPMENT F-1
APPENDIX G: CHECKLISTS G-1
APPENDIX H: MILESTONE AND ATTAINMENT FAILURES FOR MARGINAL
AND MODERATE OZONE NONATTAINMENT AREAS H-1
APPENDIX I: MODEL MULTI-STATS LETTER 1-1
APPENDIX J: ALTERNATIVE CONTROL TECHNIQUE (ACT) DOCUMENTS,
NEW SOURCE PERFORMANCE STANDARDS (NSPS), AND
TWO SCAQMD AREA SOURCE RULES FOR CONTROLLING
NITROGEN OXIDE (NO*) EMISSIONS J- .
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LIST OF FIGURES
Number Page
Figure 1. Flowchart for rate-of-progress calculations... 9
Figure 2. Flowchart for a moderate ozone nonattainment
area attainment demonstration 11
Figure F-1. Flowchart for example rate-of-progress
calculations F-2
Figure H-1. Marginal area attainment process flowchart. . . H-1
Figure H-2. Moderate area attainment process flowchart. . . H-2
LIST. OF -TABLES
Number Page
A-1. MAJOR SOURCE THRESHOLDS AND MINIMUM EMISSIONS OFFSET
RATIO REQUIREMENTS FOR OZONE NONATTAINMENT AREA
CLASSIFICATIONS A-3
F-1: SUGGESTED FORMAT FOR 15 PERCENT RATE-OF-PROGRESS
CONTROL STRATEGY SUMMARY SUBMITTAL F-12
F-2: SUGGESTED FORMAT FOR ATTAINMENT CONTROL STRATEGY
SUMMARY SUBMITTAL F-13
F-3: SUGGESTED FORMAT FOR CONTINGENCY MEASURE SUBMITTAL . . F-15
F-4: SUMMARY OF EMISSIONS REDUCTIONS FOR THE 15 PERCENT
RATE-OF-PROGRESS PLAN AND THE ATTAINMENT DEMONSTRATION F-16
F-5: 'SUGGESTED FORMAT FOR SUBMITTAL OF RULE
EFFECTIVENESS (RE) IMPROVEMENT MEASURES F-17
F-6: SUGGESTED FORMAT FOR SUBMITTAL OF STATIONARY SOURCE
CONTROL MEASURES FOR THE 15 PERCENT RATE-OF-PROGRESS
PLAN F-17
F-7: SUGGESTED FORMAT FOR SUBMITTAL OF STATIONARY SOURCE
CONTROL MEASURES FOR THE ATTAINMENT DEMONSTRATION . . F-17
F-8: SERIOUS NONATTAINMENT AREA EXAMPLE FOR 15 PERCENT RATE-
OF-PROGRESS CONTROL STRATEGY SUMMARY SUBMITTAL .... F-24
F-9: SUGGESTED FORMAT FOR CONTINGENCY MEASURE SUBMITTAL . . F-25
x
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ABBREVIATIONS AND ACRONYMS
Act
ACT
AFS
AFUE
AIRS
AMS
ANSI
ASTM
APCD
AQMD
ASC
ATM
BACT
BEA
BID
BTU
CAAA
CFR
CO
CTC
CTG
Cu.Ft.
DOE
DOT
E-GAS
EKMA
EPA
EPS
FIP
FMVCP
GACT
gal
HAP
HON
I/M
in. hg
IRS
LADCO
LAER
Ib
Ib/dav
Ib/hr"
LDT
LDV
LEV
* » x f*rn
-'l»~t.Vrf *m
Clean Air Act
Alternative Control Technique
AIRS Facility Subsystem
Annual Fuel Utilization Efficiency
Aerometric Information Retrieval System
Area and Mobile Source Subsystem
American National Standards Institute
American Society for Testing and Materials
Air Pollution Control District
Air Quality Management District
Area Source Category Code
Atmosphere
Best Available Control Technology
Bureau of Economic Analysis
Background Information Document
British Thermal Units
1990 Clean Air Act Amendments
Code of Federal Regulations
Carbon monoxide
Control Technology Center
Control Technique Guidelines
Cubic Foot
Department of Energy
Department of Transportation
Economic Growth Analysis System
Empirical Kinetic Modeling Analysis
U.S. Environmental Protection Agency
Emissions Preprocessor System
Federal Implementation Plan
Federal Motor Vehicle Control Program
Generally Available Control Technology
GalIon(s)
Hazardous Air Pollutant
Hazardous Organic NESHAP
Inspection and Maintenance
Inches of Mercury
Internal Revenue Service
Lake Michigan Air Directors Consortium
Lowest Achievable Emissions Rate
Pound(s ?
Pounds per day
Pounds per hour
Light-duty trucks
Light-duty vehicles
Lev:-emission vehicle
ortr.easr states rcr Coordinate1
•ianace-en-
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NESHAP
NOX
NSPS
NSR
NTIS
OAQPS
ppm
psi
RACT
RCRA
RE
RFP
rpm
RVP
SAS
SCAQMD
SIC
SIP
SOCMI
SSCD
TCM
tpy
TSDF
UAM
VMT
VOC
National Emission Standard for Hazardous Air
Pollutants
Oxides of nitrogen
New Source Performance Standard
New Source Review
National Technical Information Service
Office of Air Quality Planning and Standards of
EPA
Parts per million
Pounds per square inch
Reasonably Available Control Technology
Resource Conservation and Recovery Act
Rule Effectiveness
Reasonable Further Progress
Revolutions per minute
Reid Vapor Pressure
Statistical Analysis System
South Coast Air Quality Management District
Standard Industrial Classification
State Implementation Plan
Synthetic Organic Chemicals Manufacturing Industry
Stationary Source Compliance Division of EPA's
Office of Air Quality Planning and Standards
Transportation Control Measures
Tons per year
Hazardous Waste Treatment, Storage, and Disposal
Facility
Urban Airshed Model
Vehicle Miles Traveled
Volatile Organic Compound
Xli
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EXECUTIVE SUMMARY
Section 182(b)(1) of the Clean Air Act (Act) requires all
ozone nonattainment areas classified as moderate and above to
submit a State implementation plan (SIP) revision by November 15,
1993, which describes, in part, how the areas will achieve an
actual volatile organic compound (VO.C) emissions reduction of at
least 15 percent during the first 6 years after enactment of the
Clean Air Act Amendments of 1990 (CAAA) (i.e., up to November 15,
1996). In addition, the SIP revision must describe how any
growth in emissions from 1990 through 1996 will be fully offset.
The portion of the SIP revision that illustrates the plan for the
achievement of these emissions reductions is subsequently defined
in .this document as the "rate-of-progress plan."
It is important to note that section 182(b)(1) also requires
the SIP for moderate areas to provide for reductions in VOC and
nitrogen oxides (NOX) emissions "as necessary to attain the
national primary ambient air quality standard for ozone" by
November 15, 1996. This requirement can be met through the use
of EPA-approved modeling techniques and the adoption of any
additional control measures beyond those needed to meet the
15 percent emissions reduction requirements. States with
intrastate moderate ozone nonattainment areas will generally be
required to submit attainment demonstrations with their SIP
revisions due by November 15, 1993 [such areas choosing to use
the Urban Airshed Model (UAM) to prepare their attainment
demonstrations will be allowed to submit attainment
demonstrations by November 15, 1994]. States choosing to run UAM
for their intrastate moderate areas must submit by November 15,
1993, their rate7of-progress plan and a committal SIP addressing
the attainment demonstration. The committal SIP subject to a
section 110(k)(4) approval would include, at a minimum, evidence
that grid modeling is well under way and a commitment, with
schedule, to complete the modeling and submit it as a SIP
revision by November 1994. The completed attainment
demonstration would include any additional controls needed for
attainment.
This guidance document focuses on the procedures for
developing 1996 projected emissions inventories and control
measures which moderate and above ozone nonattainmenr areas
include in their rate-of-progress clans. The document: ore-vices
-echnical guidance to support the policy presented in the
"General Preamble: Implementation of Title I of the CAAA of
1990" (57 FR 13498). States are asked to submit their draft "596
projected emissions inventories and control measures to EPA
May 1993. States must submit their fully adopted rate-of-
progress plans .to SPA by November 1993. Moderate ozone
nonattainment areas not using UAM must include an attainment
demonstration in their fully adopted rate-of-progress plans.
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This document- provides guidance to the States for
calculating the VOC emissions reductions and for developing the
control measures necessary to meet the 15 percent VOC emissions
reduction requirements, net of growth, by November 1996.
Calculation of the 15 percent VOC emissions reduction, net of
growth, includes the calculation of the following three
components:
The 15 percent VOC emissions reduction from the 1990
adjusted base year emissions inventory.
The 1996 target level of emissions.
Emissions reductions needed to fully offset emissions
growth from 1990 through 1996.
In October of 1992, the U.S. Environmental Protection Agency
(EPA) issued a document entitled Guidance on the Adjusted Base
Year Emissions Inventory and the 1996 Target for the 15 Percent
Rate-of-Progress Plans. (See reference 1.) The document provides
detailed guidance for calculating the 15 percent VOC emissions
reduction from the 1990 adjusted base year emissions inventory,
and the 1996 target level of emissions. The guidance provided in
the October 1992 document should be reviewed along with the
guidance in this document when preparing a rate-of-progress plan.
The rate-of-progress plan must account for the effects of
growth experienced in a nonattainment area from 1990 to 1996.
One purpose of this document is to provide guidance on the use of
equations for projecting 1990 base year emissions to 1996. The
document describes how growth factors, emissions reductions
associated with regulations, rule effectiveness (RE), and rule
penetration should be used in the equations. Guidance is also
provided for determining whether projections should be based on
actual versus allowable emissions. The information sources for
developing growth factors or indicators that could be used as
part of the preparation of the 1996 projected emissions
inventories are also discussed. Several examples for calculating
15 percent VOC emissions reduction requirements, net of growth,
are provided for different ozone nonattainment area
classifications.
A icey component of the rate-of-progress plan is the control
measures that the State plans to adopt and implement to reduce
VOC emissions to meet the 15 percent VOC emissions reduction
requirements, net of growth, by November 1996. One of the
purposes of this document is to provide information concerning
the types of control technologies and strategies upon which
control measures can be based to control VOC and NOX emissions
from point, area, and mobile sources. This document summarizes
past and ongoing work by EPA in preparing Control Technique
Guideline (CTG), Alternative Control Technique (ACT), and
2.
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background information documents for specific industrial sources
or processes. It also presents information on existing and new
Federal regulatory programs for VOC and NOX sources. The broad
range of mobile source control strategies, from vapor recovery to
transportation control measures (TCM's), is also discussed.
A sample checklist is also provided to aid States in a step-by-
step review of their rate-of-progress plans to ensure that they
contain all of the necessary components required for approval by
EPA.
This document also discusses the requirements for an
attainment demonstration for marginal and moderate ozone
nonattainment areas, and presents the models involved in making
this demonstration. Furthermore, this document presents the
implications of attainment and milestone failures for marginal
and moderate ozone nonattainment areas. In addition, this
document describes the requirements for contingency measures that
must be included in the rate-of-progress plans for moderate and
above ozone nonattainment areas, and provides examples of
possible contingency measures.
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1.0 INTRODUCTION
Section 182(b)(1) of the Act requires all ozone
nonattainment areas classified as moderate and above to submit a
SIP revision by November 15, 1993, which describes, in part, how
the areas will achieve an actual VOC emissions reduction of at
least 15 percent during the first 6 years after enactment of the
CAAA (i.e., up to November 15, 1996). In addition, the SIP must
describe how any growth in emissions from 1990 through 1996 will
be fully offset. Emissions and emissions reductions shall be
calculated on a typical weekday basis for the "peak" 3-month
ozone period (generally June through August) . The 15 percent VOC
emissions reduction, net of growth, required by November 15, 1996
is defined within this document as "rate of progress."1
Furthermore, the portion of the SIP revision that illustrates the
plan for the achievement of the emissions reductions is
subsequently defined in this document as the "rate-of-progress
plan."
It is important to note that section 1B2(b)(1) also requires
the SIP for moderate areas to provide for reductions in VOC and
NOX emissions "as necessary to attain the national primary
ambient air quality standard for ozone" by November 15, 1996.
This requirement can be met through the use of EPA-approved
modeling techniques and the adoption of any additional control
measures beyond those needed to meet the 15 percent emissions
reduction requirements. States with intrastate moderate ozone
nonattainment areas will generally be required to submit
attainment demonstrations with their SIP revisions due by
November 15, 1993 (such areas choosing to use UAM to prepare
their attainment demonstrations will be allowed to submit
attainment demonstrations by November 15, 1994). States choosing
to run UAM for their intrastate moderate areas must submit by
EPA recognizes that the Act terms, for both the 15 percent
VOC emissions reduction requirement of section 182(b)(1) and the
section 182(c)(2)(B) requirement for 3 percent per year VOC
emissions reductions averaged over each consecutive 3-year period
from November 15, 1996 until the attainment-date, as reasonable
further progress (KFP) requirements. However, because the Acr
requires- SIP revisions for the 15 percent reduction to be
submitted in 1993 and. SIP revisions for the 3 percent per year
reductions to be submitted in 1994, EPA believes that it would be
clearer, within the context of both the 15 percent rate-of-
progress plan and post-1996 rate-of-progress plan guidance
documents that EPA is producing, to create distinct labels for
these two seemingly similar reductions. The 1994 SIP revisions
describing the'requirement for 3 percent VOC emissions reductions
averaged over each consecutive 3-year period from November 1 5,
1996 until the attainment date, constitute the "post-1996 rate-
of -progress plan."
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November 15, 1993,, their rate-of-progress plan and a committal
SIP addressing the attainment demonstration. The committal SIP
subject to a section 110(k)(4) approval would include, at a
minimum, evidence that grid modeling is well under way and a
commitment, with schedule, to complete the modeling and submit it
as a SIP revision by November 1994. The completed attainment
demonstration would include any additional controls needed for
attainment.
Section 182(c)(2) requires all ozone nonattainment areas
classified as serious and above to submit a SIP revision by
November 15, 1994 which describes, in part, how each area will
achieve additional VOC emissions reductions of 3 percent per year
averaged over each consecutive 3-year period from November 15,
1996 until the area's attainment date. It is important to note
that section 182(c) (2)(C) allows for actual NOX emissions
reductions (exceeding growth) that occur after the base year of
1990 to be used to meet post-1996 emissions reduction
requirements for ozone nonattainment areas classified as serious
and above, provided that such NOX reductions meet the criteria
outlined in forthcoming substitution guidance. The portion of
the SIP revision (due in 1994) that illustrates the plan for the
achievement of these post-1996 reductions in VOC or NOX is
subsequently defined in this document as the "post-1996 rate-of-
progress plan." This plan must also contain an attainment
demonstration based on photochemical grid modeling. The EPA will
distribute a separate guidance document on the development of the
post-1996 rate-of-progress plan in early to mid-1993.
Demonstrating achievement of the 15 percent VOC emissions
reductions by November 15, 1996, and then subsequently
demonstrating achievement of the 3 percent per year VOC emissions
reductions averaged over each consecutive 3-year period from
November 15, 1996 until the attainment date, are termed milestone
demonstrations. Achievement of the milestones must be
demonstrated within 90 days of the milestone date (e.g. , the
15 percent VOC emissions reductions must be demonstrated by
February 13, 1997). The EPA is currently developing a rule which
will describe the information and analysis required for the
milestone demonstrations. The rule is scheduled for promulgation
in the summer of 1994. The rule will also address summary data
needs, detailed reporting requirements, and consequences of
submitting an inadequate demonstration (in terms of
documentation) as well as consequences of failure to demons tr at a
che 15 percent VOC emissions reduction requirements, net of
growth.
Section 182(a) (3) (A) requires the States to submit periodic
inventories starting 3 years after submission of the base year
inventory required by section 182 (a) (1), and every 3 years
thereafter until the area is redesignated to attainment. The EPA
recommends that-States synchronize their schedules for developing
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the periodic inventories so that the second periodic inventory
(which would be due no later than November 15, 1998) is submitted
by February 13, 1997 and addresses emissions in 1996. By
accelerating preparation and submittal of the 1996 periodic
inventory, the milestone demonstration that' is due for serious
and above areas by February 13, 1997 can be based on this
periodic inventory. If similarly accelerated, future periodic
inventories would then also coincide with subsequent milestone
demonstrations. The periodic inventory is to be based on actual
emissions and will cover VOC, NOX, and carbon monoxide (CO)
emissions sources. Like the base year inventory, the periodic
inventory is to be determined using typical peak ozone season
weekday emissions.
1.1 Purpose
This document provides guidance on the procedures for
developing 1996 projected emissions inventories and control
measures which moderate and above ozone nonattainment areas must
include in their rate-of-progress plans. These elements of the
rate-of-progress plan will be due in draft form to EPA by May 15,
1993. The fully adopted rate-of-progress plan is then due by
November 15, 1993. The information provided in this document
contains references to additional in-depth information.
The rate-of-progress plan must account for the effects of
growth experienced in a nonattainment area from 1990 to 1996.
One purpose of this document is to provide guidance on the use of
equations for projecting 1990 base year emissions to 1996. The
document describes how growth factors, emissions reductions
associated with regulations, RE, and rule penetration should be
used in the equations. Guidance is also provided for determining
whether projections should be based on actual versus allowable
emissions. The information sources for developing growth factors
or indicators that could be used as part of the preparation of
the 1996 projected emissions inventories are also discussed.
A key component of the rate-of-progress plan (due to EPA by
November 15, 1993) is the control measures that the State plans
to adopt and implement to reduce VOC emissions to meet the
15 percent VOC emissions reductions requirements, net of growth,
by November 1996. One of the purposes of this document is ~c
provide information concerning the types of control -achnoic'cr^is
and strategies upon which control measures can be cased cc
control VOC and NOX emissions from point, area, and mobile
sources. This document summarizes past and ongoing work bv EPA
in preparing CTG, ACT, and background information documents for
specific industrial sources or processes. It also presents
information on existing and new Federal regulatory crcgrams for
VOC and NOX sources.. The broad range of mobile source 'control
strategies, from vapor recovery to TCM's, is also discussed.
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1.2 Background
The rate-of-progress plan must include documentation of base
year emissions inventories, growth factors, -projected emissions
inventories, and control measures and associated emissions
reductions to demonstrate how a nonattainment area will achieve a
15 percent VOC emissions reduction, net of growth, by November
1996.2 Calculation of the 15 percent VOC emissions reduction,
net of growth, includes the calculation of the following three
components:
The 15 percent VOC emissions reduction from the 1990
adjusted base year emissions inventory.
The 1996 target level of emissions.
Emissions reductions needed to fully offset emissions
growth from 1990 through 1996.
Figure 1 presents a flowchart of the steps involved in
calculating the required emissions reductions and the 1996 target
level of emissions. The 15 percent VOC emissions reduction must
be calculated from the 1990 adjusted base year emissions
inventory. The 1990 adjusted base year emissions inventory must
exclude the following:
• Biogenic emissions.
Emissions associated with anthropogenic sources located
outside of a nonattainment area's boundaries.
Emissions reductions that would occur by 1996 as the
result of a Federal motor vehicle control program
(FMVCP) promulgated by January 1, 1990.
• Emissions reductions that would occur by 1996 as the
result of the Reid vapor pressure (RVP) control program
(55 FR 23666, June 11, 1990).
Emissions reductions associated with corrections to a -
nonattainment area's reasonably available control technology
(RACT) rules and inspection and maintenance (I/M) program, and
post-1990 emissions, reductions associated with, the FMVC? and RVP
controls are added to the 15 percent VOC emissions reduction, co
calculate total expected reductions by 1996. Total expected
reductions by 1996 are then subtracted from the 1990 rate-of-
Section 182(b) has provisions for obtaining less that a
15 percent VOC emissions reduction, if certain stringent
requirements are met. See section 8.4 of this document.
8
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FINAL BASE
YEAR (1990)
INVENTORY*
1990 RATE OF
PROGRESS
BASE YEAR
INVENTORY
SUBTRACT
BIOGENICS,
EMISSIONS OUTSIDE
NONATTAIHMENT AREA
ADD
GROWTH
1990
ADJUSTED
BASE YEAR
INVENTORY
multiply
by 0.-15
EMISSION
REDUCTION
REQUIRED BY
1996
SUBTRACT
FMVCP
RVP REDUCTIONS
B
A - B
1996 ESTIMATED
EMISSIONS
(ANTHROPOGENIC)
D
C - D
TOTAL
EXPECTED
REDUCTIONS
BY 1996
TARGET LEVEL
FOR 1996
REDUCTIONS NEEDS BY
1996 TO ACHIEVE 15
PERCENT NET OF
GROWTH
ADD
REDUCTIONS FROM:
FMVCP/RVP .
RACT RULE CORRECTIONS
I/M CORRECTIONS
DOES NOT INCLUDE' ML' -ENACTMENT BANKED EMISSION CREDIT
Figure I. Flowchart for rate-of-progress calculations
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progress emissions inventory to calculate the 1996 target level
of emissions. The 1996 target level of emissions is then
subtracted from the 1996 projected emissions inventory to include
growth in the total emissions reductions needed to achieve the
1996 target level of emissions. In October of 1992, EPA issued a
document entitled Guidance on the Adjusted Base Year Emissions
Inventory and the 1996 Target for the 15 Percent Rate-of-Progress
Plans. (See reference 1.) The document provides detailed
guidance for calculating the 15 percent VOC emissions reduction
from the 1990 adjusted base year emissions inventory, and the
1996 target level of emissions. The guidance provided in the
October 1992 document should be reviewed along with the guidance
in this document when preparing a rate-of-progress plan.
The 1990 base year inventory emissions are reported on an
annual and seasonal basis. For determination of the 15 percent
VOC emissions reduction, net of growth, emissions are based on
typical ozone season weekday emissions. For the base year
inventory, these emissions are measured for a typical weekday
during .the 1990 peak ozone season. The peak ozone season is the
contiguous 3-month period for which the highest ozone exceedance
days have occurred in the previous 3 to 4 years. The EPA's focus
on typical ozone season weekday VOC emissions [an interpretation
of the definition in section 182(b)(1)(B) of baseline actual
emissions during the "calendar year" of enactment] is consistent
with prior EPA guidance. This stems from the fact that the ozone
national ambient air quality standard (NAAQS) is an hourly
standard that is generally violated during ozone season weekdays
when conditions are conducive to ozone formation. These ozone
seasons are typically the summer months.
Moderate ozone nonattainment areas must also include in
their rate-of-progress plans a demonstration that the ozone NAAQS
will be attained by November 1996. Figure 2 presents a flowchart
of the components for developing the control measures that form
the basis of the rate-of-progress plan for an attainment
demonstration. To determine achievement of the 15 percent VOC
emissions reduction, net of growth, the 1990 rate-of-progress
emissions must be subtracted from the 1996 projection year
emissions for VOC. Failure to achieve the 15 percent VOC
emissions reduction, net of growth, will require application of
additional control measures to the 1996 projection year emissions
for VOC. If, however, the 15 percent reduction, net of growth,
is confirmed by this calculation, the next step is to add
biogenic emissions and emissions in the modeling domain but
outside the nonattainment area into the 1996 projection year
inventory, and model the inventory using the empirical kinetic
modeling analysis (EKMA). In addition, NOX emissions must also
be included in an attainment demonstration modeling analysis.
Therefore, States will need to develop a 1990 base year and rate-
of-progress emissions inventory for NOX, and then prepare a
projected NOX emissions inventory for 1996 for modeling. Those
10
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Effect ot
Current
Regulations
1990
Rate-of-Progress
Base Year Inventory
for VOC
calculate.
Apply More VOC
Control Measures
No
Effect of
Current
Regulations
1990 Base Year
Inventory for
NOx Emissions
Projection
Factors
1996 Projection Year
Emissions Inventory
for VOC
i
Add Biogenic
Emissions and
Emissions
Outside the
Nonattainment
Area
1996 Target Level
of Emissions
Yes
i
Reduction Needs by 1996
to Achieve 15 Percent
Net of Growth
Projection
Factors
1996 Projection
Year Emissions
Inventory for
NOx
Perform EKMA
Modeling Analysis
Achieve Attainment
Demonstration?
Recalculate VOC and
NOx Emissions
Inventories for 1996
No
Yes
Apply More VOC
and/or NOx
Control Measures
Draft and Implement
Regulations to
Incorporate Emissions
Reductions
Figure 2. Flowchart for a moderate ozone nonattainment area attainment demonstration
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States that also plan to account for CO emissions in their EKMA
modeling should also provide documentation for a projected CO
emissions inventory for 1996 in their SIP submittals.
Moderate ozone nonattainment areas are generally expected to
be able to demonstrate attainment of the ozone NAAQS by November
1996 if they comply with the 15 percent VOC emissions reduction,
net of growth, requirements. If the results of the modeling
analysis demonstrate attainment, the State and local agencies
should proceed to draft regulations for the control measures
needed to achieve the necessary emissions reductions. However,
if the results of the modeling analysis do not demonstrate
attainment, additional control measures must be applied to the
1996 projection year emissions to achieve the reductions in VOC
and/or NOX needed to demonstrate attainment.
Serious and above ozone nonattainment areas will .be required
to submit a post-1996 rate-of-progress plan to EPA by
November 15, 1994 which describes, in part, how each area will
achieve additional VOC emissions reductions of 3 percent per year
averaged over each consecutive 3-year period from November 15,
1996 until the area's attainment date. The plan must also
contain an attainment demonstration based on photochemical grid
modeling. The EPA will distribute a separate guidance document
on the -development of the post-1996 rate-of-progress plan in
early 1993. It is important to note that section 182(c)(2)(C)
allows for actual NOX emissions reductions (exceeding growth)
that occur after the base year of 1990 to be used to meet post-
1996 emissions reduction requirements, provided that such NOX
reductions meet the criteria outlined in forthcoming substitution
guidance. Therefore, it is recommended that States track the
actual NOX emissions reductions occurring between 1990 and 1996.
More specific guidance regarding NOX substitutions is currently
under development by EPA. The substitution guidance is planned
for release in the fall of 1993.
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2.0 GENERAL ASPECTS OF EMISSIONS PROJECTIONS
2.1 Use of Emissions Projections
Emissions projections for sources within an air basin are
needed—in conjunction with ambient modeling analyses—to
determine if the area will attain the NAAQS by the future
attainment date. Emissions projections are also needed to
determine if the rate-of-progress requirements in the CAAA will
be met. See section 6, "Control Strategy Development
Projections" for a discussion of the methods for calculating the
1996 projected inventory-
2.2 Rate-of-Progress Emissions Projections
The following reviews the discussion in Guidance on the
Adjusted Base Year Emissions Inventory and the 1996 Target for
the 15 Percent Rate-of-Progress Plans. (See reference 1.) The
reader should be familiar with that document in order to benefit
from the subsequent discussion.
The rate-of-progress plan requires the preparation of
several emissions inventories:
• 1990 base year inventory.
1990 rate-of-progress base year inventory.
• 1990 adjusted base year inventory.
1996 target level of emissions.
A detailed discussion of the calculation of these
inventories is provided in the EPA document referenced above.
Appendix F of this document expands on the information provided
in the above referenced document by describing the projection of
emissions growth between 1990 and 1996, and the calculation of
the total amount of emissions reductions needed by 1996.
Additionally, Appendix F presents -examples of hypothetical-
control strategies.
2.3 Emissions Factor Adjustments
Emissions factors, as well as inventory calculation
methodologies, are continually being revised and improved based
on field and laboratory measurements. The States should maintain
close coordination with the appropriate EPA Regional Office as
they prepare the base year and other emissions inventories to
insure that these inventories reflect current EPA guidance. If.
the emissions factors or methodologies change significantly, SPA
may advise the States to correct their base year emissions
inventories to reflect these changes.
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If emissions factors or methodologies change significantly
before November 15, 1993—the due date for the 15 percent rate-
of-progress plan—EPA may require the States to make corrections
to the base year emissions inventory and to the other
inventories/targets associated with the rate-of-progress plan
process.
The following guidance is from the General Preamble for
Title I for emissions factor and methodology changes occurring
after November 15, 1993 (which will not affect moderate
nonattainment areas, but has the potential to affect serious and
above nonattainment areas): If, however, changes occur after the
15 percent demonstration is submitted but before November 15,
1996, then the States would not have to make corrections for
purposes of reconciling attainment of the 15 percent milestone.
Serious areas should also refer to the General Preamble
discussion on the rate-of-progress plan demonstration [section
III.A.4(f); 57 FR 13516-8] for guidance on changes that might
occur before November 15, 1994, and the impact on the 1990 rate-
of-progress plan demonstration.
2.4 Actual and Allowable Emissions
Actual emissions from a source are the emissions based on
the source's actual operating hours, production rates, and
control equipment for the processes carried out at the source.
Actual emissions take into consideration instances when the
operations are consistent and when deviations from normal
operating conditions occur. Allowable emissions are a regulatory
element of the operating permit granted to.the source or element
of the applicable regulation which represents a regulatory limit
on emissions that can be emitted from the source.
By permit provision, the actual emissions cannot exceed the
allowable emissions permitted by the regulatory agencies except
under very narrow conditions, such as upsets at the source. The
value of the allowable emissions for a source is a regulatory
element important in the inspection and enforcement programs and,
•like a speed limit on the highway, is a gauge for the enforcement
agencies to determine compliance by the source. Allowable
emissions are also an accounting tool for the regulatory agencies
in their effort to balance industrial- activity within overall
emissions targets for a particular air basin, to insure compliance
with the NAAQS or other statutory requirements. As discussed
below, the projections for the rate-of-progress plan will
generally be based on allowable emissions limits (the enforceable
emissions rate multiplied by the expected activity level) for the
sources within a nonattainment area whose allowable emissions
will be reduced to meet the progress requirements.
14
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The following examples illustrate how the baseline for
future trading should be determined for a chemical manufacturing
process under four scenarios.
• Example 1: Source currently uncontrolled that will
remain uncontrolled.
In this example, the baseline for future trading is
calculated based on actual emissions. For example, if the
source is currently emitting 150 pounds per day (Ib/day) in
1990 with no controls in the base year and no controls
required in the projection year, future baseline emissions
are determined by applying the applicable growth factor
[Bureau of Economic Analysis (BEA) or Economic Growth
Analysis System (E-GAS) growth factors are recommended].
Assuming that the growth factor for 1996 for this chemical
manufacturer is 1.2, the baseline for future trading is
180 Ib/day.
• Example 2: Source currently uncontrolled that will be
controlled.
In this example, the baseline for future trading is
calculated based on allowable emissions. If the chemical
manufacturer in Example 1 is required to install a control
device reducing emissions by 75 percent (with a RE of
80 percent), future baseline emissions for trading are
determined by applying the applicable growth factor (1.2)
.plus the future control efficiency- Future uncontrolled
emissions would be 180 Ib/day. Future allowable emissions,
the baseline for future trading, are calculated by applying
the control efficiency to the uncontrolled future level.
This results in a baseline of 72 Ib/day for future trading.
• Example 3: Source currently controlled that will not
be subject to additional control.
In this example, the baseline for future trading is
calculated based on actual emissions. For example, if the
chemical manufacturer in Example 1 currently has a control
device installed reducing emissions by 50 percent (with an
30 percent RE! , base -/ear emissions would be 90 Ib/day. The
baseline for future trading would be calculated by applying
the growth factor of 1.2 which results in 108 Ib/day as the
baseline for future trading.
In this example, the projection based on allowable
emissions'may be higher than the projection based on actual
emissions. For example, if the regulatory or permit
requirement for this source mandated an overall reduction of
40 percent (with an 80 percent RE), emissions projected
based on allowable conditions would be calculated bv
16
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It is important to note that the projections are not full
allowable emissions (i.e., the allowable emissions limit
multiplied by the maximum theoretical activity level). The
purpose for using the allowable emissions limit in the
projections is to ensure that the control strategy will meet the
rate-of-progress requirement if all sources do start operating at
their allowable emissions limit.
The purpose of projecting the emissions inventories into the
future is not solely to predict what is likely to happen, but
rather to test the ability of the regulations in the control
strategy to meet RFP goals and attainment and maintenance of the
ozone NAAQS. To adequately test the control strategy, EPA
believes it is necessary to project on the basis of what sources
are allowed to do and to" evaluate the resulting air quality-
However, EPA also recognizes that 1) there are time constraints
related to assimilating the allowable emissions limit data into a
usable format and 2) the assumption that all sources in a
nonattainment area will operate at their allowable emissions
limit may not be valid.
Therefore, as an alternative to using allowable emissions
for projections, EPA believes it is appropriate to use actual
emissions in certain circumstances. For sources or source
categories that are currently subject to a regulation and the
State does not anticipate subjecting the source(s) to additional
regulation, the projected emissions may be based on actual
emissions. In addition, for sources or source categories that
are currently unregulated and are not expected to be subj ect to
future regulations, the projected emissions may be based on
actual emissions. For all other sources, i.e., sources that are
expected to be subject to additional regulation, the projections
should be based on the new allowable emissions (including RE) as
defined above. Where a State chooses to project emissions using
a different approach than described above, the State should get
the approval of the appropriate EPA Regional Office before
proceeding. In addition, the State must provide complete
documentation of the approach and documentation and technical
justification of any assumptions.
It is important to note that, regardless of whether the
projected emissions are based on actual or allowable emissions,
future emissions trades, including offsets, must be based on
assumptions that are consistent with the projected inventory. In
other words, if the projected emissions from a source are based
on actual emissions, that source must use actual emissions in
determining the amount of credit available for offsets or
emissions trading. The SPA's Emissions Trading-Policy Statement
(51 FR 43814, December 4, 1986) provides EPA's: policy on
emissions trading. Also, the proposed rules for economic
incentive programs (58 FR T1110, February 23, 1993) will provide
additional guidance in this area.
15
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substituting the required 40 percent efficiency for the
50 percent control device efficiency. Projection year
allowable emissions would be 122 Ib/day. The baseline for
future trading must be based on the actual emissions
projection to ensure that the reductions are real.
Example 4: Sources currently controlled that will be
subject to additional control.
In this example, the baseline for future trading is
calculated based on allowable emissions. If the chemical
manufacturer in Example 3 is required to install additional
control with an overall efficiency of 90 percent (with an
80 percent RE), the baseline for future trading is
calculated by applying the growth factor (1.2) to the base
year emissions and adjusting the control level to reflect
the 90 percent required control. In this example, the
baseline for future trading would be 50 Ib/day.
Because the basis of allowing credit is of major concern to
sources in the State, the State must be certain to provide
adequate notice (e.g., during the public hearing) to the affected
sources as to what the baseline for future emissions trades will
be. This is of particular concern where the projected emissions
are based on actual rather than allowable emissions.
Using this approach, EPA has made concessions in two ways.
First, the projections will be based on expected activity level,
not maximum operating capacity. Second, EPA is not requiring
that the projections be based on allowable emissions limits for
all sources, only sources for which allowable emissions are
expected to change.
The States will have the responsibility to adequately
document which projection methodology is used so that EPA will
have access -c trie dccunentaticn. during zhe SIP rev^ev crccsss
and for subsequent review of emissions reduction credits.
2.5 Effect of Rule Penetration and Rule Effectiveness
-------
regulatory requirements. On the other hand, an overestimation of
these factors can lead to continuing violations of the NAAQS at
monitoring stations even though the SIP provides a demonstration
of compliance. The purpose of RE is to provide a better estimate
of the actual emissions in recognition of the fact that it is
impossible to ensure 100 percent effectiveness of the rules
(i.e., meeting the rule target with 100 percent of the sources
100 percent of the time). See section 5.6 of this document for a
discussion of RE improvements.
18
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3.0 ECONOMIC ACTIVITY AND GROWTH
Economic activity is a factor influencing the level and form
of anthropogenic pollution. Economic activity levels are
determined by the forces of supply and demand. Emissions are
determined by specific production processes (e.g./ flexographic
printing or rotogravure printing), inputs to those processes
(e.g. low solvent inks vs. high solvent inks), and the levels of
output [e.g., gallons (gal) of ink used per unit time]. If no
change in the utilization of those processes and no additional
processes are anticipated, the relationship of output to
emissions seen in the past should be projected to occur in the
future. If, however, EPA expects utilization rates to change,
new processes to be adopted, or input changes to occur, the
relationship between output level and emissions seen in the past
may not be an appropriate assumption for projecting future
emissions.
