RACM ANALYSIS FOR FOUR SERIOUS AREAS DESIGNATED NONATTAINMENT

FOR 1-HR OZONE NAAQS

U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
and

Office of Transportation and Air Quality
Ann Arbor, MI 48105

October 12, 2000


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RACM ANALYSIS FOR FOUR SERIOUS AREAS DESIGNATED NONATTAINMENT

FOR 1-HR OZONE NAAQS

This paper provides supplemental information for EPA's notices of proposed rulemaking for State
implementation plans (SIPs) for four areas designated serious nonattainment for the 1-hour national
ambient air quality standard (NAAQS) for ground-level ozone. These nonattainment areas are:

Greater Connecticut, Western Massachusetts (Springfield), Metropolitan Washington (DC, MD, VA),
and Atlanta, GA. This information addresses comments received on those proposals that questioned
EPA's proposed approval of the SIPs regarding the Clean Air Act's (Act's) requirement that SIPs
contain reasonably available control measures (RACM).

SUMMARY

EPA has performed an analysis to evaluate emission levels of oxides of nitrogen (NOx) and volatile
organic compounds (VOC) and their relationships to the application of current and anticipated control
measures expected to be implemented in four serious one-hour ozone nonattainment areas. This
analysis was done to determine if additional reasonably available control measures (RACM) are
available after adoption of Clean Air Act (Act) required measures for the following serious ozone
nonattainment areas: Greater Connecticut, New York-New Jersey-Connecticut; Springfield,
Massachusetts; Washington, D.C.-Virginia-Maryland; and Atlanta, Georgia. The EPA performed this
analysis in response to comments that were submitted on the proposals on these areas' one-hour ozone
attainment demonstrations. The EPA took action to propose approval (and disapproval in the
alternative) of these areas' SIPs on December 16, 1999 [Greater Connecticut (64 FR 70332);
Springfield (64 FR 70319); Metropolitan Washington (64 FR 70460); and Atlanta (64 FR 70478)].
This information supplements the December 16, 1999 proposals.

Section 172(c)(1) of the Act requires SIPs to contain reasonably available control measures (RACM)
as necessary to provide for attainment as expeditiously as practicable. Several commenters have
stated that there is no evidence in the four serious ozone attainment demonstrations that were proposed
on December 16, 1999 that they have adopted all RACM, and a commenter further stated that the
mobile source emission budgets in the SIPs are inadequate by definition because the SIPs do not
demonstrate timely attainment or contain the emission reductions required for all RACM. In addition,
some commenters stated that for all potential RACM measures not adopted into the SIP, the State
must provide a justification for why they were determined not to be RACM. The analysis EPA
conducted demonstrates that a number of possible emission control measures have been evaluated for
their emission reductions. It further demonstrates that the measures evaluated either (a) are likely to
require an intensive and costly effort for numerous small area sources, or (b) do not advance the
attainment dates for the four areas, and therefore would not be considered RACM under the Act.

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EPA has previously provided guidance interpreting the RACM requirements of 172(c)(1). See 57 FR
13498, 13560. In that guidance, EPA indicated its interpretation that potentially available measures
that would not advance the attainment date for an area would not be considered RACM. EPA
concluded that a measure would not be reasonably available if it would not advance attainment. EPA
also indicated in that guidance that states should consider all potentially available measures to determine
whether they were reasonably available for implementation in the area, and whether they would
advance the attainment date. Further, states should indicate in their SIP submittals whether measures
considered were reasonably available or not, and if measures are reasonably available they must be
adopted as RACM. Finally, EPA indicated that states could reject potential RACM measures either
because they would not advance the attainment date, would cause substantial widespread and long-
term adverse impacts, or for various reasons related to local conditions, such as economics or
implementation concerns. The EPA also issued a recent memorandum on this topic, "Guidance on the
Reasonably Available Control Measures (RACM) Requirement and Attainment Demonstration
Submissions for Ozone Nonattainment Areas." John S. Seitz, Director, Office of Air Quality Planning
and Standards. November 30, 1999. Web site: http://www.epa.gov/ttn/oarpg/tlpgm.html.

