:;Note: EPA no longer updates this information,
;but it may be useful as a reference or resource.
RULE EFFECTIVENESS GUIDANCE:
INTEGRATION OF INVENTORY, COMPLIANCE,
AND ASSESSMENT APPLICATIONS
United States Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
EPA-452/4-94-001
January 1994
PROPERTY OF
EPA LIBRARY, RTP, NC
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TABLE OF CONTENTS
Section ' Page
List of Tables iii
List of Figures iii
1 INTRODUCTION . . . . 1-1
1.1 RE APPLICATIONS 1-1
1.2 POLLUTANTS 1-4
1.3 SOURCE TYPES 1-4
1.4 PURPOSE 1-4
2 APPLICABLE GUIDANCE 2-1
3 RULE EFFECTIVENESS APPLICATIONS 3-1
3.1 INVENTORY (BASE YEAR) RULE EFFECTIVENESS ..... 3-1
3.1.1 Definition and Purpose 3-1
3.1.2 Relation to Other RE Applications 3-2
3.1.3 Estimating and Applying Base Year RE .... 3-3
3.1.4 Other Interpretations of inventory RE ... 3-9
3.1,5 Mobile Sources 3-9
3.2 COMPLIANCE EFFECTIVENESS (SSCD PROTOCOL STUDY) . . 3-12
3.2.1 Purpose 3-12
3.2.2 Application 3-13
3.2.3 RE Improvement Credits 3-14
3.2.4 Effectiveness of Rules 3-14
3.2.5 CE Evaluation , -. 3-17
3.3 PROJECTION YEAR RULE EFFECTIVENESS 3-17
3.3.1 Data Elements 3-18
3.3.2 Determination of RE 3-18
3.3.3 Point Source Projection Methods 3-20
3.4 SIP EFFECTIVENESS 3-23
3.4.1 Definition and Purpose 3-23
3.4.2 Calculation Procedure 3-23
3.4.3 Interpreting SE 3-25
4 SIP RE IMPROVEMENT CREDITS 4-1
4.1 DEFINITION AND PURPOSE 4-1
4.1.1 Determination of Improvements and
Improvement Measures 4-2
4.2 CREDITABILITY 4-7
4.3 STANDARDS FOR COMMITMENT TO RE IMPROVEMENT
MEASURES 4-8
.4.4 PERMISSIBLE MODIFICATIONS TO THE RE IMPROVEMENTS
METHOD AND MATRIX 4-9
4.5 EXAMPLE 4-10
5 AN INTEGRATED VIEW OF RULE EFFECTIVENESS S-l"
5.1 _RULE EFFECTIVENESS TYPES 5-1
~~5.1.1 Compliance Effectiveness . . . 5-1
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TABLE OP CONTENTS (Continued)
Section
5.1.2 Inventory RE ................ 5~5
5.1.3 RE Improvements .............. 5"6
5.1.4 SIP Effectiveness ............. 5~8
5.2 ECONOMIC INCENTIVES PROGRAMS ...... ..... 5-8
5.2.1 Compliance and Programmatic Uncertainty
Factors ................... 5-10
5.2.2 Relation to Inventory RE .......... 5-10
5.2.3 Mobile Emission Reduction Credit Programs . 5-11
APPENDIX A CALCULATION OF RULE EFFECTIVENESS FOR EMISSIONS
INVENTORIES ...................... A'1
APPENDIX B CORRECTION ERRATA TO THE 15 PERCENT RATE-OF-
PROGRESS PLAN GUIDANCE SERIES . . .- .......... B'1
APPENDIX C RE IMPROVEMENTS MATRIX ............. C-l
APPENDIX D GLOSSARY .................... D-X
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LIST OF TABLES
Number
Page
l-l Factors Influencing Generic Rule Effectiveness 1-2
2-1 Related EPA Publications . 2-3
3-1 Applying RE in Base Year SIP Inventories 3-4
3-2 The SIP Effectiveness Indicator 3-26
5-1 RE Type and Application Matrix 5-2
5-2 Interpretation of RE Values 5-4
LIST OF FIGURES
Number Page
3-1 Controlled emissions before and after application of
3.7
3-2 RE Factor as a function of control efficiency for
two RE adjustments 3-22
4-1 RE improvements matrix 4-3
5-1 SIP milestone and rule effectiveness schedule 5-3
5-2 Relation of compliance effectiveness to actual
emissions 5.5
5-3 Relation of rule effectiveness calculated by the SSCD
method to actual emissions 5-7
5-4 Relation of SIP effectiveness to actual emissions ... 5-9
111
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SECTION 1
INTRODUCTION
Rule effectiveness (RE) is a generic term for identifying and
estimating the uncertainties in emission estimates caused by
failures and uncertainties in emission control programs. It is a
measure of the extent to which a rule actually achieves its
desired emission reductions. Because it applies where emission
control programs are in place, RE is usually identified with State
implementation plans (SIP's) for areas which are not in attainment
with the national ambient air quality standards (NAAQS). The RE
applications include base year and projected emission estimates
for SIP components, appraisals of proposed SIP emission
reductions, periodic assessments of--the progress of emission -
reductions and individual and category-specific source compliance
determination and planning.
Rule effectiveness accounts for identifiable emission
underestimates due to factors including noncompliance with
existing rules, control equipment downtime, operating and
maintenance problems and process upsets. It may also indicate
errors in the projection of emission estimates as well as the
actual estimates themselves. For many applications, an RE
assessment includes the adjustment of emissions for sources or
source-categories to correct for these failures and uncertainties.
As such, RE provides a more reliable estimate for SIP control,
planning, and modeling activities.
There are no succinct mathematical formulae that adequately
account for the many different variables influencing RE, although
it can be thought of as a complex function of the following types.
of factors: the nature of the regulation, the nature of
techniques used to comply with the regulation, the performance of
each source in complying with the regulation, and the performance
of the implementing agency in enforcing the regulation. Table 1-1
lists specific examples of each type of factor. The list is not
exhaustive; however, it demonstrates the large number and wide
variety of factors that affect RE.
1.1 RE APPLICATIONS
The term "rule effectiveness" derives from the Environmental
Protection Agency's (EPA's), rule effectiveness protocol published
by the Stationary Source Compliance Division (SSCD) in March 1988,
and the post-87 ozone and carbon monoxide (CO) SIP policy.
Readers may refer to the SSCD protocol for the use of RE for
compliance purposes (Rasnic, John B., Director SSCD, to Regional
Air Directors, revised RE national protocol, December 21, 1992)
and the Procedures .for Estimating- and Applying- Rule Effectiveness
in Post-1987 Base Year Emission Inventories for Ozone and Carbon
Monoxide State Implementation Plans (Office of Air Quality
Planning and Standards, Research Triangle Park, NC, June 1989) for
1-1
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TABLE 1-1. FACTORS INFLUENCING GENERIC RULE EFFECTIVENESS
Nature of the Regulation or Control
possible ambiguity or deficiencies in wording
level of detail of recordkeeping required
level of complexity of compliance determination
inadequate test methods
Nature of Control Techniques Used to Comply With Regulation
level of confidence in long-term capabilities of control
technique (i.e., whether the emissions control is prone to
failure or degradation even with adequate attention)- - -
complexity of control technique (i.e., likelihood that
operator error or variability in operator technique could
affect compliance)
-potential for fugitive emissions not ducted to control
device (i.e., adequacy of emissions capture system)
Performance of Source in Complying With Regulation
training for those complying with environmental regulations
schedule for maintenance and inspection of control equipment
adequacy of recordkeeping practices (i.e., can compliance be
determined from available records?)
assurance of compliance over time, considering the previous
record of process upsets or control equipment malfunction
timeliness of response to notices of violation
Performance of Implementing Agency In Enforcing Regulation
attention and resources directed at this source or source
category
communications effort with respect to compliance
re qu i rements
completeness of data maintained on file
thoroughness in training inspection personnel
timeliness and thoroughness of inspections
adequacy of follow-up on noncomplying sources
Ability to Adequately Project Future Emissions
adequacy of baseline estimate
adequacy and accuracy of economic projections
technological changes and their penetration into the markets
effect of economically-based, innovative emission control
programs
1-2
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a statement of the original policy for emissions inventories. Use
of the term "rule effectiveness" has expanded to include other,
related, applications and has resulted in confusion over the
appropriate terms,, procedures and applications.
The appropriate method for determining and using RE depends
upon the purpose of the determination: SIP inventories, SIP
improvement creditability, SIP progress, and control program
compliance. Many specific RE applications may be generically
referred to as rule effectiveness. The following common uses fall
under the generic umbrella rule effectiveness:
Improving the accuracy or representativeness
of emission estimates" -across a -nonattainment
area is called inventory rule effectiveness.
When employed in a base year SIP (the usual
application), it is also called base year
inventory RE. When used during base year
projections to develop rate-of-progress plans
and demonstrate attainment, it is called
projection year inventory RE. Both are
referred to as inventory RE.
Rule effectiveness improvements are measures
taken to improve rule compliance and effect
emission reductions as part of a rate-of-
progress emission reduction program.
Measuring, defining, and refining the control
strategy progress to achieve the required
emission reductions designated in the Clean
Air Act (Act) is more accurately called SIP .
effectiveness.
Identifying and addressing weaknesses in
control strategies and regulations related to
compliance and enforcement activities is
called compliance effectiveness. These
applications fall under the purview of EPA's
SSCD.
Each user needs to determine the effectiveness of rules and
controls in reducing emissions to the desired level as it relates
to the specific purpose. For example, inventory personnel need to
know the expected exceedance of emissions from the base estimate
and the effect on emission projections. Both inventory and
planning personnel may work with rule improvements as part of
current and projected emission control programs. The SIP planners
are concerned with the ability of the SIP strategy to meet
specific ambient pollutant targets. Compliance personnel are
interested in the relationship between actual and permissible
emissions for a particular source or source category.
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1.2 POLLUTANTS
Because RE originated with ozone/CO SIP guidance, it is
primarily associated with volatile organic compounds (VOC)
emissions and controls. Most current SIP emission controls
continue to be VOC based. The EPA requires that RE be applied to
base year SIP inventories for ozone precursors and CO. The RE
currently applies to the ozone precursors, CO, oxides of nitrogen
(NOJ , and VOC, although applications have been limited or, in the
case of NOX/ absent due to the lack of control programs. As
additional guidance and regulations are applied to other
pollutants, such as sulfur dioxide (S02) and particulates less
than 10 microns in diameter tPM-10), RE will be applied to these
emission estimates.
1.3 SOURCE TYPES
Point, area and mobile sources are all subject to RE. The RE
for point and area sources is typically an explicit component of
the emission estimate to more accurately represent actual
emissions. For mobile sources, models developed by the Office of
Mobile Sources (QMS) factor RE effects internally and not as a
single, explicit component. Readers undertaking the various
applications which are subject to RE or a similar adjustment,
should identify how and where RE is used.
1.4 PURPOSE
The purpose of this document is twofold: (1) to summarize
and integrate the various RE concepts, and (2) introduce the
procedures necessary to quantify SIP RE improvements for emission
reduction credits. Similarities and distinctions are drawn
between RE concepts and guidelines are presented for interpreting
results using different RE applications. Various EPA publications
which describe RE or refer to RE applications are identified.
1-4
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SECTION 2
APPLICABLE GUIDANCE
Various EPA publications describe RE or applications using RE
concepts. This section provides a listing of these publications
and identifies the context of the reference (Table 2-1) . Many of
these publications originated with the EPA Office of Air Quality
Planning and Standards (OAQPS), including the Air Quality
Management Division (AQMD), Ozone and CO Programs Branch (OCMPB);
the Technical Support Division (TSD), Emission Inventory Branch;
and the SSCD, Technical Support Branch. Rule effectiveness is
also mentioned in QMS guidance and in Regional Office studies.
Readers interested in various RE guidance arid applications should
refer to the appropriate guidance document; "The primary RE
publications which provide guidance on determining and calculating
RE are listed below:
Procedures for Estimating and Applying Rule Effectiveness in
Post-1987 Base Year Emission Inventories for Ozone and Carbon
Monoxide State Implementation Plans, Office of Air Quality
Planning and Standards, Research Triangle Park, NC, June 1989.
This is the first document on RE for inventory applications
and presents the post-87 SIP policy on RE. This policy is defined
in 52 FR 45059. It has been replaced by the following document
for SIP's developed under the Act.
General Preamble for the Implementation of Title I of the Clean
Air Act Amendments of 1990. 57 FR 13498, April 16, 1992.
The General Preamble, the road map for Title I
implementation, sets out the RE policy in the context of the 15
percent rate-of-progress plans required for moderate and above
nonattainment areas. Under this policy, EPA recognizes that
improving the implementation of existing rules is a valid control
measure towards meeting the mandated 15 percent emission
reduction. These "rule effectiveness improvements" are creditable
within the same constraints as other reduction measures. These
improvements must result in real emission reductions; simply
altering the method of calculating RE is not creditable.
Guidelines for Estimating and Applying Rule Effectiveness for
Ozone/CO State Implementation Plan Base Year Inventories. EPA-
454/R-92-010. Office of Air Quality Planning and Standards,
Research Triangle Park, NC. November 1992.
This publication replaces the post-87 SIP policy and is
consistent with other 1990 base year SIP inventory guidance. It
provides a background discussion, procedures for estimating
inventory RE, procedures for adjusting base year emissions and
numerous examples for applying RE. The document defines
exemptions to RE, such as direct determination, with examples. It
2-1 -
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addresses how to conduct an RE survey and interpret the results,
including approved point and area source questionnaires.
Rasnic, John B., Director SSCD, to Regional Air Directors, .Revised
Rule Effectiveness National Protocol, December 21, 1992.
This memorandum describes the SSGD RE "protocol study"
approach and updates the original policy presented in March 1988,
It identifies the procedures for States to use in conducting an RE
study. The memorandum contains an overview of the purpose and
goals of the SSCD protocol, the correct method(s) for choosing a
sample of sources, the process of field inspections and office
investigations, as well as other steps in conducting an RE study.
The attachments~in the document-have checklists for State
inspectors to use during a study. An example of a final RE study
report is provided.
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TABLE 2-1. RELATED EPA PUBLICATIONS
"Source/
Reference
Publication/
Context
OAQPS/AQMD
p. 26
p. 35
OAQPS/AQMD
p. 11
OAQPS/AQMD
p. 17
Guidance on the Adjusted Base Year Emission
Inventory and the 1996 Target for the 15 Percent
Rate-of-Progress Plans, EPA-452/R-92-005, October
1992
1996 and attainment projections. The Act-mandated
controls and their associated control efficiencies
and RE factors for both the 15--percent rate-of-
progress plan and the attainment demonstration are
required in both written and electronic formats (see
Table 1 of the guidance). Related information for
additional controls is encouraged.
RE improvements. States with pre-existing
nonattainment areas have concerns about what
additional measures are needed to achieve the 15
percent reduction requirements where RACT rules have
already been adopted. The RE improvements are
creditable reductions (and subject to the same
constraints as other creditable reductions) where
the reductions are real and not merely higher RE
calculations. The RE improvements must be
documented using a post-implementation SSCD protocol
study.
Procedures for Preparing Emissions Projections, EPA-
450/4-91-019, July 1991
For the purpose of ... projection year emissions
inventories under the Act, EPA will allow the use of
the 80 percent default value for RE, but will also
give States the option to derive local, category-
specific RE factors. In both baseline and control
strategy projections, the RE determined for the
source category should be applied to all sources in
the category .... (This guidance has been amended
herein and conforms to the subsequent base year RE
options for assigning RE to individual sources and
source categories.)
Guidance for Growth Factors, Projections and Control
Strategies for the 15 Percent Rate-of-Progress
Plans, EPA-450/R-93-002, March 1993
Projections. Rule penetration and RE measure the
number of sources subject to a regulatory
requirement that are attempting compliance and the
degree to which those sources are complying.
Assumptions concerning these two elements of a
regulatory program can have major impacts on the
nature and scope of the program.
(continued)
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TABLE 2-1. RELATED EPA PUBLICATIONS (continued)
Source/
Reference
Publication/
Context
p. 45
OAQPS/AQMD
p. 21-24
OAQPS/TSD
p. 23
OAQPS/TSD
p. 25
OAQPS/TSD
p. 2-10
RE improvements. One method of achieving creditable
emissions reductions from stationary sources is to
improve the implementation of existing regulations.
These improvements (i.e., emission reductions) are
subject to the same creditability constraints as are
the other emission reductions. The RE improvements
must reflect real emissions reductions resulting
from specific implementation of program improvements
(i.e., RE improvement measures). Actual emissions
reductions must result-from improving RE; - simply-
calculating a higher RE using a different
methodology is not creditable. The RE improvements
must be documented as a minimum by conducting a
post-implementation source-specific emission study.
Base year RE (pre-implementation) may have been
determined using any of the four approved methods.