Note that growth factors are not included in the
calculations of the 1990 adjusted base year inventory or the 1996
target. Growth factors are needed, however, for the 15 percent
VOC emissions reduction demonstration as.part of the rate-of-
progress plan that is due on November 15, 1993 for all moderate
and above nonattainment areas. Growth factors are also needed
for the attainment demonstration due on November 15, 1993 for
moderate ozone nonattainment areas using EKMA and on November 15,
1994 for moderate ozone nonattainment areas using UAM and all
serious and above ozone nonattainment areas. States should
include the draft rate-of-progress growth factors in both
computer and written formats to EPA by November 15, 1992. Two
sets of growth factors should be provided. One set is used to
project the growth between 1990 and 1996 for rate-of-progress
plan purposes, and the other set is used to project growth
through the year of attainment for the attainment demonstration
for modeling purposes. (These sets are basically the same for
moderate areas, which must demonstrate attainment by 1996.) The
computer format for growth factor submittals is presented in
Table 1 of the document entitled Guidance on the Adjusted Base
Year Emissions Inventory and the 1996 Target for the 15 Percent
Rate-of-Progress Plans. (See reference 1.) The following should
also be included with the list of growth factors: State
identification (ID), county ID, zone code (if the growth factor
is to be used for a specific zone within a county) , source
category code [either Standard Industrial Classification (SIC),
AFS source classification code, or Area and Mobile Source
Subsystem (AMS) source category code], growth factor reference
[e.g., BEA, plant-supplied], and control information discussed
below. Any information not contained in the spreadsheet file
(e.g., which agency submitted, the "growth information and
assumptions made in preparing the information) should be
submitted on paper accompanying the PC disk.
19
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Sources of information and guidance on economic activity
projections include the BEA's Regional Projections to 2040 (see
references 2, 3, and 4), and EPA's Procedures for Preparing
Emissions Projections. (See reference 5.) This last document
discusses the development of regional projections using BEA data
and lists the 57 industrial categories for which BEA data are
available (pages 17-23). In those cases where a State may have
better information than the BEA forecast (e.g., the State has
specific information regarding planned expansion at a point
source resulting in an emissions increase), States should use
their own growth factors.
20
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4.0 GROWTH PROJECTIONS
This section presents information for determining growth
factors for use in projecting" VOC and NOX emissions inventories.
This section discusses growth and retirement relationships, EPA's
Emissions Preprocessor System (EPS), and E-GAS. Moderate ozone
nonattainment areas that will rely on EKMA modeling to
demonstrate attainment with the ozone NAAQS will need to provide
documentation for projected emissions inventories for 1996 for
both VOC and NOX in their SIP submittals. Those States that plan
to account for CO emissions in their EKMA modeling should also
provide documentation for a projected CO emissions inventory for
1996 in their SIP submittals. Therefore, States that plan to
account for VOC/ NOX, and CO emissions in their EKMA modeling
will need to develop growth and retirement factors for VOC, NOX/
and CO emissions.
4.1 Growth and Retirement Relationships
Industry growth and the addition of new plants is often
accompanied by the retirement of aging facilities. It is
important to account for retirement rates when calculating
projected emissions and future control levels for two reasons.
First, projections can only be made when net growth after
retirement is determined. Second, controls are often different
for new sources and existing sources of VOC.
There are several sources of retirement rates for segments
of industry. One that is generally available is the latest
version of the Internal Revenue Service (IRS) Publication 534,
Depreciation (used for the preparation of income tax returns) .
(See reference 6.) In this publication, the IRS develops
retirement rates from its depreciation guidelines, in which
annual retirement rates are estimated as the reciprocal of the
depreciation period in years multiplied by 2. These retirement
rates may be combined with growth rates to determine projected
emissions. (Note that the BEA projected earnings data are
calculated net of plant retirements.- That is, retirement of
existing sources has been taken into account.) The EPA
publication entitled A Projection Methodology for Future State
Level Volatile Organic Compound Emissions (VOC) from Stat-onar--
Sources Version 2.0 (see reference 7.), also provides IRS
retirement races and discusses their application for projecting
VOC emissions. However, the latest version of the IRS
Publication 534 should be consulted in case the IRS has changed
the basis for depreciation rates from which retirement ratas are
calculated.
Growth and- retirement rates also affect the emissions levels
due to different control requirements for new and existing
sources. Older facilities will often have less stringent control
standards than newer facilities. As older facilities are
21
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retired, any new facilities that come on-line may replace the
output, but with substantially lower emissions. Therefore,
different retirement rate and control requirement assumptions
must be made for new and existing sources. 'Often, the emissions
factor for future years will be substantially different from the
base year due to a change in an operating procedure, spurred by
growth and retirement, for an industry segment.
4.2 Emissions Preprocessor System (EPS)
The EPA has upgraded the EPS to more effectively incorporate
future growth and controls. Projections will be made on the
county-level by source category. An accompanying software
utility will allow better growth data to be developed from BEA
regional projections. Other enhancements have made EPS more
flexible and easier to operate.
The revised version of EPS (EPS 2.0, July 1992) is a FORTRAN
based system, with a graphics option programmed in the
Statistical Analysis System (SAS) language. (See reference 8.)
Projection factors, which represent estimated changes in
activity levels between the base and projection years, are
assigned based on the first two digits of the SIC code for point
sources and the first four digits of the area source category
(ASC) code for area and mobile sources. The EPS 2.0 design
allows for projections of actual and/or allowable emissions. The
system recognizes four types of allowable emissions inventories:
(1) allowables based on activity level limits; (2) allowables
based on emissions limits; (3) allowables based oil emissions
factor limit; and (4) allowables based on both activity and
emissions factor limits. The EPS 2.0 assumes projection factors
apply to all allowable types except those that represent
emissions limits. (The user can override this feature if
desired.)
The projection.factors, currently available - with EPS 2.0 are
generated by the user using a provided BEA earnings and
population data base along with an SIC (ASC)/BEA data cross
reference data file. This relates the BEA categories to the
appropriate SIC or ASC emissions categories. Detailed
explanations of this process and data files can be found in the \
documentation for EPS..2.0. (See reference 8.)
4.3 Economic Growth Analysis System (E-GAS)
A key component of rate-of-progress plan emissions
inventories and inventories for use in photochemical grid
modeling, is the development of credible growth factors for the
existing inventories. Credible growth factors will require
accurate forecasts of economic variables and associated
activities related to ozone precursor emissions. The EPA's Air
22.
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and Energy Engineering Research Laboratory is developing E-GAS to
forecast growth in economic variables and emission-generating
activities. This system includes economic .models for each of the
ozone nonattainment areas required to use photochemical grid
modeling (i.e., serious and above ozone nonattainment areas and
moderate interstate areas), and modules for estimating fuel
consumption, vehicle miles traveled (VMT) , and physical output.
The modules translate growth in economic variables to growth in
activities associated with emissions of NOX/ VOC, and CO, which
are the primary precursors of ozone. The scope of the system is
not intended to provide growth factors for moderate intrastate
areas because E-GAS will not be available in time to meet the
deadline for these areas.
The E-GAS project is being coordinated with a number of
groups at the Office of Air Quality Planning and Standards
(OAQPS); these are the Technical Support Division/Emission
Inventory Branch, the Technical Support Division/Source Receptor
Analysis Branch, and the Air Quality Management Division/Ozone/CO
Programs Branch. In addition, the current guidance for
developing projection inventories (see reference 9), has been
reviewed to maintain consistency between it and E-GAS.
The system is being developed for the PC-AT class machine.
The anticipated minimum hardware requirements are 80286 CPU
(though 80386 CPU is strongly suggested), with math coprocessor,
EGA card/monitor, 4 MB RAM, 100 MB hard disk, and DOS 3.3 or
higher.
The anticipated schedule for completion of E-GAS has two
major milestones: (1) the first milestone, completed in
September 1992, is a first generation "beta version" of the
system, and (2) the second milestone is the final version of the
system scheduled for completion in March 1993.
The EPA is not requiring the use of E-GAS because there may
not be enough time to revise control strategies for the rate-of-
progress plans and still meet the November 15, 1993 statutory
deadline. Nevertheless, States that can adequately incorporate
new growth factors generated from the E-GAS into their 1996
projected inventories are encouraged to do so.
23
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24
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5.0 CONTROL STRATEGIES FOR VOC's
This section first presents a summary of generic VOC control
measures and then describes the source-specific guidance
documentation that has been published to date.
5.1 Stationary Source Controls
Stationary source VOC control techniques can generally be
classified into the following two groups (see reference 10):
• Add-on controls that recover or destroy VOC.
Process modifications, equipment, housekeeping
practices, or material substitution which reduce or
eliminate VOC emissions.
Add-on VOC Controls
The most widely used add-on controls include combustion,
adsorption, absorption, and condensation. The installation of
add-on controls often requires inclusion of equipment to capture
and route VOC emissions to an add-on control device. The overall
efficiency of the add-on control depends on the capture
efficiency as well as the control device efficiency. Flares,
boilers, and thermal incinerators have been shown to reduce the
uncontrolled VOC emissions by at least 98 percent. These
controls work equally well on many types of VOC streams. The
efficiency of adsorption, catalytic incineration, absorption, and
condensers are more dependent on the VOC stream characteristics.
The cost effectiveness of these devices is highly dependent
on the process to which they are applied. Overall costs will
depend on whether or not a capture system is required, and on the
flowrate and organic content of the VOC stream. The OAQPS
Control Cost Manual (see reference 11), provides guidance on
estimating the cost of incinerators (thermal and catalytic) and
carbon adsorbers, the most common add-on controls for reducing
VOC emissions.
Combustion
Combustion devices simply burn or destroy VOC emissions.
This technique is generally applied if the stream has little or
no recovery value. Combustion control devices include flares,
thermal incinerators, catalytic incinerators, boilers, and
process heaters. Incinerators can achieve control efficiencies
of at least 98 percent when properly operated. Additional fuel
may be needed if the pollutant streams" are not capable of
sustaining combustion. Flares are often used when disposing of
gas streams do not require supplemental fuel. Flares have been
25
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shown to achieve greater than 98 percent destruction of VOC
emissions.
Adsorption
Adsorption uses a solid material, most commonly carbon, to
trap the organic vapors. The VOC can then be recovered through
steam stripping. Carbon adsorption is often more economical than
combustion for stream of low organic concentration, which
increases the need for supplemental fuel during combustion.
Efficiencies of 95 percent or greater can be achieved through
carbon adsorption.
Absorption
Absorption uses a liquid to trap the organic vapors. This
process is usually not as economical as combustion or adsorption
because the low concentrations of organics require long contact
times and large quantities of absorbent.
Condensation
Condensation changes the organics on the exhaust stream from
the vapor to the liquid phase. It is often used to reduce VOC
concentrations of the exhaust gas prior to routing the stream to
other add-on devices.
Process Modifications and Substitution
Process modifications and raw material changes are another
class of techniques for reducing VOC emissions. Surface coating
emissions in many industries have been reduced by lowering the
VOC content of the coatings and solvents used in the process.
A common process change in the surface coating industry has been
the use of more efficient spray techniques (improved transfer
efficiency) which reduces the amount of paint used and thus the
VOC emissions.
Material substitution occurs in a case such as substituting
waterborne paints for solvent-borne paints in surface coating
operations. Some examples of housekeeping practices resulting in
VOC reductions are as follows:
Keeping lids on open tank cold degrsasers when not in
use.
Ensuring the connection of the vapor recovery line in
gasoline loading and unloading.
Detecting and repairing leaks at synthetic organic
chemicals manufacturing industry (SOCMI) facilities and
refineries.
26
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5.2 Motor Vehicles
Motor vehicle controls can be classified into measures
reducing the per vehicle emissions or measures reducing VMT, and
thus overall emissions. The latter group of measures are
commonly classified as TCM's.
The CAAA mandate a mix of national and area-specific motor
vehicle control measures to reduce per vehicle emissions.
National measures include RVP limits for gasoline (recently
revised to conform with the CAAA), evaporative/running loss
controls, and tailpipe/extended useful life standards. Area-
specific measures include Stage II (service station vehicle
refueling) controls, clean fuel fleet programs, the California
general clean fuels program, reformulated gasoline, and
enhanced I/M.
Federal Motor Vehicle Control Program (FMVCP)
Tailpipe/Extended Useful Life Standards
The EPA has promulgated a final rule for new emissions
standards for 1994 and later model year light-duty vehicles
(LDV's) and light-duty trucks (LDT's) (56 FR 25724, June 5,
1991). The standards will be phased-in: affecting 40 percent of
the model-year 1994 vehicle fleet, 80 percent of the model-year
1995 vehicle fleet, and 100 percent of the model-year 1996 and
later vehicle fleets. The MOBILES.0 model, which was released in
December 1992, incorporates the new standards into future year
emissions factors.
California has adopted more stringent motor vehicle
standards, referred to as the California Low-Emission Vehicle
(LEV) program. For information on the cost and effectiveness of
the LEV program, contact the California Air Resources Board.
Evaporative /Running- Loss Controls
The new Federal evaporative test procedure will account for
hot soak and diurnal emissions, running losses, and resting
losses.' The MOBILES.0 model contains guidance on estimatina the
effectiveness of evaporative/running loss controls.
RVP Limits
The gasoline volatility limits (RVP Phase I), effective from
1989 through 1991, set gasoline RVP to 10.5 in American Societv
for Testing and Materials (ASTM) Class C regions, and. the
equivalent in other regions. The'ASTM volatility class
represents the ASTM-recommended limits on the volatility of
gasoline sold in that state. There are five volatility classes-
A, B, C, D, and E, where Class A is the least volatile and
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Class E is the most volatile. The ASTM .class varies by season
and geographical area. For example, Louisiana is a Class C area
in June and a Class B area in August. The ASTM Class is higher
(more volatile) in the winter months and less volatile in the
summer months.
Phase II limits are mandated in 1992 and subsequent years.
The Phase II regulations, which were recently revised to conform
with the CAAA, place limits on EPA's authority to require less
than 9.0 psi RVP in attainment areas. The MOBILES.0 model should
be used to estimate the effects of Phase II RVP limits.
Stage II3
Stage II systems are vapor recovery systems installed at the
pumps to reduce vehicle refueling emissions. Section 182(b)(3)
of the Act requires that all ozone nonattainment areas classified
as moderate or acbove implement a Stage II vapor recovery program
as a control measure. Section 202(a) (6) of the Act provides an
exemption from the Stage II requirement for moderate ozone
nonattainment areas after EPA promulgates on-board vapor recovery
standards. After consulting with the U.S. Department of
Transportation, EPA published in the Federal Register its
decision against promulgating on-board vapor recovery standards
(57 FR 13220, April 15, 1992), removing the possibility of a
Stage II exemption for moderate areas. However, on January 22,
1993, the United States Court of Appeals for the District of
Columbia Circuit ruled that EPA's decision not to require on-
board vapor recovery controls be set aside and on-board vapor
recovery standards be promulgated pursuant to section 202(a)(6)
of the Act. The EPA is currently studying a schedule fo'r
complying with the court's ruling.
States are required to adopt Stage II rules for such areas
under sections 182(b)(3). Section 202(a)(6) states that "the
requirements of section 182(b)(3) (relating to Stage II gasoline
vapor recovery) for areas classified under section 181 as
moderate for ozone shall not apply after promulgation of such
standards (i.e., on-board controls) ..."
These provisions of the Act indicate that a State's
obligation to adopt Stage II rules for moderate areas continues
until on-board rules are actually promulgated. When on-board
rules are promulgated, a State- may withdraw its Stage II rules
for moderate areas from the SIP consistent with its obligation
under sections 1 82(b) (3) and 202 (a) (6) . Further guidance on
3Although Stage II vapor recovery control, systems for gasoline
service stations are discussed under- section 5.2 (Motor Vehicles)
of this document, the emissions from gasoline service stations
are generally inventoried as an area source.
28
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Stage II requirements for moderate nonattainment areas seeking
redesignation will be forthcoming.
There are compelling reasons for keeping Stage II
requirements even after an on-board rule is promulgated.
Vehicles equipped with on-board controls are not required to
enter the market until the fourth model year after the
requirement is adopted, and it will take several more years for
the fleet to turn over to the extent that most cars in use have
on-board controls. It could take 10-15 years before on-board
controls achieve the same overall degree of VOC emissions
reductions as Stage II controls. In the meantime, moderate and
above nonattainment areas must achieve under section 182(b)(1)(A)
a. 15 percent VOC emissions reduction by November 1996. Moderate
areas are required to achieve attainment of the ozone NAAQS by
November 1996. Stage II is one of the most promising ways to
comply with this requirement.
The EPA is further considering how this court ruling affects
a State's obligation under section 184(b)(2) regarding Stage II
or measures that get equivalent emissions reductions in the
Northeast ozone transport region. The section 184(b)(2)
requirement applies to all areas in the region regardless of the
ozone designation or classification. Guidance concerning the
Northeast ozone transport region will be issued at a later date.
In addition, the CAAA mandate a study identifying control
measures capable of achieving emissions' reductions comparable to
those achievable by Stage II controls. .All areas within the
Northeast Ozone Transport Region [defined in section 184(a) of
the Act] must adopt Stage II or comparable measures within 1 year
of completion of the study. The study is to be completed in
November 1993. Although Stage II is not specifically mandated,
controls achieving equivalent reductions must be adopted.
The EPA has published two documents relating to Stage I~
controls:
• Technical Guidance - Stage II Vapor Recovery Systems
for Control of Vehicle Refueling Emissions at Sas-oline
"^ "*' S^^T"* C "*' ~"i Ł[" ""'•=1/*>~^-^.'""I-^'S ' S"^" •**• — — rL-r-^T-1-^^, " *"x v
that controls -use have a demonstrated efficiency of 95 oeroer.t
The Z?A believes thai this is a realistic rscuirerr.er.t because _t
15. S *"^ Łi o r^ i (•*• ^ ~ — "V^- Ł^ " ""^ ~* — --_ " ™ O IT" ""1 ~ CL • ~~* ^ » St^* CT S """ *"" *™v T" *""* r** "*"* 3 rn * "" — • * <^* _^k
efficiency ; accounting for associated, wear and. eear, malfunctions
or system problems that result in reduction of the certified
eif ioiencv) defends uoon the ac'cl"1 os.'""' " ~ ~v .—'•> ——/^.——
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regulation as well as the level of enforcement performed. For
example, as shown on page 4-54 of the Stage II technical
guidance, the estimated in-use efficiency for a program where
annual inspections are conducted and all facilities dispensing
10,000 gals or more per month are regulated is 84 percent. The
Stage II technical guidance also gives the estimated in-use
efficiency for other applicability and enforcement scenarios.
Inspections identify malfunctioning equipment, which contributes
to the reduction from the demonstrated efficiency.
The CAAA establish a size cutoff of 10,000 gals of gasoline
dispensed per month with the exception of independent small
business marketers. The size cutoff for independent small
business marketers is 50,000 gals per month. Independent small
business marketers are defined in section 324 of the Act. The
10,000/50,000 gal exemptions will exclude an average of
10 percent of gasoline consumption from regulation. The CAAA do
not prohibit States from establishing lower thresholds for
independent small business marketers. With the difficulty in
determining stations that fall under the definition of
independent small business marketer, many areas choose not to
have a separate exemption level for this group. A single cutoff
of 10,000 gals per month would exclude an average of only
2.8 percent of gasoline consumption.
The emissions inventory guidance document entitled
Procedures for Emission Inventory Preparation - Volume IV:
Mobile Sources, (see reference 14), recommends the use of
MOBILES.0 emissions factors for modeling the effects of Stage II
controls on refueling emissions. Further guidance on the input
requirements can be found on pages 43 through 45 of the guidance
document.
Clean Fuel Fleet Program
Serious, severe, and extreme ozone nonattainment areas [and
CO areas with design values of 16.0 parts per million (ppm) or
greater] with 1980 populations of at least 250,000 must adopt the
clean fuel fleet program mandated by the CAAA. The phase-in
schedule for this program is as follows:
•GQQ
20% 50%
Heaw-dutv trucks 50% 50%
:ec^f:_c standards that must be met are listed in sections 242
id 245 of the Act.
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Reformulated Gasoline
Reformulated gasoline is required in the nine largest cities
with the most severe ozone pollution. States may opt to have
other nonattainment areas included in this program. Reductions
in toxic and VOC emissions of at least 15 percent are required in
1995, increasing to at least 20 percent in 2000. The emissions
reductions from reformulated gasoline can be calculated using the
MOBILE5.0 model.
Inspection and Maintenance
The EPA has promulgated a rule regarding enhanced I/M
program requirements (57 FR 52950, November 5, 1992). The final
rule includes an I/M option including a biennial centralized
program with vehicles tested both in idling mode and at 2500 rpm.
In addition, a transient exhaust emissions test, an evaporative
canister purge system check, and an evaporative system pressure
test would also be required as well as a number of tests for
tampering. Benefits of enhanced I/M programs should be modeled
using MOBILE5.0.
On-Board Diagnostic Systems
The EPA has proposed a rule that will require on-board
diagnostic systems in all LDV's and LDT's beginning in model year
1994 (56 FR 48272, September 24, 1991). On-board diagnostic
systems monitor emission-related components for malfunctions or
deterioration before such events cause emissions increases.
According to the proposed rule, on-board diagnostic systems will
be inspected as part of a State's I/M program. Therefore,
emissions reductions resulting from the use of on-board
diagnostic systems will not be separately creditable toward the
15 percent VOC emissions reduction requirements.
•Transportation Control Measures (TCM's)
The EPA has recently developed guidance on an assortment of
TCM's. The TCM's attempt to decrease traffic congestion,
especially during peak commuting hours, by providinc alterr.a-;."eŁ
Programs for improved, public transit.
Restrict-on cf certain reads 3r lanes to, cr
passenger buses cr high-occupancy vehicles.
Employer-cased transportation Tuar.acerr.er.t clans,
including incentives.
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Trip-reduction ordinances.
Traffic flow improvement programs that achieve
emissions reductions.
Fringe and transportation corridor parking facilities
serving multiple occupancy vehicle programs or transit
service.
Programs to limit or restrict vehicle use in downtown
areas or other areas of emissions concentration,
particularly during periods of peak use.
Programs for the provision of all forms of high-
occupancy, shared-ride services.
Programs to limit portions of road surfaces or certain
sections of the metropolitan area to the use of
nonmotorized vehicles or pedestrian use, both as to
time and place.
Programs for secure bicycle storage and other
facilities, including bicycle lanes, for the
convenience and protection of bicyclists in both public
and private areas.
Programs to control extended idling of vehicles.
Programs to reduce motor vehicle emissions, consistent
with Title II, which are caused by extreme cold start
conditions.
'Employer-sponsored programs to permit flexible work
schedules.
Programs and ordinances to facilitate nonautomobiie
travel, prevision and utilization of mass transir, and
to generally reduce the need for single-occupant
vehicle travel, as part of transportation planning and
development efforts of a locality, including programs
and ordinances applicable to new shopping centers,
?rccra~s fcr r.ev ;cn.szruc_:-cn. and ma-or reccns-ruc-:.::r-3
of paths, -racks, cr areas solely fcr use by pedes-r^ar.
cr czr.er r.cnmc~ crazed means cf transpcriacicn '.crier.
economically feasible and in. the public interest.
and the marketplace cf pre-', 980 model light-duty
vehicles and trucks.
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The TCM implementation guidance for SIP's may be found in an EPA
guidance document entitled Transportation Control Measures:
State Implementation Plan Guidance. (See reference 16.) This
source also contains a list of TCM reference documents.
Additional travel demand management measures to relieve
congestion may be obtained from a U.S. Department of
Transportation (DOT) document entitled Evaluation of Travel
Demand Management Measures to Relieve Congestion. (See
reference 17.)
The EPA's Office of Policy, Planning & Evaluation is doing
significant work in this area. The new tools should be available
in the Spring of 1993. Please call Jon Kessler (202-260-3761) or
Will Schroeer (202-260-1126) with questions on these tools.
5.3 Other Mobile Sources
Fewer control measures exist for other mobile sources.
Most control technology for these sources focuses on emissions
reductions from diesel engines. Information will soon be
available for controls for railroads, construction equipment, and
farm equipment. The EPA's Office of Mobile Sources plans to
provide guidance on emissions reductions that may be achieved
from off-road sources due to the use of reformulated gasoline.
Controlling emissions from diesel engines can usually be
accomplished by tailoring the air induction, fuel injection,
fuel-air mixing, and other elements of the combustion process.
Additionally, after-treatment of the exhaust gases may be
possible in some cases. Diesel engine controls should be
adaptable to most off-road sources. (See reference 18.) Although
no specific controls have been required to date, EPA has targeted
nonroad diesel engines for first-time regulation. Heavy-duty
nonroad (farm and construction) equipment is specifically
targeted, but recreational boats and small farm and garden
equipment may also be affected by future regulations.
5.4 Control Strategy Documentation for Stationary Sources
The EPA has implemented several VOC control programs either
through the promulgation of regulations, or by issuing guideline
documents for States to use in developing 'their own regulations.
Under secrion 11 1 of the Act, EPA has promulgated new source
performance standards (NSPS) for several VOC'source cateaories
The NSPS are national standards- that affect new, modified, or
reconstructed stationary sources. Under section 112 of the Act
EPA has promulgated national emission standards for hazardous ai-
pollutants (NESHAPS). The NESHAPS are national standards that:
affect existing and new stationary sources. Some of the NESHAPS
control VOC emissions from stationary sources because the NESHAPS
regulate hazardous air pollutants that are classified as VOC \s
a result of the CAAA, section 112 of the Act was amended to " "
33
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authorize EPA to promulgate maximum achievable control technology
(MACT) standards for stationary point and area sources. For area
sources, EPA can develop standards based on generally available
control technology (GACT) or management practices. rather than
MACT. The MACT and GACT standards will be issued as national
standards that will affect existing and new stationary sources.
Information on alternative control technologies and associated
costs used to support the technical basis for existing NSPS and
NESHAPS is published in background information documents (BID's)
for the proposed standards. Information on alternative control
technologies and associated costs used to support the technical
basis for future NSPS, NESHAPS, MACT, and GACT regulations is
also expected to be published in BID'S or similar documents.
The EPA has issued CTG documents for several VOC source
categories. The CTG documents recommend presumptive levels of
RACT that States must use as a guideline in preparing their
SIP's. The RACT rules adopted by States affect existing and new
sources. The CTG documents issued before the CAAA are classified
into Group I, II, and III source categories. The EPA is
continuing to develop CTG documents for additional VOC source
categories. The EPA also publishes alternative control technique
(ACT) documents for VOC source categories. The ACT documents
provide technical and cost information on emissions control
techniques, but do not recommend presumptive levels of RACT, for
stationary sources. States may use the ACT documents to support
development of their own regulations.
The purpose of section 5.4 of this document is to provide a
brief overview of the regulatory programs that EPA has and will
continue to implement, and to provide references for the
technical and cost documentation that has or will be published to
support the basis for the regulatory programs.
Information on the status of EPA's VOC control programs is
available through the Control Technology Center (CTC) at (919)
541-0800. Copies of BID'S and CTG and ACT documents can be
obtained .for a fee from the National Technical Information
Service:
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22.161
(703) 437-4600.
Information on control technologies is also available
through certain State and local air pollution control agencies.
The EPA focuses its efforts on controlling* VOC emissions from
source categories or subcategories that have a larger impact: on
national VOC emissions. State and local agencies can focus
efforts on source categories or subcategories important in their
specific areas. California's South Coast Air Quality Management
34
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District (SCAQMD) has developed and adopted a number of
stationary (point and area) and mobile source control measures in
its 1991 Air Quality Management Plan. A list of the SCAQMD's
control measures is provided in Appendix D of this document. The
list of stationary source control measures presented in
Appendix D is for source categories that are not covered by CTG
documents. Copies of the management plan may be obtained from
the SCAQMD.
The EPA recognizes that some of the new CTG documents and
Federal regulations for other programs (e.g., NSPS, NESHAPS, and
MACT) may not be promulgated in time to be used by States to
develop and adopt RACT rules or other control measures for their
final rate-of-progress plans (due to EPA by November 15, 1993).
In general, a State may only credit expected emissions reductions
toward meeting the 15 percent VOC emissions reduction
requirements, net of growth, if the emissions reductions are
associated with control measures that the State has fully
developed, adopted, and included in its rate-of-progress plan.
In general, a State may not take credit for expected emissions
reductions associated with Federal regulations that have not been
promulgated. A State may choose to revise its rate-of-progress
plan after November 15, 1993, to replace existing control
measures with new control measures based on newly promulgated CTG
documents or Federal regulations. The EPA is currently
investigating whether and under what circumstances a State may be
able to take credit for unadopted control measures in its rate-
of-progress plan. Further guidance from EPA may be forthcoming.
Group I CTG Documents
Prior to January 1978, EPA published 11 CTG documents for
15 source categories. These Group I CTG documents were
summarized in a December 1978 document entitled Summary of Group
I Control Technique Guideline Documents for Control of Volatile
Organic Compound Emissions from Stationary Sources. (See
reference 19.) The summary document provides the main ideas
found in the actual CTG documents, including information on
affected facilities,*VOC emissions, available control
technologies, recommended emissions limits, and expected control
costs. The information in the summary document is also presented.
in the SPA document entitled Issues Relating to yoc Regulation
Cutpoxnts, Deficiencies, and Deviations: Clarification to
Appendix D of -November 24, 1987 Federal Register. (See
reference 20.) The VOC source categories covered by the Group I
CTG documents are as follows:
Surface coating of cans.
Surface coating of metal coils.
Surface coating of paper products.
Surface coating of fabrics.
Surface coating of automobiles and light-duty trucks.
35
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Surface coating of metal furniture.
• Surface coating for insulation of magnet wire.
• Surface coating of large appliances..
• Tank truck gasoline loading terminals.
• Bulk gasoline plants.
Design criteria for Stage I vapor control systems at
gasoline service stations.
• Storage of petroleum liquids in fixed-roof tanks.
• Refinery vacuum processing systems/ wastewater
separators, and process unit turnarounds.
• Solvent metal cleaning.
• Use of cutback asphalt.
Appendix B of this document provides the references for. each
of the Group I CTG documents.
Group II CTG Documents
The EPA published eight CTG documents between January 1978
and January 1979. These Group II CTG documents were summarized
in a December 1979 document entitled Summary of Group II Control
Technique Guideline Documents for Control of Volatile Organic
Compound Emissions from Stationary Sources. (See reference 21.)
The summary document provides the main ideas found in the actual
CTG documents, including information on affected facilities, VOC
emissions, available control technologies, recommended emissions
limits, and expected control costs. The information in the
summary document is also presented in the EPA document entitled
Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations: Clarification to Appendix D of November 24. 1987
Federal Register. (See reference 22.) The VOC source categories
covered by the Group II CTG documents are as follows:
• Leaks from petroleum refinery equipment.
• Surface coating of miscellaneous metal parts and
products.
• Surface coating of flat wood paneling.
• Manufacture of synthesized pharmaceutical products.
• Manufacture of pneumatic rubber tires.
• Graphic arts - rotogravure and flexography.
* Petroleum liquid storage in external floating roof
tanks.
• Leaks from gasoline tank trucks and vapor coliecr-on
systems.
Appendix B of this document provides the references for each
of the Group II CTG documents.
36
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Group III CTG Documents
Since September 1982, EPA has published CTG documents for
five additional source categories. No summary document has been
prepared for the Group III CTG documents. The EPA document
entitled Issues Relating to VOC Regulation Cutpoints,
Deficiencies, and Deviations: Clarification to Appendix D of
November 24, 1987 Federal Register summarizes the information on
affected facilities, VOC emissions, available control
technologies, recommended emissions limits, and expected control
costs presented in the actual CTG documents. (See reference 22.)
The VOC source categories covered by the Group III CTG documents
are as follows:
• Manufacture of high-density polyethylene,
polypropylene, and polystyrene resins.
• Leaks from synthetic organic chemical and polymer
manufacturing equipment.
• Large petroleum dry cleaners.
Air oxidation processes in synthetic organic chemical
manufacturing industry.
• Equipment leaks from natural gas/gasoline processing
plants.
Appendix B of this document provides the references for each
of the Group III CTG documents.
Model RACT Rules
On June 24, 1992, EPA's Ozone/Carbon Monoxide Programs
Branch of OAQPS issued a final set of model RACT rules to the EPA
Regional Offices, (See reference 23.) The model RACT rules cover
29 CTG source categories. The model rules are to be used by
EPA's Regional Offices as a template for proposing Federal
implementation plans (FIP's) under section 110(c)(1) of the Act
for areas that fail to submit approvable RACT corrections
required under section 182(a)(2)(A) of the Act. States may
obtain copies of the model rules from their EPA Regional Office.
However, the model rules should not be construed to be
operational guidance on the approvability of State rules. States
may adopt rules that are different from the model rules that are
fully approvable for a SIP. The basis by which State rules 2.ra
evaluated and findings are made are published in the document
entitled Issues Relating to VOC Curooints. Deficiencies, and
Deviations: Clarification to Appendix D of November 24. 1987
Federal Register. (See reference 24.)
A generic non-CTG RACT rule is- also included in the sei: of
model rules. Where insufficient information is available to
determine RACT for a source or source category, the generic non-
CTG RACT rule may be considered as default RACT. However, it is
recommended that those using the guidance seek additional
37
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information to tailor the rule to the affected source or source
category because the preferred method of establishing non-CTG
RACT is on a case-by-case basis.
Several of the model rules include requirements for
measuring capture efficiency. When the model RACT rules were
issued/ EPA's OAQPS was conducting a year-long study to
reevaluate EPA's position on capture efficiency testing.
Additional guidance will be forthcoming.
Although the model rules are intended to provide guidance
for EPA Regional Offices to use in developing FIP's, States may
use the model rules as examples of what EPA generally considers
consistent with EPA guidance. Any questions regarding the model
rules should be directed to Mr. David Cole/ EPA/OAQPS,, at
(919) 541-3356.
New CTG Documents
Section 183(a) of the Act requires EPA to issue CTG
documents for 11 stationary VOC source categories by November 15,
1993. The EPA published the 11 source categories for which it
will develop CTG documents in Appendix E of the General Preamble
(57 FR 18077). The source categories.are as follows:
SOCMI distillation.
SOCMI reactors.
SOCMI batch processing.
Wood furniture.
Plastic parts coating (business machines).
Plastic parts coating (other).
Web offset lithography.
Industrial wastewater.
Autobody refinishing.
Volatile organic liquid storage in floating and fixed-
roof tanks.
• Clean-up solvents.
Draft CTG documents have been prepared for SOCMI batch
processing, SOCMI reactors and distillation, autobody
refinishing, volatile organic liquid storage in floating and
fixed-roof tanks, coating of wood furniture, coating of plastic
parts, and web offset lithography. The references for these
draft CTG documents are presented in Appendix B of this document.
A reference for best available control technology (BACT)/lowest
achievable emission rate (LAER) determinations for industrial
wastewater processes is also provided in Appendix B of this
document.
In addition, section 183(b) of the Act requires EPA to
prepare CTG documents for two additional stationary VOC sources
by November 15, 1993. Section 183(b)(3) requires EPA to issue a
38
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CTG document to control VOC emissions from aerospace coatings and
solvents. Section 183(b)(4) requires EPA to issue a CTG document
to control VOC emissions from paints, coatings, and solvents used
in ship building and repair operations. A.brief summary of the
work on the CTG documents for these two source categories is
provided in Appendix B of this document. Information on the
status of the development of the new CTG documents, as well as
copies of the draft and final CTG documents when completed, may
be obtained through EPA's CTC.