In response to public comments received on the proposed rulemakings in December, EPA has
reviewed the SIP submittals for the four serious areas and determined that they did not include sufficient
documentation concerning available RACM measures. Therefore, EPA has itself reviewed numerous
potential RACM measures, as documented in the following analysis. Based on this analysis, EPA
concluded these measures would either (a) likely require an intensive and costly effort for numerous
small area sources, or (b) not advance the attainment date in any of the four areas.

EPA reached this conclusion primarily because the reductions expected to be achieved by the potential
RACM measures are relatively small, in the range of 8.4 to 29.7 tons per day of VOC and 4.5 to 16.7
tons per day of NOx for stationary sources and 2.03 to 11.38 tons per day of VOC and 3.56 to 17.07
tons per day of NOx for mobile sources. These potential reductions are far less than the emissions
reductions needed within the nonattainment areas to reach attainment.

In addition, all of the four areas rely in part on reductions from outside the nonattainment areas from
EPA's NOx SIP call or section 126 rule (65 Fed. Reg. 2674, January 18, 2000) to reach attainment.
In the NOx SIP call, 63 Fed. Reg. 57356, EPA concluded that reductions from various upwind states
were necessary to provide for timely attainment in various downwind states, including all six of the
states discussed in this analysis. The NOx SIP call therefore established requirements for control of
sources of significant emissions in all upwind states. However, these reductions were not slated for full
implementation until May 2003. Further, the United States Court of Appeals for the District of
Columbia Circuit recently ordered that EPA could not require full implementation of the NOx SIP call
prior to May 2004. Michigan, et al.. v. EPA D. C. Cir. No. 98-1497, Order of Aug. 30, 2000.

The attainment demonstrations for the four serious areas indicate that the ozone benefit expected to be
achieved from regional NOx reductions (such as the NOx SIP call) are substantial. (See the individual

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attainment demonstrations in the docket for each of these areas.) In addition, many of the measures
designed to achieve emissions reductions from within the four nonattainment areas will also not be fully
implemented prior to the respective attainment date. Therefore, EPA concludes, based on the available
documentation, that since the reductions from potential RACM measures do not nearly equate to the
reductions needed to demonstrate attainment, none of these measures could advance the attainment
date prior to full implementation of the SIP call or section 126 rule in 2003 or 2004 and all local
measures by the respective attainment date, and thus none of these potential measures can be
considered RACM for these four areas.

Although EPA encourages areas to implement available RACM measures as potentially cost effective
methods to achieve emissions reductions in the short term, EPA does not believe that section 172(c)(1)
requires implementation of potential RACM measures that either require costly implementation efforts
or produce relatively small emissions reductions that will not be sufficient to allow any of the four areas
to achieve attainment in advance of full implementation of all other required measures.

ANALYSIS

The analysis for mobile source categories differs from that for stationary source categories in several
respects:

1.	The mobile source categories are fewer in number, and therefore the emissions inventory information
for the attainment year was more readily available from SIP files for EPA to use. The stationary source
categories are more numerous, and detailed category-by-category emissions information for the
attainment year was not readily available for the analysis. An available projected 2007 emission
inventory was therefore used for the stationary source analysis.

2.	Limited emissions control information was readily available for the analysis of both stationary and
mobile sources. However, for the mobile source analysis, individual control measures were evaluated.
For the stationary source analysis, a "top down" technique was used to estimate the source categories
and emissions that are potentially available for additional control, and then supplemented with readily
available information specific to each of the four areas.

MOBILE SOURCE ANALYSIS

Attachment 1 is an analysis of a broad range of transportation control measures (TCMs) to determine if
they are RACM for the four nonattainment areas in question. Emission reductions that might result from
implementation of these TCMs were derived from on-road emissions and vehicles miles of travel
(VMT) data in the attainment year emissions inventory for each nonattainment area.