Guidance on Preparing Enforceable Regulations and
Compliance Programs for the 15 Percent Rate-of-
Progress Plans, EPA-452/R-93-005, June 1993
Brief overview of different applications of RE.
Emission Inventory Requirements for CO State
Implementation Plans, EPA-450/4-91-011, March 1991
Base year inventory RE (CO). The RE shall be
applied for stationary sources that are affected by
a regulation and for which emissions are determined
by means of emission factors and control efficiency
estimates, and for fuel programs.
Emission Inventory Requirements for Ozone State
Implementation Plans, EPA-450/4-91-010, March 1991
Base year inventory RE (ozone). The RE determined
for the source category shall be applied to all
sources in the category (both point and area
sources).
Procedures for the Preparation of Emission
Inventories for CO and Precursors of Ozone, Volume
I: General Guidance for Stationary Sources, EPA*
450/4-91-016, May 1991
Base year inventory RE. An adjustment applicable to-
base year stationary point and area emissions is RE.
The RE is a factor applied from an individual
source's or a source category's average emissions
control efficiency to adjust the estimated emissions
to a more realistic level.
(continued)
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TABLE 2-1. RELATED EPA PUBLICATIONS (continued)
Source/
Reference
Publication/
Context
OAQPS/TSD
QMS
p. 43-61
Procedures for Emission Inventory Preparation,
Volume IV: Mobile Sources, EPA-450/4-81-026d, 1992
Mobile sources. Factoring compliance rates into
emission control programs is discussed, including
reference to default values, MOBILE model inputs and
references to additional, detailed guidance for
model inputs.
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SECTION 3
RULE EFFECTIVENESS APPLICATIONS
This section presents the current applications of RE. These
applications include the following uses:
Inventory (base year) SIP
Inventory (projection year) SIP
Compliance effectiveness
SIP RE improvements
SIP effectiveness
The first two, base year and projection year RE, employ inventory
RE and differ only in the application of inventory RE, not the
determination of RE.
Each application is presented with relevant equations and
guidance on appropriate use. Where applicable, examples are
included to illustrate the calculation procedure. Inventory RE
and compliance effectiveness, which are discussed in detail in
other guidance documents, are only summarized here. The SIP RE
improvement is a new concept and a complete description and
quantification procedure are presented here. The SIP
effectiveness has been referenced in other documents, but a more
complete and integrated exposition is provided here.
3.1 INVENTORY (BASE YEAR) RULE EFFECTIVENESS
3.1.1 Definition and Purpose
The inventory RE is an adjustment to estimated emission data
to account for emission underestimates due to compliance failures
and the inability of most inventory techniques to include these
failures in an emission estimate. The RE adjustment, applied to
the base year SIP inventories, accounts for known or suspected
underestimates due to noncompliance with existing rules, control
equipment downtime or operating problems and process upsets. The
result is a best estimate of actual base year emissions, leading
to more reliable estimates of expected emission reductions and
control measure effectiveness in future years. The EPA requires
that base year SIP inventories for ozone and CO nonattainment
areas apply and report RE. As post-Act guidance for other
nonattainment area inventories (e.g., S02 or PM-10) is released,
these inventories may also require the RE adjustment.
The RE adjustment is a category-specific emission adjustment
applied to both point and area sources operating under emission
control rules [e.g., sources in a control techniques guidelines
(CTG) category]. Rule effectiveness is applied to point and area
source emissions by category; for point sources the calculation
procedure requires that emissions be calculated process by
3-1
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process. Area sources also include a rule penetration factor
which adjusts the inventory according to the percent of sources in
a category which is actually covered by the regulation. The
results of an RE evaluation should be interpreted as an aggregate
for the category as control strategies are developed and not
solely applied to the individual sources that were evaluated.
Base year inventory RE considers that emission changes
brought on by growth, production changes, etc. are artifacts that
should be excluded when determining RE. Inventory RE simply
adjusts the estimated emissions for the effects of noncompliance.
By definition, all source categories for which a regulation exists
should have an RE value between zero and 100 percent (i.e., source
categories for-which no-regulation exists-would-have-no RE factor
associated with them). To say that a particular regulation was
100 percent effective would mean that the regulatory agency could
ensure complete and continual compliance at all sources covered by
the regulation, with no incidence of control equipment failure or
process upset at any source and no sources evading control
requirements. To say that a regulation was zero percent effective
would mean that no sources in the category had made any effort to
comply with the applicable regulation. The RE cannot tie less than
zero or greater than 100 by definition.1
3.1.2 Relation to Other RE Applications
State or local agencies must assume that there will be less
than 100 percent compliance of rules in the absence of
substantiation. Otherwise, rules will not actually achieve the
intended reductions mandated in Section 182(b)(l) and 182(c)(2)(B)
of the Act: 15 percent over 6 years, and 3 percent per year
thereafter until attainment is reached.
Because inventory RE relates directly to the compliance
procedures and history of sources in the inventory, measures of
compliance effectiveness can be used as the basis for an RE
determination. Results from an appropriate SSCD Protocol study,
discussed later in this section, may be used as the basis for an
inventory RE calculation.
Greater than 100 percent RE would imply that rules or controls are more
effective than, designed. Certain circumstances such as economic downturns and
process changes may cause a real reduction in emissions, but these decreases
are not attributable to RE, Some- States have suggested that overcompliance co
avoid potential violation ramifications does- indeed produce greater than
anticipated reductions. The EPA encourages States to document and quantify
overcompliance within the context of the emission estimate, but will not
recognize RE in excess of 100 percent.
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Although not typically identified by the term rule
effectiveness, mobile source inventories account for noncompliance
within the EPA-sponsored software designed to generate emission
factors for mobile sources (the MOBILES model). Mobile sources
are addressed separately at the close of this discussion.
3.1.3 Estimating and Applying Base Year RE
The information presented in this"section has been taken from
Guidelines for Estimating- and Applying RE for Ozone/CO SIP Base
Year Inventories (EPA-454/R-92-010, Office of Air Quality Planning
and Standards, Research Triangle Park, NC, November 1992).
Consult that document for detailed procedures, explanations and
documentation of RE before applying RE to-a base year inventory.
Table 3-1 summarizes the steps involved.
3.1.3.1 Identifying relevant categories and sources
Every source category subject to an emission control
regulation during the inventory period should be considered for
application of RE. For many nonattainment areas, the list of CTG
categories provides a starting point to identify regulated
sources. It is important to include all-regulated sources,
regardless of whether the regulation had received official EPA
approval prior to the inventory period. In some cases, sources
are exempt from emission regulations if an emission cap (e.g., 25
tons VOC per year) is not exceeded as defined by the emission
control rule. These sources are not necessarily subject to RE,
although a State or local agency may choose to include these
sources if compliance with the emission cap after the application
of the appropriate RE factor is a known problem. Once the
affected emission categories and sources have been identified,
each source within a category is reviewed to determine the
appropriate RE application.
The following sources are exempt from the RE adjustment:
sources where no controls are required
(i.e., the source is unregulated)
sources for which control is achieved by means
of an irreversible process change that
eliminates the use of VOC or the potential for
CO emissions
sources for which emissions are calculated by
means of a direct determination
For sources that are affected by a rule but are completely
uncontrolled, an RE of zero percent should be recorded in the
inventory. Sources using an irreversible process change to
control emissions should be assumed to be achieving 100 percent
3-3
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TABLE 3-1. APPLYING RE IN BASE YEAR SIP INVENTORIES
Step
Considerations
Determine
relevant emission
categories
Identify exempt
sources
Calculate an RE
value (%) for
each relevant
category
Calculate control
efficiency for
each affected
source
Calculate base
year emissions
(adjusted for RE)
Document RE
calculations
Source categories which are subject to
emission controls (i.e., there is a rule
in place) during the year of inventory
should be considered.
Emissions from sources with uncontrolled,
directly determined or permanently
eliminated emissions are.exempt, from
adjustment for RE.
Agencies calculate RE values derived from
an SSCD study, RE questionnaires or the
default value. Questionnaires require a
survey of sources in the categories
identified in the first step. Alternate
methods for highly controlled sources may
be developed with the approval of EPA.
A reasonable estimate of the emission
control efficiency for each source (point)
or category (area) is essential to the RE
calculation. This efficiency may be
measured or estimated based on the control
device or estimated based on the rule in
place.
Emissions are adjusted for RE as described
in the Guidelines for Estimating and
Applying" RE guidance using uncontrolled
emissions, control efficiency and the RE
value; these emissions are the SIP base
year emissions.
When submitting the SIP inventory,
agencies should document the procedures
and calculations made to show that RE has
been appropriately addressed, including
criteria used to exempt sources.
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RE. When emissions can be calculated by means of a direct
determination, RE falls out of the calculation and, thus, is not
applicable (i.e., the emission estimate is not contingent on the
effectiveness of controls).
3.1.3.2 Determining RE
In determining an RE value for adjusting the base year VOC
emission inventory, State and local agencies may elect to (1) use
an across-the-board RE presumption of 80 percent for all sources;
(2) use the questionnaire approach specified in the Guidelines for
Estimating and Applying RE to determine a category-specific RE
value for both point sources and area sources; (3) use or design a
study- specific to a category in--accordance with the procedure
developed by SSCD; or (4) develop an alternate approach specific
to the Region, State or locality as approved by EPA.2 Special
consideration and options for highly-controlled sources have been
proposed by EPA.
/
3.1.3.3 Applying RE
Applying RE requires three inventory data elements: (1) the
RE value (percent); (2) overall control efficiency; and (3)
estimated uncontrolled emissions. Once a source has been
determined to be subject to RE and an RE percentage has been
determined for each source category, the emissions from that point
or area source can be adjusted. If the questionnaire approach was
used, each category will be composed of surveyed and non-surveyed
sources. Apply the individual questionnaire RE result for sources
surveyed by the questionnaire; apply the calculated category RE
value to the sources in the category which were not surveyed. The
calculation is done source by source at the emission calculation
step [typically the segment or process level in the Aerometric
Information Retrieval System (AIRS) for point sources and category
by category for area sources].
The following equation is used to calculate rule-affected
emissions:
RE Emissions = Uncontrolled Emissions x (1 - (Control Efficiency x RE )) (1)
100 100
where RE and control efficiency are expressed as percent. The
equation clearly demonstrates that RE accounts for the
effectiveness of the control and should be applied to both
2 Seitz, John S.; Memorandum on Calculation of Rule Effectiveness for
Emissions Inventories; May 26, 1993. This memorandum is reproduced as
Appendix A.
3-5
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regulatory and physical controls. Figure 3-1 displays the RE
adjustment effect based on 80 and 90 percent inventory RE across a
range of control efficiencies.
Regulatory controls are emission limits implemented through
either regulatory or physical means. A solely regulatory control
is typically an emission rate limitation unrelated to a control
device. For example, an industrial coating operation may be
limited to usi-ng a coating of no more than 2.0 Ibs VOC per gallon
coating. In these cases, the control efficiency derived for
equation (l) is based on the difference between total solvent
consumption pre- and post-regulation or the expected emission
reduction percent calculated for the regulation(s) affecting the
source. ~ - ....
A physical control is a control device such as an incinerator
or carbon adsorber used to reduce emissions from a process.
Control efficiency may be reported on -the basis of the
manufacturer's specifications or emission testing. To be
reliable, capture efficiency, actual operating conditions, and
process and/or device upsets must be included when estimating
emissions. These variables may be factored into a single average
control efficiency or emissions may be estimated for each
different operational mode (refer to the appropriate emission
inventory guidance).
Rule effectiveness must be documented in the SIP inventory
submittal, consistent with the OAQPS Emissions Inventory
Requirements, the Quality Review Guidelines, and the individual
inventory preparation plans. These requirements include a
discussion of how RE was incorporated into the inventory. States
should clearly annotate emission summary tables as either adjusted
or unadjusted for RE. Emission estimates will be reviewed to
ensure appropriate application of RE in the base year inventories.
Any deviations from OAQPS guidance on RE should be discussed in
the submittal.
3.1.3.4 Highly-controlled sources
The EPA recognizes that emissions from sources with control
efficiencies in excess of 95 percent may appear to be artificially
inflated and can negatively impact air quality modeling analyses.
EPA guidance permits three options to evaluate highly-controlled
sources (i.e., sources with control efficiencies in excess of 95
percent). Prior to implementing these options, the State should
attempt to verify both capture and control efficiencies for these
highly-controlled sources. The following options are summarized
from Guidelines for. Estimating- and Applying- RE:
Option I: apply the questionnaire to
determine the actual RE source by source. If
the questionnaires cannot be completed by the
3-6
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study between the base year inventory and
control strategy development phases of a SIP.)
Adjust the base year emissions inventory after
the new RE values have been calculated for
these sources.
As of the publication of this document, two State agencies
successfully implemented Option I in addition to application of
the 80 percent default (Option II).
Example
The following example illustrates how to assess and calculate
RE in a base year emission calculation. The EPA Guideline
referenced previously contains many examples for both point and
area source applications, including examples using regulatory
controls and requiring calculation of solids equivalency for
coatings.
An assembly plant that coats automobile parts uses 150
gallons per day of coatings containing 5.5 pounds VOC per gallon.
An additional 10 gallons of solvent, with a density of 7.1 pounds
VOC per gallon, is used for cleanup each day. Emissions are
controlled by an incinerator that demonstrated a 90 percent
capture and control efficiency during a recent test. The plant
keeps substantial records of coating and solvent usage, but no
data on control device operation and/or maintenance. The RE for
this source category has been determined to be 75 percent based on
questionnaire responses. What emissions should be reported in the
inventory?
It may appear that emissions can be calculated by means of a
direct determination due to the good coating and solvent records
at the source. However, the presence of a control device
precludes direct determination of emissions. Therefore, RE needs
to be included in the emission calculation.
Uncontrolled Emissions = (150 gal Coating/day x 5.5 Ibs VOC/gal Coating)
+ (10 gal Solvent/day x 7.1 Ibs VOC/gal Solvent)
= 825 Ibs VOC/day + 71 Ibs, VOC/day
= 896 Ibs VOC/day (1)
(Had the RE value been 35 percent rather than 75 percent, Che
adjusted emissions would have been 211 Ibs/day rather than 291
Ibs/day, The 10 percent RE 'increase would have translated into a
27 percent decrease in estimated emissions.)
3-8
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Emissions = Uncontrolled Emissions x [1 - (Control EfficiencyxKE)]
= 896 IJbs VOC/dayx [1 - (0.90) (0.75)]
= 291 IJbs VOC/day (2)
3.1.4 Other Interpretations of Inventory RE
Other Agencies have or may adopt different approaches to
incorporating RE into their base year inventories based on their
experience. Any alternate approaches applied to SIP inventories
must be approved by EPA prior to submittal of the-inventory.
3.1.5 Mobile Sources
The term rule effectiveness is infrequently applied to mobile
sources. The effects of noncompliance have been integrated into
the inputs of the MOBILE models developed by QMS, including the
latest MOBILES. Because RE has historically not been treated
explicitly, mobile source guidance does not identify any single
term or group of terms as RE- However, some of the various
components of base year RE, as applied to mobile sources, are
identifiable.
Procedures for Emissions Inventory Preparation, Volume IV:
Mobile Sources (EPA-450/4-8l-026d; 1992) identifies several mobile
source control measures which could be affected by noncompliance.
Although this list is not exhaustive, it introduces the major
control program types and RE components integrated into a base
year inventory:
Inspection and Maintenance (I/M)
Anti-tampering programs (ATP's)
Fuel volatility specifications for Reid vapor
pressure
-------
terminology of RE. For a more complete discussion of these
concepts and their specific relationships to the MOBILE model,
refer to pages 43-61 of Procedures for Emission Inventory
Preparation, Volume IV: Mobile Sources.
The four major control programs listed previously are general
emission reduction classifications. Other programs, notably
economically-based approaches such as the mobile emission
reduction credit program, do exist and should be adjusted for
noncompliance as well.
3.1.5.1 I/M
The I/M programs-are inspections-of vehicles-using a
measurement of tailpipe emissions. Vehicles exceeding program
cutpoints are repaired to pass a retest (or the owner is required
to spend up to a maximum dollar amount to meet the standards).
The I/M effectiveness depends on numerous factors, including the
compliance rate. The annual compliance rate is simply the
percentage of subject vehicles which complete the inspection and
certification process. The I/M compliance can be determined
through sticker surveys, license plate surveys or a gross
comparison of the final tests completed to the total number of
subject vehicles. The EPA assumes that a 98 percent compliance
rate is possible in areas with: (1) a registration system using
automatically-generated compliance documents to uniquely and
serially identify complying vehicles with, (2) centralized
government processing under management oversight. Areas with less
stringent requirements or enforcement will have lower compliance
rates.