Section 182(b)(2) of the Act specifies the time schedule for
the implementation of RACT rules for moderate and above ozone
non-attainment areas. For sources covered by CTG documents issued
between the date of enactment of the CAAA (i.e., November 15,
1990) and the attainment date for the nonattainment area, RACT
rules must be implemented according to the schedule specified in
the CTG document. For sources covered by CTG documents issued
prior to enactment of the CAAA and for major stationary sources
not covered by a CTG document, RACT rules must be submitted to
EPA by November 15, 1992, and implemented by May 31, 1995. The
EPA recognizes the potential schedule problem between submitting
RACT rules for major stationary sources by November 15, 1992,
which may be covered by one of the CTG documents it plans to
issue in November 1993. Therefore, EPA has established the
following general time table for States to submit their RACT
rules for sources that are identified in a November 15, 1992
submittal as being covered by a post-enactment CTG document:
On November 15, 1992, the State must submit a list of
major stationary sources that it anticipates will be
subject to one of the CTG documents being prepared for
the 13 stationary VOC source categories identified
above, which EPA plans to issue by November 15, 1993.
For those major sources on the list submitted by the
State in the 1992 submitcal that are not covered by a
CTG document that EPA has issued by November 15, 1993,
the State must submit a RACT rule by November 15, 1994
that requires implementation of RACT by May 15, 1S95.
Sect C_Cn 3 2 ' 2. 2."" i ~ —"~ *;'"" ~ •"'•"" ~" •" — - "~ = — 3 -=cr — — — ' — ^
tne _zne schedule set fcrth in the relevant. "G
dccunent.
adeemed and SPA approved \ir.cler sect^cn ' z2 ,'c] 2V :
tc. SPA's issuance of an applicable 'CTG document, i
will wcr:< with the State to determine whether the
-------
existing rule should be revised once a CTG has been
issued that would apply to that source.
For further details on preparing RACT rules to meet the
schedule required by section 182(b)(2) of the Act, the reader is
referred to Appendix E of the General Preamble (57 FR 18077) and
also a memorandum from G.T. Helms dated August 7, 1992 on
"Determining Applicability for Sources Subject to Pending New
Control Technique Guidelines (CTG's)."
Non-CTG RACT Rules
Prior to enactment of the CAAA, it was EPA's policy to
require non-CTG major stationary sources located in ozone
nonattainment areas that emit or have the potential to emit
100 tons per year (tpy) or more of VOC to apply RACT. Section
182 of the Act lowered the emissions threshold for the definition
of "major stationary source" for many of the ozone nonattainment
classifications. The major stationary source thresholds for
serious, severe, and extreme ozone nonattainment areas are,
respectively, 50, 25, and 10 tpy or more of VOC or NOX. The
major stationary source threshold for marginal and moderate ozone
nonattainment areas in an ozone transport region is 50 tpy or
more of VOC and 100 tpy or more of NOX. The major stationary
source threshold for attainment areas in an ozone transport
region is also 50 tpy or more of VOC and 100 tpy or more of NOX.
The major stationary source threshold for intrastate marginal and
moderate areas and all other nonattainraent areas (i.e.,
submarginal, transitional, and incomplete/no data) remains at
100 tpy or more of VOC or NOX. Lowering the threshold for major
stationary sources will increase the number of sources subject to
non-CTG RACT rules. Emissions reductions associated with
lowering the threshold in non-CTG RACT rules that occur prior to
November 15, 1996 in a nonattainment area are creditable toward
the 15 percent VOC emissions reduction requirements, net of
growth.
ACT Documents
The EPA has published ACT documents for halogenated solvent
cleaners, application of traffic markings, automobile
refinishing, ethylene oxide sterilization/fumigation operations,
and organic waste processes. The references for these ACT
documents are presented in Appendix B of this document. The ACT
documents are good sources of technical information, including
emissions control technologies and expected costs. Unlike CTG
documents, ACT documents do not provide recommended RACT limits.
The five ACT documents published to date have been briefly
summarized, in Appendix S of this document. Information on these
and new ACT documents that EPA publishes may be obtained from the
CTC.
40
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New Source Performance Standards
Under section 111 of the Act, EPA has promulgated NSPS to
control VOC emissions from facilities in the following source
categories:
VOC equipment
Bulk gasoline terminals.
Municipal waste combustors.
On-shore natural gas processing plants:
leaks.
Petroleum dry cleaners.
Petroleum refineries: equipment leaks.
Petroleum refinery wastewater systems.
Polymer manufacturing.
Publication rotogravure printing.
Rubber tire manufacturing.
Storage vessels for petroleum liquids.
Storage vessels for volatile organic liquids.
Synthetic fiber production.
Surface coating operations:
Automobiles and light-duty trucks.
Beverage cans.
Flexible vinyl and urethane coating and printing.
Large appliances.
Magnet tape.
Metal coil.
Metal furniture.
Plastic parts for business machines.
Polymeric coating of supporting substrates.
Pressure sensitive tapes and labels.
• SOCMI air oxidation unit processes.
• SOCMI distillation unit operations.
• SOCMI equipment leaks.
Appendix C of this document provides the Code of Federal
Regulation (CFR) citations for the NSPS, and EPA publication
numbers for the BID'S developed to support the technical basis
for the NSPS. The BID'S contain technical information on the
emissions sources and emissions, alternative controls considered
during the development of the NSPS, the performance of the
alternative controls evaluated, and estimated control costs.
On May 30, 1991, EPA proposed an NSPS to control air
emissions from municipal waste landfills (56 FR 24468) . The NSPS
is expected to be promulgated in the fall of 1993. The prooosed
NSPS would limit emissions from certain new and modified
landfills and would establish guidelines for States to follow in
preparing plans to limit emissions from existing landfills.
Technical information on emissions estimates and control
techniques for municipal solid waste, landfills is presented in
41
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the document entitled Air Emissions from Municipal Solid Waste
Landfills - Background Information for Proposed Standards and
Emission Guidelines; (See reference 25.) The proposed and final
regulations should be consulted for the definition of affected
facilities and control requirements. For further information on
the NSPS, contact EPA's Emission Standards Division of OAQPS.
Section 112 Standards
The EPA has promulgated NESHAPS to control hazardous air
pollutants from the following VOC source categories:
• Vinyl chloride production plants.
Benzene emissions from equipment leaks.
• Benzene emissions from benzene storage vessels.
• Benzene emissions from coke by-product recovery plants.
• Benzene emissions from benzene transfer operations.
• Benzdne waste operations.
Appendix C of this document provides the CFR citations for
the NESHAPS, and provides EPA publication numbers for the BID'S
developed to support the technical basis for the NESHAPS. The
BID'S contain technical information on the emissions sources and
emissions, alternative controls considered during the development
of the NESHAPS, the performance of the alternative controls
evaluated, and estimated control costs.
The EPA will be developing several programs to control
hazardous air pollutants under section 112 of the Act. Many of
the hazardous air pollutants are covered by the definition of
VOC. The document entitled Guidance on the Relationship Between
the 15 Percent Rate-of-Progress Plans and Other Provisions of the
Clean Air Act (to be released in the spring of 1993) provides a
detailed description of the Federal programs that will be
developed under Section 112 of the Act. The programs include
MACT standards, early reduction programs, major modifications to
existing sources, and standards more stringent than MACT to
protect the public health. The following documents have been
published for early reduction programs:
• Enabling Document for Regulations Governing Compliance
Extensions for Early Reductions of Hazardous Air
Pollutants. (See reference 26,)
• Questions and Answers about the Early Reductions
Program. (See reference 27.)
Procedures for Establishing Emissions for Sarlv
Reduction Compliance Extensions. (See reference 28.)
42
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On July 16, 1992, EPA published in the Federal Register a
revised list of 174 categories and subcategories of sources for
which it intends to develop MACT standards (57 FR 31576). On
September 24, 1992, EPA published in the Federal Register a
proposed schedule for developing MACT standards for the
174 categories and subcategories (57 FR 44147). The final
schedule for preparing MACT standards is expected to be finalized
in September of 1993.
The EPA proposed a rulemaking for an hazardous organic
NESHAP (HON) on December 31, 1992 (57 FR 62608). The final rule
is expected to be promulgated in late 1993 or early 1994. The
proposed rule would regulate the emissions of organic hazardous
air pollutants/ all of which are classified as VOC's, from SOCMI
processes and from equipment leaks in seven non-SOCMI processes.
The SOCMI processes include process vents, transfer operations,
storage vessels, and wastewater operations. The seven non-SOCMI
processes are as follows:
Styrene/butadiene rubber products.
Polybutadiene rubber products.
Chlorine production.
Pesticide production.
Chlorinated hydrocarbon use.
Pharmaceutical production.
Miscellaneous butadiene use.
Controls must be installed to control SOCMI emissions points
other than equipment leaks within 3 years after promulgation of
the rule. The compliance schedule for the equipment leaks in
SOCMI and the seven non-SOCMI processes is staggered, starting
6 months after promulgation. The reader is referred to the
Federal Register notice of proposed rulemaking for further
details.
The EPA proposed a NESHAP for coke oven batteries in 1987.
On December 4, 1992, EPA withdrew the 1987 proposal (57 FR 57403)
and proposed a new NESHAP for coke oven batteries (57 FR 57534) .
Although the BID for the original proposal (see reference 29) has
not been updated, some of the information in the BID is still
relevant to the new proposal. Materials prepared to support the
new proposal ase contained in the docket for the proposed
rulemaking. The NESHAP is expected to be promulgated in the
spring of 1993.
Other Federal Control Measures
The EPA is planning to prepare VOC control measures for
consumer and cdmmercial products, adhesives, application of
agricultural pesticides, marine vessel loading operations,
architectural and industrial coatings, autobody refinishing, and
ship building operations and ship repair. The control measures
43
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for these source categories may be published as future BID'S/ ACT
documents, or possibly as CTG documents. The developmental
status of the control measures and the documents EPA anticipates
issuing to support the technical basis for the control measures
for these source categories is presented in Appendix E of this
document.
The EPA is also preparing standards under the Resource
Conservation and Recovery Act (RCRA) to control organic air
emissions from hazardous waste treatment/ storage/ and disposal
facilities (TSDF's). Phase I standards were promulgated on
June 21, 1990 (55 FR 25454). The Phase I standards cover
equipment leaks and process vents. Technical information on
emissions estimates and control techniques for facilities covered
by the Phase I standards are presented in the document entitled
Hazardous Waste TSDF/s - Technical Guidance Document for RCRA Air
Emissions Standards for Process Vents and Equipment Leaks. (See
reference 30.) Phase II standards were proposed on July 22, 1991
(56 FR 33490) . The Phase II standards have been proposed to
cover tanks, surface impoundments/ containers/ and miscellaneous
units. Technical information on emissions estimates and control
techniques for facilities covered by the Phase II standards are
presented in the document entitled Hazardous Waste TSDF/s -
Background Information for Proposed RCRA Air Emissions Standards.
(See reference 31.) The Phase II standards are expected to be
promulgated in the fall of 1993. The Phase I and II regulations
should be consulted for the definitions of the affected
facilities. For further information on the Phase I and II
standards/ contact EPA's Emission Standards Division of OAQPS.
5.5 Rule Effectiveness Improvements
Many States with preexisting nonattainment areas have
already adopted rules defining RACT for most of the larger
sources, including major non-CTG categories. In such cases,
there is considerable concern about what additional measures are
needed to meet the 1 5 percent VOC rate-of-progress requirement.
One method of achieving creditable emissions reductions from
stationary sources in such areas is to improve the implementation
of existing regulations. This is referred to as RE improvement.
These improvements are subject to the same creditability
constraints as are the other- emissions reductions.4 Rule
effectiveness improvements must reflect real emissions reductions
resulting from specific implementation program improvements.
Actual emissions reductions must result from improving RE; simply
calculating a higher RE using a different methodology is not
creditable.
4For example, some RACT rule corrections that result in improved
RE may be creditable; a discussion of this appears in section
III.3.a.4 of the General Preamble (.57 FR 13509).
44.
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Rule effectiveness improvements must be documented at a
minimum by conducting a post-implementation (after the
implementation of RE improvement programs) source-specific
emissions study. Two methods ar.e available 'for calculating
creditable RE improvements; both require that a post-
implementation Stationary Source Compliance Division (SSCD)
Protocol Study be conducted. The first method involves pre- and
post-RE improvement implementation studies as delineated by SSCD.
For example, if the RE increases from 50 percent to 75 percent,
the emissions reductions associated with this improvement would
be creditable. The second approvable method uses the EPA default
value of 80 percent for the RE value prior to the rule-
effectiveness improvement program. Thus, if the results of a
SSCD protocol study show 85 percent RE after implementation, the
increase in emissions reductions associated with the improvement
from 80 to 85 percent would be creditable toward the 15 percent
rate-of-progress requirement. Additional discussion of RE,
including provisions for the calculation and use of category-
specific RE factors, is available in Guidelines for Estimating
and Applying Rule Effectiveness for Ozone/CO State Implementation
Plan Base Year Inventories. (See reference 32.)
If a State can show an improvement in the RE of a SIP
provision (for further information refer to the December 21, 1992
memorandum from John B. Rasnic, Director SSCD, to Regional Air
Division Directors, regarding "Revised Rule Effectiveness
National Protocol") above the default value through the use of an
EPA protocol test, then the emissions reductions associated with
the improvement would be creditable toward meeting the 15 percent
VOC emissions reduction requirement. If the EPA protocol test
for the effectiveness of a SIP rule indicates that the RE was
less than the default value, further reductions would be
necessary to meet the statutory requirements.
The SPA plans to issue guidance on the quantification of RE
improvements in early Spring 1993. Suggested measures for
improving RE are as follows:
Agency Compliance
• Increase number of people in inspection program.
Increase frequency and nature of inspecrions.
Implement and improve recordkeeping requirements
(perhaps automated to estimate that they are in
compliance over time).
• Improve follow-up program once violations are found.
Establish a formal documentation and enforcement
system.
Implement an SSCD protocol which is self-monitoring.
• Facilitate communication through publicity.
45
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Source
Implement internal audits that would routinely review
and trigger remedial action—an automatic assessment
program.
Improve adequacy of recordkeeping.
Assign responsible people.
Implement a periodic checking system with explicit
follow-up to evaluate the on-going system.
Implement an SSCD protocol which is self-monitoring.
Improvements in Technology
Implement an operation and maintenance program for
control equipment (e.g., monitoring and alarm system
for the equipment).
Education
Rules
Increase training of plant operators.
Require qualified and trained inspectors.
Implement periodic updating of training programs and
periodic training.
Revise complex and ambiguous rules.
Create methodologies to simplify rules.
The following items provide several suggestions .for what EPA
will accept in a State's SIP to demonstrate adoption and
implementation of RE improvements: adoption of a rule, a letter
to the Governor, additional staff, or incorporation of the
activity in a permit. The RE improvements will be evaluated on a
case-by-case basis. Other guidance on evidence of adoption and
commitment is found on pages 218-220 in Workshop on Requirements
for Nonattainment Area Plans. (See reference 33.)
5.6 Quantification of Rule Effectiveness Improvement Programs
In order to estimate the amount of creditable emissions
reductions from RE improvements, States will need to calculate
the RE values associated with their improvement programs. These
values will be developed using a methodology similar to that for
calculating the base year RE values.
The EPA is currently developing a list of specific control
measures that will yield real improvements in RE. A. group of
experienced compliance experts, comprising State and local
agencies/ EPA Regional Offices, and EPA Headquarters, will assess
the. relative weights for the groups of measures. Furthermore,
some groups of measures will also contain several different
46
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possible levels of activities (e.g., under the group "nature of
regulation," one level would be "possible ambiguity or deficiency.
in rule") . These levels of activities will also be weighted
relative to one another. The EPA will employ the use of the
Delphi method to reach consensus on the weightings. (The Delphi
method involves the solicitation of opinions from experts on a
subject/ the compilation of the opinions/ and the determination
of an average opinion based on the averaging of the collected
opinions.) The States will determine a weighted value for each
group by multiplying the weight of each level of activity by the
weight of its group. The values would be summed to provide a raw
score, which would be an initial relative indicator of the new RE
value.
The table will also include instructions for increasing or
decreasing the weight if it is determined that certain groups of
activities or conditions performed simultaneously provide
enhanced or decreased effect on RE. The grouping of RE
improvement measures, the weights that EPA assigns to these
measures, and the description of how the scores are to be used to
compute the improved RE will be provided in forthcoming EPA
guidance expected in Spring 1993.
47
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48
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6.0 CONTROL STRATEGY DEVELOPMENT PROJECTIONS
6.1 Introduction
This section discusses the purpose and elements of emissions
projections, the types of emissions projections that must be
developed to meet the requirements for the rate-of-progress
plans/ and several alternative methods or equations that can be
used to calculate the 1996 projection year emissions inventories
for point, area, and mobile sources. Moderate ozone
nonattainment areas that will rely on EKMA modeling to
demonstrate attainment with the ozone NAAQS will need to provide
documentation for projected emissions inventories for 1996 for
both VOC and NOX in their SIP submittals. Those States that also
plan to account for CO emissions in their EKMA modeling should
also provide documentation for a proj ected CO emissions inventory
for 1996 in their SIP submittals. The guidance presented in this
section is applicable for projecting VOC, NOX, and CO emissions.
In general, projection year emissions are to be based on
allowable ozone season typical weekday emissions. However, as
discussed in section 2.4 of this document, EPA recognizes that
1) there are time constraints related to assimilating the
allowable emissions limit data into a usable format and 2) the
assumption that all sources in a nonattainment area will operate
at their allowable emissions limit may not be valid. Therefore,
as an alternative to using allowable emissions for projections,
EPA believes it is appropriate to use actual emissions in certain
circumstances. For sources or source categories that are
currently subject to a regulation and the State does not
anticipate subjecting the source(s) to additional regulation, the
projected emissions may be based on actual emissions. In
addition, for sources or source categories that are currently
unregulated and are not expected to be subject to future
regulations, the projected emissions may be based on actual
emissions. For all other sources, i.e., sources that are
expected to be subject to additional regulation, the projections
should be based on the new allowable emissions (including RE) .
The reader is referred to section 2.4 of. this document for
detailed guidance on EPA's policy concerning the use of actual or
allowable emissions for emissions projections.
The States will have the responsibility to adequately
document which projection methodology is used so that EPA will
have access to the documentation during the SIP review process
and for subsequent review of emissions reduction credits. The
purpose of this section is to describe and illustrate the various
projection methodologies which States can use for preparing
emissions projections.
49
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6.2 Purpose and Elements of Emissions Projections
The purpose of developing a 1996 projected inventory is to
determine the emissions reductions that will be needed to meet
reasonable further progress requirements or to attain the ozone
NAAQS. After the emissions reductions are determined, States
must then prepare, adopt, and implement legally enforceable
control measures needed to achieve the emissions reductions.
Projection year emissions are to be based on ozone season typical
weekday emissions.
Actual emissions, for purposes of projections, are to be
based on a source's actual operating hours, production rates, and
control equipment for the processes carried out at the source.
Actual emissions take into consideration instances when the
operations are consistent and when deviations from normal
operating conditions occur.
Allowable emissions, for the purposes of projections, are to
be based on expected future operating conditions (operating rates
or throughput and hours of operation) and maximum emissions
limits. Maximum emissions limits may be process-based emissions
factors [e.g., pounds of VOC per gallon (Ib VOC/gal) of coating
applied, Ib VOC/ton processed], capture and/or control device
efficiencies, or emissions rate limits (e.g., tpy, Ib/day) .
Emissions factor limits and capture and/or control device
efficiency limits should take precedence over emissions rate
(time-based) limits when both are available. In determining the
maximum emissions limit, existing regulations and permits must be
considered in addition to future planned regulations and permit
modifications.
Emissions rate limits (mass/time) should only be used if
there are procedures for demonstrating compliance with these
limits. Emissions rate limits may be expressed as annual ton-
per-year limits (long-term) or short-term limits on a monthly,
daily, or hourly basis (e.g., Ib/day) . The permit must contain a
method for determining compliance with these limits. Long-term
(e.g., annual average) limits should be used in the calculation
of projection year emissions. Short-term limits [e.g., Ib/day or
pounds per hour (Ib/hr) 3 may be based on maximum operating
conditions to allow for fluctuations in operation. If an
emissions rate limit (mass/time) is used, annual, long-term limits
should be converted to daily limits based on the source's
operating schedule. The long-term limits are more representative
of expected activity, while the short-term limits are more
representative of maximum activity.
50
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The following data elements are also important for
projections and have been discussed previously in this document.
• Growth factors.
• Control efficiency.
RE.
• Rule penetration.
6.3 Types of Emissions Projections
The Current Control Projection estimates projection year
allowable emissions, accounting for controls required in the SIP
by November 1990 (whether or not they have yet been implemented)
and growth. The Control Strategy Projection estimates projection
year allowable emissions accounting for future control strategies
(those that are not yet in the SIP) and growth. The Current
Control Projection incorporates growth between 1990 and 1996 and
adjusts the emissions to reflect existing regulatory or permit
conditions. The Control Strategy Projection builds on the
Current Control Projection by incorporating future control
strategies. These future control strategies may take the form of
areawide regulations affecting a source category or a specific
source.
The Current Control Projection is used to assess the
additional reductions needed by an area to meet 1996 rate-of-
progress (moderate and above areas must meet the 15 percent VOC
emissions reduction requirements, net of growth) and/or
attainment date deadlines (November 1993 for marginal areas and
November 1996 for moderate areas). The Current Control
Projection reflects existing control levels, which are adjusted
to reflect the allowable emissions factors or mass emissions
rates.
The Control Strategy Projection will reflect the controls
mandated by the CAAA, plus additional controls needed to meet
rate-of-progress targets. It is anticipated that several
iterations of the Control Strategy Projection will be completed
to determine the mix of control measures needed to meet the rate-
of -progress targets, taking into account the costs of these
measures.
6.4 Methods for Calculating Point, Area, and Mobile Source 1996
Projection Year Emissions
The following discussion is divided into separate sections
for point, area, and mobile sources, because the methods for
calculating the 1996 projection year emissions differ for these
three emissions source types. Detailed projection equations are
presented for'point sources. The equations presented for area
and mobile sources parallel those used within AIRS-AMS. The last
section is a brief discussion of the projection equations from
51
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EPS, which may also be used by the States to complete emissions
projections. The equations presented for point, area, and mobile
sources can be used to project either allowable or actual
emissions.
The EPA is in the process of developing a PC-based multiple
projections computer system to aid States in developing 1996
projected inventories. The equations used in this system will
parallel those used in EPS. Unlike EPS, however, the system will
be used strictly for preparing emissions projections rather than
as a preprocessor for preparing UAM inputs. The system will also
produce transaction files for uploading emissions projections to
AIRS after the necessary data elements have been added to AFS.
States may also complete their projections using the detailed
equations presented in the following sections. It is believed
that these detailed equations will provide the best emissions
projections. However, projection year inventories based on any
of these options will be accepted by EPA.
Point Source Emissions Projections
This section presents five equations for calculating the
1996 projection year emissions. The equations presented here
assume that the calculations will be on a source-specific basis.
The following data are needed to calculate 1996 projection year
emissions:
Base Year (1990) Data:
Operating rate (ozone season).
Emissions (ozone season).
Emissions factor.
Control efficiency (capture and control device
efficiency).
RE.
• Projection Year Data:
Growth factor.
Allowable limits — emissions' factor.
control efficiency. .
emissions rate.
RE.
•5rr.issi.cns 2-.LL~i.ri
^ ' ii. ^^^C^iJ \~fi3 -i ^~
s.r.issLcns ars calculated cy using emissions factcrs, the
crc~setter, year sr.issicns can be calculated in the sar.s manner
«-«5lS — *- ^ — . *~ w'->«rZr*- C% — — - .-^l — Gi *_ *^P ,'>'••>.«.* C^^IiS -fc'^AW.— Ci S- —>*_'.- SMT'-!. JTv^ll / ' ', v • N.J * /
test]- , the emissions projection calculation will be obtained by
-------
applying RE and growth factors to the 1990 emissions, rather than
being based on the operating rate.
The calculation methodology for the 1996 projected emissions
depends on the methodology used to calculate base year emissions
(emissions factor method or alternative), the data available, and
the form of the allowable emissions limits. Five equations are
presented below for projecting point source emissions. These are
followed by examples illustrating the situations for which the
equations are appropriate.
Some of the following equations use emissions factors for
coating sources that are expressed in terms of mass of VOC per
unit of production (e.g., Ib VOC/gal of coating). The regulatory
VOC RACT rules should already be expressed in terms of units such
as Ib VOC/gal of coating minus water and exempt solvents. In
calculating base- or future-year emissions, however, one must
maintain consistency between the VOC content and the production
units. If volume of coating, including water and exempt
solvents, is the only form of records kept for historical
production, then the VOC content must be adjusted from the
regulatory limit to be consistent with the units of production
used to calculate base- or future-year emissions.
Equation 1 - Projection calculated from base year operating rate,
uncontrolled or vrecontrol emissions factor, control efficiency,
RE, and growth factor
This equation should be applied when the base year emissions
are calculated by the emissions factor method and control
efficiencies are used to reflect current or future control
strategies. In these cases, the base year emissions are
calculated from the operating rate, base year emissions factor,
control efficiency (current or future), and RE.
The equation for projecting emissions in this case is:
EMISPY = ORATEBYi0 * EMFPYipc * [l - (f^j (Ł*SJ] '* GF (1 )
where: SMISpy = Projection year emissions - ozone season
typical weekday (mass of pollutant/day)
ORATEBY(0 = Base year operating rate (activitv
level) - ozone season daily (production
units/day)
EMFPY,PO = Projection year precontrol emissions
factor (mass of pollutant/production
unit)
CEpY = Projection year control efficiency
(percent)
53
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REPY' = Projection year RE (percent)
GF = Growth factor (dimensionless)
The precontrol emissions factor (EMFPYtpc) reflects the mass
of VOC per production unit emitted before control. In this case,
the control is reflected through the control efficiency rather
than through a reduced or post-control emissions factor.
If the projection year control efficiency and RE values
reflect current regulatory or permit conditions, then the
projection year emissions will be the Current Control Projection.
If the control efficiency and RE values reflect future control
strategies, then the emissions projection will be the Control
Strategy Projection.
Equation 2 - Projection calculated from base year operating rate,
allowable (post-control) emissions factor, RE, and growth factor
This equation should be applied when the base year emissions
are calculated by the emissions factor method and the emissions
factor accounts for the control level for the projection year.
The equation for projecting emissions in this case is:
(200 -
J - 1QQ * GF
where: EMISPY = Projection year emissions - ozone season
typical weekday (mass of pollutant/day)
ORATEg^o = Base year operating rate (activity
level) - ozone season daily (production
units/day)
EMFpy = Projection year (post -control) emissions
factor (mass of pollutant /product ion
unit)
REpY = Projection year RE (percent)
GF = Growth factor (dimensionless)
Current Control Projection emissions in this case are
calculated if the projection year emissions factor and RE values
represent current regulatory or permit conditions and/or actual
conditions where appropriate (see section 2.4 of this document).
Control Strategy Projection emissions in this case are calculated
if the projection year emissions factor and RE values represent
future control strategies or regulations developed to meet rate-
of -progress targets.
Equation (2) will be used- for emissions factor-based control
measures such as solvent content limits on surface coating.
These projections must also account for RE. The factor [(200 -
REPY)/100] adjusts emissions for RE. With a RE of 80 percent,
54
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emissions will be adjusted by a factor of 1.2. The impact of
applying RE in combination with a control efficiency varies as
follows:
Uncontrolled
Emissions
(Ib/day)
100
100
100
100
100
100
100
Control
Efficiency
(%)
99
98
95
90
80
50
30
Controlled
Emissions
(100% RE)
1
2
5
10
20
50
70
Controlled
Emissions
(80% RE)
20.8
21 .6
24.0
28.0
36.0
60.0
76.0
RE
Factor
20.8
10.8
4.8
2.8
1 .8
1 .2
1 .1
The factor [(200 - RE)/100] is equivalent to the impact (on
emissions) of applying RE to a 50 percent control efficiency.
If, for instance, the allowable (post-control) emissions factor
is converted to a percentage reduction from the precontrol
emissions factor and used as the projection year control
efficiency in equation (1), different results may be produced
depending on how much the resulting percentage reduction varies
from 50 percent. The [(200 - REpy)/100] factor is not valid for
low RE values.
Equation 3 - Projection calculated from base year actual
emissions, future control levels, EE, and growth factor
This equation will be used for processes where the base year
emissions are calculated by material balance, stack test, or any
method other than an emissions factor. This equation can be
applied without using the process or operating rate for the
source.
The equation for projecting emissions in this case is:
EMISBYi0 *
1 -
i -
CEBY\I REBY
100 A 100 ,
* GF
(3)
where:
EMIS.
EMIS
8Y,0
Projection year emissions - ozone season
typical weekday (mass of pollutant/day)
Base year ozone season actual emissions
(mass of 'pollutant/day)
55
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CEPV
REpy
GF
Projection year control efficiency
(percent)
Projection year RE (percent)
Base year control efficiency (percent)
Base year RE (percent)
Growth factor (dimensionless)
Current Control Projection emissions in this case will be
calculated if the projection year control efficiency reflects
existing regulatory or permit conditions. In this case, the
projection year and base year control efficiencies may be
equivalent if the base year control efficiency reflects allowable
conditions. Since base year emissions reflect actual rather than
allowable conditions, the base year control efficiency may be
higher than the allowable efficiency or the minimum control
mandated by existing regulations/permits.
Control Strategy Projection emissions in this case will be
calculated if the projection year control efficiency -reflects
future control measures.
Equation 4
emissions,
factor
- Projection calculated from base year actual
emissions factor-based control levels, RE, and growth
This equation will be used for processes where the base year
emissions are calculated by material balance, stack test, or any
method other than emissions factors. Equation (4) must be used
for emissions factor-based control measures such as solvent
content limits on surface coating if the operating rate is
unavailable. This equation differs from equation (3) in that
control levels are represented by emissions factors rather than
control efficiencies.
The equation for projecting emissions in this case is:
(200 -. REpr)
T ravfp*_..1
* GF
EMISPY = EMISBYt0 *
100
(200 - RESY)
100
I
EMF*
(4)
where:
EMIS
EMIS
REpy
REBy
EMFrv
PY
BY,O
Projection year emissions - ozone season
typical weekday (mass of pollutant/day)
Base year ozone season actual emissions
(mass of pollutant/day)
Base year RE (percent)
Projection year RE (percent)
Projection year emissions factor (mass
of pollutant/production unit)
56
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EMFBY = Base year actual emissions factor (mass
of pollutant /product ion unit)
GF = Growth factor (dimensionless)
Emissions for the Current Control Projectipn in this case
are calculated when the projection year emissions factor and RE
values represent existing regulatory or permit conditions. Under
the Current Control Projection, the projection year emissions
factor may be equivalent to the base year emissions factor if the
actual conditions are equivalent to (i.e., not more stringent
than) the regulatory or permit conditions.
Control Strategy Projection emissions in this case are
calculated by using the future control strategy emissions factor
and RE values in equation (4) .
These projections must also account for RE. The factor
[(200 - RE) 7100] adjusts emissions for RE. With a RE of
80 percent, emissions will be adjusted by a factor of 1.2.
This is equivalent to the impact (on emissions) of applying an
80 percent RE to a 50 percent control efficiency. If, for
instance, the allowable emissions factor is converted to a
percentage reduction from the precontrol emissions factor
and used as the projection year control efficiency in equation
(3) , different results may be produced depending on how much
the resulting percentage reduction varies from 50 percent.
The [(200 - RE)/100] factor is not valid for low RE values.
Equation 5 - Projection calculated from permitted emissions rates
Permits often express limitations in terms of mass emissions
rates (hourly, daily, monthly, or annual maximums) . These
emissions rates will require different processing than the
emissions factor limits described for equations (1), (2),
and (4). Long-term (e.g., annual) rates should be used as an
estimate of the allowable emissions. The long-term limit must be
converted to an ozone season typical weekday limit.
The equation for projecting emissions in this case is:
EMISpy = ERPY * ™>° (5)
EMISBY,Annual
where: EMISPY = Projection year emissions ozone
season typical weekday (mass of
pollutant /day)
ERpY = Projection year annual emissions
cap (mass of pollutant /year)
EMISgYi0 = Base year ozone season typical
weekday emissions (mass of
pollutant /day)
57
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EMISBY/Annuai = Base year annual emissions (mass of
pollutant/year)
The factor EMISBY/0/EMISBYfAnnual converts the long-term annual
emissions cap to an ozone season typical weekday emissions cap
using the ratio of base year ozone season typical weekday to
annual emissions. Note that the mass units (i.e., tons, pounds)
must be equivalent in both terms.
Emissions for the Current Control Projection are calculated
in this case if the annual emissions cap (ERpy) reflects current
permit conditions. Emissions for the Control Strategy Projection
are calculated if the annual emissions cap reflects the future
emissions cap for the source. If future regulatory or permit
conditions are in the form of emissions factor limits or control
efficiencies, then the Control Strategy Projection emissions
should be calculated using either equations (1), (2), (3), or
(4) .
Special Cases - Use of several equations
Some situations will not fall under a single method
identified above, but will require the use of several equations.
One situation requiring special processing is for facilities that
do not have process-specific limits but do have facility-wide
limits. An allocation should be developed to estimate process-
specific limits for the facility. The equations above could then
be used to calculate projection year emissions.
Emissions Projections Examples for Point Sources
The following examples illustrate the application of the
above equations for projecting emissions.
1. Surface Coating: Solvent Content Based Regulations
Base Year Ozone Season Operating Conditions:
Operating rate = 10 gal coating/day
Emissions factor = 2.6 Ib VOC/gal coating
(Base year emissions are calculated from the solvent
usage rate and the emissions factor. The emissions
factor must be in terms of VOC, excluding water and
exempt solvents)
Projection. Year Conditions:
Growth factor = 1.2 (dimensionless)
Current regulatory
emissions limit = 2.8 Ib VOC/gal
coating
Control efficiency = not required for
equation
RE = 80 percent
58
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Since the emissions limit is expressed in terms of an
emissions factor, equation (2) would be used to calculate
projection year emissions. The variables in equation (2) are:
ORATEBY>0 = 10 gal coating/day
EMFpy ' = 2.8 Ib VOC/gal coating
GF = 1.2 (dimensionless)
REpY = 80 percent
Projection year emissions are calculated as follows:
(200 - REPY)
EMISPY = ORATESYf0 * EMFPY * —
* GF
(2)
EMISPY = 10 * 2.8 *iOQ * 1.2
= 40.3 Ib VOC/day
Since the emissions factor represents current regulatory
conditions, this projection reflects the Current Control
Projection for this case. Rule effectiveness must be accounted
for in the emissions projection since not all sources may be
complying and future emissions are not calculated by direct
determination .
The State may decide to restrict this operation to the
2.6 Ib VOC/gal coating emissions level (2.8 Ib VOC/gal coating is
the requirement) or lower through a new regulation or by permit
conditions. The State would use this new emissions factor limit
to calculate projection year emissions for the Control Strategy
Projection for this case as follows:
Control Strategy Emissions Factor = 2.6 Ib VOC/gal coating
= 10 * 2 . 6 * " 8° * i . 2
100
= 37 . 4 Ib VOC/day
If the throughput is in units incompatible with the
emissions factor (VOC content) limit, then one of the parameters
must be converted for use in the equation. For example, flatwood
coaters may report operating rates in terms of 1 , 000 souare feet
coated. These ..units are compatible with the Federal (AP-42)
emissions factors but are incompatible with solvent -based limits.
In most cases, the facility should have records on the gallons of
59
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coating used for each process (prime coating, etc.). The average
gallons of coating per unit can be multiplied by the VOC limit to
yield a limit in terms of Ib VOC/unit produced. This could then
be used in equation (2).
This example illustrates the use of equation (2) for
emissions projections. Equation (2) is used for emissions
factor-based controls such as VOC limits. Equation (2) can only
be used if the base year operating rate is available. This
example also illustrates the difference between the Current
Control Projection and the Control Strategy Projection.