Table 1 shows, for each nonattainment area, attainment year on-road emissions for volatile organic
compounds (VOC) and nitrogen oxides (NOx) in tons per day (TPD) in column 3. Light-duty cars
and light-duty trucks generally contribute 80% of the on-road VOC inventory, and 70% of the on-road
NOx inventory. For the purpose of this analysis, EPA assumes that only light-duty cars and light-duty


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trucks are affected by the TCMs. Column 4 shows the on-road VOC inventory and NOx inventory
reduced by 20% and 30% respectively to account for this assumption. The light-duty vehicle VOC
and NOx inventory for each nonattainment area is divided by the average daily attainment year VMT
(shown in column 5) for each nonattainment area, to calculate emissions in daily tons per mile (shown in
column 6).

Tables 2-5 show a range of emissions reductions that could potentially be achieved through the
implementation of TCMs in Atlanta, GA; Greater Connecticut; Springfield (Western), MA; and
Washington, DC-MD-VA, respectively. Column 1 shows a range of TCMs, widely recognized by the
literature, grouped into seven broad categories. The literature also contains estimates of reductions in
VMT that could be expected from implementation of these TCMs. The VMT reductions vary in
magnitude, depending on the scope and scale of the TCMs, the number of years over which the effects
are analyzed, the existing transportation infrastructure and demand management (ie. existing TCMs) in
the area, development patterns, and a number of other economic and demographic characteristics. It is
important to note that in the United States, empirical evidence of the travel activity effects of TCMs
have come primarily from case studies of small scale TCM programs, and that estimates of larger
effects have come from studies of theoretical programs for which there is little actual large scale
implementation experience. The high range of VMT reductions, as the result of scenarios which may
require fundamental changes in infrastructure investment policies, or in the case of "Smart Growth"
measures, governmental and other institutional relationships, may, in reality be very difficult to achieve
within the timeframe for demonstrating attainment.

Nevertheless, Column 2 shows the range of VMT reductions by percent of total regional VMT, that
could occur as a result of TCM implementation according to the literature. By multiplying the
attainment year daily VMT (Table 1, Column 5) for each nonattainment area, by the range of VMT
reductions by percent, one can estimate the range of VMT reduced in each nonattainment area for each
category of TCMs. Column 3, shows this range of daily VMT reduced for each category. The figures
in Column 4 show the range of estimated emission reductions in tons per day (TPD). These estimates
were calculated by multiplying the emissions, in daily tons per mile (Table 1, Column 6), by the range of
daily VMT reduced for each category of TCMs.

Table 6 compares the estimated emission reductions from TCMs for each nonattainment area to the
emission reductions necessary for each area to demonstrate attainment. Column 1 shows the total
emission reduction needed to demonstrate attainment. Column 2 shows the midpoint of the range of
estimated emission reductions (from Tables 2-5, Column 6) from TCMs. Column 3 shows the
estimated emission reductions as a percent of the total reduction needed to demonstrate attainment.
EPA believes it is appropriate to use these figures for the purpose of this analysis, given the wide range
of potential emission reduction cited in the literature. As noted above, the emission reductions on the
high end of the range, are based on theoretical programs, which would require implementation on a
scale and scope unlikely to be manageable within the timeframe for reaching attainment. The literature
and implementation experience in urban areas leads EPA to believe that the low to midpoint range of

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emission reductions are achievable with careful planning, adequate implementation resources,
aggressive public information programs and a sustained commitment by the implementing agencies.
Using the midpoint of the range of emission reductions provides a liberal estimate of potential reductions
from TCMs, to compare against the emission reductions required to demonstrate attainment. When
compared to emission reductions necessary for attainment, emission reductions from TCMs that could
potentially be implemented are only a small percentage of emission reductions needed. Potential VOC
reductions range from 1.4% of the reductions needed for Greater Connecticut, to 5.2% of the
reductions needed for Washington, DC-MD-VA. Potential NOx reductions range from 3.3% of the
reductions needed for Greater Connecticut, to 11% of the reductions needed for Atlanta, GA. From
this analysis, EPA concludes that implementation of these TCMs would not produce emission
reductions sufficient to advance the attainment date without obtaining further reductions from sources
already regulated, or about to be regulated, to a reasonable level, and that will not be fully achieved
until the attainment date. This includes the substantial reductions achieved from the NOx SIP call or
EPA's rule under section 126 of the Act (65 FR 2674 (January 18, 2000)), both within and upwind of
the relevant States, which will not be achieved until 2003 or 2004.