3.1.5.2 ATP'S
The ATP's encompass periodic inspections of vehicles to
detect damage to, disabling of, or removal of emission controls.
Many mobile emission control programs combine I/M and ATP into a
single inspection; the MOBILE model uses a single compliance rate
to reduce both the I/M and ATP portions of the program. The ATP's
may include inspection of several vehicle components:
Air pump
Catalyst
Fuel inlet restrictor
Tailpipe lead (misfueling indicator)
Exhaust gas recirculation system
Evaporative control system
Positive crankcase ventilation system
Gas cap
The MOBILE models calculate tampering rates based on these
eight components. The OMS developed and recommends tampering
rates from their analysis of multi-city tampering surveys.
- 3-10
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3.1.5.3 Fliel specifications
Evaporative and exhaust emissions vary with fuel volatility.
EPA describes specific procedures to determine fuel volatility
(RVP) in the User's Guide to MOBILES (10/93) available from QMS,
Emission Planning and Strategies Division. The RVP data may be
available from several sources and should be used in the following
order of preference:
Local survey data which, because these are
actual measured values, show noncompliance or
overcompliance. These data are available for
many cities as published by the Motor Vehicle
Manufacturer's Association~or~the National
Institute for Petroleum and Energy Research,
or may be gathered in a local, quality-assured
survey.
Nearby area survey data available from the
sources listed above.
Federal or State RVP limits which are adjusted
up or down based on available information on over-
or under-compliance.
3.1.5.4 Refueling
Refueling emissions for gasoline-fueled vehicles result from
the displacement of vapor from the fuel tank to the atmosphere.
Controls include "at the pump" (Stage II) and "onboard" vehicle
refueling systems. Spillage and the inherent efficiency of these
systems impact the overall control effectiveness. Exemptions,
equipment age, maintenance, and frequency and stringency of
inspections by service station operators and personnel influence
the efficiency of the systems.
The EPA recommends that MOBILES be used to model refueling
emissions. The Z7ser's Guide to MOBILES (10/93) shows how to input
this information and allows user input for control efficiency and
phase-in parameters. The EPA has estimated the typical
effectiveness of Stage II programs in Technical Guidance - Stage
IX Vapor Recovery Systems for Control of Vehicle Refueling
Emissions at Gasoline Dispensing Facilities, EPA-450/3-91-022A,
November 1991. Based on Act exemptions for stations selling fewer
than 10,000 gallons of gasoline per month (50,000 gallons per
month for small, independent marketers), EPA has supplied these
overall control estimates for combined emissions from spillage and
displacement:
83 percent for semi-annual agency inspection
programs
3-11
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77 percent for annual agency inspection
programs
56 percent for minimal agency inspections
Local studies of Stage II controls are preferred. The MOBILE
model supports locally-derived control estimates or these default
values as inputs.
3.2 COMPLIANCE EFFECTIVENESS (SSCD PROTOCOL STUDY)
3.2.1 Purpose
The rule effectiveness national protocol provides guidance to
the States and local agencies for conducting-rule effectiveness
studies that conform to standards set by the SSCD. The SSCD
protocol studies, as they are called, were initiated in 1988 as a
compliance tool. Recent revisions, including the 1992 revision,
have extended -their scope to include the emissions inventory and
SIP planning processes.
There are two primary purposes for the SSCD studies. First,
they "determine the effectiveness of rules for a specific source
category in a specific nonattainment area."3 Second, the studies
"identify specific implementation problems which need to be
addressed by the State and EPA compliance and enforcement staff."3
The two purposes are complementary because States determining the
effectiveness of a rule usually identify problems that the
regulatory agency has had in implementing and enforcing it. Once
the problems have been identified, recommendations can be made to
correct them.
The SSCD recognizes the following three applications of the
results of a protocol study:
Compliance effectiveness; the original and primary
reason to study source category compliance histories,
implementation procedures, and regulatory applicability
and effects on emissions
Rule effectiveness; derived from compliance
effectiveness, to assess the "excess" emissions which
should be attributed to a source category
The SIP effectiveness; derived from compliance
effectiveness, to identify emission surpluses and
shortfalls during SIP implementation
Rasnic, John B.; Memorandum on Revised Rule Effectiveness National Protocol;
December 21, 1992.
3-12
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In addition to these applications, the RE improvement credits
discussed in detail in section 3.2.3 rely on protocol study
results to demonstrate planned reductions.
3.2.2 Application
The SSCD protocol prescribes inspections, emissions tests and
agency audits to compare actual measured emissions to "allowable"
emissions under the existing rule(s). The difference represents
the degree of compliance with the rules (i.e., the RE in achieving
emissions reductions). The protocol requires that the source
sample size from a single source category be determined
statistically, with considerations given to the allocation of
personnel for -inspections.3- (Sampling requirements -are outlined
in the national protocol.)
The protocol describes the criteria and procedures that the
States should use in conducting the two phases of the SSCD
studies. The State or local agency should recommend the
appropriate order for conducting these phases in their particular
area. One phase is a field inspection in which the State agency
visits a representative number of facilities and determines their
compliance with the rule. A second phase is an office
investigation in which the State agency evaluates the
implementation of the regulatory program. The SSCD protocol
ensures that studies are completed so that the integrity of the RE
factors developed for a specific source category in a specific
region is maintained. As the studies are source- category-specific
for a particular nonattainment area, the RE factors cannot be
generalized to a whole population. Similarities in implementation
problems, compliance and rule applicability may be identified when
reviewing studies from different regions for the same source
category. One State has requested and received approval to use
the results of their protocol study in their 1990 base year
inventory for that source category.
An SSCD study identifies problems which can be corrected,
processes corrective action options, and comments on advantages
and disadvantages of each option. Within one year following a
study, a follow-up audit is conducted to determine whether
corrective actions were implemented. Finally, an SSCD study
includes an inventory demonstration for the selected source
category which includes the following elements: (1) field
investigation follow-ups if inventory discrepancies evolve; and
(2) a search for potentially omitted sources, including a survey
of source exemption applicability and a ground survey to locate
unregistered sources.
3-13
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3.2.3 RE Improvement Credits
The SSCD studies are important to States seeking to quantify
the reductions in actual VOC and/or NOX emissions in nonattainment
areas. For example, section 182(b)(l)(A) of the Act requires
States with ozone nonattainment areas classified as moderate and
above to submit revisions to their SIP's by November 15, 1993.
These SIP revisions must include rate-of-progress plans that
demonstrate a 15 percent reduction in actual VOC emissions by
November 15, 1996. States are allowed to use RE improvements in
rate-of-progress plans and attainment demonstrations. Refer to
section 4 for a more detailed discussion of RE improvements,
To receive-credits -for an RE improvement, a State must
document the emission reductions associated with the improvement.
The General Preamble for Title I identifies SSCD studies as the
primary tool States should use for the documentation. The
Preamble suggests that the studies be completed before and after
an RE improvement has been implemented. The difference in actual
emissions before and after the improvement should be documented in
the SSCD study. The requirement of the 1996 SSCD study ensures
that only real reductions will be counted. Once the documentation
has occurred, the State can calculate the emission reduction
credits to be earned from the RE improvement.
For those States that have been using the 80 percent RE level
in their emission inventories, the SSCD study would have to
demonstrate an RE above that level after the RE improvement for
the State to receive emission reduction credits for an RE
improvement. For example, assume that an SSCD study revealed that
a rule has been 75 percent effective in reducing emissions from a
source category. The State has been applying 80 percent RE to its
emission inventories for that source category. If a second SSCD
study revealed that the RE would be 85 percent after an
improvement to the rule, then the State would receive the emission
reduction credits associated with a 5 percent (85 percent - 80
percent) RE improvement, not 10 percent (85 percent - 75 percent).
If the State had applied the 75 percent RE factor to their base
year inventory, the entire 10 percent difference would be
creditable.
3.2.4 Effectiveness of Rules
The SSCD national protocol defines three methods
corresponding to the three applications mentioned in
Section 3.2.1: compliance effectiveness, rule effectiveness, and
SIP effectiveness. Each method relies on data generated through
the SSCD study, but each represents a different evaluation of the
overall effectiveness of an emissions control program.
3-14
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The SSCD study approach may be applied only to a single
source category for which a given study is designed. The result
of each study is a category-specific RE estimate for a particular
geographic area and category. States and local agencies may need
to determine if previously existing SSCD study results remain
valid or if the study is outdated due to industry or regulatory
changes. Only studies deemed valid for the inventory period may
be used. To apply the result for SIP purposes, the calculation
must reflect this context.
In meeting the objective of determining the effectiveness of
a rule, an SSCD study should generate an effectiveness ratings.
These ratings attempt to quantify how well sources are cpmplying
with the rule and how well "the -regulatory-agency is enforcing -it.
There are three methods for assessing the effectiveness of a rule:
the compliance effectiveness (CE) method, the rule effectiveness
method, and the SIP effectiveness method. The first two methods
focus on the severity of noncompliance with a rule, as measured in
excess emissions.
The equation for the CE method is the following:
CE = [Allowable - (Actual - Allowable) ] x 1QO
Allowable
The CE method quantifies excess emissions in relation to allowable
emissions. The method provides an accurate gauge of the excess
emissions generated by a particular source category and the degree
to which those emissions exceed the standard. For example, assume
an auto body finishing shop has a VOC coating standard of 3.8 Ibs.
VOC/gallon of solids. If an auto body finishing facility is using
a coating that exceeds the standard by 1.0 Ibs./gallon of solids,
the percentage effectiveness according to the CE method would be
the following:
CE = [3'8 ~ (4.8-3.8)]
There are inherent limitations with the CE method. None of.
the variables in the equation takes into account the emission
reductions required or achieved under a rule. Therefore, one
cannot directly compare the excess emissions with the reductions
required by a given rule. The method also has an inherent
mathematical problem. If actual emissions are greater than twice
the allowable emissions for a source category, the equation
generates a negative percentage effectiveness. A negative
3-15
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percentage effectiveness indicates that a rule would actually
increase emissions from a source category, which is highly
unlikely. In such a case, the regulations agency should closely
examine both source compliance and the rule itself to determine
how the rule is increasing emissions.
The equation for the RE method is the following:
RE
(Baseline - Actual)
(Baseline - Allowable!"
x 100
(6a)
or
Allowable
RE = (1 - Control Efficiency)
- Actual
Allowable
x 100
(6b)
(1 - Control Efficiency)
- Allowable
where: baseline
actual
allowable =
control efficiency
uncontrolled base year
emissions
actual emissions from the
source or source category
allowable emissions determined
from the SIP
control efficiency defined in
the CTG
Like the CE method, the RE method measures the magnitude of excess
emissions. However, it differs for the other two in that it ties
excess emissions to the reductions achieved and required by the
rule. In the framework of the previous example for the CE method,
consider the auto body finishing category. Assume that the shops
purchase reformulated coatings to meet a new standard, 2.2 Ibs. of
VOC/gallon of solids. The CTG considers this to equate to a 60
percent reduction in emission rate. However, the auto body
finishers operate above the standard, at 2.6 Ibs. VOC/gallon
solids. Therefore, the percentage effectiveness would be:
2.2
RE
(1 - 0.6)
- 2.6
2.2
x 100 = 87
(7)
(1 - 0.6)
- 2.2
The RE method also has some limitations associated with it.
If baseline data are not available, the method allows the use of
the categorical reduction assumptions in the control technique
guidelines. The assumptions are often inaccurate, which can lead
3-16
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to an inaccurate RE rating for a source category. Another
limitation with the method occurs when few, if any, emission
reductions are required for a facility. If the facility generates
small excess emissions, the RE method gives it a very poor
effectiveness .
The SIP effectiveness method provides information on the
current progress toward the planned emission reductions:
_ (Baseline Emmissions - Current Emissions)
(Baseline Emissions - Projected Emissions)
The SIP effectiveness is discussed separately in detail in
section 3.4.
3.2.5 CE Evaluation
A percentage effectiveness rating is not enough to describe
the compliance effectiveness of a rule for a source category. An
SSCD study should attempt to link the rating to a regulatory
agency's overall effort. The study should address the factors
that affect the percentage effectiveness rating such as the
compliance rate of the sources in a category, inspection frequency
and thoroughness, the language of the rule (i.e., whether or not
it has loopholes), and the reporting and recordkeeping by the
regulatory agency. Evaluating these factors will provide a more
complete evaluation of the effectiveness of a rule.
3.3 PROJECTION YEAR RULE EFFECTIVENESS
The RE must also be factored into the projected inventories
that support the SIP rate-of-progress plans. New control measures
cannot be assumed to be 100 percent effective; the emission
estimates based on the emission control strategies must account
for the same effects of noncompliance as did the base year
inventory. The EPA recently published guidance on the preparation
of emission projections to support the 15 percent rate-of-progress
plans required for the Act (Guidance .for Growth Factors,
Projections, and Control Strategies for the 15 Percent Rate-of-
Progress Plans, EPA-450/R-93-002, March'1993), Emission
projections are used in conjunction with ambient air quality
modeling analyses to determine whether NAAQS attainment will be
reached. The EPA requires rate-of-progress plans submitted by
November 1993 to demonstrate reductions planned by 1996.
Subsequent EPA guidance will address the 3 percent-per-year
reductions required after 1996 for areas requiring further
reductions to reach attainment. Areas which meet the required
reductions in terms of real, permanent, enforceable reductions are
making reasonable further progress (RFP).
3-17
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3..3.1 Data Elements
Emission projections are used to predict future inventory
(and, in part, ambient) conditions and test the ability of
regulatory control strategies to show RFP and demonstrate
attainment. The following data are required to calculate
projection year emissions:
Base year data
Operating rate
Emissions
Emission factor
Control efficiency
Rule effectiveness
Projection year data
Growth factor
Allowable limits (emission factor, control
efficiency, emission rate)
Rule effectiveness
Later in this section,, the equations necessary to calculate
projected emissions will be presented. The terms Current Control
Projection Emissions and Control Strategy Projection Emissions
will be used. The former refers to emissions which have been
projected from current emissions or operating conditions and
growth factors on the basis of current controls and RE only. The
latter refers to emissions projected based on future control
strategies and RE values for those strategies.
3.3.2 Determination of RE
The function of RE in projecting emissions is the same as the
base year role: to account for the effects of rule noncompliance
on the emission estimate. RE assumptions may have a major impact
on the control programs and planned reductions. An underestimate
of actual RE may result in more extensive or stringent control
measures than necessary to reach attainment. An overestimate of
RE may mean that planned control measures are insufficient to
reach attainment (as measured by monitoring stations) despite
supposed reasonable further progress in the SIP. Inventory RE for
projections may be assessed in two ways for sources adjusted for
RE in the base year inventory:
The base year RE value may be applied to
projection years when no RE improvements are
planned as part of the emission reduction
strategy. The base year value may be the 80
. percent default value or it may be derived
from an SSCD protocol study, RE
questionnaires, or another approved RE
evaluation method.
3-18
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The projected emissions may incorporate
planned, creditable RE improvements to the
base year value. Calculation of these
improvements is treated separately in a later
section, but credit for such improvements are
subject to the same restrictions as other
reductions. The State or local agency must
plan for a future S3CD protocol study to
demonstrate the improvements (e.g., an SSCD
study must he conducted by 1996 to meet the
requirements of the 15 percent rate-of-
progress plans).
For sources not in the base year inventory--or which were
unadjusted for RE because they were uncontrolled or because
emissions were directly determined, an RE value should be applied
consistent with the application of inventory RE:
Sources with directly determined emission
estimates should not have RE applied in a
projected inventory. Since direct
determination represents actual emissions, no
RE is applied in the base year. If a source
is exceeding allowable emissions, the level of
noncompliance is already included in the base
year emissions. The best assumption for
emission projections is that this level of
noncompliance will remain constant in the
absence of new regulatory programs. Note that
this assumption precludes any calculation of
potential RE improvements where direct
determination.has been used. (Sources which
were deemed to be controlled by an
irreversible process change are not subject to
any inventory RE adjustment in the base or
projection years'.)
Uncontrolled sources (both base and projection
years) are not subject to an RE adjustment.
Currently uncontrolled sources which will be
controlled under the emission reduction
strategy should use (1) the category RE value
for categories already subject to RE or (2)
the default RE value for the projection years
for currently uncontrolled categories unless
another approved method is available. The
first case covers sources which were
previously uncontrolled because they made no
attempt at compliance or are below established
cut-offs in the base year. The second case
3-19
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covers sources in categories which are not
subject to current control regulations.
Any differences between base year and projection year RE should be
identified and supported in the documentation for the 15 percent
rate-of-progress plan.
3.3.3 Point Source Projection Methods
The role of RE in emission projections is described'in
Guidance for Growth Factors, Projections, and Control Strategies
for the 15 Percent Rate-of-Progress Plans, EPA-452/R-93-002, March
1993 beginning on page 51. The reader is directed to this
reference for a complete discussion of projections for the rate-
of-progress projection plans with sample emission projections
calculations and scenarios. The correction errata for the
15 percent rate-of-progress guidance is included as Appendix B.