2. Surface Coating: No Throughput
If the throughput is unavailable, or is in units
incompatible with the base year and allowable emissions factor,
equation (4) must be used to calculate allowable emissions.
Material balances may be used to calculate base year emissions
rather than emissions factor methods which use throughput and
emissions factors.
Base Year Operating Conditions:
Emissions = 40 Ib VOC/day
Emissions factor = 2.6 Ib VOC/gal coating
Projection Year Conditions:
Growth factor = 1.2 (dimensionless)
Current regulatory/permit
emissions limit = 2.8 Ib VOC/gal coating
Variables in equation (4) are
EMISBY/0 = 40 GF
= oU KEgY
= 2.8 EMFBY
1.2
80
2.6
= EMI-SBYi0 *
r (200
- REpy.) ]
100 .
f (200
- **ar) 1
1 10° JJ
.[.
EMF
* GF
(4)
BY
SOS, - 40 .
Since the current regulatory or permit conditions are used
in the emissions projection calculation, Current Control
Projection emissions are calculated.
60
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This example uses equation (4) to project emissions.
Equation (4) is used for emissions factor-based control
strategies such as VOC limits. Equation (4) must be used if
operating rates are unavailable (if the operating rate is
available, equation (2) should be used) .
3. Surface Coating: Control Device Versus VOC Content
Limits
Surface coating regulatory conditions may be met by a
control device or by the use of low-solvent coatings. The
emissions factor should be converted to a "Ib VOC/gal solids
applied" basis for calculating emissions. Coatings that vary
widely in VOC content will also vary in solids content. More
lower-solids coating would be required to coat the same surface
area. This factor is accounted for by converting to the
Ib VOC/gal solids basis. (In example 1, which compared the
2.8 Ib VOC/gal coating to the 2.6 Ib VOC/gal coating, it was
assumed that the solids contents were equivalent. The accuracy
of this assumption decreases as the difference in VOC content
increases.)
Base Year Operating Conditions:
Operating Rate = 60 gal solids/day
VOC content = 3.5 Ib VOC/gal coating
Control efficiency = 0 percent
RE = N/A
Solids content = 52.4 percent
Solvent content = 47.6 percent
The base year emissions- factor is calculated as:
3.5 Ib VOC/gal coating * Jj?1 cofCin?., =6.68 Ib VOC/gal solids
0 .524 gal solids
The base year emissions are calculated as:
60 gal solids/day * 6.68 Ib VOC/gal solids = 400.8 Ib VOC/day
In the first case, assume the coater meets the regulatory
condition of 2.8 Ib VOC/gal coating by using low-solvent coating.
The projection year emissions would be calculated using
equation (2).
Projection Year Conditions:
Growth factor = 1.2 (dimensionless)
VOC content limit = 2.8 Ib VOC/gal coating
VOC density = 7.36 Ib VOC/gal VOC
=80 percent
61
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The projection year emissions factor is calculated as:
2.8 Ib VOC/gal coating * 713faj|.VSSc = 0.380 gal VOC/gal coating
1 - 0.380 - 0.620 gal solids/ gal coating
2.8 Ib VOC/gal coating * n \ fff1 c°atin?^ = 4.52 Jjb VOC/gal solids
0.620 gal solids s
Projection year emissions are calculated using equation (2)
EMISpy = ORATESYi0 * EMFPY * * GF
EMISPY =60 * 4.52 * * 1>2
= 390.5 Ib VOC/day
In the second case, assume the regulatory condition is in
the form of a control efficiency.
Projection Year Conditions:
Growth factor = 1.2 (dimensionless)
Control efficiency = 50 percent
RE =80 percent
Equation ( 1 ) is used to calculate proj ection year emissions as
follows :
* fl -
[
EMIS = 60 * 6 .68 * l - -- -- * 1.2
100 100
= 288.6 Ijbs VOC/day
This example illustrates the difference in the calculation
of projection year emissions for surface coating when a control
efficiency rather than a lower VOC content coating is specified
in the control measure.
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Control Efficiency-Based Regulations/Permits
Some permits and regulations specify a control device and
efficiency with which the source must comply. In these cases,
equation (1) or equation (3) would be used depending on the
availability of the base year operating rate.
In some cases, the regulatory condition or permit may be
exceeded by the source. Projection year emissions for the
Current Control Projection should be calculated using the
permitted rather than actual efficiency-
Base Year Conditions:
Emissions
Control efficiency
RE
Operating rate
Projection Year Conditions:
Growth factor
Permitted efficiency
RE
120 Ib VOC/day
98 percent
80 percent
not available
1.05 (dimensionless)
95 percent
80 percent
Equation (3) is used to calculate Current Control Projection
emissions as follows:
EMISBYi0 *
1 -
1 -
100 A 100
:)l
* GF
(3)
= 120 *
(1-(0.95) (0.80))
(1-(0.98) (0.30))
1 * 1.05 = 140 Ib/day
In order to retain the base year efficiency of 98 percent, a
permit modification would have to be made or a new regulation
would have to be promulgated changing the legally enforceable
efficiency to 98 percent. This would then be reflected in the
Control Strategy Projection.
This example illustrates the use of equation (3) for control
device/efficiency-based control strategies. Equation (1) or (3)
should be used for control efficiency-based strategies.
Equation (3) is used if the operating rate is unavailable.
63
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Synthetic Fiber Manufacturing - Carbon Adsorber Control
Equation (1) calculates proj ection year emissions from the
base year operating rate and projection year control information.
The base year operating rate "is grown to the projection year
using the growth factor.
The base year operating rate from the process is 30 tons of
product per day. The uncontrolled emissions factor is 90 Ibs of
VOC per ton of product. The future control strategy is to
install a carbon adsorber with an estimated overall control
efficiency of 60 percent. The variables in equation (1) are as
follows:
ORATE
EMF
BY,O
^ PY>pc
CEPY
REpy
GF
30 tons product/day
90 Ib VOC/ton product
60 percent
80 percent
1.3 (dimensionless)
These are applied to equation ( 1 ) as follows :
* GF
(1)
1,825 Ib VOC/day = 0.9 tons VOC/day
Since this reflected a future control strategy, the
emissions projection will be the Control Strategy Projection.
The Current Control Projection would be calculated using the
current control efficiency of zero, as follows:
ORATE3Yr0 * EMFPYrpc *
1 -
CEOV\ RE,
PY
100 } \ 100
* GF
(1
= 3,510 Ib VOC/day =1.8 tons VOC/day
64
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This example illustrates the use of equation ( 1 ) for
emissions projections. Equation (1) is used for control
efficiency-based strategies when the operating rate is known.
This example also illustrates the difference between the Current
Control Projection and the Control Strategy 'Projection.
6. Mass Emissions Limit-Based Permits
Many permits simply present mass emissions limits for the
process. These may be hourly (Ib/hr) , daily (Ib/day) , monthly
(tons /month) , annual (tpy) , or any combination of the above.
Permits with more than one limit may specify short- and long-
term limits that allow for seasonal or other fluctuations in
production. Other permits specify the short-term limit as simply
the long-term limit divided by the days or hours operated. This
type of specification does not allow for large fluctuations in
operation.
The long-term annual limits will be used for emissions
projections since these are more representative of expected
rather than maximum activity. These limits must be converted to
reflect ozone season typical weekday conditions. Annual limits
are converted using the ratio of base year ozone season emissions
to base year annual emissions.
Base Year Operating Conditions
Ozone season emissions =150 Ib/day = 0.075 tons/day
Annual emissions = 23 tpy
Projection Year Conditions
Current permit = 30 tpy
Equation (5) is used to calculate projection year emissions
as follows:
EMISPY - ERpr * Y'° (5)
EMISPY = 30 * [°-075] = 0.098 Cons /day = 196 Ib/day
[ 23 J
Since the limit used above reflects the current permit, the
emissions calculated are the Current Control Projection. This
example demonstrates the use of equation (5) for mass emissions
limit-based permits. If control efficiency or emissions factor
limits are available for the source, equations (1), (2), (3) , or
(4) should be use instead of equation (5).
65
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Under future control strategies, the State may control the
source through specified emissions factor limits, control device
specifications, or control efficiency limits. In these cases,
the State should use the appropriate equation [choosing from
equations (1) through (4)] to calculate Control Strategy
Projection emissions. These limits would take precedence over
mass emissions rate limits. If the State chooses instead to
lower the permitted mass emissions rate limits, equation (5)
would also be used in the Control Strategy Projection for this
source .
Area Source Emissions Projections
The current repository for base year area source emissions
inventories is the AMS of AIRS. The AMS has incorporated
emissions projections into the system design. The AMS projects
emissions using the following data:
• Activity Level (actual and limits) .
• Emissions Factor (actual and limits) .
• Growth Factor.
• Control Information — ^efficiency.
-------
BASE ACTIVITY LEVEL * GROWTH FACTOR NEW CONTROLS
BASE ACTIVITY LEVEL * GROWTH FACTOR
Thus, the State may enter a projection year limit. The
activity level for the "new controls" projection may
differ from the "base" projection. If activity limits
are not entered, the system will use actual activity.
PERIOD EMISSIONS FACTOR LIMIT NEW CONTROLS is the
period emissions factor limit for the new controls
projection. The hierarchy for selecting the emissions
factor is:
PERIOD EMISSIONS FACTOR LIMIT NEW CONTROLS
ANNUAL EMISSIONS FACTOR LIMIT NEW CONTROLS
PERIOD EMISSIONS FACTOR LIMIT
ANNUAL EMISSIONS FACTOR LIMIT
PERIOD EMISSIONS FACTOR
ANNUAL EMISSIONS FACTOR
Thus, the State may enter a projection year emissions
factor limit (allowable emissions factor). The factor
may be ozone season specific, or, if not entered, the
annual factor will be applied. The "limit new
controls" reflects the control strategy projection
whereas the "limit" reflects the baseline projection.
CEFF is the projected control efficiency.
REFF is the projected RE.
RPEN is the projected rule penetration.
The AMS equation also includes ash or sulfur content, the
fuel loading factor, the percent reactivity, and unit conversion
factors as applicable.
The AMS includes equations for calculating both the Current
Control Projection and the Control Strategy Projection. The
Control Strategy Projection is reflected in equation (6). The
Current Control Projection is similar with the Period Emissions
Factor Limit substituted for the Period Emissions Factor Limit
New Controls.
67
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The AMS equation can be rewritten using the terminology
presented in' equations (1) through (5) as follows:
f ( CEPY}( REPY PY i -7 \
EMISpr - ORATED . OT . M . l - __»_JS ( 7 )
where: EMISPY = Projection year emissions [ozone season
typical weekday allowable emissions
(mass of pollutant /day) ]
ORATEBYj0 = Base year activity level (operating
rate) - ozone season daily (production
units/day)
GF = Growth factor
= Projection year emissions factor (mass
of pollutant/production unit)
= Projection year control efficiency
(percent)
= Projection year RE (percent)
RPpY = Projection year rule penetration
(percent)
Note that while equation (6) does not include a growth
factor, the projection year activity level is used directly in
equation (6) and may be entered by the user. (In other words,
growth is still considered.) Alternatively, the projection year
activity level can be calculated in AMS from the base year
activity and a growth factor.
The major difference between the AMS equation and the point
source equations is the inclusion of the rule penetration factor.
The rule penetration accounts for the percentage of emissions
within the area source category that are covered by the
regulation. For example, a regulation may only affect sources
above 10 tpy, The rule penetration would be equivalent to the
percentage of emissions from sources above 10 tpy within the are;
source categcrv.
The AMS equation also differs in that activity level limits
may be entered in addition to actual or expected activity levels.
States should not enter activity level limits because emissions
-------
AIRS User/s Guide: AMS Data Storage. (See
reference 34.)
Mobile Source Emissions Projections
This section is divided into separate discussions on highway
vehicles and other mobile sources.
Highway Vehicle Emissions Projections
Highway vehicle emissions are projected by combining base
year VMT, VMT growth factors, and MOBILES.0 emissions factors.
The equation for calculating projection year emissions is:
EMISpy. = VMTBYf 0*GF*EMFPYio* CONV (8)
where: EMISPY = Projection year emissions [ozone season
typical weekday allowable emissions
(mass of pollutant/day)]
VMTBY.O = Base year ozone season daily VMT
GF ' = Growth factor
EMFPYf0 = MOBILES.0 emissions factor, projection
year (1996) ozone season
CONV = Units conversion factor
The effects of highway vehicle controls (i.e., new vehicle
standards, enhanced I/M, reformulated gasoline) will be -reflected
in the MOBILES.0 emissions factors. The effects of programs
designed to reduce VMT (e.g., TCM's such as employee trip
reductions) should be reflected in the growth factor for VMT. It
should be noted that these measures may also affect vehicle
speeds which, in turn, will affect the motor vehicle emissions
factors.
Highway vehicle projections should be completed at a
desegregated level represented by vehicle type and roadway class.
This is described in more detail in the motor vehicle inventory
guidance. (See reference 35.) The VMT growth factors should be
developed based on the VMT forecasting guidance developed by
EPA's Office of Mobile Sources (57 FR 9549, March 19, 1992).
Highway vehicle emissions projections can be completed
within AMS. Period (ozone season) projected emissions for 1996
are equivalent to the projection year emissions. The State
should obtain additional information on the data requirements and
format for AMS projection inventories and the interaction of
MOBILES.0 and AMS. This information is available in the AMS
manuals referenced in the previous section.
69
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Other Mobile Sources
Emissions must also be projected for aircraft, locomotives,
and other nonroad mobile equipment and vehicles. No new Federal
controls are expected to be in place by 1996 for these sources.
The 1990 emissions should be projected to future years based on
the expected growth in activity levels. These projections can be
completed within AMS following the methods described above for
area sources. The EPA's Office of Mobile Sources plans to
provide guidance on how to project growth from nonroad mobile
•equipment and vehicles.
Emissions Preprocessor System (EPS)
The EPS may be used by the States to calculate projection
year emissions. The EPS accepts work files from AFS and AMS that
contain information on base year emissions, including control
equipment, control efficiency, RE, and rule penetration. Ozone
season daily emissions should be used in EPS to meet the
requirements of the rate-of-progress plan.
The Control Emissions (CNTLEM) module allows the user to
simulate the effects of various control strategies on the
emissions. The user supplies projection factors reflecting
changes in activity levels (operating rates) by 2-digit SIC or
the first 4 digits of the ASC. The"user also supplies control
factors for CTG's, MACT, non-CTG RACT, highway vehicle controls,
and other•source- or source category-specific controls. The user
may also specify allowable emissions limits; however, these
limits must be expressed as emissions rate limits (tons per day) .
For the Current Controls Projection, the user should supply
control information for measures currently in the SIP including
CTG's, non-CTG RACT, and existing I/M programs. Motor vehicle
control factors (which represent ratios of future year to base
year MOBILE4.1 emissions factors) are created with a separate EPS
utility (MVADJ) . Enhancements to EPS, scheduled for the end of
January 1993, will include, updating the EPS motor vehicle utility
to MOBILE5.0.
For the Control Strategy Projection, the user should add
CAAA-mandated control measures and other control measures which
the State wishes to test. In general, States will begin with, the
CAAA-mandated measures and assess progress- towards the 15 percent
VOC emissions reduction requirement. If shortfalls in necessary
reductions exist, additional control measures must be considered.
The EPS applies all controls as replacement technologies.
Base year uncontrolled emissions are calculated from base year
actual emissions and the control parameters- Emissions are then
projected by applying the projection factor (or growth factor)
and the projection year control parameters. The end result is
70
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that emissions are projected using an equation similar to
equation (3) , as shown below.
EMISpY = EMISBy *
1 -
1 -
* GF
(9)
where:
EMI S
py
EMIS
BY
CEBy
REBY
RPBY
GF
Projection year emissions (mass of
pollutant/time)
Base year emissions (mass of
pollutant/time)
Projection year control efficiency
(percent)
Projection year RE (percent)
Projection year rule penetration
(percent)
Base year control efficiency (percent)
Base year RE (percent)
Base year rule penetration (percent)
Growth factor (dimensionless)
Since the controls are treated as replacement technologies,
the projection year control efficiency used may actually be lower
than the base year control efficiency. In defining source
category-specific controls, the user should be aware of any
individual sources within the category that are currently
required to achieve a greater reduction. These should be input
as source specific controls. The user should also ensure that
multiple control strategies (with the exception of CTG, non-CTG
RACT, and MACT strategies) are not applied to the same source.
This will lead to double-counting of controls. For example, if
the user specifies a RACT reduction of 50 percent and a
discretionary control of 90 percent, CNTLEM will first apply the
50 percent control and apply an additional 90 percent reduction
to the remaining emissions.
Allowable emissions for projection purposes are to be based
on emissions factor or control efficiency limits in combination
with expected activity. Allowable emissions limits must be input
to EPS in terms of mass per unit time (tons per day) . The user
must convert emissions factor limits to emissions rate limits.
Since control efficiency is a valid input, permitted control
efficiencies may be input for use in the emissions projections.
For sources using emissions factor limits, the emissions limit
may be calculated using the detailed equations presented earlier.
The projection year emissions can then be input as the allowable
emissions limit in EPS. These limits should be specified as
71
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replacement so that CNTLEM replaces the emissions projection for
the source with the user-specified limit.
Refer to the following user's guide for more detailed
instructions on EPS:
• User's Guide for the Urban Airshed Model - Volume IV:
User's Manual for the Emissions Preprocessor
System 2.0, Part A: Core FORTRAN System, and Part B:
Interface and Emissions Display System. [EPA-450/4-90-
007D(R)], U.S. Environmental Protection Agency, Office
of Air Quality Planning and Standards, Research
Triangle Park, NC. June 1992.
6.5 Effects of Equipment Replacement and New Source Requirements
Failure to consider the effects of equipment replacement and
NSPS requirements for an affected facility's existing capital
stock, may result in development of a SIP which requires more
emissions reductions than necessary to meet rate-of-progress
milestones or NAAQS attainment dates.
As an existing facility wears out and is replaced with newer
equipment, it may become subject to a NSPS. To the extent NSPS
requirements are more restrictive than present requirements on
the existing (not modified or reconstructed) facility, future
emissions will be reduced. The implications of such emissions
reductions can be assessed using the following formula:
Ext = [ (Eb - En} * (1 + r) exp t]
where: Ert = Emissions reductions in year t
Eb = Emissions in the base year
En = NSPS emissions
r = Annual replacement rate for worn out capital
stock
t = Years from the base year
Consequently, zero net growth emissions need not be the same
as baseline; they might actually be less.
Failure to consider the effect of offset requirements .-nay
also result in emissions reduction requirements greater than
necessary to meet rate-of-progress or NAAQS attainment dates.
•As additions to the existing capital stock become subject to
offset requirements greater than ,1:1, base emissions levels
should decrease. Such emissions reduction consequences of offset
requirements can be assessed using the following formula:
72
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Ext = [ (1 - Or) * Eb] * (l + gr) exp t
where: Ert = Emissions reductions in year t
Or = Offset ratio
Eb = Emissions in the base year
g = Annual growth rate
t = Years from the base year
A State may use the foregoing procedures in combination with
the previously presented equations to account for emissions
reductions that occur due to new major point source growth. The
annual replacement rate for worn out capital stock may be
calculated using replacement rates for various industrial
categories provided by the Internal Revenue Service in the most
recent version of their Publication 534, Depreciation, used for
preparation of income tax returns. (See reference 36.) The State
will have to determine the fraction of growth in a source
category that is due to major sources, which would have to meet
at least the NSPS limit and which would have to obtain emissions
offsets. That fraction should be based on representative recent
historical information (ratios of major source growth to total
growth) for the source category.
6.6 Submitting Projection Year Inventories and Supporting Data
Submission of the projection year inventory to EPA must
include:
• Hardcopy summary of emissions estimates.
• Documentation of methodology/procedures.
• Emissions projections in computerized format.
The level of documentation necessary will depend to some
extent on the procedures used in the emissions projections. For
example, if .growth factors from BEA or E-GAS are used in the
projections, required documentation would be limited to simply
stating this, since these are EPA-recommended sources for growth
factors. If nonrecommended sources of data, procedures, or
methodologies are used, documentation must be sufficient for Z?A
to duplicate calculations and make a judgment as to the
acceptability of the submission.
Emissions projections should be summarized in hardcopy form
and also submitted in computerized format. The computerized
format will depend on whether projections are completed using the
detailed equations, EPS, or the jiew software being developed by
SPA. Emissions projections will most likely be required to be
submitted through AIRS. More information on the computerized
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format for emissions projections will be available within the
next few months.
Since the data necessary to complete the inventories may
include confidential business information (operating rates) or
data that can lead to the calculation of t*his information
(emissions combined with emissions factors), EPA will allow
States to submit ratios of emissions factors (projection year to
base year) or operating rates, rather than the individual
factors/rates. States must have the individual data elements
available for EPA to spot-check. In addition, States must save
the background historical information in order to reproduce the
base year and projection year emissions inventories.
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7.0 CONTROL STRATEGIES FOR NO.
X
Nitrogen oxide emissions reductions occurring in the period
1990-1996 may not be substituted for VOC emissions reductions for
the rate-of-progress requirements. Nitrogen oxide emissions
reductions occurring in the period 1990-1996, in excess of growth
since 1990, may be considered as substitutes for VOC emissions
reductions for the post-1996 rate-of-progress requirements.
States may choose to pursue NOX control strategies to achieve
some portion of future VOC emissions reductions through this
substitution. The EPA expects to issue guidance for substitution
of NOX for VOC emissions reductions in the fall of 1993 for the
post-1996 period.
7-1 Stationary Source Controls
For extreme ozone nonattainment areas, section 183(e)(3) of
the Act requires certain boilers to implement clean fuels or
advanced control technology by November 15, 1998 (this
information should be included in a.SIP revision due by November
15, 1993). Affected boilers are individual new, modified, or
existing electric utility, industrial, or
commercial/institutional boilers that emit more than 25 tpy of
NOX. The Act specifies, for purposes of this section, that clean
fuels are "natural gas, methanol, or ethanol (or a comparably low
polluting fuel)," advanced control technology generally means
"catalytic control technology or other comparably effective
control methods," and the clean fuel must be "used 90 percent or
more of the. operating time." [See General Preamble, section
III.A.6.d (57 FR 13523).]
For further information on applicable NOX controls for
stationary sources, States should refer to NOX RACT rules, as
well as NOX ACT documents (see Appendix J for list of ACT's) . In
the event that the ACT's are not released soon enough, some
control strategies might be found by consulting the BACT/LAER
Clearinghouse and/or NS?S (see Appendix J).
Under Title IV of the Act, the acid deposition program
requires NOX emissions reductions from tangentially fired boilers
and dry bottom wall-fired boilers (see Proposed Rule 57 FR 55622'
tangentlally f^red cellars 'see 57 ??. 55632 for di.scus3i.cr. cf
these technologies and techniques) . The acid deccs^-^cn prcccsed
rule also allows for alternative technologies under certain
conditions such as returning, selective cataly-lc reduction, and
selective nencatalvt^c reductlcn \ncne of these alternative
technologies -should be deemed oeVered by RACT, however).
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The air quality programs in California, specifically for the
South Coast, Ventura, San Diego, Santa Barbara, and Kern County
may also incorporate additional NOX stationary source controls.
These programs also required nonstationary source controls such
as controls on lawn equipment and pleasure boats, and the
requirement that all new homes be built with solar water heaters
[the specific air quality offices should be contacted for
information].
7.2 Area Source Controls
States may also elect to have control measures for area
sources even though the CAAA do not specifically require them.
For instance, California .has adopted rules covering home heaters.
Appendix J contains two rules that are part of the California
SIP—both are SCAQMD rules. The growth in NOX emissions due to
new housing developments that would use natural gas fired heaters
could be particularly offset by such a requirement.
Below is a list of present and future NOX home heating
rules, that either are not currently part of the SIP or are
scheduled for adoption in early 1993 or 1994. Contact the
appropriate Air Pollution Control District (APCD) or Air Quality
Management District (AQMD) for more information.
Ventura APCD Gas-Fired Water Heaters Rule 74.11
El Dorado APCD Residential Wood Combustion 1/93
Residential Space Heating 2/93
Residential Water Heating 3/94
Kern County APCD Residential/Commercial Water 1/93
Heaters
Bay Area AQMD Residential Water Heaters 1993
Residential Wood Combustion 1993
7.3 Mobile Source Controls
States may take credit for certain NOX emissions reductions
achieved through implementation of TCM's and enhanced I/M
programs. Emissions reducri.on.s may also occur chrough oonrrol of
r.cnroad engines, bui: these reductions .-nay not be realized ur.ci.1
after 2000 due to the phase-in schedule (note that the CAAA
applies to new engines only; the State would have ~o adopt a
separate rule for rebuilt engines) .
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8.0 ATTAINMENT DEMONSTRATION
This section explains the attainment demonstration
requirements for the SIP for moderate and above ozone
nonattainment areas, presents the modeling tools that can be used
for attainment demonstrations/ and discusses several unique air
quality situations that can affect the SIP attainment
demonstration. It should be noted that both biogenic and
anthropogenic emissions are included in the modeling domain and
both must also be included in the development of the attainment
demonstration.
8.1 Requirements for Moderate and Above Nonattainment Areas
Section 181(a)(1) establishes a schedule for attainment of
the NAAQS for ozone for the nonattainment areas classified as
marginal and above, based on the design value for the area.
Section 182(b)(1)(A) requires a SIP for moderate and above
nonattainment areas to provide for VOC and NOX emissions
reductions necessary to attain the standard. This "showing" of
attainment by a SIP is the attainment demonstration. For
moderate areas (other than multi-State nonattainment areas) this
requirement can be met through the application of an EPA-approved
model and EPA-approved modeling techniques described in the
•current version of the Guideline on Air Quality Models. (See
reference 37.)
Two models are suggested: UAM or EKMA. The General
Preamble should be consulted regarding the attainment
demonstration implications of using each model (57 FR 13510). If
EKMA is used, the attainment demonstration is due by November 15,
1993. States choosing to run UAM for their intrastate moderate
areas must submit their 15 percent rate-of-progress plan and a
committal SIP addressing the attainment demonstration. The
committal SIP subject to a section 110(k)(4) approval would
include, at a minimum, evidence that grid modeling is well under
way and a commitment, with schedule, to complete the modeling and
submit it as a SIP revision by November 15, 1994. The completed
attainment demonstration would include any additional controls
needed for attainment. For further discussion of committal
SIP's, see July 9, 1992 memorandum from John Calcagni, Director,
Air Quality Management Division, OAQPS, to Regional
concerning "Processing of. State Ir.pl em en
(S_P) Submittais."
States should plan to achieve emissions reductions as early
in the process as possible, since section 181 (b%? (2X requires IPA
to make a determination as to whether an area has attained the
ozone NAAQS within 5 months following an applicable atta^r.-ent
-ate. This requirement dictates^the use of the most recent
3 years of air quality data, which means EPA will use 1SS4-1996
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data in determining whether a moderate area has attained the
ozone NAAQS. [See the General Preamble (57 FR 13509).]
8.2 Requirements for Serious and Above Nonattainment Areas
Serious and above nonattainment areas must, through their
SIP's, provide an attainment demonstration by November 15, 1994.
The attainment demonstration for these areas must be based on
photochemical grid modeling, such as UAM.
8.3 Modeling Considerations
Empirical Kinetic Modeling Analysis (EKMA)
The use of EKMA is described in Guideline for Use of City-
Specific EKMA in Preparing Ozone SIP/s (see reference 38), as
well as the Guideline on Air Quality Models (see reference 39),
and should be consulted, along with the appropriate EPA Regional
Office, before an analysis is conducted with this modeling
approach.
Urban Airshed Model (UAM)
The use of UAM, a photochemical grid model, is recommended
or required for modeling applications involving -all areas
classified serious and above, and for all interstate moderate
areas.
The UAM is described in Guideline for Regulatory Application
of the Urban Airshed Model (see reference 40), and the User's
Guide for the Urban Airshed Model (see reference 41). These
documents and the appropriate EPA Regional Office should be
consulted before an analysis is conducted with this modeling
approach.
8.4 Special Air Quality Situations
Areas Requiring Emissions Reductions in Excess of 15 Percent
There will be circumstances under which a moderate area will
be able to show attainment of the NAAQS can be achieved only
through VOC emissions reductions in excess of the 15 percent vcc
emissions reduction mandated in section 182(b)(1)(A)(i). Th:_s
condition may exist for an area that has a design value at the
top of the range (0.138 to 0.159 ppm) of the moderate
nonattainment classification, where there is a heavy
concentration of VOC sources in a smaller area of the
nonattainment area, or when atmospheric conditions favor the
formation of ozone. The underlying requirement of the SIP for
these areas is the attainment of the standard by the attainment
date, not solely the achievement of the 15 percent VOC emissions
reduction.
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Areas Requiring Emissions Reductions Less Than 1 5 Percent
Section 182(b)(1)(A)(ii) allows moderate, serious, and
severe ozone nonattainment areas to reduce VOC emissions by less
than 15 percent if the following conditions are met. First, the
State must demonstrate that the area has a new source review
(NSR) program equivalent to the requirements in extreme areas
[section 182(e)], except that a "major source" must include any
source that emits, or has the potential to emit, 5 tpy. All
major sources (down to those with emissions of 5 tpy or greater)
in the area must be required to have RACT-level controls. The
plan must also include all measures that can be feasibly
implemented in the area, in light, of technological achievability-
To qualify for the lesser percentage, the State must demonstrate
that the SIP includes all measures (both stationary and mobile)
that are achieved in practice by sources in the same source
category in nonattainment areas of the next higher
classification.
Rural Nonattainment Areas
Section 182(h) addresses the situation of a rural area
downwind of a larger urban area and classified as a nonattainment
area due to the transport of ozone and ozone precursors from the
larger upwind urban area. A rural area is treated as a transport
area if the EPA Administrator finds that sources of VOC and NOX
emissions within the area do not make a significant contribution
to the ozone concentrations measured in the area or in other
areas. The only requirements for these areas are the
requirements specified in section 182(a) for marginal areas, the
assumption being that the controls in the upwind area will solve
the problem in the rural transport area as well.
Section 185(e) provides a further exemption for small areas
unable to attain the ozone standard due to transport of ozone and
its precursors from other areas. A small area, defined as an
area with a total population under 200,000, is exempt from all
sanctions if the area can demonstrate that attainment is
prevented because of ozone or ozone precursors transported from
other areas. The exemption applies only if the area has met all
other applicable requirements of the CAAA.
Section 182(j) defines and establishes recuirender,-3 for
ozcne nonattainment areas covering areas in more tr.an cr.e State
called multi-State nonattainment areas. Beyond the requirement:3
in section 182 for the classification of the ncnat~a^r.nier-z areas
(marginal, moderate, serious, severe, extreme, transport1 .
section "32(jj (') requires Stares in these areas tc coordinate
the revisions" and implementation of the SIP's applicable tc the
nonattainment areas and tc use photochemical grid mccelir.cr -icr
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another method determined by EPA) as part of the SIP-preparation
process.
Each State in a multi-State nonattainment area should
develop and submit to EPA a joint work plan to demonstrate early
cooperation and integration. The work plan should include a
schedule for developing the control strategies and the attainment
demonstration for'the entire multi-State area. The work plans
should also reference the applicable modeling protocol. The work
plan should be submitted by the State Air Directors to the
Regional Air Division Directors no later than May 31, 1993. Each
State should write their own letter for their appropriate
Regional Office and send a copy to the other States in the
nonattainment area for review (see Appendix I for an example
model letter). Please note that States should check with their
Regional Offices on appropriate schedule dates. For example,
some States may negotiate dates through the 105 grants process.
Section 1.82 (j) (2) recognizes that an area in one State
within the multi-State nonattainment area may not be able to
demonstrate attainment "but for the failure of one or more other
States, in which other portions of the area are located, to
commit to the implementation of all measures required by section
182 " If the EPA Administrator makes a finding that this
situation is occurring, the sanctions of section 179 shall not
apply to the petitioning State. Section II.A.9 of the General
Preamble provides the primary guidance for these nonattainment
area SIP's. Appendix I of this document contains a model letter
written by EPA as guidance to multi-State planners.
International Border Areas
Section 179B of the Act applies to nonattainment areas that
are affected by emissions emanating from outside the United
States. This section provides relief for nonattainment areas
along international borders analogous to what is provided to
States within multi-State nonattainment areas by section 182(j):
EPA shall approve the SIP if it meets all the requirements in the
CAAA and if the State establishes that the implementation of the
plan would be adequate to attain and maintain the relevant NAAQS
"but for emissions emanating from outside the United States."
Section 179B (created by Title VIII, section 818 of the CAAA) and
section Y.C of the General Preamble provide SI? guidance for
areas on international borders.
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9.0 CONTINGENCY MEASURES
The Act require that States with areas of moderate or higher
levels of nonattainment include contingency' measures in their
SIP's [sections 172(c)(9) and 182(c)(9)]. The contingency
measures in these plans describe the additional controls to be
implemented in the event of an attainment or milestone failure.
Section 172(c) (9) of the Act pertains to nonattainment area
failures to demonstrate either attainment or RFP. Section
182(c)(9) requires SIP contingency measures for serious and above
area milestone failures.
The SIP's for moderate and above nonattainment areas must
include provisions for the implementation of contingency measures
without further State or EPA action. Sections 172(c) (9) and
182(c) (9) specify that the contingency measures shall "take
effect without further action by the State or the Administrator."
The EPA interprets this requirement to mean that no further
rulemaking activities by the State or the EPA should be needed to
implement the contingency measures. The EPA recognizes that
certain actions, such as notification of sources or modification
of permits, would probably be needed before a measure could be
implemented effectively. States must show that their contingency
measures can be implemented with minimal further action on their
part and with no additional rulemaking activities such as public
hearings or legislative review. In general, EPA will expect all
actions needed to affect full implementation of the measures to
occur within 60 days after EPA notifies the State of its
attainment or milestone failure.
9.1 Marginal Areas
Section 182(a) specifically exempts marginal nonattainment
areas from the contingency measures requirement stated in section
172(c)(9).
Although marginal areas are excluded from the requirement
for contingency measures in their SIP's, marginal areas should
carefully consider contingency measures in case an area does not
attain by the 1993 date. This issue arises because of the short
planning and implementation time frame (3 years) available
between the attainment dates for marginal and moderate areas.
If a marginal area fails to attain by its November 15, 1993 date,
it will become subject to all of the requirements for moderate
areas, specifically the I/M program, RACT, and the 15 percent VOC
emissions reduction requirements. The additional moderate
nonattainment area requirements would have to be met after
reclassification and the standard would have to be attained by
November 15, 1996, an extremely tight- time frame for these
provisions if, no prior planning and adoption actions had
occurred. If the area then misses the November 15, 1996
attainment date, the area would again be reclassified and,
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therefore, subject to the more stringent requirements of serious
areas. This is also an important issue for marginal areas.
Appendix H describes in more detail the process following the
finding of a milestone or attainment failure for marginal and
moderate areas.
9.2 Moderate and Above Areas
Ozone nonattainment areas classified as moderate or above
must include in their SIP submittals, due by November 15, 1993,
contingency measures to be implemented in the event of an
attainment or milestone failure. This contingency submittal date
is appropriate because States must submit demonstrations on that
date that show the 15 percent VOG emissions milestone will be
achieved in 1996. Under sections 182(g)(1) and 182(g)(2),
demonstrations of milestone compliance are not required when a
nonattainment area's milestone and attainment dates are identical
and the area is determined to have attained (e.g., a serious area
that is found to have attained the standard by November 15, 1999,
is not obligated to demonstrate that the 1996-1999 milestone was
achieved because November 15, 1999, is also the milestone date
for serious areas). It should be remembered that in developing a
maintenance plan for an area that is redesignated attainment, the
State must show that its SIP was fully implemented.
The CAAA do not specify how many contingency measures are
needed or the magnitude of emissions reductions that must be
provided by these measures. Assuming that all of the State
measures may fail to produce their expected reductions, one
interpretation of the CAAA is that a State would have to adopt
sufficient contingency measures in the November 15, 1993, SIP
submittal to make up for this entire shortfall. The EPA believes
that this would be an unreasonable requirement given the
difficulty many States already have in identifying and adopting
sufficient measures to meet the rate-of-progress and other CAAA
requirements.