Additional Area-Specific Information on Mobile Measures for Atlanta-In addition to the above mobile
source analysis, EPA had readily available information concerning certain control measures currently in
place in Georgia. A list of the SIP-approved transportation control measures and the program activities
from the Partnership for a Smog-free Georgia (PSG) are listed in the table below. The table provides
an indication of whether the measure is a SIP TCM, in the PSG program or both; the table also
indicates where the SIP took emission reduction credit for the measures. For the other SIP measures,
they were approved except as noted, but no emission reduction credit was taken. Thus Georgia has
actually implemented most of the programs listed in the above analysis. This provides additional
justification for EPA's position that the Atlanta SIP has met the RACM requirement of the Act.

CONTROL MEASURE

EMISSION REDUCTION
CREDIT TAKEN IN SIP

Employer-Based transportation demand management (TDM)



-van/car pools (SIP TCM/PSG)

X

-guarantee ride home (PSG)

X

- mid-day shuttles (PSG)

X

-transit subsidies (SIP TCM/PSG)

X

-telecommuting (PSG)

X

Area-wide Rideshare



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CONTROL MEASURE

EMISSION REDUCTION
CREDIT TAKEN IN SIP

-park and ride (SIP TCM)



-ride matching (PSG)

X

-Transportation Management Associations (TMA's) (SIP

TCM)



Parking Management



-preferential parking for High Occupancy Vehicles
(HOV) (PSG)

X

Bike/Pedestrian Programs



-designated lanes/routes (SIP TCM)

X

-safety enhancements (SIP TCM)

X

Improved Public Transit



-express bus (SIP TCM)



-paratransit (PSG)

X

-shuttle circulators (PSG)

X

Activity Centers



-Multi-Modal transfer centers (PSG)

X

-incident/congestion response (PSG)

X

Smart Growth (Atlantic Steel)



-infill development (SIP TCM PENDING APPROVAL)



-Transit-Oriented Development (TOD) (SIP TCM
PENDING APPROVAL)



-mixed use development (SIP TCM PENDING
APPROVAL)



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STATIONARY SOURCE ANALYSIS

Attachment 2 is a report on an analysis done for EPA to determine what emission reduction controls
might be available that would be considered reasonably available control measures. EPA looked at
projected 2007 emissions after Clean Air Act mandatory controls and additional regional and national
controls, as well as State SIP controls were accounted for. These include the NOx SIP call or section
126 rule reductions in the eastern US and the mobile source Tier II control program. For this analysis,
EPA assumed that stationary source categories that have already been controlled nationally, regionally
or locally in the SIP would not be effective candidates for additional controls that could be considered
RACM, since these categories have only recently installed their level of control or are about to shortly.
Controls assumed in the SIP were applied based on national assumptions for those controls and may
not match the controls actually documented in the individual SIPs. The area-specific descriptions
below, however, address substantial differences that exist and other conditions unique to each area, and
appropriate corrections have been incorporated below.

EPA considered 2007 projected emissions regardless of an area's specific requested attainment date
because it represents a level of control that will have already occurred by the area's attainment date, or
will occur shortly afterward. Also, the 2007 projected emissions inventory was readily available for this
analysis, whereas detailed category-by-category projected emission inventories for other earlier dates
were not readily available.