Several of the methods [referenced as (2) and (4) in the
document] use the RE value differently from traditional base year
applications which depend upon applying RE to the control
efficiency. In these alternate cases, no control efficiency is
explicitly available and a different adjustment to the emission
factor (including controls) is made. These methods are
highlighted below. The reader should refer to the 15 percent
rate-of-progress guidance.
Method 2: Projection calculated from base year operating rate,
allowable (post-control) emission factor, RE, and growth factor
This method should be applied when the base year emissions
are calculated by the emission factor method and the emission
factor accounts for the control level for the projection year.
The equation for projecting emissions'in this case is:
= ORATEBYi0 x EMFPY x
(200 - REPY)
100
X GF
(9)
where:
EMIS
PY
ORATE
BY,O
EMFB
GF
Projection year emissions - ozone season
typical weekday (mass of pollutant/day)
Base year operating rate (activity level)
- ozone season daily rate (production
units/day)
Projection year (post-control) emission
factor (mass of pollutant/production
unit)
Projection year RE (percent)
Growth factor (dimensionless)
3-20
-------
Current control projection emissions in this case are
calculated if the projection year emissions factor and base year
RE values represent current regulatory or permit conditions and/or
actual conditions where appropriate. Control strategy projection
emissions in this case are calculated if the projection year
emission factor and RE values represent future control strategies
or regulations developed to meet rate-of-progress targets.
Projection year RE values can only improve from base year RE on
the basis of an RE improvements analysis.
Method (2) will be used for emission 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-, . .
emissions will be adjusted by a factor of 1.2. You will note that
this mathematical treatment of RE is different from base year RE.
The impact of applying RE in combination with a control efficiency
is explained in the base year discussion. In this equation (9),
control efficiency is not explicit; rather, it is integral to the
post-control emission factor. To apply RE, the term [(200 -
RE)/100] has been introduced. It is equivalent to the impact (on
emissions) of applying RE to a 50 percent control efficiency.
Figure 3-2 shows the increasing difference between the effect
of the traditional RE application and this new RE term when the RE
Factor, defined as the ration of RE-adjusted emissions to
controlled emissions) is examined. If, for instance, the
allowable (post-control) emission factor is converted to a
percentage reduction from the pre-control emission factor and used
as the projection year control efficiency in method (1), different
results may be produced depending on how much the resulting
percentage reduction varies from 50 percent. The difference is
very large for high control efficiencies.
Method 4: Projection calculated from base year actual emissions,
emission factor-based control levels, RE, and growth factor
This method will be used for processes where the base year
emissions are calculated by material balance, stack test, or any
method other than emission factors. Method (4) must be used for
emission factor-based control measures such as solvent content
limits on surface coating if the operating rate is unavailable.
The equation for projecting emissions in this case is:
EMISP7 = EMISBYO x
(200 - RE,Y)
100
(200 - KE.J
100
EMF,
FY
EMFD
X GF
(10)
3-21
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4.5
in
in
c
o
1.
O
I
LU
CE
3.5
2.5
1.5
35% 40* 43% 50% 55% BOSK 65% 70% 75% 30% 85% 9D*
Control £-T-FTcIency £95}
Q 1-CCE SQCRE 5*O + C200 - RE SQ/100
Figure 3-2. RE Factor as a function of control efficiency for two
RE adjustments (uncontrolled emissions = 100 tons).
where:
EMISpy
EMIS
BY,O
RE
RE
PY
BY
EMFBY
GF
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 emission factor (mass of
pollutant/production unit)
Base year actual emission factor (mass of
pollutant/production unit)
Growth factor (dimensionless)
Emissions for the current control projection in this case are
calculated when the projection year emission factor and RE values
represent existing regulatory or permit conditions. Under the
current control projection, the projection year emission factor
may be equivalent to the base year emission factor if the actual
3-22
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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 emission factor
and RE values in method (4). Projection year RE values can only
improve from base year RE on the basis of an RE improvements
analysis.
These projections must also account for RE. The factor
[(200 - RE)/100] adjusts emissions for RE as discussed previously
under Method (2). .
3.4 SIP EFFECTIVENESS
3.4.1 Definition and Purpose
The SIP Effectiveness (SE) is defined as the ability of the
attainment plan(s) to achieve the planned emission reductions.
The SE is estimated by comparing actual emission reductions to the
projected emission reductions. By contrast, RE estimates the
degree to which an existing rule is working. The SE may be
influenced by both the suitability of the rule and the ability to
make accurate projections. Low SE may be caused by an inadequate
rule; poor compliance, emission violations, variances and
enforcement problems; and unrealistic baseline emissions or
underestimated growth. High SE may be due to overcompliance,
unrelated source process changes or overestimated growth.
The purpose of SE is to provide a SIP planner with
information on progress through emission reductions towards
attainment and to refine the planning process. The technique is
currently used in Region IX to gauge progress towards attainment
and is referenced in Appendix F of the SSCD protocol study
guidance. Significant variations from 100 percent indicate a
problem in one or more of the areas previously noted. If there is
evidence that attainment may not be reached, the cause and extent
of the emission surplus requires investigation.
3.4.2 Calculation Procedure
The EPA equation to calculate SE is applied on a source
category basis, not individual source by source analysis. The
equation expresses a relationship between the baseline (base year)
emissions, current emissions, and projected emissions. Baseline
emissions are annual emissions for the year the control strategy
was adopted. For this example, 1990 is the base year. Current
year refers to the actual emission inventory corresponding to the
SE determination; the SE for 1992 requires the 1992 inventory be
used as the current year._ Future year SE cannot be calculated.
Projected emissions refer to_the emissions projected from the
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baseline (1990) to the current year (1992) . This procedure works
as well for seasonal daily emissions as for annual, but the
dimensional emission units must be consistent throughout the
procedure. (If emissions must be converted for some data, use 250
work-days as equivalent to one year.) This equation calculates
the progress towards attainment (SE) from baseline, current, and
projected emissions:
(Baseline -Emissions) - (Current Emissions)
(Baseline Emissions) - (Projected Emissions)
Base - Current
Base - Projected
3.4.2.1 Projected emissions
The baseline and current year emissions should be available
from the respective emissions inventories. Projected emissions
must be calculated and should be consistent with Procedures for
Preparing Emissions Projections (EPA-450/4-91-019., July 1991) .
This guidance defines projected emissions in the following manner:
Projected = Base x GF x (1°° " ^ct^y (16)
. (100 -
where,
E projected y«r = Emissions in the projected year
E bMeline = Emissions in the baseline year
Growth Factor = Growth factor used to prepare projection
Eff prated year = Control strategy efficiency as percent in
the projected year
Effbaseiine = Control strategy efficiency as percent in
the baseline year
Region IX' s experience indicates that control factors (the
estimated control impact of a regulation on a category) rather
than control efficiencies are used in preparing projections.
Equations (15) and (16) may be adjusted where control factors
(CF) , rather than control efficiencies, are used:
\
Projected = Base x GF x T*a*3 (17)
The difference between baseline, and projected emissions is a
combination of two elements: growth among sources that are
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controlled and growth among uncontrolled sources. An equivalent
form of equation (17) factors these two components:
Projected = Base + (Controlled Growth.) + (Uncontrolled Growth) (18)
Projected = Base + [(Base + Base x (GF - l))x(CF - 1)] + Base x (GF - 1)] (19)
where,
Base: Baseline emissions
(Base + Base x (GF-1)) x (GF-1): Effects of growth and increased
controls in the projected year
Base x (GF-l) Effect of growth due to
uncontrolled sources
Where CF is higher in the projected year than the base, the term
(CF -1) will be negative and serves to discount base year
emissions. Negative growth will be represented by GF<1, which
will also discount the current emission baseline.
3.4.2.2 Absolute shortfall or surplus
Once the projected emissions have been determined, the SE can
be calculated. (SE is calculated throughout the duration of a SIP
as an indicator of reasonable further progress.) The SE does not
quantify the success or failure of the SIP. The absolute
magnitude of the emissions shortfall or surplus in a given year is
a better indicator of success or failure. The emission reduction
claimed in a SIP for a category is calculated as follows:
Emission Reduction - -[Base + Base x (GF - !) ] x (CF - l) (2°)
Equation (20) is the middle term in equation (19); it is the
projected emission reduction based on growth and control.
Shortfall or surplus is simply the difference between current and
projected emissions and the corresponding emissions that were
projected based on growth and control:
Shortfall = Current Emissions - Projected Emissions (21)
or
Surplus
Current emissions will only equal the baseline in the base year.
3.4.3 Interpreting SE
As mentioned, the absolute shortfall or surplus is key to
determining the severity of any problem, or the magnitude of
success of the SIP. The value of the SEs (Table 3-2) will provide
a quick indicator and direct further investigations as to whether
growth or control projections were in error.
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TABLE 3-2. THE SIP EFFECTIVENESS INDICATOR
SE Value Emissions Interpretation
>100% Planned reductions are being
exceeded
100% - Planned reductions are being met
<100% Shortfall in planned reductions
<0% Absolute emissions have increased
Examples
Two examples for calculating and using SIP Effectiveness are
presented. The examples have been provided courtesy of EPA Region
IX and the California Air Resources Board. The data necessary to
complete the SE calculation are baseline emissions, current
emissions, projection and baseline year control efficiencies (or
control factors), and category growth factors.
Example l
An agency has determined baseline emissions for metal coil
coating to be 500. tons per year. The control factor is 1.0 for
the baseline and 0.64 for the projection year (i.e., emissions
from the source category are planned to be reduced by 64 percent).
The projected growth factor for the category is 1.10. The current
emissions are 150 tons per year.
Substituting into equation (19), the projected emissions for
this year can be computed:
These projected emissions of 352 tons per year are divided
between controlled (500 - 198 = 302 tons per year) and
uncontrolled (50 tons per year), Compared to current emissions
(150 tons), there are 202 tons in surplus reduction this year.
Using equation (15), these figures can be substituted to determine
SE: .
Projected = [Base] + [(Base + Base x (GF - 1)) x (CF - 1)] + [Base x (GF -1)]
= [500] + [(500 -l- 500 x (1.1 - 1)) x (O.S4 - 1)] -f- [500 x (1.1 - 1)]
= [500] - [198] + [501 (22)
= 352
These projected emissions of 352 per year are divided between
controlled (500 - 198 + 302 tons per year) and uncontrolled (50
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t0ns Pf:r year) Compared to current emissions (150 tons) therp
ahlf?-t0nS ln SUrplus Deduction this year. Using elation u!
these figures can be substituted to determine SE: ^ai::Lon I"
(Base) - (Current)
(Base) - (Projected)
= 50° -
500 - 352
236.5%
~ 100 (23)
U
Example 2
Lnfn"^ "X?r^*???lin:l ?"issi°ns 9f 1 t°n per day for
The projected control factor must first be calculated from
the projected control efficiency: 1 - 0.42 =WJ J^cu±ai:ea trom
Projected . [Base] + [Base + Base x (GF - !) x (CF - i)j + ^ase * fGF -i;j
= tl] + [(1 + l x (1.05 - 1}) x (0.58 - 1)] + [i x (1.o5 - i) ]
- [1] - [0.441] -.- [0.05] (24)
= 0.609
Compared to projected emissions of 0.609 tons per day current
"
: (Base) - (Current)
(.Base) - (Projected)
SE = 1 ~ °-8 (25)
1 - 0.609
= 51.2%
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An SE below 100 percent indicates that there is an emission
reduction shortfall in the miscellaneous metal coating category.
The air pollution control agency should investigate to determine
the source of the deficiency.
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SECTION 4
SIP RE IMPROVEMENT CREDITS
4.1 DEFINITION AND PURPOSE
A rule effectiveness improvement is a reduction in emissions
due to an improvement in the implementation of a rule for a
regulatory program. It refers to a comparison of the
implementation of the rule before the improvement to the
implementation of the rule after the improvement. The RE
improvement measures are the discrete actions taken to improve
compliance, enforcement, and the rule itself. The RE improvements
are a major source of emission reductions for nonattainment areas
previously subject to SIP requirements prior to the Clean Air Act
as amended (Amended Act) because these areas have already adopted
reasonably available control technologies (RACT) for many, if not
most, of their larger sources.
The RE improvement measures can take several forms, ranging
from more frequent and in-depth training of inspectors to larger
fines for sources that do not comply with a given rule. An RE
improvement or improvement measures should not be confused with
RE. The RE is an evaluation of the effectiveness of a rule for an
existing or future regulatory program. There is no comparison
between different forms of rule implementation; rather RE provides
EPA with a snapshot at a given point in time of how well point and
area sources are achieving the emission reductions the rule was
designed to provide.
The purpose of RE improvements is to provide States with
additional strategies to achieve actual emission reductions for
their SIP's. Section 182(b)(1)(A) of the Act requires States with
ozone nonattainment areas classified as moderate and above to
submit SIP revisions by November IS, 1993. A portion of the
revisions, known as rate-of-progress plans, focuses on how the
nonattainment areas will meet the NAAQS for ozone by November 15,
1996. The rate-of-progress plans must demonstrate that the
nonattainment areas will achieve a 15 percent reduction in actual
VOC emissions by the 1996 date. Some States have already
implemented rules for RACT, particularly if they had ozone
nonattainment areas prior to the Amended Act. These States need
additional means to obtain actual reductions in VOC and/or NOX
emissions. The General Preamble for Title I identifies RE
improvements as one of the means States can use to meet the 15
percent reduction requirement by November 15, 1996.
The primary purpose of this section is to help the reader
determine the effect of RE improvement measures so that States can
use them for emission reduction credits in their rate of progress
plans. The remainder of the section focuses on determining
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creditable RE improvements and illustrating the process through a
sample calculation.4
4.1.1 Determination of Improvements and Improvement Measures
To estimate the creditable emission reductions from RE
improvement measures, State and local agencies need to be able to
quantify the predicted increase in RE.5 The methodology,
therefore, must measure the impact of specific improvement
measures available to a State or local agency.
No existing compliance and emission data were available to
quantitatively assess the reduction in emissions from any single
or set of measures. Consequently;- a panel- of experts -represent ing -
State, Regional, and Headquarters personnel from AQMD, SSCD, and
TSD used the Delphi method to develop quantitative values for
specific RE improvement measures.6 These values are presented in
the RE matrix in Appendix C.
The matrix is based upon a questionnaire that EPA uses to
estimate base RE for source categories (see Guidelines .for
Estimating- and Applying- RE for Ozone/CO State Implementation Plan
Base Year Inventories). It contains various levels of activities
and conditions (e.g., frequency of inspections, level of
recordkeeping, procedures,for operation and maintenance of control
equipment) that influence RE. As a result of the panel's work,
the questionnaire was modified to reflect RE improvements. The
Ozone/CO Programs Branch then incorporated input from personnel at
State and local agencies, EPA Headquarters, and Regional offices.
Several principles helped to guide the development of the matrix:
All States should be guaranteed at least 80
percent base RE unless an SSCD protocol
reveals a lower RE.
States will not receive credit for RE
improvements which do not increase RE above 80
percent.
4 Emissions from sources or source categories which have been directly
determined are not eligible for creditable RE improvements because the base
year RE is not an explicit component of the calculation. For directly
determined emissions, emissions due to noncompliance are already accounted in
the emission estimate.
5 RE improvement creditability is subject to the same creditability
constraints as other reductions (57 PR 13509, Section III.3.a.4 of the General
Preamble).
6 Helmer, Olaf; Analysis of the Future: the Delphi Method .(DDC-649 640); March
19S7.
4-2
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Expected Rule Effectiveness Improvements From Various
Measures For Point Source And Area Source Categories
Category/Measure
A. TRAINING OF PLANT
OPERATORS
Percent of emissions* from sources
covered by a regulation or permit
that:
1. Require formal operator
introductory training course of:
a. More than SO hours
b. 41-80 hours
c. 25-40 hours
d. 24 hours or less
e. On job training only
Total
2. Require operators to take
refresher training annually of:
a. More than 80 hours
b. 41-80 hours
c. 25-40 hours
d. 24 hours or less
e. On job training only
Total
Weights
(X)
Current
Percent of
Emissions
^::-:v--:;-:::f:::-:;
X *::Y
Future
Percent
': -'.'** '
Emissions :
;::, .,;.;.;(Z) ; -,
X*Z
G(A)=_20_
G(A1)=_1_
10
8
5
2
-ra i
;- :v":f / y;.:":".
.-.
G(A7)= 7
10
8
5
a 1
' - ':!', -.
- - ..-"" : -
Emissions are actual emissions from sources without control devices and uncontrolled emissions from sources with control devices.
» Indicates the measure presumed to be indicative of a program achieving 80 percent RE.
Figure 4-1. RE improvements matrix.