Contingency measures should, at a minimum, ensure that an
appropriate level of emissions reduction progress continues to be
made while the State plans additional control measures.
Therefore, as stated in section III.A.3.c of the General Preamble
(57 FR 13498), EPA interprets the CAAA*to require States with
moderate and above ozone nonattainment areas to include
sufficient contingency measures in the November 15, 1993
submittal so that, upon implementation of such measures,
additional emissions reductions of up to 3 percent of the
emissions in the adjusted base year inventory would be achieved
in the year following that in which the attainment failure has
been identified. These emissions reductions are in addition, to
those that are already scheduled to occur in accordance with the
general control strategy for the area. This provision ensures
that (1) progress toward attainment occurs at a rate similar to
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that specified under the rate-of-progress requirements, and (2)
the State will achieve these reductions while developing and
implementing additional control measures to correct for the
shortfall in emissions reductions or adopting newly required
measures resulting from the bump-up to a higher classification.
States must identify the order in which the contingency measures
will be implemented and the percentage reductions that are
projected for each contingency measure.
It is important to note that the EPA only requires that
contingency measures be implemented to compensate for the degree
of failure. In other words, a shortfall of 2 percent requires
implementation of sufficient measures to make up for the
2 percent, not the 3 percent (or possibly more, as discussed
below) . If EPA determines that a shortfall of less than
3 percent exists in a nonattainment area, EPA will select
individual control measures from the initial 3 percent
contingency plan as prioritized by the State until the shortfall
is covered. For example, four measures equaling a 3 percent VOC
reduction from the adjusted base year inventory are included in
an area's contingency plan. Contingency measures are listed
within the plan in the order that they would be implemented. The
first two measures are projected to result in a 1 percent VOC
reduction each, while the last two are projected to produce a
0.5 percent reduction each. If a 1 percent shortfall is
identified, the first contingency measure would be implemented;
if a 2.5 percent shortfall is identified, then the first three
contingency measures would be implemented.
Under this approach, the State would have 1 year to modify
its SIP and take other corrective action needed to ensure that
milestones are achieved and that rate-of-progress towards
attainment continues. The EPA believes that 1 year to revise the
SIP is appropriate in most cases as this is consistent with the
time frame of other rate-of-progress requirements. If a State
needs significantly longer than 1 year to revise its SIP (perhaps
due to the length of the State's legislative process) , then the
State is expected to provide for additional contingency measures'
commensurate with the length of time necessary for the SIP
revision. For example, if the State anticipates that it will
require 2 years to revise its SIP, then the plan should include
contingency measures that will produce 6 percent emissions
reductions (3 percent per year).0 In the case of moderate areas,
contingency measures would be needed when an area incurs an
attainment failure (or, for serious and above areas, if the area
incurs either an attainment or a milestone failure). If, for
Similarly, if the State's SIP revision process is shorter than
1 year, contingency measures providing proportionally less than
3 percent will be acceptable (e.g., 1.5 percent reduction for a
6-raonth revision time frame).
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example, a moderate area fails to attain, it will be bumped-up to
a higher classification and become subject to the requirements
that apply to this new classification. The contingency measures
would be implemented while the State would develop and adopt the
new measures associated with its new classification.
One way that States can meet the contingency measures
requirement is by providing for early implementation of measures
before the dates scheduled in the overall SIP control strategy.
That is, a State may include as a contingency measure the
requirement that control measures that would be implemented in
later years, would instead be implemented earlier if the area
either does not meet its milestone or attain the NAAQS by the
applicable date. For example, a severe area has control measure
A scheduled for implementation in June 1.998. Control measure A
is also included in its contingency plan. The area fails to meet
the 1996 milestone and elects to implement its contingency plan.
Control measure A is then implemented in October 1997. Areas
that implement control measures from their overall SIP control
strategy as a contingency measure must develop new measures to
backfill both the control strategy and the contingency plan.
Within 1 year of the triggering of a contingency requiring the
early implementation of control measures, the State must submit a
SIP revision containing whatever additional provisions are needed
to backfill the SIP to remedy any eventual' shortfall that may
occur as the result of the early use of the control measures.
The EPA expects any control measures that are implemented early
as part of a contingency plan will remain in place (or be
superseded by replacement control measures) until the next
milestone. At the next milestone, the State can demonstrate
whether or not these control measures are needed to stay on
track.
The EPA believes that a 3 percent contingency will be
adequate for most areas but, in some cases 3 percent may be
inadequate, especially if corrective action is not instituted in
a timely manner prior to a milestone date. To address the
possibility of a greater than 3 percent shortfall, EPA requires
moderate and above areas to submit contingency measures providing
for a 3 percent reduction as well as an enforceable commitment to
submit an annual tracking program describing the degree to which
it has achieved its projected annual emissions reduction.
Compliance for this requirement will be to participate in EPA's
tracking efforts and respond accordingly. Because EPA believes I .
it is necessary to assess the progress of States during the '
interim periods between plan submittals and milestone compliance
determinations, it is developing a computer system to track the
States' rate-of-progress plans. " It is anticipated that this
system will be utilized by EPA to develop tracking reports chat
estimate the percentage reduction, in VOC. emissions. States would
review these reports and revise them if they do not agree with
EPA's tracking assessment. Two options are available to States
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when a shortfall is determined by the annual tracking reports.
First, the State may describe in its follow-up report what
actions it will take before the next milestone to make up for
this shortfall [i.e., adopt and implement additional measures
(apart from the contingency measures) ] to avoid a milestone
failure. For example, if annual tracking shows a 2 percent
shortfall/ the State could include in this follow-up tracking
report additional control measures (equaling the 2 percent
shortfall) to be implemented before the milestone demonstration.
As an alternative to this approach, the State may provide for
extra contingency measures sufficient to cover the additional
shortfall expected by the milestone demonstration date. Under
this approach, the State must submit to EPA within 1 year from
the submittal of the follow-up report, the additional measures
that will be needed to remedy the shortfall. Thus, more than the
3 percent of contingency measures would be available in reserve,
even though EPA would only require that sufficient contingency
measures be implemented to compensate for the degree of failure.
For example, if annual tracking determines a 2 percent shortfall,
the State could include in its next annual tracking report
additional contingency measures (equaling -the 2 percent
shortfall) to be implemented if the milestone demonstration •
ascertains a shortfall of more than 3 percent.
Sections 172(c)(9>, 182(c){9), and 187(a)(3) of the Act
specify that the contingency measures shall "take effect without
further action by the State or the Administrator." The EPA
interprets this requirement to mean that no further rulemaking
activities by the State or EPA would be needed to implement the
contingency measures. The EPA recognizes that certain actions,
such as notification of sources and modification of permits,
would probably be needed before a measure could be implemented
effectively. States must show that their contingency measures
can be implemented with minimal further action on their part and
with no additional rulemaking actions such as public hearings or
legislative review. In general, EPA will expect all actions
needed to effect full implementation of the measures to occur
within 60 days after EPA notifies the State of its failure.
9.3 Serious and Severe Areas
Within 90 days of a serious or severe area milestone
failure, the CAAA require that States elect one of three options.
If a State elects to implement measures from the applicable
contingency plan, then the EPA will review the plan within
90 days and make a determination as to whether further measures
are necessary to meet the milestone. The contingency measures
could be additional measures not already adopted to meet RF? cr
other requirements, or the accelerated implementation of measures
already planned to meet a future "milestone. In this later case,
the State would have to adopt additional measures to backfill the
SIP with replacement measures to replace those that were
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previously used as early-implementation contingency measures, and
to assure the continuing adequacy of the contingency program.
[See section III.A.4.p.of the General Preamble (57 FR 13498).]
States are encouraged to implement measures as soon as a
milestone failure is deemed likely. States that wait until the
milestone failure occurs will have extremely limited time
available to implement and evaluate the measures before the next
milestone is met.
9.4 Nonclassifiable Areas
Nonclassifiable areas include transitional, submarginal, and
incomplete/no data areas. Section 185A exempts transitional
areas from the Subpart 2 rules until December 31, 1991. It is
not clear from the CAAA, however, which of the Subpart 1
provisions are required of transitional areas, and in particular,
if contingency measures are required. Because these areas have
design values that fall below the moderate nonattainment area
designation, and because marginal areas are exempt from the
contingency measure requirement, the CAAA are interpreted as not
requiring contingency measures for nonclassifiable areas. If the
transitional areas are reclassified as a moderate or higher
nonattainment area, however, they would be subject to the
contingency measures requirement of that particular
classification (again, marginal areas are exempt from the
requirement). [See section III.A.7.a.7 of the General Preamble
(57 FR 13498).]
Because submarginal and incomplete/no data areas generally
present ozone problems "that are less serious than marginal areas,
which are expressly exempted from the contingency measures
requirement, and contingency measures are not likely to be
necessary to ensure attainment for these areas, EPA believes that
. it is not appropriate to apply the contingency measure
requirement for these areas under a de minimis approach.
Nevertheless, contingency measures are required as part of the
maintenance plan for nonclassifiable or other nonattainment areas
that are redesignated attainment by EPA; these contingencies are
discussed in a September 4, 1992 memorandum from John Calcagni,
Director, Air Quality Management Division, OAQPS, to Regional Air
Division Directors, concerning "Procedures for Processing
Requests to Redesignate Areas to Attainment."
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9.5 Examples
Some examples of contingency measures for these areas
include:
• Measures required by the next higher classification.
• Transportation control measures.
An employer trip reduction program.
• An economic incentive program. The EPA has published a
"Notice of Proposed Rulemaking" for economic incentive
programs (58 FR 11110, February 23, 1993). The final
rule will be codified in 40 CFR Part 51 . Appendix W of
the proposed rule (58 FR 11130-11132) includes examples
of stationary and mobile source control measures for
economic incentive programs. Examples of mobile source
control measures (discussed on pages 11131 and 11132 of
the Federal Register notice) which could be used as
contingency measures include, but are not limited to,
the following:
Fee Programs — Road pricing mechanisms are fee
programs that are available to curtail low occupancy
vehicle use, fund transportation system improvements
and control measures, spatially and temporally shift
driving patterns, and attempt to effect land usage
changes. Primary examples include increased peak
period roadway, bridge, or tunnel tolls (this could
also be accomplished with automated vehicle
identification systems), and toll discounts for pooling
arrangements and zero-emitting/low-emitting vehicles.
Tax Code Provisions — Mobile source tax code incentive
strategies include waiving or lowering any of the
following for zero or low-emitting vehicles: vehicle
registration fees, vehicle property tax, sales tax,
taxicab license fees, and parking taxes.
Subsidies — A State may create incentives for reducing
emissions by offering direct subsidies, grants, or low
interest loans to encourage purchase of lower-emitting
capital equipment or a switch to less-polluting
operating practices. Examples of such programs include
clean vehicle conversions, starting shuttle bus or van
pool programs, and mass transit fare subsidies.
Preretirement Reduction Program — An example would
include an old car scrappage program.
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88
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REFERENCES
1 . Guidance on the Adjusted Base Year Emissions Inventory and
the 1996 Target for the 15 Percent Rate-of-Progress Plans.
EPA-452/R-92-005, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. October 1992.
2. BEA Regional Projections to 2040, Volume I: States, U.S.
Department of Commerce, Bureau of Economic Analysis,
(Washington, DC: U.S. Government Printing Office). October
1990.
3. BEA Regional Projections to 2040, Volume II: Metropolitan
Statistical Areas', U.S. Department of Commerce, Bureau of
Economic Analysis, (Washington, DC: U.S. Government
Printing Office). October 1990.
4. BEA Regional Proiections to 2040, Volume III: BEA Economic
Areas, U.S. Department of Commerce, Bureau of Economic
Analysis, (Washington, DC: U.S. Government Printing
Office). October 1990.
5. Procedures for Preparing Emissions Proiections, EPA-450/4-
91-019, U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle Park, NC.
July 1991.
6. Depreciation: for Use in Preparing 1992 Returns,
Publication No. 534, Catalog No. 150640, U.S. Department of
Treasury, Internal Revenue Service, Washington, DC.
7.'' A Prelection Methodology for Future State Level Volatile
Organic Compound (VOC) Emissions from Stationary Sources
Version 2.0. EPA-600/8-88-090, U.S. Environmental Protection
Agency, Air and Engineering Research Laboratory, Research
Triangle Park, NC. July 1988.
8. User's Guide for the Urban Airshed Model. Volume IV; User's
Manual for the Emissions Preprocessor System 2.0. Part A:
Core FORTRAN System, and Part B: Interface and Emissions
Display System, EPA-450/4-90-007D(R), U.S. Environmental
Protection Agency,- Office of Air Quality Planning and
Standards, Research Triangle Park, NC. June 1992.
9. Reference 5.
10. Control Techniques for Volatile Organic Compound Emissions
from Stationary Sources, EPA-453/R-92-018 (Revises EPA-
450/2-78-O22), U.S. Environmental Protection Agency, Office
of Air Quality Planning and Standards, Research Triangle
Park, NC. December 1992.
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11. OAOPS Control Cost Manual, EPA-450/3-90-006, U.S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
January 1990.
12. Technical Guidance - Stage II Vapor Recovery Systems for
Control of Vehicle Refueling Emissions at Gasoline
dispensing Facilities, EPA-450/3-91-022a, U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC. November 1991.
13. Enforcement Guidance for Stage II Vehicle Refueling Control
Programs. Draft, U.S. Environmental Protection Agency,
Office of Mobile Sources, Ann Arbor, MI. December 1991.
14. Procedures for Emission Inventory Preparation, Volume IV:
Mobile Sources. EPA-450/4-81-026d (Revised), U.S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. 1992.
1 5. Transportation Control Measure Information Documents, draft,
U.S. Environmental Protection Agency, Office of Mobile
Sources, Ann Arbor. MI. October 1991.
16. Transportation Control Measures: State Implementation Plan
Guidance, U.S. Environmental Protection Agency, Office of
Mobile Sources, Ann Arbor, MI. September 1990.
1 7. Evaluation of Travel Demand Management Measures to Relieve
Congestion, Report No, FHWA-SAi-90-005, U.S. Department of
Transportation, Federal Highway Administration,
Washington, .DC. February 1990.
18. Feasibility and Cost-Effectiveness of Controlling Emissions
from Diesel Engines in Rail. Marine, Construction, Farm, and
Other Mobile Off-Highway Equipment. U.S. Environmental
Protection Agency, Office of Policy Analysis,
Washington, DC. February 1988.
19. Summary of Group I Control Technique Guideline Documents for
Control of Volatile Organic Emissions from Existing
Stationary Sources, EPA-450/3-78-120, U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC. December 1978.
20. Issues relating to VOC Regulation Cutpoints, Deficiencies,
and Deviations: Clarification to Appendix D of November 24,
1987 Federal Register, (no document number issued), U.S.
Environmental Protection Agency, Office'of Air Quality
Planning and Standards. May 25, 1988 (revised January 11,
1990) .
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21. Summary of Group II Control Technique Guideline Documents
for Control of Volatile Organic Emissions from Existing
Stationary Sources. EPA-450/2-80-001 , U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC. 1980.
22. Reference 20.
23. "Volatile Organic Compounds (VOC) Rules for Reasonably
Available Control Technology (RACT)," Memorandum from
G.T. Helms, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Ozone and Carbon
Monoxide Programs Branch, Research Triangle Park, NC, to
Regional Division Directors. June 24, 1992.
24. Reference 20.
•
25. Air Emissions from Municipal Solid Waste Landfills -
Background Information for Proposed Standards and Emission
Guidelines. EPA-450/3-90-011 (a) , U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC. March 1991.
26. Enabling Document for Regulations Governing Compliance
Extensions for Early Reductions of Hazardous Air Pollutants,
EPA-450/3-91-013, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. July 1991.
27. Questions and Answers about the Early Reductions Program,
EPA-450/3-92-005, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. January 1992.
28. Procedures for Establishing Emissions for Early Reduction
Compliance Extensions, EPA-450/3-91-012a, U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC. February 1992.
29. Coke Oven Emissions from Wet-Coal Charged Bv-Product Coke
Oven Batteries - Background Information for Proposed
Standards, EPA-450/3-85-028a, U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. 1987.
30. Hazardous Waste TSDF's - Technical Guidance Document for
RCRA Air Emissions for Process Vents and Eguioment Leaks,
EPA-450/3-89-021, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. July 1990.
91
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31 . Hazardous Waste TSDF/s - Background Information for Proposed
RCRA Air Emissions Standards. EPA-450/3-89-023a,b,&c,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
June 1991. (Note: This reference is three volumes.)
32. Guidelines for Estimating and Applying Rule Effectiveness
for Ozone /CO State Implementation Plan Base Year
Inventories . EPA-452/R-92-010, U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Ozone
and Carbon Monoxide Programs Branch, Research Triangle Park,
NC. November 1992.
33. Workshop on Requirements for Nonattainment Area Plans, No.
1.2-102, U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards. Revised Edition of April
1978.
34. AIRS User/s Guide: AMS Data Storage, U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC. June 1992.
35. Reference 14.
36. Reference 6.
37. Guideline on Air Quality Models. EPA-450/2-78-027R, U.S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
July 1986.
38. Guideline for Use of Citv-Specific EKMA in Preparing Ozone
SIP's, EPA-450/4-80-027, U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. 1980.
39. Reference 37.
40. Guideline for Regulatory Application of the Urban Airshed
Model . EPA-450/4-91-01 , U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. 1991.
'Jser'3 Guide for the Urban Airshed Model, SPA-450/4-90-007,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. 1990.
42 . Reference 5 .
44. Reference 1 .
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APPENDIX A: DEFINITION OF TERMS
This appendix provides the specific definitions of EPA terms
as they are used in this guidance. Different EPA programs
sometimes use different definitions of the same term (e.g., major
source). This appendix notes where conflicts occur in the
definition of a term used in this guidance. These definitions
are presented for the purposes of this guidance document only;
the reader is advised to refer to specific regulations, policies,
and sections of the Act to obtain complete definitions for the
program or title of interest.
Area Source Any stationary or nonroad source that is too small
and/or too numerous to be included in the stationary point-source
emissions inventories.
Attainment Demonstration Moderate and above ozone nonattainment
areas must demonstrate that the reductions specified in the
revised SIP will result in -modeled air quality for the
nonattainment area that achieves attainment by the applicable
attainment date. This requirement can be met through the
application of an EPA-approved model and EPA-approved modeling
techniques described in the current version of the Guidance on
Air Quality Models,6 which is currently under revision. Two
models are suggested: the UAM or EKMA. The EPA requires the
submittal of attainment demonstrations employing UAM for serious
and above areas and multi-State moderate areas as part of the SIP
revision due by November 15, 1994. Attainment demonstrations
based on EKMA for moderate nonattainment areas within a single
State (intrastate moderate areas) must be submitted as part of
the SIP revision due by November 15, 1993, unless the State
chooses to use UAM, in which case the demonstration must be
submitted as part of the SIP revision due by November 15, 1994.
The use of EKMA is described in Guideline for Use of City-
Specific EKMA in Preparing Ozone SIP's,7 as well as the
aforementioned guideline that is under revision. This document,
and the appropriate EPA Regional Office, should be consulted
before an analysis is conducted with this modeling approach. The
6Guidance on Air Quality Models (Revised), EPA-450/2-78-027R,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. July 1986
(currently under revision).
7Guideline for^ Use of City-Specific EKMA in Preparing Ozone
SIP's, EPA-450/4-80-027, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. 1980.-
A-1
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use of UAM is described in Guideline for Regulatory Application
of the Urban" Airshed Model."8
Attainment Determination The EPA must determine within .6 months
after the applicable attainment date whether an area has attained
the NAAQS for ozone. The attainment dates are as follows:
Marginal areas — November 15, 1993.
Moderate areas — November 15, 1996.
• Serious areas — November 15, 1999.
Severe areas — November 15, 2005 (severe areas
with a 1986-1988 ozone design value
of 0.190 up to, but not including,
0.280 parts per million have until
November 15, 2007).
• Extreme areas — November 15, 2010.
In making the attainment determination, EPA will use the most
recently available, quality-assured air quality data covering the
3-year period preceding the attainment date. For ozone, the
average number of exceedances per year after adjustment for
missing data are used to determine whether the area has attained.
Basic Inspection and Maintenance (I/M) Programs requiring the
inspection of vehicles including, but not limited to, measurement
of tailpipe emissions, and mandating that vehicles with tailpipe
emissions higher than the program outpoints be repaired to pass a
tailpipe emissions retest. Basic I/M programs must be at least
as stringent as the requirements set out in section 182(a)(2)(B).
Manor Stationary Source The Act has multiple definitions for
major stationary sources depending upon the nonattainment
classification and the pollutant. Section 302 of the Act defines
a major stationary source as one that directly emits, or has the
potential to emit, 100 tpy or more of any air pollutant. As
exceptions to this rule, major stationary source emissions
thresholds, as defined in Part D of Title I of the Act, are
listed in Table A-1 for both VOC and NOX sources.
Milestone Compliance Demonstration For serious and above
classified nonattainment areas, demonstrating achievement of the
15 percent VOC emissions reduction over the 1990-1996 period, or
demonstrating subsequent 3 percent VOC emissions reductions per
year averaged over each consecutive 3-year period from
November 15, 1996 until the attainment date. Section 182(g)(2)
requires that within 90 days of the date on which an applicable
8Guideline for Regulatory Application of the Urban Airshed Model,
EPA-450/4-91-013, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park, NC.
1991.
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TABLE A-1. MAJOR SOURCE THRESHOLDS AND MINIMUM EMISSIONS OFFSET
RATIO REQUIREMENTS FOR OZONE NONATTAINMENT AREA CLASSIFICATIONS
Ozone Nonattainment Area
voc
(tpy)9
(tpy)
Minimum
Emissions
Offset Ratio
•Required
Extreme
Severe
Serious
Moderate
Moderate, in an ozone
transport region
Marginal
Marginal, in an ozone
transport region
All other nonattainment areas,
outside of an ozone
transport region11
All other nonattainment areas,
in an ozone transport
region11
Attainment, in an ozone
transport region
10
25
50
100
50
100
50
100
100
50
10
25
50
100
100
-100
100
100
100
100
1.5 to 110
1.3 to 110
1.2 to 1
1.15 to 1
1.15 to 1
1.1 to 1
1.15 to 1
>1.0 to 1
1.15 to 1
1.15 to 1
tpy = tons per year.
10The minimum ratio is reduced to 1.2 to 1 if the applicable
State implementation plan requires all major sources of VOC and
NOX emissions to use best available control technology.
11 The other nonattainment areas are submarginal, transitional,
and incomplete/no data.
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milestone occurs (not including an attainment date on which a
milestone occurs in cases where the standard has been attained),
States with'nonattainment areas must submit a demonstration that
the milestone has been met (e.g., the 15 percent VOC emissions
reduction is demonstrated by February 13, 1997). The EPA expects
to release regulations pertaining to the requirements of the
milestone demonstration in the summer of 1993.
1990 Adjusted Base Year Inventory Section 182(b)(1)(B) and (D)
describe the inventory (hereafter referred to as the adjusted
base year inventory) from which moderate and above ozone
nonattainment areas must achieve a 15 percent reduction in VOC
emissions by 1996. This inventory is equal "the total amount of
actual VOC or NOX emissions from all anthropogenic (man-made)
sources in the area during the calendar year of enactment,"
excluding the emissions that would be eliminated by Federal Motor
Vehicle Control Program (FMVCP) regulations promulgated by
January 1, 1990, and Reid vapor pressure (RVP) regulations (55 FR
23666, June 11 / 1990), which require specific maximum RVP levels
for gasoline in particular nonattainment areas during the peak
ozone season. The 1990 rate-of-progress base year inventory
(defined below) removes biogenic emissions and emissions from
sources listed in the base year inventory that are located
outside the nonattainment area. The adjusted base year inventory
removes the emissions reductions from the FMVCP and RVP program
from the 1990 rate-of-progress base year inventory. The adjusted
base year inventory, which is due by November 15, 1992, is used
to calculate the required 15 percent reductions.
Adjusted Base Year Emissions Inventory = Base Year Emissions
Inventory, minus the following:
• Biogenic source emissions.
• Emissions from sources outside of the nonattainment
area boundary.
• Emissions reductions from the FMVCP.
• Emissions reductions from the RVP rules.
1990 Base Year Inventory The 1990 base year inventory is an
inventory of actual annual and typical weekday peak ozone season
emissions that States use in calculating their adjusted and
projected inventories, and in developing their control strategy.
The base year inventory comprises emissions for the area durincr
the peak ozone season, which is generally the summer months. it
includes anthropogenic sources of NOX and CO emissions, and both
anthropogenic and biogenic sources of VOC emissions. Also
included in the inventory are emissions from all stationary point
sources and area sources as well as highway and nonhighway mobile
sources located within the nonattainment area, and stationary
sources with emissions of 100 tpy or more of VOC, NOX, and CO
emissions within a 25-mile wide buffer zone of the designated
nonattainment area. The base year inventory contains off-shore
A-4
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sources located within the nonattainment area boundaries and off-
shore stationary sources with emissions of 100 tpy or greater of
VOC, NOX/ or CO emissions within the 25-mile wide buffer area.
For nonattainment areas that will perform photochemical grid
modeling (e.g., serious and above areas and multi-State moderate
areas), emissions for the entire modeling domain, which is
usually larger than the nonattainment area because ozone is an
areawide problem, are required in the modeling inventory. This
modeling inventory could be submitted with the base year
inventory, or the modeling inventory submittal could be in a
separate package. It is important to note that the 1990 base
year inventory serves as the starting point for all other
inventories.
1990 Rate-of-Progress Base Year Inventory The 1990 rate-of-
progress base year inventory is an accounting of all
anthropogenic VOC, CO, and NOX emissions in the nonattainment
area. This emissions inventory is calculated by removing
biogenic emissions and the emissions from sources that are
located outside of the nonattainment area from the base year
inventory. This inventory is used in developing the adjusted
base year inventory. It is also used as the basis from which to
calculate the 1996 target level of emissions.
1996 Target Level Of Emissions The 1996 target level of
emissions is the maximum amount of ozone season VOC emissions
that can been emitted by an ozone nonattainment area in 1996 for
that nonattainment area to be in compliance with the 15 percent
rate-of-progress requirements. It is calculated by first taking
15 percent of the adjusted base year inventory emissions. This
emissions value is then added to the expected emissions
reductions due to the FMVCP and RVP program, and from corrections
to any deficient RACT rules and I/M programs. The summation of
the 15 percent, the expected reductions from deficient I/M and
RACT programs, and reductions from the FMVCP and RVP program are
then subtracted from the 1990 rate-of'-progress base year
inventory to arrive at the 1996 target level of emissions. This
target is used by States to design their 15 percent VOC emissions
reduction control strategies. The projected contr.ol strategy
inventory used in the rate-of-progress plan must be at or below
the 1996 target level of emissions to demonstrate that the
15 percent VOC emissions reduction will be accomplished.
1996 Target Level of Emissions = Rate-of-Progress Base Year
Inventory, minus the following:
• 15 percent of the adjusted base year inventory
emissions.
• Emissions reductions from corrections to any deficient
RACT rules.
• Emissions reductions from corrections to deficient I/M
programs.
A-5
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• Emissions reductions from the pre-1990 FMVCP-
• Emissions reductions from RVP rules.
Peak Ozone Season The contiguous 3-month period of the year
during which the highest ozone exceedance days have occurred over
the 3 to 4 years prior to the 1990 base year. Most ozone
nonattainment areas have a peak ozone season lasting from June
through August.
Offset Ratios For the purpose of satisfying the emissions offset
reduction requirements of section 173(a)(1)(A), the emissions
offset ratio is defined as the ratio of total actual emissions
reductions of VOC [and NOX unless exempted under section 182(f)]
obtained as offsets from existing sources to total allowable
emissions increases of such pollutant from the new source. (See
Table A-1 for a list of offset ratios by nonattainment area.)
Additional information on the credibility of offsets toward the
15 percent VOC-emissions reduction requirements, net of growth,
will be provided in an EPA document entitled Guidance on the
Relationship Between the 15 Percent Rate-of-Progress Plans and
Other Provisions of the Clean Air Act. This document will be
released in the spring of 1993.
Point Source Any stationary source that has the potential to
emit more than some specified threshold level of a pollutant or
is identified as an individual source in a State's emissions
inventory. For base year SIP inventory purposes, point sources
are defined as sources emitting 10 tpy or more of VOC emissions
or 100 tpy or more of NOX or CO emissions.
Post-1996 Rate-of-Progress Plan The post-199.6 rate-of-progress
plan is the portion of the SIP revision due by November 15, 1994,
which describes how serious and above areas plan to achieve the
post-1996, 3 percent per year VOC emissions reductions averaged
over each consecutive 3-year period from November. 15, 1996 until
the attainment date. This SIP revision also includes the
attainment demonstration for moderate interstate nonattainment
areas and serious and above nonattainment areas.
RACT "Catch-ups" RACT "catch-up" refers to the application of
RACT for all applicable sources as listed in section 182(b)(2),
regardless of what was previously required. Each moderate and
above ozone nonattainment area (as well as attainment areas
within the ozone transport region) are subject to the RACT
"catch-up" requirement of section 182(b)(2). The new law
requires any of the above areas that had not previously been
required to adopt RACT consistent with all of the CTG's to
"catch-up" and apply RACT to all sources covered by a pre-
enactment or post-enactment CTG document. Many- of"these areas
were not previously required to apply RACT to sources covered by
the Group III CTG documents (i.e., CTG documents published after
September 1982). In addition, areas previously considered rural
A-6
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nonattainment, which had to apply RACT only to certain major
sources in certain CTG categories under prior policy, will have
to revise their SIP's to apply RACT to all sources, including
nonmajor sources, that are covered by any CTG. The RACT "catch-
up" provision also requires these nonattainment areas to adopt
RACT rules for all major sources not covered by a CTG.
Additional information on the RACT "catch-up" program will be
provided in forthcoming guidance regarding the interaction of
RACT rules with emissions inventories.
RACT "Fix-ups" These are corrections States are required to make
under section 182 (a) (2) (1) to their current RACT rules to make up
for deficiencies (e.g., improper exemptions) in preamendment
plans. Under RACT "fix-ups," States are required to have RACT
rules that comply with section 172(b) of the pre-1990 Act, as
interpreted by EPA's preamendment guidance. Since the RACT "fix-
up" provisions refer to RACT as required by preamended section
172(b), only areas subject to preamended section 172(b) need to
meet the RACT "fix-up" requirement. Therefore, for nonattainment
areas that will be expanded to contain regions that were
designated attainment prior to enactment, the RACT corrections
are only for the original nonattainment area. The RACT "fix-up"
provision essentially codifies EPA's SIP calls, issued in May
1988 and November 1989 [as announced in the Federal Register on
September 7, 1988 (53 FR 34500) and July 30, 1990 (55 FR 30973)].
The RACT fix-ups were due on May 15, 1991. Between May 24 and
June 24, 1991, EPA's Regional Offices mailed letters to several
Governors and air agency officials concerning the progress of the
States in meeting RACT "fix-up" requirements and listing the
deficiencies remaining. Additional information on the RACT "fix-
up" program will be provided in forthcoming guidance regarding
the interaction of RACT rules with emissions inventories.
Rate-of-Progress Plan The portion of the SIP revision due by
November 15, 1993, that describes how moderate and above ozone
nonattainment areas plan to achieve the 15 percent VOC emissions
reduction. All moderate intrastate areas that choose to utilize
the EKMA in their attainment demonstrations, are also required to
include their attainment demonstration in this SIP revision.
Rule Effectiveness (RE) For stationary sources, a measure of the
extent to which a regulatory program achieves emissions
reductions. An RE of 100 percent reflects a regulatory program
achieving all the emissions reductions that could be achieved by
full compliance with the applicable regulations at all sources at
all times. However, regulations typically are not 100 percent
effective due to limitations of control techniques or
shortcomings in the implementation and enforcement process. The
EPA allows the use of several different methods for determining
RE including-: . an 80 percent default value, results from EPA
questionnaires, or results from a Stationary Source Compliance
Division (SSCD) study.
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Volatile Organic Compound Any compound of carbon, excluding CO,
carbon dioxide, carbonic acid, metallic carbides or carbonates,
and ammonium carbonate, which participates in atmospheric
photochemical reactions. This includes any. organic compound
other than those EPA has determined to have negligible
photochemical reactivity (57 FR 3945, February 3, 1992).
A-8
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APPENDIX B: REFERENCES FOR CTG AND ACT DOCUMENTS FOR
STATIONARY VOC SOURCES
Group I CTG Documents for Stationary VOC Sources
Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume I; Control Methods for Surface Coating
Operations, EPA-450/2-76-028, U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, NC. November 1976.
Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume II: Surface Coating of Cans, Coils, Paper,
Fabrics, Automobiles, and Light-Duty Trucks, EPA-450/2-77-008,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. May 1977.
Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume III: Surface Coating of Metal Furniture,
EPA-450/2-77-032, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park, NC.
December 1977.
Control.of Volatile Organic Emissions from Existing Stationary
Sources - Volume IV: Surface Coating for Insulation of Magnet
Wire. EPA-450/2-77-033, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. December 1977.
Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume V: Surface Coating of Large Appliances.
EPA-450/2-77-034, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park, NC.
December 1977-
Control of Volatile Organic Emissions from Bulk Gasoline Plants,
EPA-450/2-77-035, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park, NC.
December 1977.
Control of Volatile Organic Emissions from Storage of Petroleum
Liguids in Fixed-Roof Tanks, EPA-450/2-77-036, U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. December 1977.
Control of Refinery Vacuum Producing Systems, Wastewater
Separators, and Process Unit Turnarounds, SPA-450/2-77-025,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
October 1977.
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Control of Volatile Organic Compounds from Use of Cutback
Asphalt. EPA-450/2-77-037, U.S. Environmental Protection Agency.-
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. December 1977.
Control of Hydrocarbons from Tank Truck Gasoline Loading
Terminals. EPA-450/2-77-026, U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, NC. October 1977.
Design Criteria for Stage I Vapor Control Systems - Gasoline
Service Stations, (no document number issued), U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. November 1975.
Control of Volatile Organic Emissions from Solvent Metal
Cleaning. EPA-450/2-77-022, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. November 1977.
Summary of Group I Control Technigue Guideline Documents for
Control of Volatile Organic Emissions from Existing Stationary
Sources, EPA-450/3-78-120, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. December 1978.
Group II CTG Documents for Stationary VOC Sources
Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume VI: Surface Coating of Miscellaneous Metal
Parts.and Products. EPA-450/2-78-015, U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. June 1978.
Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume VII: Factory Surface Coating of Flat Wood
Paneling, EPA-450/2-78-032, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. June 1978.
Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume VIII: Graphic Arts - Rotogravure and
Flexoaraphv, EPA-450/2-78-033, U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, NC. December 1978.
Control of Volatile Organic Compound Leaks from Petroleum
Refinery Eguipment, EPA-450/2-78-036, U.S. Environmental
Protection Agency, Office of Air Quality Planning- and Standards,
Research Triangle Park, NC. June 1978.
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Control of Volatile Organic Emissions from Petroleum Liquid
Storage in External Floating Roof Tanks. EPA-450/2-78-047,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
December 1978.
Control of Volatile Organic Compound Leaks from Gasoline Tank
Trucks and Vapor Collection Systems. EPA-450/2-78-051,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
December 1978.
Control of Volatile Organic Emissions from Manufacture of
Synthesized Pharmaceutical Products, EPA-450/2-78-029,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
December 1978.
Control of Volatile Organic Emissions from Manufacture of
Pneumatic Rubber Tires, EPA-450/2-78-030, U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. December 1978.
Summary of Group II Control Technique Guideline Documents for
Control of Volatile Organic Emissions from Existing Stationary
Sources, EPA-450/2-80-001, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. December 1979.