As described in Attachment 2, categories and their emissions were identified that would remain after the
other national, regional and SIP controls were accounted for. The remaining source categories were
then ranked on the basis of emissions by category. The bottom 20 percent of the categories were
removed from consideration based on the assumption that their individual category contribution would
be considered too small and too numerous to regulate individually, and therefore would not be
considered reasonably available. The emissions from top 80 percent of the categories were then
totaled. Tables 6 and 7 of Attachment 2 present the summary of the top 80 percent of the "potentially
controllable" emissions for each of the four areas. These are summarized for each of the four areas in
Table A below; however, where there was area-specific information readily available to provide more
accurate information, that is presented in the area-specific discussion below, and Table A reflects these
differences. The EPA then assumed a generalized level of control (50 percent) applied to each of these
categories; this is also presented in Table A below. Even though approximately 81 percent control was
generally assumed to be a default level of control for previous Control Techniques Guidelines for VOC
in the past, those CTG's were developed for categories that were more readily controlled. For this
RACM analysis, EPA has assumed the lower amount (50 percent) for remaining categories, since
controls may not be quite as effective or as readily available.

Next, EPA compared the results of these levels of control possible with the emission reductions needed
for attainment. The results of this comparison appear in Table B below.

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The NOx controls potentially available range from about 8 percent of the NOx reductions needed for
attainment (in Western Massachusetts) to over 10 percent (in Atlanta). Table 7 of Attachment 2
presents the Tier 3 source categories with these potential controls. With the exceptions noted below
for Atlanta, it appears that the kinds of categories with the most emissions available for control (e.g.,
industrial, residential, and commercial/ institutional distillate oil and gas combustion; and waste
incineration) generally affect area sources, which are smaller and numerous. Requiring NOx control on
these sources would therefore likely require an intensive, costly effort. Also, as noted in EPA's final
rule on the NOx SIP call:

Area Sources. In the NPR, EPA noted that control levels for area sources (i.e., sources other
than mobile or point sources) could not be determined based on available information
concerning applicable control technologies. Comments to the NPR did not identify specific
NOx control technologies that were both technologically feasible and highly cost-effective.
Because EPA has no new information on applicable control technologies for area sources, no
additional control level is assumed for these sources in this rulemaking. (63 FR 57402, October
27, 1998.)

As a result, controls on these categories are not considered reasonably available.

Atlanta Exceptions:

1.	For Atlanta, one of the tier 3 categories from Table 7 is "other industrial processes/mineral
products/surface mining" with 5.4 tons NOx/day. Table 14 identifies that these emissions are from one
point source, a glass manufacturer. Further investigation revealed that this source already has a permit
that requires a RACT level of emissions, and therefore additional NOx controls would not be
considered reasonably available.

2.	Atlanta has a regulation (i.e., Rule 391-3-1.02, paragraph 2) for NOx emissions from fuel-burning
equipment. The regulation applicability is based on heat input capacity (i.e., > or = 10 mmBTU/hr and
< or = 250 mmBTU/hr). Because this regulation is not connected to an emission limit, it is likely that
some of the stationary area sources listed in Tables 7 and 9 of Attachment 2 could be controlled under
this regulation. It should be noted that due to timing constraints, a direct comparison between the
sources Georgia has controlled and what was identified in the stationary source analysis of Attachment
2 as potential candidates for control was not possible.

For VOC, individual areas are discussed below.

Western Massachusetts rSpringfield): As shown in the modeled attainment demonstration, this area
relies heavily on NOx controls from upwind areas, and further local VOC reductions in this area would
not produce significant ozone reductions. However, the potential for additional VOC reductions was
still considered as noted below.

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Column 5 of Table B indicates that close to 14 percent additional VOC reductions may be possibly
available (compared to the reductions needed for attainment from a 1990 baseline). (Note that the
actual reductions will be more, since the attainment level of emissions must also account for additional
control to offset emissions growth from 1990 to the attainment year.) However, the analysis described
above did not account for some of the specific regulations that Massachusetts has already adopted and
are approved into the SIP. In Massachusetts, emissions from top 80 percent of the categories that were
assumed to be uncontrolled included the following (from Attachment 2, Table 6):