4-3
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States improving from a level over 80 percent should
receive full credit for any additional improvement.
RE improvement measures should be documented
in a permit or in a SIP revision.
One hundred percent RE is rarely achieved, except in
cases of direct determination of emissions or
elimination of VOCs or other pollutants altogether
through an irreversible process change; one hundred
percent RE is* normally approached "asymptotically."7
The matrix is divided into 13 categories"designated by the
capital letters A through M. The categories represent a range of
activities and conditions that influence RE. Within six of the
categories are subcategories that more specifically define their
respective categories. Subcategories are designated by numbers
ranging from 1 to 3. Measures are the most specific item on the
matrix. They represent the levels of activities and conditions
and are arranged in a descending order with the first measure
having the most significant impact on RE and the last measure
having the least significant impact. Measures are designated by
small letters ranging from a to f.
Once the matrix was developed, the Delphi Method was used to
assign weights to the various categories, subcategories, and
measures. The Delphi Method relies on a panel of experts to
narrow choices on a topic with varying degrees of interpretation.
The OCMPB invited seven experts from State regulatory agencies and
the EPA to serve on the panel. The experts reviewed the matrix
four times, assessing the relative values of each category,
subcategory, and measure. This was an iterative process where
panelists had the opportunity to anonymously review other
panelists' ratings and comments, explain their "own rationales, and
revise their ratings to narrow the range of values.
After narrowing the choice of values, the panel assigned a
weight to each category on a scale of 1 to 30 and distributed the
weight among the subcategories (where applicable). The experts
also assigned weights to each measure on a scale of 1 to 10.
The first (most stringent) measure in each category and
subcategory automatically received a 10 to ensure consistency
among the most effective measures. The measures at and below the
80 percent level automatically received a l. This ensures that
Arguments have been made that sources may over-comply with rules to avoid or
decrease the potential for rule or emission limit violations. While these
situations may occur, there would be no effect on base year inventories and
improvement programs should not anticipate such overcompliance.
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States do not receive emission reduction credits for RE
improvements below the 80 percent level.
The first category in the matrix in "Training of plant
operators," which is designated by "A." The Delphi Panel assigned
it a weight of 20, G(A)=20. The weight was distributed among
subcategories 1, 2, and 3 in the following manner; G(&l)=9i
G(&2)='7I and G(A3)=4. The panel also assigned weights from l to 10
to each measure within the subcategories. For example, the 5
measures of subcategory G(Aj), which gauges RE for operator
training courses, have the weights of 10, 8, 5, 2, and 1
respectively.
In addition tro assigning weights, the Delphi Panel selected
the measure that best represents the 80 percent default for each
category and subcategory. The 80 percent default is the level of
activity or condition that a State regulatory program or a source
must perform at to achieve 80 percent RE for a given rule. The
checked boxes in the matrix signify the 80 percent default levels.
In subcategory G(Aj) , the 80 percent default is measure e, "on the
job training only." Because States cannot receive emission
reduction credits for RE improvements below the 80 percent default
using the matrix, it represents the measure with the least impact
on RE for each category and subcategory.
The reviewer must use the weights in the matrix to calculate
a Rule Effectiveness Raw Score (RERS) for a given source category.
The RERS is then used to determine the effect of the RE
improvement measures and the final RE after the improvement
measures have been implemented. The final RE is a percentage that
the reviewer multiplies by the emission inventory for a given
source category in a nonattainment area. The product of RE and
emissions is the actual emissions from the source category after
the RE improvement has been implemented. It is compared to the
actual emissions from the source category before the RE
improvement measures were implemented, and the difference is the
actual emission reductions for which the State can receive credit
in its rate-of-progress plan.
Equations 1 through 4 below illustrate how a State regulatory
agency would calculate the RERS and use it to determine the effect
of the RE improvement measures, the final RE, and the emission
reduction credits. (An example calculation is provided after the
presentation of the methodology.)
4-5
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.o) xy(t,o)]} (D
" weight assigned to subcategory s of category x
(for some categories, s is equal to l)
F(t,G(xJ) = weight assigned to measure t of subcategory s
F(t,G(x,),o) = value of measure t of subcategory s before
REimprovement is implemented
F(t,G(x,),f) = value of measure t of subcategory s after RE
improvement is implemented
y(t/0) = emissions corresponding to -facilities
implementing measure t as a % of total
emissions from the source category before
improvement is implemented, where applicable,
or 1
z(tff) = emissions corresponding to facilities
implementing measure t as a % of total
emissions from the source category after
improvement is implemented, where applicable
or l '
RERS(i) = [100 - RE(o)] x RERS/RERS(max) (2)
RB(f) = RE(o) + RE(i) (3)
SRC = [RE(f) x J] - [RE(o) x J] (4)
RERS(max) = maximum RERS = 1818 (from sum of differences
between minimum and maximum values of the measures
in each category and subcategory)
? = original RE (base RE) before RE improvement
t1' = RE improvement over base RE
(f) = final RE after RE improvement
I = current emission inventory for the stationary
source category
ERC = total emission reduction credits from RE
improvements
The matrix was assembled assuming that the baseline 30
percent RE value was used. No credit is given in the matrix for
improvements up to 80 percent. (The result of the matrix is a
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delta RE percent to be added to the baseline.) If 80 percent was
used for the baseline, but real RE in the base year is greater
(e.g., 90 percent), it will be difficult to show much improvement
in the matrix, although a subsequent SSCD study may show that a
higher RE can be applied in the 1996 inventory. In this case, the
State may add RE improvement-measures and project a small RE
increase (e.g., 5 percent), but could receive credit for a larger
one (e.g-., 15 percent) if the SSCD study shows 95 percent RE. In
some ways, this could be seen as an unjustified credit owing to
the original overinflation of the baseline inventory. It would,
however, be a real reduction in the emission inventories and
creditable.
4.2 CREDXTABILITY . .. -
Creditability of emission reductions towards SIP requirements
(e.g., reasonable further progress, and attainment demonstrations)
is the key issue in RE improvements. The RE credits will range
from zero (no improvements) to 20 percent (future complete source
compliance from an 80 percent base year) where the 80 percent
default value was used. If base year RE was determined from an
SSCD protocol study and was lower than 80 percent, the RE
improvement credit may exceed 20 percent. Creditable emissions
must meet three tests to be creditable in a SIP and ultimately to
show reasonable further progress.
No credit will be given for improvements that
bring a program up to the 80 percent RE
(default) level unless the base year RE was
determined using an SSCD protocol study.
*
Credit must be computed and documented by
source category using the RE improvements
matrix explained in this document.
An SSCD protocol study must be performed after
implementation of the improvement to show the
actual emission reductions achieved by the RE
improvement measures implemented as a result
of the rate-of-progress plans.
The RE improvements must reflect actual emission reductions
resulting from specific implementation program improvement
measures. To receive emission reduction credits for RE
improvement measures, a State agency must document the
improvements (i.e., emission reductions). An SSCD protocol study
that meets EPA's protocol requirements must be performed to
confirm that emission reductions have been achieved after the
implementation of the improvement program.
Emission reduction credits due to RE improvement measures are
based on the difference between RE in 1996 and RE in the base
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year. States that have been assuming 80 percent RE for a given
rule before an RE improvement goes into effect can only receive
credits for the portion of emission reductions over the 80 percent
level. (If the State or local agency has used a prior SSCD study,
the RE questionnaire or an approved RE study, all improvements up
to and in excess of the 80 percent level are creditable.) For
example, a State might have a rule that requires the vapor
recovery systems of gasoline tank trucks to be tested for leaks
every year by certified vapor tightness contractors. The State
may have assumed in the base year emission inventory that testing
the vapor recovery systems on gasoline tank trucks every year
achieved an 80 percent RE. Based on the RE improvements matrix,
the State projects that doubling1 the frequency of testing will
achieve a- 10 percent improvement-,-If the follow-up SSCD study
shows that increasing the frequency :of testing from every year to
every 6 months improves the RE to 90- percent, the State would
receive the emission reduction credits associated with a 10
percent RE improvement (90 percent - 80 percent).
Sources with directly determined base year emission estimates
are not eligible for creditable RE improvements. Since direct
determination represents actual emissions, no RE is applied in the
base year. If a source is exceeding allowable emissions, the
level of noncompliance is already included in the base year
emissions. The RE improvements cannot be calculated where base
year RE has not been explicitly estimated and applied. For these
sources, the level of noncompliance is assumed to remain constant
in the absence of new regulatory programs.
4.3 STANDARDS FOR COMMITMENT TO RE IMPROVEMENT MEASURES
The RE improvement measures must result in actual emission
reductions and not mere "paper reductions." An SSCD study is
therefore required to document actual emission reductions after
improvement measures are in place. To obtain credit for future RE
improvements in 15% rate-of-progress plans, there must be a
binding commitment by the State to implement proposed RE
improvement measures. The following types of improvement measures
should be part of the regulations or permits submitted with the
SIP revision as part of the overall SIP emission reduction
strategy:
training of plant operators;
procedures for operation and maintenance of control
and/or process equipment;
clarity of testing procedures and schedules;
monitoring;
administrative authority--prison,' fines, citations.
Implementation of RE improvement measures will be subject to the
enforcement and sanction provisions of the Act.
4-8
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In addition, EPA is studying whether RE improvement
commitments can be written into existing Memoranda of
Understanding (MOU) or Agreement (MOA) between the States and
EPA's Regional Offices. The following types of improvement
measures could be listed in an MOA:
inspector training (commitment for travel and training);
educational opportunities for source (commitment to
develop education materials and conduct workshops);
RE'evaluation program (commitment for rule monitoring
and evaluation and/or audit plan);
different types of inspections (commitment for the level
of inspection for the affected sources);
-media publicity of enforcement action (commitment to-.
publish notice of violations);
follow-up inspections (section 105 grant condition for
funds to ensure sufficient inspectors to perform follow-
up inspections).
If permitted by the Office of the General Council (OGC), MOA may
be a useful addition to ensure long-term adoption of the
improvements, although MOU's and MOA's will not be sufficient in
and of themselves. States, local agencies, and Regional Offices
may use or develop other strategies for ensuring commitments as
approved by headquarters and the OGC, where necessary.
4.4 PERMISSIBLE MODIFICATIONS TO TEE RE IMPROVEMENTS METHOD AND
MATRIX
To ensure a consistent national standard for measuring RE
improvements, the RE improvements matrix must be used by all
States in calculating emission reduction credits for reasonable
further progress. No other methods may be used to quantify these
improvements for the SIP. Although every effort was made to
include the relevant RE improvement categories and measures, EPA.
recognizes that the matrix does not contain all the current or
potential strategies or measures that a State or local agency may
find appropriate. Some modifications of the matrix are
permissible to accommodate effective strategies, although any
changes or additions are strictly circumscribed.
Matrix modifications are currently limited to two types:
Addition or change to measures within a
category or subcategory.
Addition or change to subcategories already in one of
the category groupings (as represented by the capital
letters A through M in the matrix).
For example, some agencies achieve a higher rate of._
compliance by conducting whole facility inspections. The matrix,
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however, is limited to the traditional Level 0 through Level 4
inspection criteria. In this case, the agency would be permitted
to increase the measure value assigned to the relevant inspection
level if the whole facility approach is taken. In no case can any
measure exceed a value of 10.
In-a second example, agencies may use pollution prevention-
biased compliance rather than or in addition to traditional
enforcement methods to bring about the mandated emission
reductions. Because the pollution prevention options'may bring
about a permanent reduction through reformulation, modernization,
recycling or reuse, an agency may have experience that such
nontraditional enforcement is more effective than imposition of
large fines. In this case, pollution prevention compliance
measure(s) should be integrated into the enforcement measures in
the matrix.
In both cases, measure weights will need to be assigned to
the new measures. 'Insofar as possible, the existing weights
assigned by the Delphi panel should be used as guides to placement
of other measures in the 1 to 10 scale. In the above example, a
weight would need to be assigned to the RE improvement measure,
whole facility inspection. Assume this was the highest level of
inspection, Level 5, and therefore would receive a weight of 10.
The weights for levels 0-4 could then be redistributed as follows:
Level 4, 5-points; Level 3, 3-points; Levels 2, 1, and 0, 1-point
each. Any modifications to the matrix should be documented and
justified as part of the SIP documentation supplied to the
Regional Offices and headquarters.
The addition of any subcategories will require the
redistribution of weights between the subcategories in a category.
The overall category weight assigned by the Delphi panel must be
retained.
4:5 EXAMPLE
A large city named Opa City is located in an ozone
nonattainment area. Opa City has several rules that attempt to
reduce VOC emissions from one of the area's stationary source
categories, gasoline marketing sources. In the late 1980's, the
EPA Regional office conducted several SSCD studies of the gasoline
marketing sources in the area and determined that the RE for the
rules governing the source category was 82 percent. When the
Amended Act was enacted, Opa City was classified as a serious
ozone nonattainment area. In accordance with section
182(b)(1)(A), the local air regulatory agency, Countywide Air
Management Programs (CAMP), began to develop its rate of progress
plan to demonstrate that the Opa City area would be able to
achieve the 15 percent reduction in VOC emissions by November 15,
1996. Having implemented RACT rules for most of_the area's larger
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sources, CAMP looked for additional means to achieve the
reductions.
The Agency implemented several changes to the regulatory
program for the gasoline marketing source category. One of the
changes was to initiate a training program of 25 hours for
gasoline tank truck drivers and workers at gasoline bulk terminals
to increase their awareness of the air regulations. In another
regulatory change, CAMP increased the fine from $1,000 per month
to $12,000 per day for gasoline tank "trucks that do not use the
Stage I vapor recovery systems while they deliver gasoline to
service stations. The CAMP does not have to take court action to
impose the fine.
For its rate of progress plan to receive emission- reduction
credits from the rule changes, CAMP has to calculate the RERS for
the source category by filling out the matrix. After answering
each question on the matrix, CAMP determined the difference
between implementation of the rules before and after the rule
changes for each category or subcategory on the matrix. For
example, in subcategory A:/ CAMP determined that, 'before the rule
changes, measure e, "on the job training," applied to 100 percent
of the emissions from gasoline marketing sources. After the rule
changes were implemented, CAMP determined that measure c,
"requiring 25-40 hours of introductory training," applied to
gasoline marketers representing 75 percent of the emissions from
gasoline marketing because tank truck operators and bulk terminal
workers had to complete the new 25 hour training course. Measure
e continued to apply to the remaining 25 percent of emissions
after the rule changes. The CAMP calculated the difference
between subcategory At before and after the rule changes in the
following manner:
G(Aj) - 9 (weight assigned by Delphi Panel)
F(e(A!)) = 1 (weight assigned by Delphi Panel)
F(c(Aj)) = 5 (weight assigned by Delphi Panel)
F(e(A!),o) = F(e(At)) * 100% = 1
F(e,c(A!),f) = [F(C(A!)) * 75%] + [F(e(A1)J * 25%) = 5 * 75% +
1 * 25% = 4.75
F(e,c, (A,) ,f) - F(e(Aj) ,o) = 4 . 75 - 1 = 3 . 75 (5)
The CAMP has to repeat the process for all of the other
categories and subcategories in the matrix. For example, there is
a significant difference in the score for subcategory Jl because
of the increased fines for gasoline tank truck drivers that do not
use the Stage I vapor recovery equipment. The difference in
subcategory J1 before and after .the rule changes is the following
4-11
-------
emissions)r ~ ' Jl requires no weighting factor for
G(Ji) = 8
F(b(jl)) = 7
P(e(J1),o) = 1x1 = 1
F(b(J!) ,f) = 1x7 = 7
=7-1 = 6 (6)
f ronr the matrix, they
,o) xy(t,on}
= 946
- ess a
S«
-------
ERC = [90% x 500 tons] - [82% x 500 tons] = 450 - 410 = 40 tons (10)
The(CAMP can receive 40 tons in emission reduction credits for its
RE improvement measures.
4-13
-------
SECTION 5
AN INTEGRATED VIEW OP RULE EFFECTIVENESS
Various types of RE and RE applications have been discussed
in the preceding chapters . The purpose of this document has been
to present an overview of the different types of RE in a single
document that integrates the guidance materials. While it is
important to understand these individual applications and
methodologies, their common purpose is evaluating the real effect
of 'emission control programs on emission estimates. All RE types
evaluate single sources or source categories and are applicable to
a single geographic (usually nonattainment) area. This common
purpose led to the more or less common terminology of "rule
effectiveness" which this- document has attempted to separate into
four maj or RE types :
Compliance effectiveness
Inventory rule effectiveness
(Inventory) rule effectiveness improvements
SIP effectiveness
As explained in the previous chapters, each RE type fulfills
a different purpose within the SIP process. With the exception of
compliance effectiveness, as represented by the SSCD protocol
approach, and inventory RE, there are no provisions for converting
from one type to another. Table 5-1 presents a summary of RE
types and typical SIP applications, and shows which applications
require the interaction of several RE types. Figure 5-1 shows an
example of how RE fits into the SIP process through 1997. The
salient aspects of each RE value are summarized below and in
Table 5-2.