Group III CTG Documents for Stationary VOC Sources
Control of Volatile Organic Compound Emissions from Large
Petroleum Dry Cleaners, EPA-450/3-82-009, U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. September 1982.
Control of Volatile Organic Compound Emissions from Manufacture
of High-Density Polyethylene, Polypropylene, and Polystyrene
Resins. EPA-450/3-83-008, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. November 1983.
Control of Volatile Organic Compound Equipment Leaks from Natural
Gas/Gasoline Processing Plants, EPA-450/2-83-007,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
December 1983.
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Control of VOC Fugitive Emissions from Synthetic Organic
Chemical, Polymer, and Resin Manufacturing Equipment,
EPA-450/3-83-006, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park, NC.
March 1984.
Control of Volatile Organic Compound Emissions from Air Oxidation
Processes in Synthetic Organic Chemical Manufacturing Industry,
EPA-450/3-84-015, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park, NC.
December, 1984.
Procedures for the Preparation of Emission Inventories for Carbon
Monoxide and Precursors of Ozone Volume I: General Guidance for
Stationary Sources, Appendix C, EPA-450/4-91-016,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. May 1991.
New CTG Documents for Stationary VOC Sources
Appendix E of the General Preamble (57 FR 18077) discusses
EPA's plans for publishing new CTG documents. The EPA must issue
11 CTG documents by November 15, 1993. The 11 source categories
for which EPA plans to issue CTG documents are as follows:
(1) SOCMI distillation; (2) SOCMI reactors; (3) SOCMI batch
processing; (4) wood furniture; (5) plastic parts coating
(business machines); (6) plastic parts coating (other); (7) web
offset lithography; (8) industrial wastewater; (9) autobody
refinishing; (10) volatile organic liquid storage in floating
and fixed-roof tanks; and 11) clean-up solvents. In addition,
section 183(b) of the Act specifically requires EPA to prepare
CTG documents for aerospace coatings and solvents, and for
paints, coatings, and solvents used in ship building and repair
by November 15, 1993.
As of March 1993, none of the new CTG documents have been
finalized. The following discusses the most recent background
information or draft CTG document available.
SOCMI Reactor Processes and Distillation Operations
Control of Volatile Organic Compound Emissions from Reactor
Processes and Distillation Operations Processes in the
Synthetic Organic Chemical Manufacturing Industry, draft
CTG, U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research. Triangle Park, NC.
This document is expected to be finalized in the spring of
1993.
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SOCMI Batch Processes
Control of Volatile Organic Compound Emissions from Batch
Processes, draft CTG, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. September 1991.
Coating of Wood Furniture
Control of Volatile Organic Compound Emissions from Wood
Furniture Coating Operations, draft CTG (chapters 1-5),
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
October 1991.
Coating of Plastic Parts
Surface Coating of Plastic Parts Control Techniques
Guideline, draft CTG, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. October 1, 1991.
Web Offset Lithography
Offset Lithographic Printing Control Techniques Guideline,
draft CTG, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park,
NC. 1991.
Industrial Wastewater
As of March 1993, a draft CTG document for industrial
wastewater has not been prepared. The following document for
BACT/LAER determinations may be consulted for information on
control techniques for industrial wastewater.
Industrial Wastewater Volatile Organic Compound Emissions -
Background Information for BACT/LAER Determinations.
EPA-450/3-90-004, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. January 1990.
Autobodv Refinishinq
Automobile Refinishina Control Techniques Guideline, draft
CTG, U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle Park, NC.
September 27, 1991. [Note: The EPA originally intended to
issue a CTG document for autobody refinishing. However, EPA
has decided to prepare a national rulemaking instead of
issuing a CTG document. For further information on the
status of the rulemaking, contact Ms. Ellen Ducey of EPA's
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Office of Air Quality Planning and Standards [(919) 541-
5408)]. .
Volatile Organic Liquid Storage in Floating'and Fixed-Roof Tanks
Control of Volatile Organic Compound Emissions from Volatile
Organic Liquid Storage in Floating and Fixed-Roof Tanks,
draft CTG, U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park,
NC. September 30, 1991.
Clean-Up Solvents
As of March 1993, a draft CTG document for clean-up solvents
has not been prepared.
Aerospace Coatings and Solvents
As of March 1993, a draft CTG document for aerospace
coatings and solvents has not been prepared. A background
information study of aerospace coating facilities in California
has been completed by the EPA Region IX Office in conjunction
with several local California air quality control agencies.
Aerospace coatings include radiation coatings, thermocontrol
coatings, electrostatic discharge coatings, fuel tank coatings,
and all other protective coatings. Emissions may occur during
application of the prime coat, during lubricant application, and
while topcoating. No emissions limits, costs, or monitoring
techniques have been established for controls on this industry.
Ship Building Operations and Ship Repair
The EPA is preparing a CTG document for controlling VOC
emissions from ship building operations and ship repair. A draft
CTG document is planned for release in the fall of 1993. A final
CTG document is planned for release in the fall of 1994. The CTG
document will contain information on the VOC'emissions sources
associated with ship building operations and ship repair, VOC
emissions estimates, best available control measures, and control
cost estimates.
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ACT Documents for Stationary VOC Sources
Haloaenated Solvent Cleaners. EPA-450/3-89-030, U.S.
Environmental Protection Agency, Office of Air Quality Planning
and Standards, Research Triangle Park, NC. August 1989. [Note:
This ACT document discusses five halogenated solvents; four of
which are exempted from the definition of VOC. Trichloroethylene
is the only solvent discussed in the document which is classified
as a VOC. Trichloroethylene emissions reductions may be
creditable toward the 15 percent VOC emissions reduction
requirements, net of growth. However, emissions reductions for
solvents exempted from the definition of VOC are not creditable
toward the 15 percent requirements. ]
Reduction of Volatile Organic Compound Emissions from Application
of Traffic Markings, EPA-450/3-88-007, U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. August 1988.
Ethvlene Oxide Sterilization/Fumigation Operations, EPA-450/3-89-
007, U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. March 1989.
Reduction of Volatile Organic Compound Emissions from Automobile
Refinishiner. EPA-450/3-88-009, U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, NC. October 1988.
Organic Waste Process Vents. EPA-450/3-91-007, U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. December 1990.
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APPENDIX C: BACKGROUND INFORMATION DOCUMENTS FOR
STATIONARY VOC SOURCES SUBJECT TO NEW SOURCE
PERFORMANCE STANDARDS (NSPS) AND NATIONAL EMISSION
STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
This appendix lists the NSPS and NESHAPS that EPA has
promulgated for stationary sources of VOC emissions, and cites
the CFR references and BID numbers for the NSPS and NESHAPS. The
NSPS are national standards that affect new, modified, or
reconstructed stationary sources. The NESHAPS are national
standards for controlling HAP's from existing and new stationary
sources. Only the NESHAPS that control HAP's that are also
classified as VOC are presented in this appendix.
Each of the NSPS and NESHAP regulations define the affected
facility or facilities. The reader should consult the relevant
CFR reference for details on the definition of the affected
facility or facilities; the emissions standards; and
recordkeeping, reporting, monitoring, and emissions testing
requirements. The BID'S contain technical information on the
emissions sources and emissions, alternative controls considered
during the development of the standards, the performance of the
alternative controls evaluated, and estimated control costs.
Subpart A of 40 CFR Part 60 contains the General Provisions
for NSPS. Subpart A discusses the applicability of NSPS;
provides definitions of terms; and contains general requirements
(including but not limited to) that address recordkeeping,
performance tests, monitoring, reconstruction, and modification.
Subpart B of 40 CFR Part 60 contains requirements for adoption
and submittal of SIP's for designated facilities.
Subpart A of 40 CFR Part 61 contains the General Provisions
for NESHAPS. Subpart A provides definitions of terms, and
contains general requirements (including but not limited to) that
address prohibited activities, the determination of construction
or modification, application for approval of construction or
modification, notification of .startup, recordkeeping, reporting,
monitoring, and emissions testing.
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New Source Performance Standards
Source Category
Emissions guidelines and
compliance times for
municipal waste combustors
Municipal waste combustors
Storage vessels for
petroleum liquids for which
construction,
reconstruction, or
modification commenced
after 6/11/73 and prior to
5/19/78
Storage vessels for
petroleum liquids for which
construction,
reconstruction, or
modification commenced
after 5/18/78 and prior to
7/23/84
Volatile organic liquid
storage vessels (including
petroleum liquid) for which
construction ,
reconstruction, or
modification commenced
after 7/23/84
Surface coating of metal
furniture
Automobile and light -duty
truck surface coating
operations
Graphic arts industry:
publication rotogravure
printing
Pressure sensitive tape and
label surface coating
operations
Industrial surface coating
of large appliances
Metal coil surface coating
SOCMI equipment leaks
Beverage can surface
coating industry
Bulk gasoline terminals
Reference :
40 CFR Part 60
Subpart Ca
Subpart Ea
Subpart K
Subpart Ka
Subpart Kb
Subpart EE
Subpart MM
Subpart QQ
Subpart RR
Subpart SS
Subpart TT
Subpart W
Subpart WW
Subpart XX
BID Number (s)
EPA-450/3-89-027
a,b,c,&e
APTD-1352a&b
EPA-450/2-74-003
EPA-450/3-81 -003a&b
EPA-450/3-80-007a&b
EPA-450/3-79-030a&b
EPA-450/3-80-031a&b
EPA-450/3-80-003a&b
SPA-450/3-30-037a&b
EPA-450/3-80-035a&b
EPA-450/3-80-033a&b
[
\
EPA-450/3-80-036a&b
EPA-450/3-80-038a&b
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New Source Performance Standards (Continued)
Source Category
Rubber tire manufacturing
industry
Polymer manufacturing
industry
Flexible vinyl and urethane
coating and printing
Petroleum refineries:
equipment leaks
Synthetic fiber production
facilities
SOCMI air oxidation unit
processes
Petroleum dry cleaners
On-shore natural gas
processing plants
SOCMI distillation
operations
Petroleum refinery
wastewater systems
Magnetic tape coating
facilities
Surface coating of plastic
parts for business machines
Polymeric coating of
supporting substrates
facilities
Reference :
40 CFR Part 60
Subpart BBB
Subpart DDD
Subpart FFF
Subpart GGG
Subpart HHH
Subpart III
Subpart JJJ
Subpart KKK
Subpart NNN
Subpart QQQ
Subpart SSS
Subpart TTT
Subpart VW
BID Number (s)
EPA-450/3-81 -008a&b
EPA-450/3-83-01 9a&b
EPA-450/3-81 -01 6a&b
EPA-450/3-81 -01 5a&b
EPA-450/3-82-01 la&b
EPA-450/3-82-001 a&b
EPA-450/3-82-01 2a&b
EPA-450/3-82-024a&b
EPA-450/3-83-005a&b
EPA-450/3-85-001 a&b
EPA-450/3-85-029a&b
EPA-450/3-85-01 9a&b
EPA-450/3-85-022a
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National Emission Standards for Hazardous Air Pollutants
Source Category
Vinyl chloride
production plants
Equipment leaks
(fugitive emission
sources) of benzene
Benzene emissions from
coke by-product
recovery plants
Equipment leaks
(fugitive emission
sources) of VOC's
Benzene emissions from
benzene storage
vessels
Benzene emissions from
benzene transfer
operations
Benzene waste
operations
Benzene emissions from
ethylbenzene/
styrene12
Reference :
40 CFR Part 61
Subpart F
Subpart J
Subpart L
Subpart V
Subpart Y
Subpart BB
Subpart FF
BID Number (s)
EPA-450/2-75-009a&b
EPA-450/3-80-032a&b
EPA-450/3-83-01 6a&b
EPA-450/3-80-034a
EPA-450/3-78-031
EPA-450/5-84-001
EPA-450/3-80-028b
EPA-450/3-87-001a
EPA-450/3-79-035a
EPA-450/3-84-003
12The proposed NESHAP for this source category was followed by a
proposal to withdraw the proposed NESHAP.
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APPENDIX D: CONTROL MEASURES FROM THE AIR QUALITY
MANAGEMENT PLAN FOR THE SOUTH COAST AIR QUALITY
MANAGEMENT DISTRICT OF CALIFORNIA
The following is a list of control measures for stationary
(point and area) and mobile VOC (or reactive organic gases)
source categories from the SCAQMD's 1991 Air Quality Management
Plan for the South Coast Air Basin. The list of stationary
source control measures is for source categories not covered by
CTG documents. Additional information on these control measures
can be obtained from the Public Information Office of the SCAQMD
[(714) 396-2000].
Stationary Source Control Measures - Point Sources (From
Appendix IV-A)
Surface Coating and Solvent Use:
Manufacture of Electronic Components.
Petroleum and Gas Production:
• Outer Continental Shelf Exploration, Development, and
Production.
• Petroleum Refinery Flares.
Industrial and Commercial Processes:
• Manufacture of Rubber Products.
Residential and Public Sectors:
• Publicly Owned Treatment Works.
Other Sources:
• Emission Minimization Management Plan.
Marketable Permit Program.
Stationary Source Control Measures - Area Sources (From
Appendix IV-B)
Surface Coating and Solvent Use:
Architectural Coatings.
• Substitute Solvents for Surface Coating Clean-Up.
Domestic Products.
Solvent waste.
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Petroleum and- Gas Production:
Gasoline Transfer: Fail Safe Phase-I Vapor Recovery
Systems.
• Gasoline Transfer: Improved Installation and Repair of
Phase-II Vapor Recovery Systems.
• Pleasure Boat Fueling Operations.
Organic Liquid Transfer.
• Gasoline Dispensing Facilities.
Utility Engine Refueling Operations.
• Over-Filling Vehicle Fuel Tanks.
• Draining of Liquid Products.
Commercial and Industrial Processes:
Large Commercial Bakeries.
• Commercial Charbroiling.
• Laboratory Fume Hoods.
• Deep Fat Frying.
• Miscellaneous Combustion Sources.
• Internal Combustion Engines.
Residential and Public Sectors:
Out-of-Basin Transport of Solid Waste.
Agricultural Processes:
• Pesticide Application.
• Livestock Waste.
Others:
• Installation of Best Available Retrofit Control Technology
on Miscellaneous Sources.
• Low Emission Methods and Materials for Building
Construction.
Mobile and Indirect Source Control Measures (From Appendix IV-C)
On-road Vehicles:
Zero-emission Urban Bus Implementation.
• Low-emission New Fleet Vehicles.
• Motor-Vehicle Buy-back Program.
Eliminate Excessive Car Dealership Cold Starts.
• Eliminate Excessive Curb Idling.
Aerodynamic Devices for Trucks.
Eliminate Emissions from Advertising Vehicles.
Inspection and Maintenance Program Enhancements.
Off-road Vehicles:
Control of Emissions from Jet Aircraft.
Control of Emissions from Marine Vessel Tanks.
Lower Emissions from Military Aircraft-
• Eliminate Leaf Blowers.
• Emission Standards for Construction and Farm Equipment.
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Indirect Sources:
Environmental Review Program.
Trip Reduction for Schools.
Supplement Development Standards,
Special Activities Centers.
Enhanced Regulations.
Truck Programs.
Registration Programs.
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APPENDIX E; CURRENT ACT DOCUMENTS AND OTHER FEDERAL
CONTROL MEASURES
Appendix E of this document provides a summary of the
information presented in the ACT documents for halogenated
solvent cleaners, application of traffic markings, automobile
refinishing., ethylene oxide sterilization/fumigation operations,
and organic waste processes. The references for .these ACT
documents are presented in Appendix B of this document. The EPA
has not performed a word-by-word comparison of the information
presented in Appendix E of this document to the information
presented in the ACT documents. Where discrepancies occur
between Appendix E and the ACT documents, the information in the
ACT documents takes precedence.
Appendix E of this document also provides a brief status
report on the development of other federal control measures for
consumer and commercial products, adhesives, application of
agricultural pesticides, architectural and industrial coatings,
autobody refinishing, marine vessel loading operations, and ship
building operations and ship repair.
ACT Documents
Halogenated Solvent Cleaners
Halogenated solvent cleaners commonly employ one of five
halogenated solvents: 1,1,1-trichloroethane, perchloroethylene,
methylene chloride, trichlorotrifluoroethane, and
trichloroethylene. The cleaning apparatuses that use these
solvents vary in size from small benchtop models to large
industrial size cleaners. Solvent evaporation emissions may come
from the air/solvent vapor interface, from the clean parts as
they emerge from the cleaner, from equipment and storage leaks,
and from transfer losses. Of the five halogenated solvents
discussed in the ACT document, four have been exempted from the
definition of VOC. Trichloroethylene is the only solvent
discussed in the document which is classified as a VOC.
Trichloroethylene emissions reductions may be creditable toward
the 15 percent VOC emissions reduction requirements, net of
growth. However, emissions reductions for solvents exempted from
the definition of VOC are not creditable toward the 1 5 percent
requirements.
Emissions reduction techniques will include features which
limit losses from diffusion and convection, carryout, leaks,
downtime, solvent transfer, water contamination, and waste
disposal. Multiple control techniques are examined in the ACT,
for interface, in-line emissions, and fugitive emissions. Vapor
interface emissions may be reduced by a combination of carbon
adsorption, reducing the primary condenser temperature, a
E-1
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freeboard refrigeration device, and other controls. Workload
emissions may be reduced by carbon adsorption. Adequate control
will usually be attained through several control technologies,
with emissions reductions of approximately 70 percent.
Additionally, the ACT document suggests alternative cleaning
agents that would further reduce emissions.
Costs vary widely with the respective control technologies.
The document presents retrofit cost estimates for three model
cleaner sizes and two operating schedules. Cost-effective
control .strategies are available for all halogenated solvent
cleaners.
No monitoring techniques are provided in the document.
Reduction of Volatile Organic Compounds from the Application of
Traffic Markings
Traffic marking materials must withstand different types of
weather and varying levels of tire wear. Because of the variety
of performance requirements for traffic markings, these materials
have many different physical and chemical properties. 'Most
emissions occur from solvent-borne paint traffic markings, which
are the most widely used.
Five alternatives to solvent-borne paint are discussed in
the ACT document. The five alternatives include waterborne
paints, thermoplastics, preformed tapes, field-reacted materials,
and permanent markers. Each alternative emits less VOC than
solvent-borne paints. Use of thermoplastics, preformed tapes
without adhesive primer, field-reacted materials, and permanent
markers can reduce emissions associated with solvent-borne paints
by 100 percent. Preformed tapes with adhesive primer can reduce
VOC emissions by 15 percent. Waterborne paints may achieve an
81 percent reduction in VOC emissions. Waterborne paints are
latex emulsions which typically contain organic solvents
(approximately 80 grams of VOC per liter of coating).
* A cost analysis was performed for solvent-borne paint,
waterborne paint, thermoplastic, and field-reacted materials.
A cost savings over solvent-borne paint was found for all
alternatives except for thermoplastic.
No monitoring techniques are discussed in the document.
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Reduction of Volatile Organic Compound Emissions from Automobile
Refinishing
Automobile refinishing may be categorized into four
processes: vehicle preparation, primer application, topcoat
application, and spray equipment cleanup. Emissions occur from
solvent evaporation during preparation, cleanup, and directly
after coating applications.
Alternative controls were examined for small, medium, and
large shops. Emissions reduction techniques include alternative
coatings, new spray equipment with improved transfer efficiency,
installation of solvent recovery spray equipment cleaning
systems, and add-on controls (for volume shops only).
Significant VOC emissions reductions (30 percent to
45 percent) result from replacing conventional air-atomizing
spray guns with high-volume, low-pressure spray guns, at a cost
savings due to higher transfer efficiency. Volatile organic
compound emissions reductions of 15 percent can be attained from
using a cleanup solvent recovery system, which also results in
savings due to reduced solvent usage. Switching from
conventional primers to waterborne primers results in a
20 percent VOC emissions reduction at no additional cost. Add-
on controls can achieve emissions reductions up to 60 percent;
however, add-on controls are more costly than the other three
control techniques discussed in the document.
Applicable monitoring techniques include recordkeeping,
testing the VOC content of coatings, inspections, emissions
testing, and equipment testing. Recordkeeping is the most
universal approach, augmented by inspections and the testing of
the VOC content of coatings. Emissions testing and equipment
testing are less effective.
Sthvlene Oxide Sterili~ation/Fu-rnicaticn. Operations
Ethylene oxide is used as a sterilant/fumigant in the
production of medical equipment supplies, in miscellaneous
sterilization and fumigation operations, and at hospitals.
. — - - . —. «» —• A - - - -—• ŁJ^ -"• J^ - • — •»— Ł•_ ™ f^ "• —» «•..-— •»— *«n , »
_ - * * -mm ™ * • " •— - •> —- *•** **"•• " ~ * " *•* " -——•—. —— ^-» ~1- *-*• - • * •—•" —. 'wrf1 _
-------
Control efficiencies range from 98 percent to 99 percent for
emissions from sterilizer vents. No control efficiencies have
been developed for the low ethylene oxide concentrations from
aeration rooms. A cost analysis is developed in the ACT for an
acid hydrolysis system with a vacuum pump for recirculation of
each sterilizer.
No monitoring techniques are discussed in the document.
Organic Waste Process Vents
The waste management industry is diverse and complex, and
covers a broad spectrum of industry types and sizes. Major
elements of waste management include generation, transportation,
storage, treatment, and disposal. Organic-containing wastes may
be emitted from process vents associated with each of the above
elements.
Both vapor recovery control devices (condensers, adsorbers,
and absorbers) -and vapor combustion control devices
(incinerators, flares, and industrial boilers) are discussed in
the ACT document. Vapor recovery devices are cited as the more
attractive option where a significant quantity of usable organics
can be recovered. However, these control technologies may not be
applicable to certain process vent streams. Expected emissions
reductions for all control options range from 95 percent to
98 percent.
Costs are estimated for 71 model process vent streams and
are too numerous to be summarized here. Monitoring techniques
are described for each control technology in the ACT document.
Monitoring may be performed on the emissions streams themselves
or on parameters of the control, devices. For most control
devices described in the ACT document, monitoring variables such
as flowrate and temperature are sufficient.
Other Federal Control Measures
Consumer and Commercial Products
Consumer and commercial products include a wide variety of
items, including deodorants, spray paints, hair care products,
and household cleaners. Although no information on control
technologies is available at this time, the final document will
consist of 17 different volumes, divided into 6 generic reports
and 11 product category studies. The- consumer and commercial
products study will not be available in its entirety until
November 1993.
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Adhesives
Control measures for adhesives are no -longer under
development as a separate document, but limited information is to
be included in the guidance on consumer and commercial products.
No information is available at this time.
Architectural and Industrial Coatings
The EPA is using regulatory negotiation to prepare a
national rulemaking for controlling VOC emissions from
architectural and industrial coatings. For further information
on the status of the rulemaking, contact Ms. Ellen Ducey of EPA's
Office of Air Quality Planning and Standards [(919) 541-5408)].
Autobodv Refinishing
The EPA originally intended to issue a CTG document for
autobody refinishing. However, EPA has decided to prepare a
national rulemaking instead of issuing a CTG document. For
further information on the status of the rulemaking, contact
Ms. Ellen Ducey of EPA's Office of Air Quality Planning and
Standards [(919) 541-5408)].
Application of Agricultural Pesticides
The EPA has prepared a final ACT document which presents
information on control techniques for reducing VOC emissions
associated with the application of" agricultural pesticides. The
document also presents nationwide emissions estimates for organic
solvents and nationwide usage estimates for active ingredients in
agricultural pesticides. The reference for the ACT document is
as follows:
Control of Volatile Organic Compound Emissions from the
Application of Agricultural Pesticides, EPA-453/R-92-011,
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. 1993.
Marine Vessel Loading Operations
The SPA has prepared a technical support document wnz.cn
presents information on control techniques for reducing VOC and
hazardous air pollutant (HAP) emissions associated with marine
vessel loading and unloading operations. Standards for marine
vessel loading operations are scheduled to be proposed in 1993.
The reference for the technical support document is as follows:
E-5
-------
VOC/HAP .Emissions from Marine Vessel Loading Operations:
Technical Support Document for Proposed Standards, EPA-
450/3-93-001a, U.S. Environmental Protection Agency, Office
of Air Quality Planning and Standards, Research Triangle
Park, NC. May 1992.
Ship Building Operations and Ship Repair
The EPA is preparing a CTG document for controlling VOC
emissions from ship building operations and ship repair. A draft
CTG document is planned for release in the fall of 1993. A final
CTG document is planned for release in the fall of 1994. The CTG
document will contain information on the VOC emissions sources
associated with ship building operations and ship repair, VOC
emissions estimates, best available control measures, and control
cost estimates. In addition, EPA is preparing an NESHAP to
control emissions of hazardous air pollutants from ship building
operations and ship repair. The NESHAP is planned for
promulgation in 1994.
E-6
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APPENDIX F: PROCEDURES FOR CALCULATING THE 1996 TARGET LEVEL OF
EMISSIONS AND DISCUSSION OF CONTROL STRATEGY DEVELOPMENT
This appendix provides an overview of the steps involved in
calculating the target level of emissions and total emissions
reductions for 1996, and discusses the development of control
strategies for achieving the required emissions reductions.
A hypothetical example is used to show the steps involved in
calculating the target level of emissions and total emissions
reductions for 1996. The discussion on the development of
control strategies summarizes the control measures required by
the CAAA for moderate and serious nonattainment areas. Issues
concerning the creditability of emissions reductions toward the
15 percent VOC emissions reduction requirements are also
discussed. Examples of five hypothetical nonattainment areas
(four moderate and one serious) are presented to illustrate the
control strategy development process, development of contingency
measures, and to provide suggested formats for reporting control
measures and associated emissions reductions in the rate-of-
progress plans.
Calculation of the Target Level of Emissions and Total Emissions
Reductions for 1996
To determine their control strategies for achieving the
required 15 percent VOC emissions reductions, net of growth,
States will need to calculate the 1996 target level of emissions
-- the maximum amount of emissions allowed in 1996 given the
rate-of-progress requirement. This section presents a
hypothetical example to describe the calculation of the target
level and total emissions reductions for 1996. Figure F-1
presents a flowchart of the steps involved in calculating the
target level and the emissions reductions for the hypothetical
example.
Calculation of the 1990 Adjusted Base Year Inventory
Section 182(b)(1) of the Act specifies the emissions
"baseline" from which the 15 percent VOC emissions reduction is
calculated. This baseline value is termed the 1990 adjusted base
vear inventory Section 182(b)(1)(3) defines baseline emissions
(for purposes of calculating che 15 perosnt VOC emissions
reduction) as "the _ocai amount of actual VOC or MOX emissions
from all anthropogenic sources in the area during the calendar
year of enactment." Section 182(b)(1)(D) excludes fro™, the
baseline the emissions that would be eliminated by FMVC?
regulations oromulgated by January 1, 1990, and RVP regulations
-------
FINAL BASE
YEAR (1990)
INVENTORY*
12,000 LB/DAY
I
NJ
1990 RATE-OF-
PROGRESS
BASE YEAR
INVENTORY
5,800 LB/DAY
SUBTRACT
BIOGENICS.
EMISSIONS OUTSIDE
NONATTAINMENT AREA
ADD GROWTH
650 LB/DAY
1990 ADJUSTED
BASE YEAR
INVENTORY
5,300 LB/DAY
SUBTRACT
FMVCP
RVP REDUCTIONS
A - B
1996 ESTIMATED
EMISSIONS
(ANTHROPOGENIC)
6,450 LB/DAY
C - D
TARGET LEVEL
FOR 1996
5,800-1,800=
4,000 LB/DAY
multiply
by 0.1S
B
EMISSIONS
REDUCTION
REQUIRED BY
1996
0.15(5,300)=
795 LB/DAY
TOTAL
EXPECTED
REDUCTIONS
BY 1996
1,800 LB/DAY
ADD
REDUCTIONS NEEDS BY
1996 TO ACHIEVE
15 PERCENT NET OF
GROWTH
2,450 LB/DAY
REDUCTIONS FROM:
FMVCP/RVP (500 LB/DAY)
RACT RULE CORRECTIONS (305 LB/DAY)
I/M CORRECTIONS (200 LB/DAY)
* DOES NOT INCLUDE PRE-ENACTMENT BANKED EMISSIONS CREDITS
Figure F-l. Flowchart for example rate-of-progress calculations.
-------
nonattainment areas during the peak ozone season. Three steps
are followed in calculating the 1990 adjusted base year
inventory.
Step 1. Develop the 1990 base year inventory: the total
1990 base year emissions from the four emissions source types
(point, area, mobile, and biogenic) are compiled;
Step 2. Develop the 1990 rate-of-progress base year
inventory for nonattainment area: biogenic source emissions and
other emissions from sources located outside the nonattainment
area, but included in step 1, are removed from the 1990 base year
inventory; and
Step 3. Develop adjusted base year inventory: remove the
expected emissions reductions from the FMVCP and RVP programs
from the 1990 rate-of-progress base year inventory.
Additional information on these three steps is available in
an EPA document entitled Guidance on the Adjusted Base Year
Emissions Inventory and the 1996 Target for the 15 Percent Rate-
of-Progress Plans. (See reference 42). Employing the same
hypothetical emissions estimates from that document, the adjusted
base year inventory in this example is expected to equal
5,300 Ib/day of VOC emissions.
Calculation of the 1996 Target Level of Emissions
Steps 4 through 6 are used to calculate the 1996 target
level of emissions for planning purposes (additional information
on these steps is also available in the aforementioned EPA
guidance document).
Step 4. Calculate required (15 percent) creditable
reductions: 15 percent = 5,300 x 0.15 = 795 Ib/day of VOC.
Step 5. Calculate total expected reductions by 1996:
this step involves summing the emissions reductions that are
creditable toward the 15 percent requirement (calculated in Step
4) and the total emissions reductions from programs that are
required, but are not creditable toward the 15 percent
requirement (i.e., RACT rule and I/M program corrections, pre-
CAAA FMVCP, and. Federal RVP regulations) . The estimated total
expected reductions are assumed to equal 1,800 Ib/day of VOC.
The 1996 target level of emissions is then calculated by
subtracting the total expected reductions by 1996 from the 1990
rate-of-progress base year inventory.
F-3
-------
Step 6. Set target level for 1996:
Target Level = Step 2 - Step 5
1990 Rate-of-Progress Base Year
Inventory For Nonattainment Area -
Total Reductions
5,800 Ib/day - 1,800 Ib/day
4,000 Ib/day
The next major step involved in calculating the extent of
the necessary emissions controls for meeting the 15 percent rate-
of-progress requirement is to project emissions growth.
Calculation of Total Emissions Reductions Needed by 1996
Step 7. Project emissions growth for the 1990-1996 period:
1990-1996 Projected Emissions Growth (Ib/day)
Point Sources
Area Sources
Mobile Sources
Total
The expected emissions growth between 1990 and 1996 is
estimated using the 1990 rate-of-progress base year inventory for
the nonattainment area and the methods outlined in an EPA
document entitled Procedures for Preparing Emissions Projections.
(See reference 43.) Section 6 of this document provides detailed
guidance on the procedures for projecting VOC emissions. States
must be sure to include the amount of preenactment banked
emissions reduction credits that they plan to use during the
1990-1996 period in these projections. The use of such credits
in the post-CAAA period must be considered emissions growth. For
example, assume a State expects to use 50 Ib/day of its
preenactment banked emissions reduction credits to offset major
source growth during the 1990-1996 period. Furthermore, the
State expects an additional 50 Ib/day of nonmajor point source
growth that will not be offset with preenactment banked credits.'
Therefore, the State should incorporate a total of 100- Ib/day of
point source growth for this nonattainment area. After
aggregating the emissions from each source, it is estimated that
the hypothetical example nonattainment area will see increases in
VOC emissions of 250 Ib/day for area sources and 300 Ib/day for
mobile sources, in addition to the 100 Ib/day for point sources.
F-4
-------
Step 8. Add emissions growth to other required reductions
for planning purposes (includes offsetting emissions growth):
Required Additional Controlled Emissions in 1996 (Ib/day)
Required 15 percent 795
Expected Reductions from FMVCP and RVP
(1990-1996) 500
Corrections to RACT Rules
(noncreditable) 305
Corrections to I/M Program
(noncreditable) 200
Anticipated emissions growth (1990-
1996) based on projections
Total
Once the 1996 target emissions level and projected emissions
growth are calculated, States must develop a control strategy
that meets the target while offsetting the projected growth. The
control strategy must take into account the required emissions
reductions (15 percent), the noncreditable emissions reductions,
and the growth projected to occur between 1990 and 1996 (i.e.,
650 Ib/day of VOC) . The total 1996 VOC emissions reductions for
the hypothetical nonattainment area are 2,450 Ib/day.
Development Of Control Strategies
Moderate Nonattainment Area Requirements
Under section 182(b) of the Act, moderate ozone
nonattainment areas are required to implement the following
measures to control VOC emissions:
• RACT rule fix-ups.
RACT catch-ups with a major stationary source emissions
size cut-off of 100 tpy.
• Corrections to I/M programs if they were implemented
before enactment of the CAAA and did not comply with
EPA's basic I/M program requirements, or,
implementation of a basic I/M program if the
nonattainment area had not implemented an I/M program
prior to enactment of the CAAA.
Stage II vapor recovery.
Emissions offsets for new sources [emissions reductions
from existing stationary sources offsetting the
emissions increases from new major stationary sources
F-5
-------
(100 tpy-or greater) or major modifications to major
stationary sources by a ratio of 1.15:1].
Emissions reductions associated with RACT fix-ups and
corrections to I/M programs implemented prior to enactment of the
CAAA are not creditable toward the 15 percent VOC emissions
reduction requirements. Emissions reductions associated with
RACT catch-ups, Stage II vapor recovery programs, and basic I/M
programs implemented after enactment of the CAAA are creditable
toward the 15 percent VOC emissions reduction requirements to the
extent that they are implemented by 1996 and represent emissions
reductions that are real, permanent, and enforceable.
Due to the uncertainty inherent in projecting new source
growth, and in determining the amount of the emissions reductions
from offsets that will be needed to offset minor source growth,
EPA is taking a conservative approach to the crediting of
emissions reductions from offsets in the rate-of-progress plan.
While emissions reductions associated with RACT rule catch-ups,
RACT- rules based on any new CTG or ACT document, and Stage II
vapor recovery required for moderate and above areas are
creditable reductions in the 15 percent rate-of-progress plan,
emissions offsets are not creditable in the plan. However, any
additional, actual, permanent, and enforceable emissions
reductions resulting after 1990 from an offset that are not used
to offset minor source growth will be creditable in the milestone
compliance demonstration due in February 1997 for serious and
above areas. The issues related to the interaction of emissions
offsets and the 15 percent requirement will be discussed more
fully in an EPA document entitled Guidance on the Relationship
Between the 15 Percent Rate-of-Proaress Plans and Other
Provisions of the Clean Air Act. This document will be released
in the spring of 1993.
It is important to note that although moderate and above
nonattainment areas are required to provide a rate-of-progress
plan describing how a 15 percent VOC emissions reduction, net of
growth, will be achieved by November 1996, moderate areas are not
required to show that they have met the 15 percent requirement in
a milestone compliance demonstration due by February T5, 1993,
because the 15 percent milestone date falls on the attainment
date for moderate areas (November 15, 1996). Instead, they are
required to show that they have attained the ozone. NAAQS by
November 15, 1996.
Moderate areas must, therefore, plan for and implement a
control strategy that will result in attainment. If, for
example, modeling for the attainment demonstration shows that an
18 percent VOC emissions reduction will be necessary for a
moderate area to attain the ozone NAAQS by 1996, then the State
should adopt control measures in its rate-of-progress plan that
will achieve an 18 percent reduction. The State would need to
F-6
-------
track the post-implement at ion. emissions against the modeled
attainment percentage rather than the 15 percent rate-of-progress
requirement.
States must be aware that the assessment of whether an area
has met the 15 percent VOC emissions reduction requirements, net
of growth, in 1996 will be based on whether an area is at or
below its 1996 target level of emissions, and not whether the
area has achieved a particular actual emissions reduction
relative to having maintained the control strategy.