Springfield, MA categories

2007 Uncontrolled

Tier2 Name

Tier3 Name

VOC OSD







Surface Coating

industrial adhesives

6.70

Surface Coating

other

3.59

Surface Coating

thinning solvents

2.15

Other Industrial

rubber & plastics mfg

1.52

Agriculture, Food, &
Kindred Products

bakeries

1.02

Surface Coating

electronic & other electrical

0.98

Graphic Arts

other

0.86



Totals

16.82

For the "Surface Coating - industrial adhesives" category, which the largest uncontrolled category
listed, it is important to look to see how this category may already be controlled under Massachusetts
statewide VOC regulations. In the Massachusetts air pollution control regulations, the definition of
"coating" includes adhesives as well as paints, varnishes, sealants and temporary protective coatings.
Thus, industrial adhesives are probably already largely controlled under the surface coating regulations
that Massachusetts has adopted pursuant to EPA's CTG documents. For the "Agriculture, Food, &
Kindred Products - Bakeries" category, Massachusetts regulation 310 CMR 7.18(29), entitled
"Bakeries" already covers this category with a reasonable level of control. For "Surface Coating -
other," and "Graphic Arts - other,"

regulations adopted by Massachusetts in the early 1990's that were not covered by EPA CTG's
address some of these categories. Those rules are 310 CMR 7.18(22), Leather surface coating; 310
CMR 7.18(25), Offset lithographic printing; 310 CMR 7.18(26), Textile finishing; and 310 CMR
7.18(27), Coating mixing tanks. Lastly, for the "Surface Coating - thinning solvents" category,it
appears that most of the emissions attributed to this category are from point sources that are known to
be subject to surface coating regulations that Massachusetts has adopted pursuant to EPA's CTG
documents.

Thus, the amount of reduction potentially available from further controls on these listed categories is
most likely very small. Therefore EPA believes it would not advance the attainment date for the
western MA nonattainment area, particularly since this area relies heavily on NOx controls from upwind
areas, and further local VOC reductions in this area would not produce significant ozone reductions.

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Greater Connecticut: Column 5 of Table B indicates that close to 17 percent additional VOC
reductions may be possibly available (compared to the reductions needed for attainment from a 1990
baseline).

However, the analysis described above did not account for some of the specific requirements that
Connecticut already has in its SIP. In Connecticut, emissions from top 80 percent of the categories that
were assumed to be uncontrolled included the following:

Greater CT categories

2007 Uncontrolled

Tier2 Name

Tier3 Name

VOC OSD







Surface Coating

industrial adhesives

27.97

Surface Coating

other

13.08

Surface Coating

thinning solvents

5.64

Surface Coating

electronic & other electrical

4.83

Service Stations: Breathing
& Emptying

other

3.07

Other

other

2.81

Other Combustion

other

2.03





59.43

For the "Surface Coating - industrial adhesives" category, which the largest uncontrolled category
listed, it is important to look to see how this category may already be controlled under Connecticut
statewide VOC regulations. In some circumstances, industrial adhesives would be covered by the
surface coating regulations that Connecticut has adopted pursuant to EPA's CTG documents. In other
circumstances, industrial adhesives would be covered by Connecticut's regulation (i.e., 22a-174-20(f))
governing equipment that emits more than certain amounts of VOC per hour and per day.

For the "Surface Coating - other" category, some of the emissions attributed to this category are from
sources that are subject to the surface coating regulations that Connecticut has adopted pursuant to
EPA's CTG documents.

For the "Surface Coating - thinning solvents" category, it appears that many of the emissions attributed
to this category are from point sources that are known to be subject to either the surface coating
regulations that Connecticut has adopted pursuant to EPA's CTG documents or pursuant to
Connecticut's non-CTGRACT regulation.

For the "Surface Coating - electronic & other electrical" category, it appears that given that
Connecticut's miscellaneous metal parts and products surface coating regulation covers sources under

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Standard Industrial Classification (SIC) code of Major Group 36 (electrical machinery), that many of
the emissions attributed to this category are covered by that regulation.

For the "Service Stations: Breathing & Emptying" category, some portion of the gasoline dispensing
facilities in the state have installed pressure relief valves on their underground storage tank vents already
as part of their stage II equipment, which is required throughout the state for all facilities dispensing
more than 10,000 gallons per month. These pressure relief valves, where installed, would already
substantially reduce the breathing losses from the underground tanks.