5.1 RULE EFFECTIVENESS TYPES
5.1.1 Compliance Effectiveness
Compliance effectiveness is represented by the SSCD protocol
study approach. The determination is made to evaluate the extent
to which a rule actually achieves (or has the capability of
achieving) desired emission reductions, both in terms of the
reductions projected for that rule and the reductions that would
be ordinarily achieved if the rule was properly implemented. The
study is specific to a particular category in a single geographic
area. The calculation of compliance effectiveness (CE) is
strictly "the relationship between actual and allowable emissions
at the time of the evaluation:
- Allowable - (Actual - Allowable)
~ - _ - _. -
Allowable
, nn
X 1UU
5-1
-------
TABLE 5-1. KB TYPE AND APPLICATION MATRIX
Application
Category-
specific
stationary-
source
compliance
Base year SIP
inventory
Emission control
and reduction
strategies
Periodic
inventories
Interim progress
of SIP measures
Rate -of -Progress
(6 -year)
inventory
RE Improvement
Credits
RE Type
Compliance"
/
/
/
/
/
/
Inventory
/
/
/
/
RE
Improvements
/
/
SIP
Effectiveness
- -
/
/
SSCD protocol study must be used to demonstrate RE improvements in 1996.
At 100 percent, the source category is in compliance and
produces neither excess emissions nor excess reductions. Results
above 100 percent indicate that actual emissions are below
allowable (overcompliance); CE between 0 and 100 shows that actual
emissions exceed allowable emissions. (Where actual emissions are
twice allowable emissions, CE reaches 0 and becomes negative as
the ratio of actual to allowable increases beyond 2.) Figure 5-2
displays the relationship between CE and actual emissions for a
given allowable emission level.
The results of an SSCD protocol study may be used to
determine inventory RE, although the calculation method is
different. Likewise, information gathered within the SSCD study
provides data applicable to a SIP effectiveness estimate, although
the two types of rule effectiveness are calculated and evaluated
differently.
5-2
-------
SIP
MILESTONE ~*
MILESTONE
DATE -»
RE TYPE 4
Compliance
(SSCD
Protocol
Study r
Inventory RE"
RE
Improvements
SIP
Effectiveness
1990 Base Year
Inventory
1992
Apply
Protocol REb
Apply Default
or
Questionnaire
Attainment
Plan / 15%
Rate of
Progress
1993
Apply
Matrix
'93 Periodic
Inventory
1994
Apply
Protocol REb
Apply Default
or
Questionnaire
Progress
Tracking
1995
Progress
Tracking
Milestone
Compliance
Demonstration
1996
i
" ' ! ..:' ' ? I-"*'1..;..
- ': 'VV.-^K
Confirm RE
Improvement s°
'Apply Default
or
Que s t i onnai re
Use SSCD
study to
confirm
improvements
and receive
credit
Progress
Tracking
'96 Periodic
Inventory
1!»97
' ,.:: ' ;.. ;_ . V ' ./;.;:';:-
^f-^'ir.''. '-'- ''-vU/if j1;;^
Apply
Protocol RE"
Apply Default
or
Que s t i onnai re
Progress
Tracking
in
i
u>
RE for the base and periodic year inventories can be determined from either an SSCD Protocol
study, the RE questionnaire or the 80 percent default or the approved alternative method.
Apply the Protocol results applicable to the base year.
Apply the results of the follow-up SSCD study for the 1996 milestone compliance demonstration.
Figure 5-1. SIP milestone and rule effectiveness schedule.
-------
TABLE 5-2
INTERPRETATION OF RE VALUES
^^^===^=======^^=^^^^^^^^^^=^=^=^
Emissions Interpretation of RE Value
100%
Value
Range {%)
Compliance
e ffe c t ivene s s
(CE)
Unlimited
actual <
allowable
actual =
allowable
allowable
exceeded;
sources not in
compliance
actual =
twice
allowable
actual
exceeds 2
sources in
compliance
sources in
compliance
allowable
Inventory
rule
effectiveness
(RE)
0 - 100
(defined)
all sources in
full compliance
(maximum)
degree of
compliance
no sources
attempting
compliance
RE
Improvements
(0 - 20} ;
improvement'
over 80% that
may be
creditable
towards
reductions
no
improvement
SIP
effectiveness
(SB)
Unlimited
planned
reductions
exceeded
(surplus)
planned
reductions met
planned
reductions not
met (shortfall)
current =
baseline
current
exceeds
baseline
N/A = not allowable
-------
250
200
150
TOO
Allowable=100 tons
-50
-100
-150
-200 -
-250
100
150
200
250
300
350
400
Actual Emissions C"tonsD
Figure 5-2. Relation of compliance effectiveness to actual
emissions (allowable emissions held constant at 100 tons).
5.1.2 Inventory RE
Inventory RE is determined from the RE questionnaire, an SSCD
protocol study, or an approved alternative method for a particular
source category in a particular geographic area. Inventory RE
applies to all sources operating under an emission control rule in
a nonattainment area. The EPA has suggested that an 80 percent
default be applied when no other information is available. In the
questionnaire case, the RE calculation is made by completing and
weighting the questionnaire results.8 When applying SSCD protocol
study results, either of two equations is applicable:
Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State
Implementation Plan Base Year Inventories. EPA-454/R-92-010. Office of Air
Quality Planning and Standards, Research Triangle Park, NC. November 1992
5-5
-------
% RE = Baseline - Actual x 10Q (2)
Baseline - Allowable
Where the baseline cannot be determined, the following equation,
which calculates the baseline from allowable emissions and the
control efficiency, is used:
( y1^^ . -Actual)
% RE = 1 - Control Efficiency x 1QQ {3)
(_ Allowable -Allowable)
1 - Control Efficiency
By definition, inventory RE ranges only between 0 and 100.
One hundred-implies that all sources in a category are in
compliance all the time; zero indicates that no sources are making
an effort to comply. Using the SSCD RE equations, RE values in
excess of 100 are mathematically possible when allowable emissions
exceed actual emissions. Results exceeding the defined upper
bound- of 100 are not recognized for inventory RE applications as
discussed in previous chapters. Base year inventory RE may also
be used as the baseline for RE improvements where the base year RE
is at least 80 percent.
Note that the specific RE calculation can be a function of
control efficiency if the second SSCD option is used. This
control efficiency is the control associated with the rule (e.g.,
the CTG). As a mathematical artifact, sources with lower control
efficiencies will have intrinsically lower RE in the 0 to 100
range for a given set of allowable and actual emissions (i.e., the
only difference between the sources is the control efficiency).
Figure 5-3 displays the relationship between RE calculated from
equation (3) and actual emissions for a given allowable emission
level and two control efficiencies.
5.1.3 RE Improvements
Emission reduction strategies based on increasing RE are
termed RE improvements. Estimated improvements from the base year
(as percent RE) are calculated by defining the RE improvement
measures to be taken and applying the RE improvements matrix:
RE Improvement = (100 - REhaacv=J x RE Matrix Total (4)
ba"year RE Matrix Maximum
The RE improvement creditability is the key issue in RE
improvements. The RE credits will range from zero (no
improvements) to 20 percent (future complete source compliance
from an 80 percent base year) where the 80 percent default vctl
was used. If base year RE was determined from an SSCD protocol
5-6
-------
100
Ai Iowable=l00 tons
Q
CJ
W
HI
tr
50
200
250
300
350
400
450
500
Actual Emissions
Control Ef f V = 90K + Control Ef f V = SOSC
5~l^ Relation of rule effectiveness calculated by the
SSCD method to actual emissions (allowable emissions held
constant at 100 tons).
study, RE credit may exceed 20 percent. Creditable emissions must
meet three tests to be creditable in a SIP and ultimately to show
reasonable further progress.
No credit will be given for improvements that
bring a program up to the 80 percent RE
(default) level unless the base year RE was
determined using an SSCD protocol study
Credit must be computed and documented by
source category using the RE improvements
matrix explained in this document
An SSCD protocol study must be performed to
show the actual RE improvements that were
achieved (e.g., a 1996 RE study is required to
demonstrate the actual achievement of.
5-7
-------
improvements that were planned as part of the
mandated 15 percent reductions by 1996)
States and local agencies are free to devise their own RE
improvement programs in concert with their Regions. Due to the
nature of the RE calculation, highly- controlled source emissions
will benefit most from improved RE. Selection of source
categories and improvements should be based on the characteristics
of an area's sources and regulatory program.
The EPA SSCD is currently exploring options for a streamlined
RE Protocol applicable only to RE improvement studies. The goal
of this streamlining would be a less time- and resource -intensive
study designed specifically to allow RE improvements to be
verified within the time frame of the 1996 RFP demonstration.
5.1.4 SIP Effectiveness
The SE. is defined aa the ability of the attainment plan(s) to
achieve the planned emission reductions. SIP Effectiveness is
estimated by comparing actual emission reductions to the projected
emission reductions.
SE (Baseline Emissions) - (Current Emissions)
(Baseline Emissions) - (Projected Emissions)
The SE can be calculated using information gathered as part of an
SSCD protocol study or from current, base year and projected
emission inventory data. The SE is calculated by source category
by nonattainment area.
The SE values of 100 indicate that planned SIP reductions are
being met in the current year. Values above 100 signify surplus
reductions in proportion to the expected reduction; values below
100 denote a shortfall. Negative values connote an absolute
increase of emissions over the base year. The SE values are .
indicators of SIP progress; the underlying causes must be
investigated separately. Figure 5-4 displays the relationship
between SE and current emissions for a given baseline emission
level (100 tons) and projected emission level (90 tons) .
5.2 ECONOMIC INCENTIVES PROGRAMS
A full discussion of RE includes related, but different,
concepts that will be applied in EPA' s economic incentives
programs (EIP's) . The specific types of RE discussed in this
document do not apply directly to the EIP's, These programs are
mandates under the Act [see Section 182 (g) (4) (3)] and EPA has
proposed rules for implementing EIP's in the Federal Register (FR
11110, Vol. 58, Number 4; February 23, .1993). In general, EIP's
pursue CO or ozone precursor emission reductions through
5-8
-------
in
in
250
200
150
100
50
-sn
-too
-150
-200
-250
Allowable=100 tons; Projected=90 tons
BO
90 1QO
Actual Emissions ctons}
110
120
Figure 5-4. Relation of SIP effectiveness to actual emissions
(fcaseline emissions and projected emissions held constant) .
'. ijmov;t±ve strategies. These programs may be
three broad regulatory categories:
Emission limiting- strategies such as a
marketable emission allowance program.
Market response strategies that create
economic incentives such as fees to reduce
emissions .
Directionally sound strategies such as public
awareness campaigns that are conducive to
emission reductions.
tw° cjasses V *>e creditable within certain
toward rt he required 1996 and subsequent reductions -
n0t reditabl
H ?^ ^ n0t £reditable* The relation to RE rests on
creditabxlity. The EIP emission reductions, like more ?raditional
5-9
-------
performance standards and technological emission controls, require
both an emission baseline and reduction quantifiability to be
creditable. Traditional stationary source reduction strategies
must account for the potential failure to meet the anticipated
reductions due to noncompliance and other factors through the use
of the RE factor.
5.2.1 Compliance and Programmatic Uncertainty Factors
The EIP's may also be subject to uncertainties in the actual
emission reductions due to noncompliance as well as inherent
quantification problems. While the first type of uncertainty,
noncompliance, is typical of the traditional inventory RE concept,
the second type is not.- -Inherent quantification difficulties have
been identified as "programmatic uncertainties" and originate from
the very design of certain EIP types as well as the strategies
employed.
The EPA has defined two classes of programmatic uncertainty.
Where market incentives are employed, it will be impossible to
specify the resulting emission reduction with certainty regardless
of compliance. Under this scenario, all sources could be in
complete compliance with an emission fee program, for example,
with no certain reduction in emissions. (Likely emission
reductions must be in some way estimable, even with uncertainty,
to be creditable.) The second type of uncertainty stems from
"soft" quantification methods necessary to define compliance in
some circumstances. Examples include emission caps on fugitive
sources, inherently difficult to quantify, and some mobile source
strategies.
The EPA has suggested that the rule compliance factor may be
based on historical compliance with traditional programs as
measured by inventory RE. Programmatic uncertainties may require
one or more "presumptive norms" to address: 1) inexperience and
uncertain techniques for strategies relying on market response,
and 2) accuracy and precision in emission quantification for
emission limiting strategies.
The EPA has not issued rules or guidance assessing the rule
compliance factor or the two classes of programmatic uncertainty.
According to EPA's proposed rules, however, State and local
agencies will be required to justify whatever factors are used in
the context of the design of an EIP.
5.2.2 Relation to Inventory RE
It is not EPA'3 intention that uncertainty associated with
SIP's be added to inventory RE, Rather, the emission baseline and
projection components of an EIP should be subject to the relevant
EIP uncertainty factors. States and local agencies should take
care to distinguish between the base; year inventory for the rate-
5-10
-------
of-progress plans and the EIP baseline. The EPA will be
developing policy and guidance in this area.
5.2.3 Mobile Emission Reduction Credit Programs
Mobile emission reduction credit (MERC) program rules have
also been proposed by EPA (FR 11134, Vol. 58, Number 4; February
23, 1993). The MERC programs are quite similar to the EIP
concepts just discussed but apply to mobile sources. In light of
the inherent uncertainty of reductions from a large,
decentralized, heterogenous source population, MERC programs will
be required to reflect uncertainties in compliance with and design
of the program. These factors can again be labelled the rule
compliance and program uncertainty factors, including 1) anti-
tampering methods, 2) procedures to determine actual, remaining
useful life, 3) techniques to provide unbiased measures of use
among mobile sources, and 4) auditing and enforcement procedures.
5-11
-------
APPENDIX A
CALCULATION OP RULE EFFECTIVENESS FOR EMISSIONS INVENTORIES
A-l
-------
MEMORANDUM
SUBJECT: Calculation of Rule Effectiveness for Emissions
Inventories
FROM: John S. Seitz, Director
Office of Air Quality Planning and Standards (MD-10)
TO: Director, Air, Pesticides and Toxics
Management Division, Regions I and IV
Director, Air and Waste Management Division, Region II
Director, Air, Radiation and Toxics Division, Region III
Director, Air and Radiation Division, Region V
Director, Air, Pesticides and Toxics Division, Region VI
Director, Air and Toxics Division, Regions VII, VIII,
and X
There has been some confusion about acceptable methods for
determining rule effectiveness (RE) for 1990 base year emissions
inventories and the necessary requirements for receiving emission
reduction credits in 1996 for RE improvements. This memorandum
clarifies the criteria that should be applied by the Regions when
reviewing a State's method for assessing RE. In addition, it
explains the requirement for taking credit for RE improvements in
State 15 percent plans.
Review of Alternative RE Methods
In November 1992, the Environmental Protection Agency (EPA)
published "Guidelines For Estimating and Applying Rule
Effectiveness For 02one/CO State Implementation Plan Base Year
Inventories" (EPA-452/R-92-010). In this document, three methods
for estimating RE were identified as acceptable strategies:
1. 80 Percent Default - uses an across-the-board RE
presumption of 80 percent for all sources.
2. Questionnaire Approach - uses an EPA questionnaire to
determine a category-specific RE value for both point
sources and area sources.
A-2
-------
3. Stationary Source Compliance Division (SSCD) Protocol
Study - uses a study specific to a category in
accordance with the procedure developed by SSCD.
In addition to these three methods, a fourth option was also made
available in the addendum to the November 1992 guidance. This
additional option gave States greater flexibility in designing an
alternate method for estimating RE. The addendum outlined the
following information that States should consider in alternative
RE methods:
l. The overall capture and control efficiency generally
available from the kind of capture and control equipment
being assessed. -- ---
2. Any stack test/performance evaluation that was performed
on the capture and control equipment.
3. The rated capture and control efficiency (from
manufacturer's specifications or literature).
4. The kinds of activities that affect the determination of
day-to-day performance of the capture and control
equipment that are listed in the questionnaires
contained in the guideline document (e.g., ease of
determining compliance, type of control equipment,
frequency, and quality of inspections, and level of
training of inspectors).
If a State develops an alternative RE method, it must not
only account for the above information, but should also follow the
basic requirements outlined in the guidelines. These include:
1. Following the sampling strategy outlined in section
2.4.2.3 of the guidelines and determining the
appropriate sample size according to the method
described in Appendix D. This means, for example, that
if a State plans to use a modified version of the
questionnaire, the following conditions should be met.