Serious Nonattainment Area Requirements
Under section 182(c) of the Act, serious nonattainment areas
are subject to the control measures required for moderate areas
(except for emissions offset requirements) as well as the
following additional control measures:
• Enhanced I/M program.
• Enhanced emissions monitoring.
• A major stationary source emissions cut-off for RACT of
50 tpy.
• Clean-fuel vehicle program in areas with a population
greater than or equal to 250,000.
• Emissions offset of 1.2:1.
Emissions reductions- associated with the first four control
measures are creditable toward the 15 percent VOC emissions
reduction requirements to the extent that they are implemented by
1996 and represent emissions reductions that are real/ permanent,
and enforceable. As discussed previously, EPA will not allow
States to take credit in the 15 percent rate-of-progress plan for
projected emissions reductions resulting from emissions offsets.
Any additional, actual, permanent, and enforceable emissions
reductions resulting after 1990 from an offset that is not used
to offset minor source growth will be creditable in the milestone
compliance demonstration required for serious areas in 1997.
In addition, the Federally implemented program for
reformulated, gasoline is required in the nine serious areas with
the highest ozone design values during the 1987-1989 period and
populations over 250,000 (assume that this hypothetical
nonattainment area does not meet these criteria). Emissions
reductions from the use of reformulated gasoline are also
creditable toward the 15 percent requirements. The clean-fuel
vehicle program is not expected to be implemented until 1998, and
therefore, no creditable emissions reductions (by 1996) are
projected for this program.
F-7
-------
Nonattainment Area Examples
This section provides hypothetical examples of five
nonattainment areas to illustrate how control strategies can be
developed to achieve emissions reductions that are creditable
toward meeting the 15 percent VOC emissions reduction
requirements, net of growth. The nonattainment area examples are
as follows:
A nonattainment that existed prior to enactment of the
CAAA that was classified as a moderate nonattainment
area upon enactment of the CAAA, without changes to its
nonattainment boundaries.
• A nonattainment area that existed prior to enactment of
the CAAA that was classified as a moderate
nonattainment area upon enactment of the CAAA, with
changes to its nonattainment boundaries that added new
portions to the nonattainment area.
An attainment area that existed prior to enactment of
the CAAA that was classified as a moderate
nonattainment area upon enactment of the CAAA.
A nonattainment area that existed prior to enactment of
the CAAA that was classified as a multi-State
nonattainment area upon enactment of the CAAA.
A nonattainment area that existed prior to enactment of
the CAAA that was classified as a serious nonattainment
area upon enactment of the CAAA, with its major
stationary source emissions cut-off lowered from
100 tpy to 50 tpy.
The first three examples are presented to illustrate
differences in how a moderate nonattainment area would develop
its control strategy depending on whether it was classified as a
nonattainment or an attainment area prior to enactment of the
CAAA, or whether its boundaries changed when it was classified as
a moderate area. The fourth example is presented to illustrate
procedures that a multi-State nonattainment area must follow when
developing its control strategy. The fifth example presents a
hypothetical serious nonattainment area to highlight the
additional controls required for serious nonattainment areas.
States must include contingency measures in their rate-of-
progress plans. Therefore, contingency measures are also
discussed for each example.
For Example 1, the emissions inventory and emissions
reduction values presented at the beginning of this appendix (and
summarized in Figure 1) are used to illustrate suggested formats
for reporting control measures, implementation dates for control
F-8
-------
measures, and associated emissions reductions in a rate-of-
progress plan. A separate emissions inventory and emissions
reduction values are presented under Example 5 for a serious
nonattainment area to illustrate suggested -reporting formats.
Blank forms for the suggested reporting formats are provided at
the end of this appendix. Although not required to do so, States
are encouraged to copy and use these forms to report the
requisite data in their rate-of-progress plans.
Note that these examples are only illustrative of the
process and format to be followed and are definitely not intended
to reflect relative reductions to be obtained from the listed
control measures.
Example 1 : Moderate Nonattainment Area without Boundary
Changes
For this example, it is assumed that the nonattainment area
existed prior to enactment of the CAAA and was classified as a
moderate nonattainment area upon enactment of the CAAA. Its
boundaries before and after enactment of the CAAA did not change.
It is assumed that prior to enactment of the CAAA, the
nonattainment area was required to have RACT rules for the Group
I and II CTG source categories, but was not required (and did not
previously choose) to have RACT rules for the Group III CTG
source categories or for major non-CTG stationary sources. It is
also assumed that the nonattainment area had implemented an I/M
program before enactment of the CAAA, However, its RACT rules
and I/M program contain deficiencies which must be corrected to
comply with EPA policies and regulations.
The area would be required to prepare RACT rule fix-ups for
the Group I and II CTG source categories and corrections to its
I/M program. In addition, the area would be required to adopt
RACT rule catch-ups for the Group III CTG source categories and
RACT rules for major non-CTG stationary sources because it had
not adopted. RACT rules for zhe Group III CTG source categories
and major non-CTG stationary sources prior to enactment of the
CAAA. The area would also be required to implement a Stage II
vapor recovery program. Because there are no boundary changes to
the ncnattainment area, there vculd be r.c requirement fcr the
rr.is
-------
Implementation of the RACT rule catch-ups is expected to
result in creditable emissions reductions of 300 Ib/day. The
MOBILES. 0 model projects that the implementation of Stage II
controls will generate emissions reductions' of 250 Ib/day in
1996. Total creditable emissions reductions associated with
implementation of these two programs would be 550 Ib/day.
The document entitled Guidance on the Adjusted Base Year
Emissions Inventory and the 1996 Target for the 15 Percent Rate-
of-Procrress Plans (see reference 44) , discusses the particular
issues and methods related to calculating the expected
noncreditable emissions reductions from FMVCP, RVP, I/M program
corrections, and RACT rule fix-ups. For this example, total
noncreditable emissions reductions are estimated to be
1,005 Ib/day. Total creditable and noncreditable emissions
reductions are estimated to be 1/555 Ib/day. Because this
nonattainment area needs to achieve a total of 2,450 Ib/day of
VOC emissions reductions to meet the 15 percent requirements, net
of growth, additional controls equaling at least 895 Ib/day of
VOC emissions reductions will need to be developed and adopted by
the State.
For this example, it is assumed that additional mobile
source controls will achieve the creditable emissions reductions
(at the least cost) necessary to meet the 15 percent
requirements, net of growth. The following are three mobile
source controls that will be adopted in January 1995 to achieve
the additional 895 Ib/day of VOC emissions reductions needed for
this - nonattainment area:
A basic I/M program in areas that surround the
nonattainment area that will result in emissions
reductions in the nonattainment area.
A lowering of the permissible maximum RVP value to
7.8 psi (assume that an RVP of 9.0 psi is required for
this area) .
An- enhanced I/M program that includes pressure testing
of vehicles' evaporative systems.
asic -_/M program will be imposed in areas adjacent to ~-
nment area to control emissions from vehicles that
c the ncr.attainment area. States should rely
n traffic counts tc verify the commuter traffic
u.on for the nonattainment area. Data for this
nr.ent area shew that more than one-third of all hich—av
sions released z_n the ncnactainment area resvzl" fro~
n o~ I. :•: program boundaries ^s projected tc reduce VCC
.= by 265 Ib/day in 1996. The MC3ILS5.0 model
-------
emissions by 400 Ib/day. in order to achieve the additional
230 Ib/day of required VOC emissions reductions, the State
decides to implement an enhanced I/M program beginning January of
1995. The particular enhanced I/M program .to be adopted includes
pressure testing of the evaporative system on 1971 and newer
vehicles. This is a program component that goes beyond the basic
I/M requirements (note that a basic I/M program is required for
moderate areas, enhanced I/M is required for serious and above
nonattainment areas). The MOBILES.0 model projects that
additional VOC reductions of 235 Ib/day will result in 1996 from
the enhanced I/M program. These non-CAAA mandated controls
result in an additional VOC emissions reduction of 900 Ib/day,
which is 5 Ib/day more than the additional 895 .Ib/day of VOC
emissions reduction required to meet the 1996 target level of
emissions.
Table F-1 presents a suggested format for the presentation
of the 15 percent rate-of-progress control strategy. When the
1 ,555 Ib/day of VOC emissions reductions from the CAAA. mandated
controls are added to the projected emissions reductions for the
controls not specifically mandated by the CAAA, total reductions
of 2,455 Ib/day are expected in 1996, 5 Ib/day more than required
(see Step 8). Similarly, Table F-2 presents EPA's suggested
format for documenting the control measures to be used in an
attainment demonstration for moderate nonattainment areas. Note
that EKMA modeling for this hypothetical nonattainment area
demonstrates that 2,805 Ib/day of VOC emissions reductions will
be needed for the nonattainment area to attain the ozone NAAQS by
1996. This represents 350 Ib/day of VOC emissions reductions in
addition to the 2,455 Ib/day of VOC emissions reductions
associated with the control measures needed to meet the
15 percent VOC emissions reduction requirements, net of growth.
This nonattainment area decides that it will opt-in to the
Federal reformulated gasoline program and will implement a RE
improvement program to obtain the additional emissions
reductions.
Table F-2 also contains a column for recording expected NOX
emissions reductions associated with control measures implemented
from November 1990 to November 1996. This hypothetical example
does not present examples of NOX control measures and associated
emissions reductions for the attainment demonstration. However,
it is expected that nonattainment areas will rely on some amount
of NOX emissions reductions in addition to VOC emissions
reductions to achieve attainment with the NAAQS. Therefore,
States with moderate ozone nonattainment areas should report 3he
NOX control measures, the implementation date of the control
measures, and associated NOX emissions reductions in their rate-
of -progress plans.
F-11
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TABLE F-1
SUGGESTED FORMAT FOR 15 PERCENT RATE-OF-PROGRESS
CONTROL STRATEGY SUMMARY SUBMITTAL
Required 15 percent measures:
Measures to offset growth:
Noncreditable measures:
795 Ib/day
650 Ib/day
1,005 Ib/day
Total reductions required:
2,4DO ID/day
Expected
Emissions
Control Creditable/ Expected Reduction
Measure13 Noncreditable Implementation Date (Ib/day)
STATIONARY SOURCE
RACT fix-ups
RACT catch-ups
for Group III
CTG and major
non-CTG sources
CONTROLS :
Noncreditable
Creditable14
January 1 , 1 993
January 1 , 1995
TOTAL STATIONARY
305
300
605
MOBILE SOURCE CONTROLS:
I/M fix-up
FMVCP and RVP
Stage II
I/M program in
adjacent
attainment
areas
RVP lowered
beyond Federal
mandate
(to 7.8)
Enhanced I/M
TOTAL MOBILE:
Noncreditable
Noncreditable
Creditable
Creditable
Creditable
Creditable
January 1 , 1992
June 1, 1992
July 1, 1994
January 1, 1995
January 1 , 1 995
January 1 , 1995
TOTAL
200
500
250
265
400
235
1,850
2,455
13Italicized controls are in addition to the CAAA requirements for
moderate nonattainment areas.
MNote that RACT catch-ups for Group III CTG and major non-CTG
stationary sources are creditable only where the area was never
previously required by EPA (and did not previously choose) to adopt
RACT rules,for Group III CTG and major non-CTG stationary sources.
F-1 2
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TABLE F-2: SUGGESTED FORMAT FOR ATTAINMENT CONTROL STRATEGY SUMMARY SOBMITTAL
Reductions needed to achieve attainment (VOC):
Reductions needed to achieve attainment (NOJ :
2,805 Ib/day
Ib/day
Measures
Implementation
Date
Expected VOC
Emissions
Reductions
(Ib/day)15
Expected NOX
Emissions
Reductions
(Ib/day)
STATIONARY SOURCES
RACT fix-upS
i
CTG/non-CTG RACT catch-ups
Rule effectiveness improvements
TOTAL STATIONARY
January 1, 1993
January 1, 1995
January 1, 1995
305
300
100
705
i
U)
MOBILE SOURCES:
I/M fix-up
FMVCP and RVP
Stage II
I/M program in adjacent
attainment areas
RVP lowered beyond Federal
mandate (to 7.8)
Enhanced I/M
Reformulated gasoline (opt-in)
TOTAL MOBILE
January 1, 1992
June 1, 1992
July 1, 1994
January 1, 1995
January 1 , 1995
January 1 , 1995
January 1, 1996
200
500
250
265
400
235
250
2,100
TOTAL
2,805
15The VOC emissions reductions shown in this column are those associated with the control
measures implemented in the nonattainment area. If the nonattainment area's modeling
domain is larger than its nonattainment area, the VOC emissions reductions may be higher
if the control measures affect sources that are located in the modeling domain outside of
the nonatt:ainmenl: area.
-------
States must include contingency measures in their rate-of-
progress plan's that will achieve emissions reductions equivalent
to 3 percent per year, calculated from the 1990 adjusted base
year inventory- Table F-3 presents a suggested format fqr the
State's contingency measure submittal. This submittal must
identify both the absolute and the percentage (i.e./ the
percentage reduction from the 1990 adjusted base year inventory)
emissions reduction projected for each contingency measure, as
well as the order in which the contingency measures would be
implemented upon a milestone or attainment failure. The total
percentage of emissions reduction that a nonattainment area must
plan for depends on the expected length of their SIP revision
process. In the hypothetical example presented in Table F-3, it
is assumed that the State requires 2 years to complete the
legislative process and submit a SIP revision. Therefore,
contingency measures summing to at least 6 percent of the 1990
adjusted base year inventory are required as part of the
contingency measure submittal for this nonattainment area.
Section 9 of this document provides further discussion of the
contingency measure requirements for each ozone nonattainment
area classification.
Table F-4 presents a suggested format for States to use in
summarizing emissions reductions for the 15 percent requirements
and the attainment demonstration in their rate-of-progress plans.
The first two columns in Table F-4 summarize both the total 1996
precontrolled emissions for VOC and NOX (i.e., the 1990 base year
inventory for VOC and NOX projected out to 1996) as well as the
total VOC emissions reductions in 1996 for the attainment
demonstration. The last column in Table F-4 represents the
proportion of the total VOC emissions associated with achieving
the 15 percent VOC emissions reduction requirements, net of
growth. For example, the value in the 1996 emissions (pre-new
controls) cell represents the 1990 rate-of-progress base year
inventory projected out to 1996. Similarly, the value in the
1996 total emissions reductions cell (2,455 Ib/day) represents
the proportion of the total VOC emissions reductions for the
nonattainment area applied to the 15 percent rate-of-progress
requirement (see Step 8). Finally, Tables F-5, F-6, and F-7
present suggested formats for documenting RE improvements,
stationary source control measures for the rate-of-progress plan,
and stationary source control measures for the attainment
demonstration, respectively.
Example 2: Existing Nonattainment Area with Newly Designated
Portions
For this example, it is assumed that the nonattainment area
existed prior to enactment of the CAAA and was classified as a
moderate nonattainment. area upon enactment of the CAAA. When it
was classified as a moderate area, its nonattainment boundaries
were expanded to include new areas which were not previously
F-14
-------
TABLE F-3: SUGGESTED FORMAT FOR CONTINGENCY MEASURE SUBMITTAL
1990 adjusted base year inventory: 5.300 Ib/day
IMPLEMENTATION
ORDER
DESCRIPTION OF CONTROL MEASURE
EXPECTED VOC
EMISSIONS
REDUCTIONS
(Ib/day)
EMISSIONS
REDUCTION AS
A PERCENTAGE
OF THE 1990
VOC ADJUSTED
BASE YEAR
INVENTORY
I
en
1
High occupancy vehicle lanes (TCM)
Major stationary source emissions
threshold for RACT lowered to 50
tpy
Reformulated gasoline
15
125
200
TOTAL
340
0.28
2.36
3.77
6.41
-------
TABLE F-4: SUMMARY OF EMISSIONS REDUCTIONS FOR THE 15 PERCENT RATE-OF-PROGRESS PLAN AND
THE ATTAINMENT DEMONSTRATION
YEAR/TYPE
1996 Emissions (pre-new controls)
1996 Total emissions reductions
1996 Post-controlled emissions
TOTAL VOC
EMISSIONS
(Ib/day)
13,00016
2,80519
10,195
TOTAL NOX
EMISSIONS
(Ib/day)
: 17
17
17
VOC EMISSIONS FOR
THE 15 PERCENT
REQUIREMENT
(Ib/day)
6,45018
2,45520
3,995
1^Total emissions in 1996 for the attainment demonstration modeling domain.
17Appropriate emissions values would be inserted here to account for the effects of
growth, and the effects of emissions reductions associated with NOX RACT rules and other
control measures. They were omitted from this table because they did not contribute to
the purpose of this illustration.
18Total emissions in 1996 for the nonattainment area excluding biogenic emissions and
emissions from anthropogenic sources located in the modeling domain outside of the •
nonattainment area.
19Total emissions reductions in 1996 for the attainment demonstration modeling domain.
20Total emissions reductions to meet the 1996 target level of emissions, including those
required to offset growth.
-------
TABLE F-5: SUGGESTED FORMAT FOR SOBMITTAL OF RULE
EFFECTIVENESS (RE) IMPROVEMENT MEASURES
RE
IMPROVEMENT
MEASURE
1990
RE
(percent)
NEW
RE
(percent)
IMPLEMENTATION
DATE
-
TOTAL :
EXPECTED
EMISSIONS
REDUCTIONS
(lb/day)
TABLE F-6: SUGGESTED FORMAT FOR SUBMITTAL OF STATIONARY SOURCE
CONTROL MEASURES FOR THE 15 PERCENT RATE-OF-PROGRESS PLAN
CONTROL
MEASURE
IMPLEMENTATION
DATE
1990
CONTROL
EFFICIENCY
(percent)
NEW
CONTROL
EFFICIENCY
(percent)
TOTAL :
EXPECTED
EMISSIONS
REDUCTIONS
(lb/day)
TABLE F-7: SUGGESTED FORMAT FOR SUBMITTAL OF STATIONARY SOURCE
CONTROL MEASURES FOR THE ATTAINMENT DEMONSTRATION
CONTROL
MEASURE
IMPLEMENTATION
DATE
1990
CONTROL
EFFICIENCY
(percent)
NEW
CONTROL
EFFICIENCY
(percent)
t • TOTAL:
EXPECTED
EMISSIONS
REDUCTIONS
(lb/day)
F-17
-------
classified as nonattainment. For the original portion of the
nonattainment.area, it is assumed that prior to enactment of the
CAAA, the nonattainment area was required to have RACT rules for
the Group I and II CTG source categories but was not required
(and did not previously choose) to have RACT rules for the Group
III CTG source categories and for major non-CTG stationary
sources. It is also assumed that the nonattainment area had
implemented an I/M program before enactment of the CAAA.
However, its RACT rules and I/M program contain deficiencies
which must be corrected to comply with EPA policies and
regulations. For the newly designated portion of the
nonattainment area, it is assumed that the nonattainment area was
not required (and did not previously choose) to have RACT rules
or an I/M program.
For the original portion of the nonattainment area, the area
would be required to prepare RACT rule fix-ups for the Group I
and II CTG source categories, and prepare corrections to its I/M
program to meet EPA's requirements for a basic I/M program.
Emissions reductions associated with RACT rule fix-ups and I/M
program corrections in the original nonattainment area are not
creditable toward the 15 percent VOC emissions reduction
requirements. However, the area would be required to implement
RACT rules for the Groups I and II CTG source categories and the
basic I/M program to the newly designated portion of the
nonattainment area. Emissions reductions associated with the
RACT rules and basic I/M program in the newly designated portion
are creditable toward the 15 percent requirements.
For the entire nonattainment area, the area would be
required to implement a Stage II vapor recovery program and RACT
rules for the Group III CTG source categories and for major non-
CTG stationary sources. All VOC emissions reductions resulting
from implementing a Stage II vapor recovery program and the RACT
rules are creditable toward the 15 percent requirements. If
implementation of these programs does not achieve the necessary
emissions reduction required for the nonattainment area to meet
either the 15 percent requirements or to achieve attainment of
the ozone NAAQS, the nonattainment area would have to adopt
additional control measures to achieve the necessary emissions
reductions.
States have discretion in deciding on the additional control
measures to adopt for each particular nonattainment area. For
example, a State may prefer a control measure other than the RVP
program described in Example 1 to achieve the necessary emissions
reductions. For an attainment demonstration, a State may adopt
control measures to control NOX emissions if it relies on NOX
emissions reductions to demonstrate attainment. Ultimately, the
control strategy for the nonattainment area must provide for a
15 percent VOC emissions reduction calculated from the adjusted
base^ year emissions inventory, offset emissions growth from
F-18
-------
November 1990 through November 1996, as well as achieve any
additional emissions reductions in VOC and/or NOX to demonstrate
attainment by November 15, 1996. The State must also include
contingency measures in its rate-or-progress plan, and must show
that the emissions reductions associated with each control
measure, are real, permanent, and enforceable.
Example 3: Newly Designated Nonattainment Area
For this example, it is assumed that an attainment area was
classified as a moderate nonattainment area upon the enactment of
the CAAA. It is also assumed that the area never adopted (and
did not previously choose to adopt) RACT rules or an I/M program
prior to enactment of the CAAA. Therefore, there would be no
noncreditable emissions reductions associated with RACT fix-ups
and I/M program corrections for the nonattainment area.
The nonattainment area would be required to implement a
basic I/M program; a Stage II vapor recovery program; and RACT
rules for Groups I, II, and III CTG source categories and major
non-CTG stationary sources. All VOC emissions reductions
associated with implementing a basic I/M program, a Stage II
vapor recovery program, and RACT rules in the new nonattainment
area are creditable toward the 15 percent VOC emissions reduction
requirements. If implementation of these programs does not
achieve the necessary emissions reduction required for the
nonattainment area to meet the 15 percent requirements or to
achieve attainment of the ozone NAAQS, the nonattainment area
would have to adopt additional control measures to achieve the
necessary emissions reductions.
The new nonattainment area has discretion in deciding on the
additional control measures that it would adopt and implement to
achieve a 15 percent VOC emissions reduction, offset emissions
growth from November 1990 through November 1996, and demonstrate
attainment by November 15, 1996. Fcr its attainment
demonstration, it may adopt control measures to control NOX
emissions if it relies on NOX emissions reductions to demonstrate
attainment. The nonattainment area must include contingency
measures in its rate-of-progress plan, and must show that the
-------
Take all reasonable steps with all other States in the
multi-State nonattainment area to coordinate the
implementation of the required revisions to SIP's for
the nonattainment area. Note, however/ that each State
in the multi-State nonattainment area must include
control measures in its rate-of-progress plan to
achieve a 15 percent VOC emissions reduction, net of
growth, from its 1990 adjusted base year inventory.
\
• Develop and submit to EPA, pursuant to section
182(j) (1) (A) of the Act, a joint work plan which must
include (among other things) a schedule for
implementing control measures to achieve the 15 percent
VOC emissions reduction requirements, net of growth.
Use photochemical grid modeling or other equally
effective analytical method approved by EPA to
demonstrate attainment. Multi-estate nonattainment
areas will need to include their attainment
demonstrations in their post-1996 rate-of-progress
plans, which must be submitted to EPA by
November 15, 1994.
Also, if one or more States within a multi-State ozone
nonattainment area fails to provide an attainment demonstration
for that State's portion of the area, the other State(s) are
allowed by section 182(j)(2) to petition EPA to determine whether
they could have demonstrated attainment but for the failure of
the other State (s) in the area to adequately implement the
required control measures under section 182 for the given area.
If EPA finds that this scenario has taken place, then the
sanctions mandated under section 179 will not apply to any State
whose failure to make an adequate attainment demonstration was
due to failure by other States to implement section 182 control
measures.
Finally, additional requirements are imposed for multi-State
nonattainment areas designated as part of an ozone transport
region. For example, enhanced I/M is required for all areas that
are located in an ozone transport region that have a metropolitan
statistical area with population of 100,000 or more. All ozone
transport region requirements are listed in section 184 of the
Act and are discussed in the General Preamble for imolementation
of Title I of the CAAA of 1990 (57 FR 13498).
It is imperative that all States within a given multi-State
nonattainment area coordinate activities related to the
inventory, emissions projection, photochemical grid modeling, and
control strategy development processes.
F-20
-------
Example 5: Serious Nonattainment Area with a Mai or Stationary
Source Emissions Cut-off Lowered from 100 tpy to
50 tpy
For this example, it is assumed that the nonattainment area
existed prior to enactment of the CAAA and was classified as a
serious nonattainment area upon enactment of the CAAA. Its
boundaries before and after enactment of the CAAA did not change.
However, section 182(c) of the Act lowered its major stationary
source emissions cut-off from 100 tpy to 50 tpy.
The following steps show the calculation of the target level
of emissions and total emissions reductions for 1996 for the
serious nonattainment area's rate-of-progress plan.
Step 1: Develop 1990 base year inventory
' (includes all emissions within the UAM modeling domain)
Final 1990 Base Year VOC Emissions Inventory (Ib/day)
Point Sources 1,100
Area Sources 3,000
Mobile Sources 4,500
Biogenic Sources + 4,000
Total 12,600
Step 2: Develop 1990 rate-of-progress base year for
nonattainment area (NA)
1990 Rate-of-Progress Base Year Inventory (Ib/day)
Point Sources (-100 from outside NA) 1,000
Area Sources (-500 from outside NA) 2,500
Mobile Sources (-1,000 outside NA) + 3,500
Total 7,000
Step 3: Develop adjusted base year inventory
1990 Adjusted Base Year Inventory (Ib/day)
Point Sources ~\,000
Area Sources 2,500
Mobile Sources
(minus expected FMVCP and RVP reductions) 3,000
Total 6, 500
F-21
-------
Step 4: Calculate required (15 .percent) creditable reductions
i
15 percent = 6,500 x 0.15 = 975 Ib/day
Step 5: Calculate total reductions
Total Reductions from 1990 Rate-of-Progress Base Year Inventory
(Ib/day)
Required 15 percent 975
Expected Reductions from
FMVCP and RVP (1990-1996) 500
Corrections to RACT Rules 65
Corrections to I/M Programs + 1QQ
Total 1,640
Step 6: Set target level for 1996
Target level = Step 2 - Step 5
= 1990 Rate-of-Progress Base Year Inventory
for Nonattainment Area - Total Reductions
= 7,000 Ib/day - 1.640 Ib/day
= 5,360 Ib/day
Step 7: Project emissions growth for the 1990-1996 period
1990-1996 Projected Emissions Growth (Ib/day)
Point Sources 200
Area Sources 300
Mobile Sources + 900
Total 1,400
Step 8: Add emissions growth to other required reductions for
planning purposes (includes offsetting emissions
growth)
Required Additional Emissions Reduction in 1996 (Ib/day)
(1990--996} =OC
Corrections re ?JLCT Rules (noncrecitable) -55
Corrections zo I/M Programs (noncreditable) *. OC
Reduction zc cffser anticipated emissions
-------
The 1996 emissions reductions expected from the controls
required by section 182(c) of the Act are not projected to result
in a 15 percent VOC emissions reduction, net of growth. After
weighing all of its control options/ the State decides to
implement the following controls:
• A major stationary source emissions cut-off for RACT of
25 tpy-
• Basic I/M program in areas surrounding the
nonattainment area that will result in emissions
reductions in the nonattainment area.
Transportation control measures (specifically, improved
public transit and high occupancy vehicle lanes).
• Reformulated gasoline.
The VOC emissions reductions expected from each of these
control measures are presented in Table F-8. Reductions of VOC
emissions totaling 2,485 Ib/day are projected from the CAAA
mandated controls; another 690 Ib/day of VOC emissions reductions
are expected from control measures that are not specifically
mandated by the CAAA. When the emissions reductions from both
the CAAA mandated and the discretionary controls are summed,
3,175 Ib/day of VOC emissions reductions are expected —
135 Ib/day more than are required (see Step 8). Because serious
arid above ozone nonattainment areas will submit their attainment
demonstrations with the post-1996 rate-of-progress plan due by
November 15, 1994, these areas will not need to submit attainment
demonstration information with the 1 5 percent rate-of-progress
plan. The EPA is currently developing guidance on the attainment
demonstration and other components of the post-1996 rate-of-
progress plan.
Table F-9 provides the suggested format for the required
contingency measure submittal for this example nonattainment
area, which is also due with the 15 percent rate-of-progress
plan. All ozone nonattainment areas must include contingency
measures in their plan that provide emissions reductions of
3 percent per year from their 1990 adjusted base year inventory.
The total amount of reductions to be included in the contingency
measure submittal depends on the expected length of the State's
SIP revision process. For the example presented in Table F-9, it
is assumed that the State will be able to revise its SIP within
1 year of a finding of" a milestone failure; therefore, the
contingency measures provide for a 3 percent emissions reduction
from the 1990 adjusted base year inventory.
F-23
-------
TABLE F-8: SERIOUS NONATTAINMENT AREA EXAMPLE FOR 15 PERCENT RATE-OF-
PROGRESS CONTROL STRATEGY SUMMARY SUBMITTAL
Required 15 percent measures:
Measures to offset growth:
Noncreditable measures:
Total reductions required:
975 Ib/day
1,400 Ib/day
665 Ib/day
3,040 Ib/day
Expected
Emissions
Creditable/ Expected Reductions
Control Measure21 Noncreditable Implementation Date (Ib/day)
STATIONARY SOURCE CONTROLS:
RACT fix-up
Enhanced source monitoring
(RE)
RACT Catch-ups for Group
III CTG and major non-CTG
sources
Lowered RACT limit (to 25
tpy)
TOTAL STATIONARY
Noncr edi table
Creditable
Creditable22
Creditable
January 1 , 1993
January 1 , 1994
January 1 , 1995
January 1 , 1995
65
150
200
220
635
MOBILE SOURCE CONTROLS:
I/M fix-up
FMVCP and RVP
Stage II
Enhanced I/M
I/M program in adjacent
attainment areas
TCtf's:
(1) Improved public transit
(2) High occupancy vehicle
lanes
Reformulated gasoline
TOTAL MOBILE:
Noncreditable
Noncredi table
Creditable
Creditable
Creditable
Creditable
Creditable
Creditable
January 1 , 1992
June 1, 1992
July 1, 1994
January 1 , 1995
January 1 , 1995
January 1 , 1995
January 1 , 1996
January 1 , 1996
100
500
370
1,100
100
60
50
10
31
2,540
TOTAL
^Italicized controls are in addition to the CAAA requirements for
serious nonattainment areas.
:2Note -hat RACT catch-ups for Group III CTG and major non-CTG
stationary sources are creditable only where the area was never
previously required by EPA (and did not previously choose) to adopt
Group III CTG and major non-CTG RACT rules.
-------
TABLE F-9: SUGGESTED FORMAT FOR CONTINGENCY MEASURE SUBMITTAL
1990 adjusted base year inventory: 6,500 Ib/day
IMPLEMENTATION
ORDER
DESCRIPTION OF CONTROL MEASURE
EXPECTED VOC
EMISSIONS
REDUCTION
. (Ib/day)
REDUCTION AS A
PERCENTAGE OF
1990 VOC
ADJUSTED BASE
YEAR INVENTORY
I
to
ui
Major stationary source emissions
threshold for RACT lowered to 15 tpy
Employer trip reduction program
TOTAL
125
100
225
1.92
1.54
3.46
-------
15 PERCENT RATE-OF-PROGRESS CONTROL STRATEGY SUMMARY SUBMITTAL
Required 15 percent measures:
Required measures to offset growth:
Noncreditable measures:
Ib/day
Ib/day
Ib/day
Total reductions required:
-LD/aay
Expected
Expected Emissions
Control Creditable/ Implementation Reductions
Measure Noncreditable Date • (Ib/day)
STATIONARY SOU
TOTAL STATIONAJ
MOBILE SOURCE <
TOTAL MOBILE:
*CE CONTROLS:
RY
CONTROLS:
•
TOTAL
-------
CONTINGENCY MEASURE SUBMITTAL
adjusted base year inventory:
Ib/day
. HK.KMKIITATION
OHDKK
DESCRIPTION OF CONTROL MEASURE
TOTAL
EXPECTED VOC
EMISSIONS REDUCTION
(Ib/day)
REDUCTIONS AS
A PERCENTAGE
OF 1990 VOC
ADJUSTED BASE
YEAR INVENTORY
-------
ATTAINMENT DEMONSTRATION CONTROL STRATEGY SUMMARY SUBMITTAL
Reductions needed to achieve attainment (VOC):
Reductions needed to achieve attainment '(NOX) :
Ib/day
Ib/day
Measures
Implementation
Date
ExpectedVOC
Emissions
Reductions
(Ib/day)
Expected NOX
Emissions
Reductions
(Ib/day)
STATIONARY SOURCES
TOTAL STATIONARY
MOBILE SOURCES:
TOTAL MOBILE
TOTAL
-------
SUMMARY OF EMISSIONS REDUCTIONS FOR THE 15 PERCENT RATE-OF-PROGRESS PLAN AND THE
ATTAINMENT DEMONSTRATION
YEAR/TYPE
TOTAL VOC
EMISSIONS
(Ib/day)23
TOTAL NOX
EMISSIONS
(Ib/day)
VOC EMISSIONS FOR
THE 15 PERCENT
REQUIREMENT
(Ib/day)
23This represents total emissions for the attainment demonstration modeling domain.
-------
RULE EFFECTIVENESS (RE) IMPROVEMENT MEASURES
MEASURE
1990
RE
(percent)
NEW
RE
(percent)
IMPLEMENTATION
DATE
TOTAL:
EMISSIONS
REDUCTIONS
(lb/day)
,
-------
STATIONARY SOURCE CONTROL MEASURES FOR THE 15 PERCENT RATE-OF-
PROGRESS PLAN
MEASURE
IMPLEMENTATION
DATE
__
1990
CONTROL
(percent)
•
NEW
CONTROL
(percent)
TOTAL :
EXPECTED
EMISSIONS
REDUCTIONS
(Ib/day)
-------
STATIONARY SOURCE CONTROL MEASURES FOR THE ATTAINMENT
DEMONSTRATION , .
MEASURE
IMPLEMENTATION
DATE
w
1990
CONTROL
EFFICIENCY
(percent)
NEW CONTROL
EFFICIENCY
(percent)
TOTAL :
EXPECTED
EMISSIONS
REDUCTIONS
(Ib/day)
-
-------
APPENDIX G: CHECKLISTS
The review questions in this checklist' are stated in a way
such that an affirmative answer to a yes-or-no question requires
no further action or comment on behalf of the reviewer. A
negative response does not necessarily invalidate the plan but
usually will require an explanation .by the State or,
occasionally/ will require a SIP revision.
A separate document entitled, Quality Review Guidelines for
1990 Base Year Emission Inventories has been prepared to assist
in the development and review of the 1990 base year emissions
inventory.24
These checklists are designed to assist States and also to
assist EPA in reviewing SIP's for completeness. States should
not assume that these checklists are all-inclusive, however.
Reviewing Procedures
This section describes the steps taken by State agencies"and
Regional Offices for the review of rate-of-progress plans. The
completeness criteria established for SIP's (56 FR 42216,
August 26, 1991) and the time frames allotted for revisions to
the plans are outlined. The basic requirements for SIP's can be
found in 40 CFR 51 Requirements for Preparation, Adoption, and
Submittal of Implementation Plans. Technical requirements for
rate-of-progress plans are contained within this document.
State Agencies
Plan Preparation. State agencies have the responsibility of
compiling the rate-of-progress plan and to ensure that the plans
meet the minimum completeness criteria (40 CFR 51 , Appendix V) .
Once a plan has been adopted by a State, five copies of the plan
shall be submitted by the Governor (or his/her designee) to the
Regional Office of the EPA for review.
Draft Plans. A State may submit a draft copy of the rate-
of-progress plan to EPA for comments prior to the November 15,
1993 deadline. The EPA will not consider submission of requests
for parallel processing of draft plans as official plans in order
to meet statutory deadlines. There is .currently a parallel
processing exception in the completeness criteria which permits
submittal of draft plans in order for EPA to expedite the review
24Qualitv Review Guidelines for 19^90 Base Year Emission
Inventories, EPA-454/R-92-007 (Revises EPA-450/4-91-022), U.S.