The "Other combustion" category refers to structural fires which cannot effectively be controlled with
air pollution control regulations.

Thus, the amount of reduction potentially available from further controls on these listed categories is
most likely very small, and therefore EPA believes it would not advance the attainment date for the
Greater Connecticut nonattainment area.

Furthermore, as shown in the modeled attainment demonstration, Greater Connecticut relies heavily on
controls in upwind areas, especially from the NOx SIP call or the section 126 rule and from the
metropolitan New York city area. Since New York city has an attainment date of 2007, it is unlikely
that all the emission reductions necessary to bring Greater Connecticut into attainment will be obtained
until 2007. Furthermore, zero out analyses show that even eliminating all of Connecticut's emissions
does not help Connecticut attain by it 1999 attainment date, since the effects of transport are so
significant. (See 64 FR 70343) Therefore, additional VOC reductions are not seen as advancing the
attainment date for the Greater Connecticut area.

Metropolitan Washington: Column 5 of Table B indicates that 7.3 percent additional VOC reductions
may be possibly available (compared to the reductions needed for attainment from a 1990 baseline).
(Note that the actual reductions will be more, since the attainment level of emissions must also account
for additional control to offset emissions growth from 1990 to the attainment year.) However, for the
Metropolitan Washington area, it is highly unlikely that this additional potential reduction would advance
the attainment date for the area because of the following reasons:

a.	The area relies heavily on control of transported emissions and ozone.

b.	The Washington area modeling indicates that NOx emission reductions are generally more beneficial
in reducing ozone concentrations, suggesting that the area may be NOx limited. When the maximum
ozone response for VOC controls (.029 ppb/ton VOC) is applied to the potential additional VOC
emission reductions in the D.C. area due to RACM (10.2 % or approximately 17 tons/day), the result
is an ozone benefit of only .49 ppb. See Attachment 4 for a modeling sensitivity analysis (available only
in docket for Metropolitan Washington area).

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Atlanta:

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a.	Table 6 of Attachment 2 indicates that 66.28 tons per day of VOC emissions may be potentially
controllable to some level. However, as noted above, the Attachment 2 analysis was performed using
nationally available information, whereas EPA has additional readily available information for Atlanta as
follows: The category "Waste disposal & recycling-open burning-residential is shown in Table 6 to
yield 11.13 tons/day VOC emissions. However, Georgia has a rule prohibiting open burning; therefore
EPA is assuming that category as not available for additional control. Therefore the resulting emission
reductions should be 66.28 - 11.13 = 55.15 tons/day. This value is presented in the Table A below.

b.	Regulations for the managed slash and prescribed open burns exist in the 13-county nonattainment
area. A regulation for managed slash burns exist for the attainment counties in their 4-km modeling
domain. These emissions amount to 6.78 tons/day in Table 8 and would not be available for further
control.

c.	Column 5 of Table B indicates that 8.3 percent additional VOC reductions may be possibly
available (compared to the reductions needed for attainment from a 1990 baseline). (Note that the
actual reductions will be more, since the attainment level of emissions must also account for additional
control to offset emissions growth from 1990 to the attainment year.) It is well known that Atlanta is
NOx limited, and therefore relies mainly on a NOx control strategy (see, e.g., Attachment 6, p. 69) .
The nonattainment area depends heavily on emission reductions from NOx sources outside the
nonattainment area. Therefore, it is unlikely that even as large a possible reduction as indicated here
would advance the attainment date.

d.	In identifying sources to make up the shortfall identified as needed for attainment, GA has identified
more NOx and VOC reductions( i.e., 41 tpd NOx and 27 tpd VOC) than required in the shortfall
calculations (i.e., 36 tpd NOx and 21 tpd VOC). Thus, there will be additional VOC reductions that
will occur even without consideration of RACM.

e.	In applying for a fuel waiver for its additional lower sulfur gasoline, Georgia performed its own
analysis of why a number of controls were not considered for implementation. A copy of that analysis
appears as Attachment 3 (available only in docket for Atlanta area). That analysis also support a
conclusion that further controls are not considered reasonably available.