At least 80 percent of the total pollutant-specific
emissions (e.g., volatile organic compounds) from point
sources should be covered by questionnaires and all
categories representing 5 percent or greater of the
pollutant-specific emissions from point sources should
use the questionnaire. Both conditions (80 percent
coverage of total point source pollutant emissions and
every category representing 5 percent or more of the
total point, source pollutant emissions) should be met
for the questionnaire approach. At least. 10 point
sources within a category should be sampled; all point
sources should" be sampled if there are 10 or fewer
A-3
-------
sources in a category (see pa5es 20-21 and Appendix D of
the guidelines for a more detailed explanation).
2. Providing the rationale for the alternate RE method
(e.g., changes to the questionnaire, including why items
were added or deleted and justification of changes to
the weighting scheme for individual items).
When reviewing a State's alternate method for estimating RE,
EPA Regions should be assured that every attempt has been made to
meet the above criteria. However, there may be circumstances,
such as unavailability of resources or information, that prevent a
State from meeting these sampling guidelines. Any deviations from
these guidelines must be approved by -the Region with concurrence
from Headquarters. In determining whether to approve these
deviations, the Region should recognize the intent of the above
sampling criteria, namely to obtain a statistically valid sample
that will result in an emission estimate that is as accurate as
possible.
If, based on the documentation provided by the State, a
Region is unable to assess whether the alternative methodology
follows the appropriate procedures, it should require the State
agency to provide additional documentation. After the Regional
Office has completed its review, the Region must consult with the
Office of Air Quality Planning and Standards (OAQPS). Both Region
and Headquarters concurrences are needed on any alternative RE
method.
An alternative RE method that has already been approved by
the Regional Office is exempt from any additional requirements of
this memorandum.
Credit for RE Improvements
Rule effectiveness improvements must reflect actual emissions
reductions resulting from specific implementation program
improvements. To receive emission reduction credits for RE
improvements, a State agency must document the improvements. An
SSCD protocol study that meets EPA's protocol requirements must be
performed to confirm that reductions have been made after the
implementation of the improvement program. A State that plans to
take credit for RE improvements in its 15 percent rate-of-progress
plan to be submitted by November 15, 1993 must therefore commit in
that plan to perform this study after implementation of the RE
improvement program. Note that States that have been assuming 80
percent RE for a given rule before an RE improvement goes into
effect can only receive credit for the portion of emissions
reductions over the 80 percent level.
A-4
-------
. The OAQPS is currently developing guidance on how to quantify
RE improvements in rate-of-progress plans. Questions on these
issues may be directed to Gerri Pomerantz of the Air Quality
Management Division (919-541-2317).
cc: Air Branch Chiefs, Regions I-X
Richard Biondi
Tom Helms
Linda Lay
Marcia Mia
David Mobley
Rich Ossias
Gerri Pomerantz
Bill Repsher - - -
John Silvasi
Henry Thomas
A-5
-------
APPENDIX B
CORRECTION ERRATA TO THE 15 PERCENT RATE-OP-PROGRESS PLAN
GUIDANCE SERIES
B-l
-------
MEMORANDUM
SUBJECT: Correction Errata to the 15 Percent Rate-of- Progress
Plan Guidance Series
FROM: G.T. Helms, Chief
Ozone and Carbon Monoxide Programs -Branch (MD-15)
TO: Air Branch Chief, Regions I-X
This memorandum corrects several errors in the 15 percent
rate-of-progress plan guidance series.
l. There is an error in the Table entitled, "Major Source
Thresholds and Minimum Emissions Offset Ratio
Requirements for Ozone Nonattainment Area
Classifications," in the following 15 percent guidance
documents:
."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), p. A-3.
"Guidance for Growth Factors, Projections, and Control
Strategies for the 15 Percent Rate-of-Progress Plans"
(EPA-452/R-93-002), p. A-3.
"Guidance on the Relationship Between the 15 Percent
Rate-of-Progress Plans and Other Provisions of the Clean.
Air Act" (EPA-452/R-93-007), p. 12.
"Guidance on Preparing Enforceable Regulations and
Compliance Programs for the 15 Percent Rate-of-Progress
Plans" (EPA-452/R-93-005), p. A-4.
The error is in the item, "All Other Nonattainment Areas, in an
Ozone Transport Region." The volatile organic compounds tons per
year (tpy) should be 50 tpy rather than 100 tpy.
2. The document entitled "Guidance on the Relationship
Between, the 15 Percent Rate-of-Progress Plans and Other
Provisions of the Clean Air Act" (EPA-452/R-93-007), has
an error concerning the creditability of certain
B-2
-------
transportation control measures. Section 5.8 of this
document states the following on page 39:
Emissions reductions resulting from TCM's are
creditable if the TCM is not already federally
mandated (e.g., the employee trip reduction
program required under section 182(d)(1)(B)
for severe and extreme ozone nonattainment
areas), or is not part of an already existing
SIP. As with all other emissions reductions,
emissions reductions associated with TCM's are
only creditable to the 15 percent rate-of-
progress plan if they are quantifiable, real,
enforceable,replicable, accountable, and
occur by November 15, 1996.
The correction revises the first sentence of the preceding
paragraph:
Emissions reductions resulting from TCM's are
creditable if the TCM was not a pre-1990
control measure in an already existing SIP.
As with all other emissions reductions,
emissions reductions associated with TCM's are
only creditable to the 15 percent rate-of-
progress plan if they are quantifiable, real,
enforceable, replicable, accountable, and
occur by November 15, 1996.
3. In the document, "Guidance for Growth Factors,
Projections, and Control Strategies for the 15 Percent
. Rate-of-Progress Plans" (EPA-452/R-93-002, March 1993),
there are several errors in Chapter 6.
a. On page 55, the text under the table, last sentence,
"The [ (200-REry)/100] factor is not valid for low RE
values" is incorrect and should be deleted.
b. On page 57, the sentence before the heading, "Equation 5
- Projection calculated from permitted emissions rates,"
("The [(200 - REJ/100] factor is not valid for low RE
values") is incorrect and should be deleted.
c. On page 57, the second and third paragraphs under the
heading, "Equation 5 - Projection calculated from
permitted emissions rates," should read as follows:
B-3
-------
The equation for projecting emissions in this case is:
(200 - REPY)
~\
= ERPY *
100
(200 - REBY)
100
EMIS,
3Y,0
EMIS,
(5)
BY. Annual
where:
EMISpy
ERpy
RE.
aBY
EMIS
BY.O
EMIS
BY,Aiiniul
Projection year emissions ozone season
typical weekday (mass of pollutant/day)
Projection year annual emissions cap
(mass of pollutant/year)
Base year RE (percent)
Projection year RE (percent)
Base year ozone season typical weekday
emissions (mass of pollutant/day)
Base year annual emissions (mass of
pollutant/year)
The factor EMISBYj0/EMISBYiAllIlulj 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. These projections must also
account for RE. The factor, "[(200 - RE)/100]," adjusts emissions
for RE. See the explanation under equation (2) for additional
information about this factor.
d. On page 65 under: "6. Mass Emissions Limit-Based
Permits," the second and third paragraphs should be
replaced with the following:
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
Annual emissions
RE
Projection Year Conditions
Current permit
RE
ISO Ib/day
23 tpy
80%
30 tpy
80%
= 0.075 tons/day
B-4
-------
as follows:
{5) iS USSd t0 calculate Projection year emissions
EMISpy = ERPY *
(200 - REPV)
100
(200 -
100
EMIS,
BY.O
EMIS,
(5)
BY. Annual
EMISpy = 30 *
(200 - 80)
100
(200 - 80)
100
'I = 0.098 tons/day-=-196 Ib/day,
^ease sharf this information with your State and local air
*3*nc±&3' ^Y questions about these corrections
cc: William Becker, STAPPA/ALAPCO
Kent Berry ,AQMD
John Bosch, TSD
Ogden Gerald, TSD
Phil Lorang, QMS
Ned Meyer, TSD
David Misenheimer, TSD
David Mobley, TSD
Car la Oldham, AQMD
Rich Ossias, OGC
David Sanders, AQMD
Kimber Scavo, AQMD
Laurel Schultz, AQMD
John Seitz, OAQPS
John Silvasi, AQMD
Joe Tikvart, TSD
Lydia Wegman, OAQPS
Dick Wilson, OMS
Mary Ann Warner -Selph, TSD
Howard Wright, TSD
B-5
-------
APPENDIX C
RE IMPROVEMENTS MATRIX
C-l
-------
Expected Rule Effectiveness Improvements From Various
Measures For Point Source And Area Source Categories
Category /Measure
A. TRAINING OF PLANT OPERATORS'
Percent of emissions* from sources covered by a
regulation or permit that:
1. Require formal operator introductory training
course of:
a. More than 80 hours
b. 41-80 hours
c. 25-40 hours
d, 24 hours or less
e. On job training only
Total
2. Require operators to take refresher training
annually of:
a. More than 80 hours
b. 41-80 hours
c. 25-40 hours
d. 24 hours or less
e. On job training only
Total
3 . Require appraisal and update of training
program:
a. Annually
b. Every 1-3 years
c. Every 4 or more years
d. Never or don't know
Total
Weights
(X)
G(A)= 20
p:.;;::i;y:;;;.;;;^:uy..-:;:;: ;.:,:
G(A.)= 9
10
8
5
2
*« 1
G(AJ= 7
10
8
5
w 1
.1.
G(A,)= 4
10
7
2
a 1
^Current :
^Percent <>f :'.
Emissions ,':
%'-XY>:-.;.::;;
M^'^^l
- ' j _-, . <:
-""-';. : -- ''
^i-VV.;.
Future
:;v::;Percent
;>-,.. of ": ; -;
Emissions
.'.,;..
-------
Category/Measure
B. INSPECTOR TRAINING
Percent of inspectors who receive:
1. Formal inspector introductory course*
(EPA sponsored or similar) of:
a. More than 80 hours
b. 41-80 hours
c. 25-40 hours
d. 24 hours or lew
a. On job training only
Total
2. Receive source-specific, inspector-
refresher course with annual hours
averaging:
a. More than 80 hours
b. 41-80 hours
c, 25-40 hours
d. 24 hours or less
e. No refresher training
Total
3. Frequency with which appraisal and update
training program is held for inspectors
a. Less than every six months
b. Every six months to a year
c. Every year to two years
d. Every two to three yean
e. Every three to five years
f. No annual refresher training
Total
Weights
(X)
G(B)= 20
& ;;;' i.. j*-' B ;::-" :,';.::.&:₯$' .*:'. ;
'iBV'v .;*: ":' v :"v.-B.i :;. ;::" .'3
G(B,)-_2
10
« 1
::;'.: ;-.'.- .1, '..:.:.-..>.:.; .
%'*.:.. :''. I-,. '.-: -X-';.-.- -
;;; J. ,-: ';:.':.E.. .'.., ........
-:-.'- ':. ..,,;,,. :, ; .- :- :'-.:...:-
G(Bj= 6
10
8
6
» 1
H:-:':V'.;:' E1.:'1.: '.-.: ":
G(B,)= 5
10
7
M 1
:-""::- ' ' i; '"'"; ..
- i.
;' . i.)
Current
Percent
ft:|-(₯)::|vf
H^K^iy'.S"'
S:; .'.'''.' ti
;-'' --.. '
: , .,:',.,.
N:.^*;l:::
:
::; o:f --:|.: . .|.|- . :-." _-\.
',,:',''':'-.... --.' -.
i;..;^..>^:3 '
s :,.
.,- /. .. . .'
KiFnturft:.;^
LPferceni'-
5v;(Z5;;:;.l::
>::^-'::^'-V'^'-^
':.^:I'^^ ""' "'
i;V:X:?:;Z:o--
:::.: V:..: '!. '". '.
C-3
-------
Category /Measure
C. EDUCATIONAL OPPORTUNITIES
FOR SOURCE
1 . Frequency in years of workshops
held by regulatory authority for
industry on regulatory requirements
a. Every six months or more
frequently
b. Every six months to a year
c. Every year to two years
d. Every two to three years
e. Every three to five years
f. More than every five years
Total
2. Frequency in years with which
information packages on regulatory
requirements are sent by the regulatory
authority to sources
a. Every six months or more
frequently
b. Every six months to a year
c. Every year to two years
d. Every two to three years
e. Every three to five years
f . More than every five years
Total
Weights
(X)
G(C)= 13
C(C)= 6
10
8
6
4
n i
'' "'.''' "I '., " '
G(CJ= 6
10
8
4
» 1
' '":. :'' Vl':,p::-i
:---:-;-:---i-;';;i/1.1;:-:::;f|::
":; T.::. :s;-:.--:"; "-;' >''"
;M Current /t'!
vSituaiJort*
."V ':;.' :-.f:v>x::-
:M . -v -;'-': :';;- ;':- .,,/ : ^ '-.'
'-f Current V
!.\-Vahie!!;::.:
;;i-*X^:i;;;':::
" '"^'i'?':; '":
,' ' ' '" " .: -"
....,- .'' --- '
----- . .' ---' '",
- ' ^
'. -;';- ' :.-""- ":".
- Future
;; Situation*
, .': ' -: - .-;
' : ' '" -!.-.'-
-: - :::' : -,. .
. .-..-. :-- --
Future
Value
x*i --
-; '
Percent is not applicable. Please check the box that applies.
C-4
-------
Category/Measure
D. PROCEDURES FOR OPERATION
AND MAINTENANCE (O&M) OF
CONTROL AND/OR PROCESS
EQUIPMENT
Percent of emissions* from source*
covered by a regulation or permit that:
a. Have equipment operators follow and
sign daily O&M instructions
b. Have equipment operators follow daily
written instructions for O&M
e. Have equipment operators follow daily
or weekly established O&M routine
d. Maintain and operate control or
process equipment but on no specific
schedule
e. No mention of O&M control or
process equipment in the permit or
regulation
Total
E. CLARITY OF TESTING
PROCEDURES AND SCHEDULES
Percent of emission** from source*
that have in place under permit or
regulation:
a. Specific guidelines on testing and
test method requirements and
schedule of required testing
frequency
b. Specific guidelines on testing and
test method requirements but no
schedule of required testing
frequency
c. General guidance on testing and/or
testing frequency
d. No guidance on testing and/or
testing frequency
Total
Weights
(X)
G(D)= 20
!^/:-:rf;:i:;;^;C;:-:';-J:f-
10
8
4
«» 1
;\;;--;;C V;: ':'..:;
GflE)= 17
'''.'".' ':'-'-''"' ' ... ' "'':.:. 'v
10
,. -H:- f: - -
';'.".. ''i ...';-'-;:;';
'...I;.,,....'
''' :' ' ''' ' '"'.
||.ii?w:ipj«^|::;
CJ*terc«a|t-...- '' - . - ":
:;.v ':- ;';' 'I: :- ;'
;: . ' - -." " : -
pESl
;;;-::.'-:,:;:-:--:-- ::.:.:., '
P^'A;.'^1
:: ., , , '
v ' ..--.-.'. ' ''
:^^"J '",
il'i-flitQreiv;'';;;:
|' Percent ofe
v Emissions
rR-x-(Z)t.::-i
P;, ;X;.^V.::- !":.'
- '-' - :' ;;:
':': ' ' ' -- , ,
:'
i:X::*^:
* Emissions are actual emissions from sources without control devices and uncontrolled emissions from sources with control device
C-5
-------
Category/Measure
F. RULE EFFECTIVENESS
EVALUATION PROGRAM
1 . Highest level of category-specific rule
monitoring and evaluation:
«. SSCD protocol study
b. Other rule evaluation
c. No rule evaluations after rule is
implemented
Total
2. Highest level of follow-up from rule
monitoring and evaluation:
a. Rule corrections made based on
SSCD protocol study result
b. Rule correction* made based on
other rule evaluations
c. No follow-up
Total
Weights
(X)
G
-------
Category/Measure
G- MONITORING
1. Percent of emissions* from sources
covered by a regulation or permit that:
a. Require source specific enhanced
monitoring procedures with a
detailed self-evaluation schedule -
and use these data for compliance
purposes
b. Require source specific monitoring
procedures with * detailed self-
evaluation schedule and use these
data as an indicator of compliance-
only
c. Give general guidance on source
specific enhanced monitoring
d. Do not contain source specific
guidance on enhanced monitoring
Total
2. Percent of emissions* from source*
covered by a regulation or permit
which file enhanced monitoring
records with regulatory authority
a. Every 4 months or more frequently
b. Every 4-6 months
c. Annually or lesi frequently
d. Monitoring is required by the rule
but reports are not submitted to the
regulatory authority
e. Monitoring is not performed
Total
Weights
(X)
G(G)= 25
G(G,)= 15
10
5
m i
K"'''...:..-tr:-.:''?':V
G(GJ= 10
10
9
4
"» 1
;. " i.'" .':'
; .
|lipiipinp|i
|l:BErceD|bf|!;;:
;s₯:'Emissioris₯:^
|||||i||||||;s
p;:?:.::f.:';;::;;;:;:r|:f\
:::;::-;::v:-;:-:!:::-:x:i:i:S:i i^i: ':^;^: ; ::,
i;:':''--;-i-:^f--^';::-^
1' 'V T :".::':;':i '"
;,.'' .' -..;
iilill
Illllp
f V: '& '::;.