Environmental Protection Agency, Office of Air Quality Planning
and Standards, Research Triangle Park, NC. August 1992.
G-1
-------
process. The EPA interprets the Act as requiring rules that are
acceptable under the approval options of 110(k), however.
The EPA is presently amending the completeness criteria to
remove the exception for parallel processing and to add an
exception for the submission of commitments as allowed under
110(k)(4).
Regional Offices
Completeness Review. The first step in the review process
for Regional Offices will be to determine if the rate-of-progress
plan meets the completeness criteria found in 40 CFR Part 51 ,
Appendix V. The completeness criteria require that within
60 days of EPA's receipt of a plan or plan revision, but not
later than 6 months after the date by which a State was required
to submit the plan or plan revision, the EPA shall determine
whether the completeness criteria have been met. If EPA has not
made a completeness determination by 6 months after receipt of
the submission, that submission shall on that date be considered
to meet the minimum completeness criteria. The completeness
criteria require that EPA inform the submitting official by
letter if the plan meets the requirements of Appendix V. If a
submittal is deemed incomplete, EPA shall return the submittal to
the State, requesting corrective action and identifying the
components absent or insufficient to perform a review.
G-2
-------
ADJUSTED BASE YEAR INVENTORY AND 1996 TARGET
1 . Was the MOBILES. 0 model used to estimate the expected
emissions reductions- from FMVCP and RVP?
Yes No
Comments:
Does the plan include information on how the MOBILES.0 model
was run to calculate the expected emissions reductions from
FMVCP and RVP?
Yes No
Comments:
Does the adjusted base year emissions inventory include only
emissions emanating from within the designated nonattainment
area boundaries?
Yes No
Comments: .
Does the adjusted base year emissions inventory exclude
noncreditable emissions reductions from FMVCP and RVP?
Yes No
Comments: :
5. Is the required 15 percent VOC emissions reduction
calculated from the adjusted base year emissions inventory?
Yes No
Comments:
6. Are the expected emissions reductions associated with RACT
rule fix-ups quantified as discussed in the guidance?
Yes No
Comments:
7. Are the expected emissions reductions associated with I/M
program corrections cruantified as discussed in. the Guidance'
Yes No
Comments:
G-3
-------
8. Are noncreditable emissions reductions from FMVCP, RVP, RACT
rule fix-ups, and I/M program corrections' summed and
subtracted from the 1990 rate-of-progress base year
emissions inventory to calculate the 1996 target level of
emissions?
Yes No
Comments: —
G-4
-------
CONTROL MEASURES.AND CONTROL STRATEGIES
1 . Does the plan describe the control measures to be
implement ed?
Yes No
Comments:
2. Are all CAAA-required control measures included in the plan?
Stationary Source Controls:
Marginal and above ozone nonattainraent areas:
a) RACT rule fix.-ups (for those areas with RACT rule
deficiencies): Yes No
b) Major stationary source emissions threshold of
100 tpy: Yes No
c) New source review offset ratio of 1.1 to 1 :
Yes No
Moderate and above ozone nonattainment areas:
a) RACT rule catch-ups: Yes No
b) Major stationary source emissions threshold of
100 tpy: Yes No
c) New source review offset ratio of 1.15 to 1:
Yes No
Serious ozone nonattainment areas:
a) Major stationary source emissions threshold of 50 tpv:
Yes f;o
b) .New source review offset ratio of 1.2 to 1:
Yes NO
Severe ozone nonattainment areas:
=.,• -'-5-3 or 3~5.tii.cnary scuzrcs -r~i.s3i.criS ~h.r~esh.clc cf 25 ~tr.~:
Yes " ^~-
b) New source review offset ra;:io of 1.3 to ":
-------
Extreme ozone nonattainment areas:
i vjwr
a) Major stationary source emissions threshold of 10 tpy:
__Yes No
b) New source review offset ratio of 1.5 to 1:
Yes No
Ozone transport region:
a) Major stationary source emissions threshold of 50 tpy
for VOC; 100 tpy for NOX: Yes No
b) New source review offset ratio of 1.15 to 1:
Yes No
c) Additional requirements deemed by the transport
commission as appropriate: Yes No
Comments:
Mobile Source Controls
Marginal and above ozone nonattainment areas:
a) I/M program corrections (for those areas with I/M
program deficiencies) : Yes No
b) FMVCP and RVP program:
Yes No
Moderate ozone nonattainment areas:
a) Basic I/M program: __Yes No
b) Stage II vapor recovery program: Yes No
Serious and above ozone nonattainment areas:
a') Stage II vapor recovery program: Yes No
b) Enhanced I/M program:- Yes No
c) Clean fuel fleet vehicle program: Yes No
d) TCM's: Yes. No
e) VMT demonstration: Yes No
G-6
-------
Severe and above ozone nonattainment areas:
a) Measures to offset VMT growth: . Yes NO
b) Submit employer trip reduction program:
Yes No
Ozone transport region:
a) Enhanced I/M program for any metropolitan statistical
area with a population of 100,000 or more:
Yes No
b) Adopt Stage II 'vapor recovery program or control
measures identified as achieving equivalent reductions:
• Yes No
Comments:
3. Does the plan present a control strategy implementation
schedule?
Yes No
Comments:
4. Will all control measures that are specified in the rate-of-
progress plan be implemented by 1996?
Yes No
Comments:
5. Is the implementation schedule consistent with the CAAA
requirements?
Yes No
Comments:
6. Is the agency that will have enforcement authority specified
for each control measure identified?
Yes No
Comments:
G-7
-------
7. Does the plan describe the methods used to calculate the
emissions reductions attributed to each control measure? At
a minimum, the methods should adhere to the four principles
described in the General Preamble (57 FR 13567) for
documenting emissions reductions. The four principles are
as follows: (1) baseline emissions from the source and the
control measures must be quantifiable, (2) control measures
must be enforceable, (3) interpretation of the control
measures must be replicable, and (4) control measures must
be accountable. See the General Preamble for further
discussion of these principles.
Yes No
Comments: . .
8. Are all major non-CTG stationary sources identified?
Yes No
Comments: _
9. Does the plan include RACT rules for major stationary VOC
sources for which CTG documents are not available?
Yes No
Comments:
10. Is the 80 percent default RE value factored into the
calculation of expected emissions reductions associated with
new control measures?
Yes No
If no, are the RE values that were used calculated using
SPA-approved procedures?
Yes No
Comments:
11. In estimating expected emissions reductions associated with
new control measures, is the compliance period factored into
the calculation consistent with EPA guidance?
—3 ~ne —PA :~~u.i_c.2.ncs ~C-L_cwsc. i_n ca-LCu.-L2.tn.~c
emissions reductions from RE improvements?
Yes ::c
-------
15 PERCENT VOC EMISSIONS REDUCTION DEMONSTRATION
Does the plan demonstrate that it will- achieve a 1 5 percent
reduction in VOC emissions calculated from the 1990 adjusted
base year emissions inventory?
Yes No
Comments:
2. Does the plan include a summary of projected VOC emissions
levels for 1996?
Yes No
Comments: .
3. Is the EPA guidance followed in calculating projected
emissions?
Yes No
Comments:
4. Does the control strategy contain the necessary control
measures to achieve the 1996 target level, of emissions
(i.e., does the overall control strategy provide for the
required 15 percent VOC emissions reductions, provide for
the noncreditable emissions reductions, and fully offset
growth from November 1990 to November 1996)?
Yes No
Comments:
5. Does the State follow the rate-of-progress plan guidance in
showing how the 15 percent VOC emissions reductions, net of
growth, will be achieved?
Yes No
Comments:
If a State plans to use preenactment banked emissions
reduction credits in the 1990 to 1996 period, are the use of
such banked emissions reduction credits considered as growth
in the rate-of-progress plan?
Yes No
Comments:
G-9
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STATE IMPLEMENTATION PLAN ATTAINMENT- DEMONSTRATION CHECKLIST FOR
MODERATE AREAS USING EKMA
1 . Was an approved modeling protocol completed and delivered to
EPA prior to use of the model?
Yes No
Comments:
2. Are attainment year emissions estimates projected from an
EPA approved 1990 base year inventory?
Yes No
Comments: _
3. Were allowable emissions used as the basis for future year
projections?
Yes .No
Comments:
4. Is the MOBILES.0 model used for projecting mobile source
emissions?
Yes No
Comments: ;
5. Have all MOBILES.0 model inputs for the projection emissions
inventory been incorporated?
. Yes No
Comments:
6. Have the following MOBILES.0 model inputs been considered:
Tailpipe and extended useful life standards
Evaporative /running loss controls
RVP limits
Stage II vapor recovery program
Reformulated gasoline program
Basic I/M program
Enhanced I/M program
Other measures (e.g., California's LEV
program)
Comment-?;:
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
NO
No
NO
G-10
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7. Was modeling used to estimate the level of control
(including the level of control required to fully offset
growth) heeded to attain the NAAQS?
Yes No
Comments:
8. Were emissions data preprocessed in accordance with EPA
guidelines specified in the document entitled Guideline for
Use of Citv-Specific EKMA in Preparing Ozone SIP's?2b
Yes No
Comments: _
9. Were the VOC/NOX ratios based on valid measurements
conducted during 1987 to 1989? If not/ what was used?
Yes No
Comments:
10. Were aloft boundary conditions derived from regional oxidant
modeling (ROM) in accordance with the document entitled
Guideline for Using EKMA Interface?26 If not, how were
aloft conditions derived?
Yes No
Comments:
11 . Was the default VOC speciation profile used? If not, what
was the basis assumed for the VOC speciation profile?
Yes No
Comments:
12. Was a modeling demonstration package prepared containing the
required information as documented in EPA guidance?
Yes No
Comments:
"5Guidellne for Use of City-Specific 5KMA in Preparing Ozone
SIP's, EPA-450/4-80-027, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, NC. 1980.
26Guideline for Using EKMA Interface. EPA-450/4-92-009, U.S.
Environmental Protection Agency, Office of Air Quality Plannina
and Standards,^Research Triangle Park, NC. May 1992.
G-1 1
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MILESTONE AND ATTAINMENT FAILURE CONTINGENCY MEASURES
\
Does the rate-of-progress plan include contingency measures
that will achieve an equivalent 3 percent per year VOC
emissions reduction in addition to the scheduled emissions
reductions?
Yes No
Comments:
Will the contingency measures be automatically implemented
in the event of a milestone or attainment failure (i.e.,
does the plan ensure that contingency measures will be
implemented with no additional rulemaking actions such as
public hearings or legislative review by the State)?
Yes No
Comments: '1
Do the contingency measures meet the minimum requirements
for control measures set forth in the General Preamble
(57 FR 13511 and 13520)?
Yes No
Comments:
G-12
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APPENDIX H: MILESTONE AND ATTAINMENT FAILURES FOR
MARGINAL AND MODERATE OZONE NONATTAINMENT AREAS
This appendix presents an overview of the implications of
milestone and attainment failures for marginal and moderate ozone
nonattainment areas. The discussion is a preliminary description
of the anticipated process following a finding of milestone or
attainment failure.
Marginal Areas
Figure H-1 provides an overview of the marginal area
attainment process.
Yes
Bump-up to higher
classification
Sec181(b)(2)(0or0i)
Attainment Date based on
new classification
Redesignation
Sec 107(d)(3)(E)
Figure H-1. Marginal area attainment process flowchart.
Marginal areas are required to attain the ozone NAAQS by November
15, 1993, unless they apply for and receive at least one of the
two available 1-year attainment date extensions under section
181(a)(5). Marginal areas are exempt from the milestone
demonstrations [section 182(g) (1)],. and consequentl-y will not be
subject to any milestone failure requirements. Under section
181(b)(2), marginal areas that fail to attain the ozone NAAQS by
their attainment date (or, if applicable., extended, attainment
date) will be bumped-up to a higher classification.
Moderate Areas
Figure H-2 provides an overview of the moderate area
attainment process.
H-1
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Attainment Date 1996
Yes
No
Attainment Date
1997
Yes
No
Attainment Date
1998
Bump-up to higher classification
Sec181(b)(2)0)or(ii)
Attainment Date based on
new classification, and
Implement Contingency Measures
ofSec172(cK9)
Yes
No
Redesignation
Sec 107(d)(3)(E)
Figure H-2. Moderate area attainment process flowchart.
Moderate areas are required to attain the ozone NAAQS by
November 15, 1996, unless they apply for and receive at least one
of the two available 1-year attainment date extensions under
section 181(a)(5). Moderate areas are exempt from the milestone
demonstrations [section 182(g)(1)]/ and consequently will not be
subject to any milestone failure requirements.
As with marginal areas, section 181(b)(2) specifies that
moderate areas that fail to attain the ozone NAAQS by their
attainment date (or, if applicable, extended attainment date)
will be bumped-up to a higher classification. In addition,
moderate areas must implement the contingency measures contained
in their SIP as required by section 172(c)(9).
Bump-up Requirements
The EPA classifies nonattainment areas for ozone based on
the area's calculated design value. These classifications range
from marginal to extreme, depending on the severity of
nonattainment. The CAAA specify the dates by which each area
with a particular nonattainment classification must atrain the
ozone NAAQS. Within 6 months after the applicable attainment
date, the SPA must determine whether an area has succeeded in
achieving the required standard. This "attainment determination"
will employ the most recent air quality data that has been
subject to quality assurance review, covering the preceding
2 years including the attainment date. In the case of ozone, the
average number of ozone exceedances per year, after adjustment
for missing data, shall be used to determine whether an area has
attained the ozone NAAQS.
H-2
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Under section T81 (a) (5) of the Act, a State may apply for a
1-year extension of a nonattainment area's attainment date; up to
two 1-year extensions may be awarded. This request can be
granted if the State has complied with all requirements and
commitments pertaining to the area in the applicable SIP, and no
more than one exceedance of the ozone NAAQS has occurred in the
area in the year preceding the extension year.
According to section 181(b)(2) of the Act, failure of a
marginal, moderate, or serious nonattainment area to attain the
NAAQS by the attainment date associated with its specific
classification will result in reclassification to the higher of
the following:
• The next higher classification for the area.
The classification associated with the area's design
value when EPA makes the determination that attainment
was not achieved.
This reclassification procedure does not apply to severe and
extreme areas. If a severe or extreme area fails to attain the
ozone NAAQS by the applicable date, the area must implement
contingency measures required under 172(c)(9) and individual
sources must pay the enforcement fees of section 185.
"Bump-up" refers to the reclassification process that a
marginal, moderate, or serious area automatically undergoes if it
fails to attain the NAAQS. The term bump-up also applies to
optional reclassification of a serious or severe nonattainment
area as a result of milestone failure. Serious and severe
nonattainment areas that fail to meet a milestone are required to
make an election, under section 182(g) (3) of the Act, from three
given measures. One explicit option is reclassification of the
area to the next higher classification.
Upon bump-up, the attainment date specified for the higher
classification applies to the area that has been bumped-up.
Section 182(i) of the Act allows for some flexibility in
establishing due dates for the required submittals associated
with the new classification, but does not allow EPA to adjust the
attainment date. Areas that are not expected to attain the ozone
NAAQS by their attainment date but wait until near their
attainment date to voluntarily bump-up, will find it difficult to
meet the deadlines for their new classification. An early-
voluntary bump-up will allow for more flexibility in planning for
and achieving the new requirements of the higher classification.
Since failure to submit SIP revisions can result in sanctions or
Federal implementation plan (FIP) -measures, it will be in the
best interest of States with nonattainment areas to attempt to
assess whether attainment is improbable as soon as possible.
H-3
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Marginal Areas
Marginal areas must reach the prescribed NAAQS level for
ozone by November 15, 1993. In the event that a marginal area
fails to attain the NAAQS by 1993, it will be bumped-up to the
moderate classification, or higher, depending on the area's air
quality data for the attainment year. In addition to the
requirements prescribed for marginal areas, these areas will then
be expected to meet the additional requirements of the higher
classification.
Marginal areas that are bumped-up to moderate nonattainment
status must correct existing RACT rules to make up for
deficiencies in their current plans. Upon reclas'sification, RACT
must be applied, to all sources for which a CTG document has been
issued, and to all major non-CTG stationary sources. Also, a
basic I/M program must be implemented, regardless of whether an
I/M program was in place to begin with (per the pre-CAAA
enactment requirements). The EPA's intention is to require such
areas to submit a SIP meeting the basic I/M requirements within
1 year of the reclassification. Further guidance will be issued
by EPA in the summer of 1993 to address required elements to be
included in this SIP revision.
If a marginal area is bumped-up to" moderate nonattainment
status, planning and rule development schedules can be revised,
although the moderate area attainment date will apply to the
newly classified area. Assuming none of the section 181(a)(5)
extensions are granted, bump-up to a moderate classification may
occur up to 6 months after attainment failure in November 1993;
this would allow only 2-^ years for a marginal area to meet all of
the requirements of the higher classification, including ozone
attainment by November 1996.27 If preliminary planning is not
initiated early, the likelihood of successfully implementing the
necessary control measures within this time frame is small,
considering the fact that drafting the required submittals that
describe these measures represents a significant effort. If a
marginal area that is reclassified as moderate does not attain
the NAAQS by the moderate area attainment date of November 15,
1996 (likely if preliminary planning is not initiated)-, this once
marginal area would be reclassified as a serious area. Given
this possibility, States with marginal areas that are unlikely co
attazn. the MAAQS by November 15, 1993 are encouraged to begin a
planning strategy that will allow for quick enactment of
specified measures.
27In the event that one or both of the section 181 (a) (5)
extensions are granted, an even shorter time frame would be
available for a newly classified moderate area to plan for
attainment by November 1996.
H-4
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One of the more important ramifications of a marginal area
being bumped-up is that it will be subject to the 15 percent
rate-of-progress requirement, which requires the development of a
rate-of-progress plan. In addition, a contingency plan must be
formulated, specifying additional measures to be taken
immediately upon an attainment failure. Normally, these
submittals are due in November 1993 for moderate areas, but a
marginal area being reclassified will not be able to meet these
attainment deadlines. -The EPA may establish separate plan and
implementation deadlines for a marginal area that fails to attain
and is reclassified as moderate. By setting deadlines, an area
may be more likely to achieve attainment and avoid further bump-
ups. If the determination is made in June 1994 that a marginal
area will be bumped-up, then the EPA may, for example, require
SIP revisions by June 1995, indicating measures to be implemented
in November 1995. Again, it should be stressed that the earlier
a determination is made that an area is likely to miss its
attainment date and be reclassified, the better the chance the
area has of meeting the newly imposed deadlines.
In addition, EPA may require States applying for attainment
date extensions to prove that a significant effort has been made
to initiate planning activities associated with the moderate
classification, and that control measures such as I/M and RACT
can be adopted and implemented quickly. Also, States may need to
show that steps have been taken to obtain necessary emissions
data required for the modeling analysis in the attainment
demonstration. These areas may also be required to submit their
air quality data on an accelerated time schedule, to enable early
detection of the need to develop and implement necessary
measures, provided the extensions are not sufficient to ensure
attainment.
Moderate Areas
In accordance with section 181(b)(2) of the Act, if a
moderate area fails to demonstrate attainment by November 15,
1996, it will be reclassified to the serious classification, or
higher, depending on its design value by operation of law. The
area will then be subject to the additional requirements of the
higher classification.
If a moderate area is reclassified as a serious area, both.
ambient air quality and emissions monitoring systems will need to
be upgraded- to meet the specifications outlined in section
182(c)(1). Additional mobile source provisions must be
implemented, including the enhanced I/M and clean fuel vehicle
programs. The enhanced I/M program stipulates a higher
performance standard, than the- basic I/M program, and must take
the place of the existing basic I/M program. The offset ratio
for sources subject to NSR increases, and RACT applies to
stationary sources emitting 50 tpy or more of VOC or NOX. In
H-5
-------
addition, the boundaries of a moderate area bumped-up to a
serious area must reflect the metropolitan statistical
area/consolidated metropolitan statistical area, unless EPA and
the State decide otherwise.
A moderate nonattainment area reclassified as a serious area
will not be required to demonstrate the 15 percent reduction
(milestone compliance) in emissions between 1990 and 1996 as
section 182(g)(1) specifically excludes marginal and moderate
areas from the requirement. Additionally, since the next
milestone falls on the serious area's attainment date (if no
extension is granted), this former moderate area would also not
be required to demonstrate the 3 percent per year reductions
averaged over 3 years from 1996-1999. It would need to attain
the ozone NAAQS by November 1999. Revisions to SIP's out-lining
compliance with the requirements of the serious classification
will be due 1 year after reclassification. Again, planning
should begin early if it seems likely that a moderate area will
be reclassified.
Nonclassifiable Areas
Nonclassifiable ozone areas include transitional,
submarginal, and incomplete/no data areas. Transitional areas
are defined as those areas that were designated nonattainment
both before and at the time of enactment, but were not in
violation of the primary NAAQS during the period 1987-1989.
Submarginal areas are divided into two categories: Category 1
includes areas presently designated nonattainment that are
violating the ozone standard, and Category 2 includes areas
designated unclassified/attainment that are violating the NAAQS.
Incomplete/no data areas describe those regions designated
nonattainment at enactment, but without sufficient data to prove
a violation of the ozone standard.
A SIP revision including RACT corrections, an emissions
inventory, NSR provisions, and monitoring requirements is
required for all nonclassifiable areas. This SIP revision is due
3 years from the date that areas are designated nonclassifiable
areas, which section 107(d)(1)(C)(i) of the Act clarifies to mean
the date of enactment, thereby requiring submittal by
November 15, 1993.
On June 30, 1992, an attainment determination will be made
for transitional areas based on the area's average number of
exceedances during the 3-year period from January 1, 1989 to
December 31, 1991. In the event that attainment is achieved, the
area will be redesignated attainment, the ramifications of which
are described in more detail in a July 9, 1992 memorandum from
John Calcagni, Director, Air Quality Management Division, OAQPS.,
to Regional Air Division Directors, concerning "Processing of
State Implementation Plan (SIP) Submittals." If it is determined
H-6
-------
that violations have occurred in the specified period, however,
it will be classified according to its design value, and will now
be newly subject to the requirements associated with the
appropriate nonattainment classification. Tf the area's design
value is still below 0.121 ppm, the area will be considered
"submarginal."
As with marginal areas, advanced planning should be carried
out for transitional areas in anticipation of a possible bump-up.
Again, while the dates set up for required SIP revisions can be
altered, the corresponding attainment date for the newly
reclassified area cannot be changed.
Under section 172 (a) (2), the attainment date for submarginal
and incomplete/no data areas, is specified as no later than
November 15, 1995. Specific actions to be taken in the event of
attainment failure are still being decided by EPA, but options
include mandatory bump-up to a higher classification, or the
requirement of additional measures to ensure attainment. In the
case of submarginal areas, a violation of the NAAQS and a design
value above 0.121 ppm will result in bump-up and classification
according to the area's design value. All provisions apply to
the newly bumped-up area as if it had been so classified at the
time of enactment, yet adjustment of schedule deadlines is
permitted. As with other reclassifications, however, the
corresponding attainment deadlines cannot be altered.
H-7
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H-8
-------
APPENDIX I: MODEL MULTI-STATE LETTER
DATE
ADDRESS OF
REGIONAL AIR
DIVISION DIRECTOR
Dear Regional Air Division Director,
This letter is being sent to fulfill the requirements
established in section 182(j) of the Clean Air Act, as amended
1990. As you know, section 182(j') requires States in multi-State
ozone nonattainment areas to coordinate revisions and
implementation of State implementation plans (SIP's) with other
States in the nonattainment area. In addition, section 182 (j)
requires the States to use photochemical grid modeling or any
other equally effective analytical method approved by EPA for
demonstrating attainment. Please consider this letter as
[State's name] formal notice of your efforts to ensure
appropriate coordination between the [number of States] States
involved in this plan. We expect that [name other States in
nonattainment area] will prepare similar plans to complement our
efforts. Please realize, however, that while this letter
fulfills the statutory requirement to submit a work plan, most of
the interstate coordination occurs on a person-to-person basis
between staff from the [number of States] States and the EPA
Regional Offices.
For the [State's name] portion of the nonattainment area,
our schedule to complete all the necessary portions the
attainment demonstration is listed below:
[list all plan elements up to 11/94]
Publish Public Notice for Hearing: Date:
[list all plan elements up to 11/94]
[list all plan elenier.zs up tc i
•.-.•:. 11 ce c'ccrdinaied vi-h. [nane other States in r.cnattai-rr.ent
-------
prepare an attainment demonstration for this area. This
coordination will occur through mailings and phone contacts with
each State. Additionally, air directors and staff have the
opportunity to meet and discuss these issues face to face as they
arise through regular meetings of [name Regional Consortium e.g.,
NESCAUM, LADCO, Northeast Ozone Transport Commission].
[Reference modeling protocols required by the Technical Support
Division—also may want work on the development of emissions
inventories and coordination of somewhat consistent growth
factors.]
Beyond this, we look to EPA [list appropriate Regional
Offices] to provide additional necessary coordination. To this
end, the Regional Offices and States have already participated in
meetings and conference calls over the past year. We expect to
participate in additional meetings and conference calls on the
ozone attainment demonstration as the need arises.
If you or your staff have any questions, please feel free to
contact [name State contact] at (000) 000-0000.
Sincerely,
DIRECTOR
STATE AIR DIVISION
cc: States in nonafetainment area
Appropriate Regional Offices
1-2
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APPENDIX J: ALTERNATIVE CONTROL TECHNIQUE (ACT) DOCUMENTS, NEW
SOURCE PERFORMANCE STANDARDS (NSPS), AND TWO SCAQMD AREA SOURCE
RULES FOR CONTROLLING NITROGEN OXIDE. (NOX) EMISSIONS
Status of and References for ACT Documents for Stationary NOX
Sources
The EPA has issued final ACT documents for controlling NOX
emissions from nitric and adipic acid manufacturing plants and
stationary gas turbines. The references for these two documents
are as follows:
• Alternative Control Technique Document — Nitric and Adipic
Acid Manufacturing Plants. EPA-450/3-91-026, U.S.
Environmental Protection Agency/ Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
December 1991.
• Alternative Control Technique Document — NOy Emissions from
Stationary Gas Turbines. EPA-453/R-93-007, U.S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
January 1993.
A final ACT document for controlling NOX emissions from
process heaters is expected to be completed by January or
February of 1993. The EPA completed a draft ACT document for
stationary internal combustion engines in August 1992. The final
ACT document for stationary internal combustion engines is
planned for release in the spring of 1993. The EPA is also
preparing ACT documents for utility boilers; industrial,
commercial, and institutional boilers; cement manufacturing; iron
and steel production; and glass manufacturing. Draft ACT
documents for these source cateaories are planned for release in
1993.
The following EPA reports are not ACT documents, but provide
information on NOX emissions sources, controls, and control
costs.
Svaluation and Costing of N(X Controls for Existing Utility
Boilers in the NESCAUM Region. EPA 453/R-92-010, U.S.
Environmental Protection. Agency, Office of Air Quality
Planning, and Standards, Research Triangle Park, NC.
December 1992.
Evaluation and Costing of ISKX Controls for Industrial,
Commercial, & Institutional Boilers, draft, U.S.
Environmental Protectipn Agency, Office of Air Quality
Planning and Standards) Research Triangle Park, NC.
October 1992. The document is expected to be finalized in 1993
J-1
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List of Promulgated NSPS for Stationary NOX Sources
&
i* Reference:
Source Category 40 CFR Part 60
Fossil-Fuel-Fired Steam Generators Subpart D
Electric Utility Steam Generating Plants Subpart Da
Industrial-Commercial-Institutional Steam Subpart Db
Generating Units
Small Industrial-Commercial-Institutional Steam Subpart DC
Generating Units
Gas Turbines Subpart GG
Municipal Waste Combustors Subpart Ea
Nitric Acid Plants Subpart G
The references for the BID'S prepared to support the
technical basis for the NSPS are as follows:
Electric Utility Steam Generating Units: Background
Information for Proposed NOy Emission Standards, EPA/450/2-
78/005a, U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards/ Research Triangle Park, NC.
1978.
Standards Support and Environmental Impact Statement.
Volume I: Proposed Standards of Performance for Stationary
Gas Turbines. EPA/450/2-77/017a, U.S. Environmental
Protection Agency, Emission Standard and Engineering
Division, Research Triangle Park, NC. 1977.
Standards Support and Environmental Impact Statement.
Volume II: Promulgated Standards of Performance for
Stationary Gas Turbines. EPA/450/2-77/017b, U.S.
Environmental Protection Agency, Emission Standard and
Engineering Division, Research Triangle Park, NC. i977
Municipal Waste Combustors - Background Information for
Proposed Standards: Control of N(X Emissions, Volume 4,
EPA/450/3-89/27d, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. August 14, 1989.
J-2
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Municipal Waste Combustors - Background Information for
Promulgated Standards and Guidelines, Summary of Public
Comments and Responses, Appendix A to C. EPA/450/3-89/004a/
U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
December 1990.
Background Information for Proposed New Source Performance
Standards: Steam Generators, Incinerators, Portland Cement
Plants, Nitric Acid Plants, Sulfuric.Acid Plants, No. 0711,
U.S. Environmental Protection Agency, Office.of Air
Programs, Research Triangle Park, NC. (No date available.)
J-3
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Rule 1121-Control of Nitrogen Oxides from Residential-Type
Natural Gas Fired Water Heaters
(a) Definitions
For the purpose of this rule:
(1) Water Heater is defined as a device that heats water at a
thermostatically controlled temperature for delivery on
demand.
(2) Heat Output is defined as the product obtained by
multiplying the recovery efficiency, as defined by Title 20,
California Administrative Code, Chapter 2, Subchapter 4,
Article 4, Sections.1603 and 1807, by the heating value of
the input fuel furnished to the water heater.
(b) Requirements
After December 31, 1982, a person shall not sell or offer for
sale within the South Coast Air Quality Management District:
(1) Gas-fired stationary home water heaters that:
(A) Emit nitrogen oxides in excess of 40 nanograms of NOX
(calculated as NO2) per joule (70 Ib per billion BTU) of
heat output.
(B) Are not certified in accordance with subparagraph .(c) .
(2) Gas-fired mobile home water heaters that:
(A) Emit nitrogen oxides in excess of 50- nanograms of NOX
(calculated as NO2) per joule (88 Ib per billion BTU) of
heat output.
(B) Are not certified in accordance with subparagraph (c).
(c) Certification
(1) The manufacturer shall have each water heater model tested
in accordance with the following:
(A) Each tested water heater shall be operated in accordance
with Section 2.4 of American National Standards ANSI
Z21.10.1-1975 at normal test pressure, input rates, and with
a five-foot exhaust stack installed during the nitrogen
oxides emission tests.
J-4
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(B) The measurement of nitrogen oxides emissions shall be
conducted in accordance with United States Environmental
Protection Agency test methods or other test methods or
other test methods approved by the executive officer.
(2) The following calculation shall be used to determine
the nanograms of NOX per joule of heat output:
N = (4.566 x 10 ) P U
H C E
Where:
N = nanograms of NOX emitted per joule of heat
output
P = parts per million (volume) NOX in flue gas
U = volume percentage of C02 in water-free flue
gas for stoichiometric combustion.
C= volume percentage CO2 in water free flue gas
H = gross heating value of gas, BTU/Cu.Ft. (60°F,
30 in. hg)
E = recovery efficiency, percentage
(3) The manufacturer shall submit to the Executive Officer
the following:
(A) A statement that the model is in compliance with
subparagraph (b). The statement shall be signed
and dated, and shall attest to the accuracy of all
statements.
(B) General Information
(i) Name and address of manufacturer.
(ii) Brand name.
(iii) Model number, as it appears on the water
heater rating plane.
(C) Description of each model being certified.
(d) Identification of Complying Water Heaters
The manufacturer shall display the model number of the water
heater .complying with, subparagraph (b) on the shipping-
carton and rating plate.
J-5
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(e) Enforcement
(1) The Executive Officer may require the emission test-
results be provided when deemed necessary to verify
compliance.
(2) The Executive Officer may periodically inspect
distributors, retailers and installers of water
heaters located in the District and conduct such
tests as are deemed necessary to insure compliance
with subparagraph (b).
(f) Exemption
The provisions of this rule shall not apply to:
(1) Water heaters with a rated heat input of 75,000 BTU
per hour or greater.
(2) Water heaters used in recreation vehicles.
J-6
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Rule 1111-NOX Emissions from Natural Gas-Fired Fan Type
Central Furnaces
(a) Definitions
(1) Fan Type Furnace is a self-contained space heater
providing for circulation of heated air at pressures
other than atmospheric through ducts more than
10 inches in length- that have:
(A) an input rate of less than 175,000 BTU/hr; or
(B) for combination heating and cooling unit, a
cooling rate of less than 65,000 BTU/hr.
(2) Annual Fuel Utilization Efficiency (AFUE) is defined in
Section 4.2.35 of Code of Federal Regulation, Title 10,
Part 430, Subpart B, Appendix N.
(3) Useful Heat Delivered to the heated Space is the AFUE
(expressed as a fraction) multiplied by the heat input.
(b) Requirements
(1) A manufacturer shall not, after January 1, 1984,
manufacture or supply for sale or use in the South
Coast Air Quality Management District natural gas-fired
fan type central furnaces, unless such furnaces meet
the requirements of subparagraph (3).
(2) A person shall not, after April 2, 1984 sell or offer-
for sale within the South Coast Air Quality Management
District natural gas-fired fan type central furnaces
unless such furnaces meet the requirements of
subparagraph (3).
(3) Natural gas-fired fan type central furnaces shall:
(A) not emit more than 40 nanograms of oxides of
nitrogen (calculated as N02) per joule of useful
heat delivered to the heated space; and
(B) be certified in accordance with paragraph (c) of
this rule.
(c) Certification
(1) thepmanufacturer shall,have each appliance model tested
in1 accordance with the following:
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(A) Oxides of nitrogen measurements, test equipment,
and other required test procedures shall be in
accordance with methods approved by the
Executive Officer.
(B) Operation of the furnace shall be in accordance
with the procedures specified in Section 3.1 of
Code of Federal Regulations, Title 10, Part 430.
Subpart B, Appendix N.
(2) One of the two formulas shown below shall be used to
determine the nanograms of oxides of nitrogen per joule
of useful heat delivered to the heated space:
N = -4.566 x 104 x P x U. N = 3.655 x 1010 x P
H x C x E (20.9-Y) x Z x E
Where:
N = nanograms of emitted oxides of nitrogen per joule
of useful heat.
P = concentration (ppm volume) of oxides of nitrogen in
flue gas as tested.
U = volume percent C02 in water-free flue gas for.
stoichiometric combustion.
H = gross heating value of fuel, BTU/Cu.Ft: (60°F,
30 in. Hg).
C = measured volume percent of C02 in water-free flue
gas, assuming complete combustion and no CO
present.
E = AFUE, percent (calculated using Table 2).
Y = volume percent of 02 in flue gas.
Z = heating value of gas, joules/Cu. Meter (0.0°C,
1 ATM).
(3) The manufacturer shall submit to the Executive Officer
the following:
(A) A statement that the model is in compliance with
subsection (b). (The statement shall be signed
and dated, and shall attest to the accuracy- of all
statements).
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(B) General Information
(i) Name and address of manufacturer.
(ii) Brand name.
(iii) Model number, as it appears on the furnace
rating plate.
(C) A description of the furnace and specifications
for each model being certified.
(d) Identification
The manufacturer shall display the model number of the
furnace complying with subsection (b) on the shipping carton
and rating plate.
(e) Enforcement
(1) The Executive Officer may require the emission test
results to be provided when deemed necessary to verify
compliance.
(2) The Executive Officer may periodically conduct such
tests as are deemed necessary to insure compliance with
subsection (b) .
(f) Exemptions
(1) -The provisions of this rule shall not apply to furnaces
to be installed in mobile homes.
(2) The provisions of this rule shall not apply to natural
gas-fired fan type central furnaces utilizing three-
phase electrical current until January 1, 1986.
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