IJIIIl:
^:..:;; .::-::: -:-:;
;: '
/I"" . .-::
lll'iiiili!
ffmefa^
Emissions
I^P-^illA
;.;;-.:v :':;-x::::::::;>X;:;:|::.::;::::yv-:]'-
::. '. :'' :-: , ;'':': : :'- ::':::': :-::"-.: ' '
\ "-' .;- -'-
' - :-
!^ ' '
Px;*:Z|
t^fS^
|;'
? :;,.:-, t-
* Emissions are actual emissions from sources without control device* and uncontrolled emissions from source* with control devices.
C-7
-------
Category/Measure
H. TYPE OF INSPECTION
Percent of emissions* from sources
category receiving Level 0 through Level
4 inspections (as referenced in the Act
Compliance/Enforcement Guidance
Manual 1986 (attached))
a. Level 4: stack testing
b. Level 3: detailed engineering
analysis of process parameters,
internal inspection of control and/or
process devices
c. Level 2: review of records
d. Level 1: visual inspection, opacity
check
e. Level 0: "drive by"
Total
Weights
nn
VA/
G(H)= 21
:Si;::i:-:.;:;i;:;S;:;::i;;:K:i::S;i;s!₯;:sk
:;;;;;'; ;:;---:;t;::;;;V:!::;>;;:;;;:;i;f::
: '! : .,:v;:V:":::, '>:;. s
10
8
« 1
::.::-,,:..:::;:;::::-i:-:-:y::::--;:::;.:-::::
.VV::;':'f A'-: 1'vV'^
§;;:fct^1|
iiPercent of
Emissions
'^f-l^^iW:
:.A *./.;;,.-. ' ,.,
:':. :V:.-'::.:.v:-:£; :»^:-
oKOi?&!i!:::;ii:S?:SS&?;S-;;H-;
i;y?iiS:s*;i:i;::;:?:;:sH?:;;ffiisS
S^^S
:i;llll^ii!liilll!i
Illiillllill;!;
'^r'^r^.^1:^:;;
;m:'«:Y-i
' .'. '.'''.'. "
ii.;.:::3::.|,:ii.;.",::-
;v«:s.,:i':::,''^
ilili^Ssfi'Os!:
l^^p'^
.;::::'::;::S;iMi;iS
^.ffilM^
iiiKiiirii. :?;:;:;!
;;v::;':;-:::i,i::;;y-::::'
:i:.'-.::.:.:: '.vi; :.;.?'
!: ::i:fiFuUire-- ^
percent or
Emissions ::
-:;,,.:,..-,-,, :;,-,,
-.- ---A"/- ..
':.:..:'>*:.:':..:..:,:.::;
^K^*-^;^5.:::!1'^!
:f-Cli^^
\:.o.-:-:v.;:::;;'-';;:-''-:-V':': '-lo:'!'^1' >'o
:::;:'i::':-:-:'!;':':'!-.':-:-:-''l::-i '-'v/O.-.'1-
>:ox:;-.:';:,;.;.xy v ;,'.'.' :'i.':v. :.
^Il-v^W^v:''-^
;::-i'*;i';.
: .: .':'.- ..
":!:':;;'":':;:i::::i;-V:
:; ;.;:...;x './,. /.::
i::1:::-:. :-!.:' "r::---
* Emissions are actual emissions from sources without control devices and uncontrolled emissions from sources with control devices.
C-8
-------
Category/Measure
I. Administrative Authority - Prison
Highest level of punishment the regulatory
authority m»y impose for noncompliance
and/or blatant violation of environmental
laws.
Prison sentence of:
a. Greater than 10 yean
b. 5 - 10 yean
c. 2 - 5 years
d. 6 months to 2 years
a. Up to 6 months
f. No authority
Total
Weights
(X)
G0)= 8
p;J:||;;h|;|/v
;. *:"V'?: ''?':? ';':1:-:
10
9
g
5
3
« 1
!'!.. ':'-.- ' l! !;.;'' :..;:. -::-: '-;.!'-''
Illliiii
5i Situation*
Ilillillilili
IMSllll
jjSSJS^
|: " " ' '." .:. . "
:V'--';r':'-V'::;':.i :':'-
il^uicitM:
^;;';Vai^:;i;;;;:
liiwil
|ll|l||;
|: . A\:.-.'m. '':;'$'-'', :''': ;''
llliiiiireill
^Si(Eua'fi&n^H:-
Illlll|;:|i|ii;
l&& ":
^:*:::']Pi]iture:;:i::;:
"^Valiie^--
^:-x;,*ii:!;:::-.-
:-: : .-,'.' '.' -. ' '
Percent is not applicable. Please check the box that applies.
C-9
-------
Category/Measure
J. AdmnnstratiTe Anthority - Fines
Highest level of fine* the regulatory
authority may impose for noncompli«nce
and/or blatant violation of environmental
laws.
1 . No court action required
a. > $25,000 per day per violation
b. $10,000 -$25,000 per day per
violation
c. $1,000 - $10,000 per day per
violation
d. $1,000 per month to $1,000 per day
e. Up to $1,000 per month
f. No authority to pursue fines
Total
2. Court action required
a. > $25,000 per day per violation
b. $10,000 - $25,000 per day per
violation
c. $1,000 -$10,000 per day per
violation
d. $1 ,000 per month, up to $1 ,000 per
day
e. Up to $1,000 per month
f. No authority to pursue fines
Total
Weights
(X)
GCD= 14
lipillllllllfl
G(J.)= 8
10
7
5
» 1
".' . ,r -'-'- -
.;.j
GJO= 6
10
7
4
-B ' :.] ;' '- '
,J '.': -
'- 1 '
'^Cmrait";11"'
Situation*
llliliflfl;;
- ' ' v:
' :' .- ;,
Ctirriait
Value
=:'JK>-1
:'; "o.^ :.-.:;-. :i;:
lilliifiiii
'.' ' ' ' :-,';:
Future ' i
Situation*
ii S I'^ilM
Future
Value
X»l
Percent is not applicable. Please check the box that applies.
C-10
-------
Category /Measure
K. ADMINISTRATIVE AUTHORITY -
CITATIONS
Highest level of citation the regulatory
authority may impose for noncompliance
and/or blatant violation of environment*!
law*.
a. $1,000 -$5,000 per day
b. $500 - $1,000 per day
c. Up to $500 per day
d. No field citation authority
Total
Weights
(X)
G(K)= 11
10
M 1
Pli'llWPslp^k:
Ifpffliflipfi:1
ifcui^lr
hJahmtidW::-
oi:;.:. : xoi-ViV \<:V ';U :-. ::. '''. '' ' ','-,
v£ ' '''--:'-: :'&:. '''.' ''.''' -..- ''': ''
\$?£$\ffi$^-$:;^
t^-^^zv^^
^Hjp^^:^;v;^;'
$'*&^*W'?'^:.s
:--:::'-.'-.--'-'',;'l' ': :':'''"-' ':';", ,:'..'
^l;;;f:;;-;;i:|:;;iPH^
;:;: eurreire;'1:
^"yiriws-1
$'.&&:
M&^
'-: >m^,>;U^±H .
;:; m::t^;lt^-
;/::.:. .::;:>|:.:::!.:.:::;:::;:|.;,'
Illilllllfe
W&^'^i
yf -.Fiitiure^ ::
Situation*
i-:.;-:-; .:,' ',;i.v'-.: :-:.-.i:-
Iliiiifii
iiv^lB?::-:^;--1:^:
Future
Value
i;: 'x;^l:
* Percent is not applicable. Please check the box that applies.
Oil
-------
Category /Measure
L. MEDIA PUBLICITY OF
ENFORCEMENT ACTION
Percent of notices of violation receiving
publicity in local newspaper or TV news
within 2 months of issuance
Total
M. FOLLOW-UP INSPECTIONS
Percent of non-complying sources that
received follow-up inspections
a. Within 30 days of NOV
b. Within 30 - 60 days of NOV
c. Within 60 or more days of NOV
d. No follow-up inspection or don't
know
Total
Weights
(X)
G(L)= 9
G(M)= 17
":''. '.--:--- X:£'*:K.":
10
» 1
:'i:.:-.' -' :;
I: '..':
'^fcurrent "?-:
; ^Percent of
Emissions :!
:;:::"iM*l
^titi$$$*$.:;^'^
':' ': . .":;: . . ." :'" " ; "
-:;'::X:*:'Y "
v !"J- :':--;'-
Future
.:.'. Percent of
: Emissions
:^;^(Z)':;:;;-:v':
: x*z.;
C-12
-------
APPENDIX D
GLOSSARY
f D-l
i
s
-------
GLOSSARY
This glossary 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. Where possible these
conflicts are noted. 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.
Actual Emissions: The product of an actual emission xate for a
current year (based on known physical characteristics), the actual
operating rate ("throughput") and the actual operating schedule
for the process. Actual emissions are frequently referred to as
estimated emissions.
Adjusted Base Year Inventory: Section 182 (b)(1)(B) and (D)
describes 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 to "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 of 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 was 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
Aerometric Information Retrieval System (AIRS): A computer-based
repository of information about airborne pollution in the United
States. The system is administered by EPA's National Air Data
D-2
-------
Glossary (continued)
Branch (NADB) in the Office of Air Quality Planning and Standards
(OAQPS). Point source emissions data will be stored on the AIRS
Facility Subsystem (AFS). Area and mobile source emissions data
will be stored on the AIRS Area and Mobile Sources Subsystem
(AMS) .
Allowable Emissions: The product of an enforceable emissions
irate, the anticipated operating rate or activity level and the
anticipated operating schedule. Allowable emissions are not
based on the maximum worst case condition of operations at full
load (8760 hours/year), but are calculated using the anticipated
operating rate and:"the maximum allowable emission rate. - - -
Anti-Tampering Programs: Mobile source emission control programs
providing periodic inspections of vehicles to detect damage to,
disabling of or removal of emission controls.
Area Source: Any stationary or non-road source that is too small
and/or too numerous to be included in the stationary point-source
emissions inventories.
Base Year Inventory: The base year inventory is an inventory of
actual annual and 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 during 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 greater 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 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 area-wide problem, are
required in the, modeling inventory. This modeling inventory
could be submitted with the base yean inventory, or the modeling
inventory aubmittal 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..
D-3
-------
Glossary (continued)
Clean Air Act as Amended in 1990 (Act): The Act was passed by
Congress in October 1990 and signed into law by President Bush on
November 15, 1990. November 15, 1990 is considered the date of
enactment of the Act. Title I of the Act addresses the topic of
NAAQS nonattainment, including standards for ozone and CO.
Compliance Effectiveness (CE): A determination made to evaluate
the compliance (or noncompliance) of a particular source category
in a single geographic area using the SSCD Protocol Study
approach. The calculation of CE is strictly the relationship
between actual .and allowable emissions.at the time of the
' evaluation. - - -
t
| Creditable Emission Reductions: In developing the 15 percent
! reduction control strategy required to be submitted as a SIP
[ revision, States must keep in mind that the 1990 Act explicitly-
disallowed certain reductions from counting toward fulfilling the
I 15 percent reduction in emissions requirement. All emission
! reductions from State or Federal programs are creditable toward
! the 15 percent progress requirement except the following:
i
1. The FMVCP tailpipe or evaporative standards promulgated
prior to 1990.
2. Federal regulations on RVP promulgated by November 15,
1990, or required under section 211 (h).
3. State regulations required under section 182 (a) (2) (A)
submitted to correct deficiencies in existing VOC RACT
regulations or previously required RACT rules,
4. State regulations required under section 182 (a)(2)(B)
submitted to correct deficiencies in existing I/M
programs or previously required I/M programs.
Current Year Emission Inventory: The most current year emissions,
typically referenced to determine progress towards emission
reductions. Base year refers to the original baseline inventory,
typically 1990.
Economic Incentives Programs (EIP's); Programs mandated under the
Act [see Section 182(g)(4)(B)]. EPA has also proposed rules for
implementing EIP's in the Federal Register (FR 11110, Vol. 58,
Number 4; February 23, 1993) to pursue CO or ozone precursor
emission reductions through incentive-based, innovative
strategies. These programs may i>e classified into three broad
regulatory categories: emission limiting strategies, market
response strategies, and directionally sound-strategies.
Emission Inventory: A compilation of information relating to
sources of pollutant emissions, including location, quantity of
emissions, number and type of control devices, stack dimensions
and gas flow rates, and additional pertinent details.
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Glossary (continued)
Highly Controlled Source: Sources with control efficiencies in
excess of 95 percent. Emissions may appear to be artificially
inflated by RE and can negatively impact air quality modeling
analyses.
Inspection and Maintenance (I/M) : Programs requiring the in-
spection of vehicles including, but not limited to, measurement of
tailpipe emissions, and mandating that vehicles with tailpipe
emissions higher than the program cutpoints be repaired to pass a
tailpipe emissions retest. Basic I/M programs must be at least
as stringent as the requirements set out in Act Section 182(a)
(2) (B) .
Inventory 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 four different methods for determining RE: an 80 percent
default value; results from EPA questionnaires; results from a
Stationary Source Compliance Division (SSCD) study; and results
from an EPA-approved alternate RE method. Inventory RE applies
to all base year and projected emission inventories.
Mobile Source: Any moving source of air pollutants, such as
automobiles, vessels, locomotives, aircraft, etc.
1996 Target Level of Emissions: The 1995 target level of
emissions is the maximum amount of ozone season VOC emissions that
can be 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 adding 15 percent
of the adjusted base year inventory emissions 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, is 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 control
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_
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Glossary (continued)
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
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.
Physical Control: An emissions control device such as an
incinerator or carbon adsorber used to reduce emissions from a
process.
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.
Rate of Progress Base Year Inventory: 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.
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 Empirical Kinetic Modeling Application (EKMA) in their
attainment demonstration are also required to include their
attainment demonstration in this SIP revision.
Reasonably Available Control Technology (RACT): Reasonably
available control technology is defined as the lowest emissions
limit that a particular source is capable of meeting by the
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Glossary (continued)
application of control technology that is reasonably available
considering technical and economic feasibility.
Regulatory Emission Limit: Emission limits implemented through
regulatory means, such as a limit on the pounds VOC per gallon
coating.
Rule Effectiveness (RE): A generic term for identifying and
estimating the uncertainties in emission estimates caused by
failures and uncertainties in emission control programs.
Literally, it is the extent to which a rule achieves the desired
emission reductions. Inventory-RE~ applies to specific
applications in SIP inventories.
Rule Effectiveness Improvement: An improvement in the
implementation of a rule for a regulatory program. It refers to a
quantitative reduction in emissions due to the implementation of
improvement measures. RE improvements may be creditable towards
the 15 percent emission reduction target. -
Rule Effectiveness Improvement Measure: Any specific change to
rule implementation, compliance, enforcement or the rule itself
designed to improve the effectiveness of one or more emission
control rules and to result in overall emission reductions.
Rule Effectiveness Questionnaire: A questionnaire approach to
quantifying base year RE for both point and area sources. The
questionnaires were developed by the OAQPS Air Quality Management
Division to provide an alternative procedure to an SSCD protocol
study to determine inventory RE.
Rule Penetration: The extent to which a regulation covers a
complete source category (i.e., less than 100 percent rule
penetration indicates that some sources within a category are not
covered by the rule).
SSCD Protocol Studv: National protocol of criteria and
procedures for conducting rule effectiveness studies as defined by
the Stationary Source Compliance Division at OAQPS. Primarily it
is a compliance tool to evaluate the extent to which rules
actually achieve desired emission reductions. Results may be
used for inventory RE and SIP effectiveness calculations as well.
Source Category: Any group of similar sources. For instance,
all residential dwelling units would constitute a source category.
Stata Implementation Plan (SIP) Effectiveness (SE): The ability
of the attainment plan(s) to achieve the planned emission
reductions^ SIP Effectiveness is estimated by.comparing actual
emission reductions to the projected emission reductions.
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Glossary (continued)
State Implementation Plan _(SI_P) Inventories: Emissions inven-
tories required as part of the overall State implementation plan
for achieving the National Ambient Air Quality Standards. States
are required under the Clean Air Act to submit these plans to the
U.S. Environmental Protection Agency.
Volatile Organic Compound: Any compound of carbon, excluding CO,
carbon dioxide, carbonic acid, metallic carbides or carbonates,
and ammonium carbonate, which participates in atmospheric photo-
chemical reactions. This includes any organic compound other
than those EPA has determined to have negligible photochemical
reactivity. (Federal Register 3945, February 3, 1992.)
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