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TABLE A

RACM ANALYSIS-STATIONARY SOURCES-ESTIMATED ADDITIONAL EMISSION REDUCTIONS POSSIBLE



Emission reductions (tons
VOC/day)

AREA

Col 1

Col 2

Western MA (Springfield)

16.82

8.4

Greater CT

59.43

29.7

Metro Washington (DC, VA, MD)

24.22

12.1

Atlanta GA

55.15

27.6





Emission reductions (tons
NOx/day)

AREA

Col 1

Col 2

Western MA (Springfield)

8.97

4.5

Greater CT

24.63

12.3

Metro Washington (DC, VA, MD)

26.41

113.2

Atlanta GA

33.39

16.7

Col 1

2007 emissions possible for control - Tables 6 and 7 from Attachment 2

Col 2

emissions control if 50% control assumed for these categories

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TABLE B- RACM ANALYSIS-STATIONARY SOURCES
1 841 617 046 4	COMPARISON OF POSSIBLE REDUCTIONS TO REDUCTIONS NEEDED FOR ATTAINMENT



Emission reductions (tons VOC/day)





AREA

Coll

Col 2

Col 3

Col 4

Col 5



Western MA (Springfield)

62

0

62

8.4

13.6



Greater CT

176

0

176

29.7

16.9



Metro Washington (DC, VA, MD)

167

0

167

12.1

7.3



Atlanta GA

310

21

331

27.6

8.3





Emission reductions (tons NOx/day)





AREA

Coll

Col 2

Col 3

Col 4

Col 5

Western MA (Springfield)

44

0

44

4.5

10.2

Greater CT

158

0

158

12.3

7.8

Metro Washington (DC, VA, MD)

191

0

191

13.2

7.9

Atlanta GA

120

36

156

16.7

10.7

Col 1

Attainment year reductions from original attainment demonstration (reductions at the attainment year from 1990) (from material accompanying Administrator's briefing
12/99; located athttD://www.eDa.eov/ttn/oarr)e/tl/fr notices/citiex.Ddf). Note that since these reductions are from a 1990 base, all emissions growth between 1990 and
the attainment year would also have to be offset by control to provide an attainment level of emissions, so these reductions do not account for all that additional
emission reductions needed to offset growth.

Note: The VOC and NOx emissions needed for attainment for Greater Connecticut was revised by the State of Connecticut. Connecticut submitted revised 2007
transportation conformity budgets in February 2000, and this changed both the on-road estimates for 2007 and the emission reductions necessary for attainment. The
revisions are reflected in this table. Table C below provides the derivation of the revised numbers.

Note: The NOx emission reductions needed for attainment for Western Massachusetts have been updated based on information provided by the EPA Region I office
and differ from the amounts in the 12/99 briefing material.

Note: The VOC and NOx emission reductions needed for attainment for Atlanta have been updated based on information provided by the EPA Region IV office and
differ from the amounts in the 12/99 briefing material, (see Attachment 5-available only in docket for Atlanta SIP).

Col 2

Additional shortfall needed identified by EPA or State (from material accompanying Administrator's briefing 12/99; located at
http ://www. epa. gov/ttn/oarpg/t 1 /fr notices/citiex.pdf)

Col 3

Total reductions needed for attainment (Col 1 + Col 2)

16


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Col 4

Additional reductions that might be obtained from stationary source measures under possible RACM rules (from Col. 2 of Table A)

Col 5

Percent difference (Col 3 Col 4) * 100%

TABLE C

Emissions Summary for 1-Hour Ozone Attainment Demonstrations (tons per day)

September 27, 2000

Nonattainment Area
(attainment year or attainment
year requested)

1990 Emissions

Attainment Year
Emissions

Emission
Reductions1
(This does not
include
"shortfall")

VOC

NOx

VOC

NOx

VOC

NOx

Greater Connecticut
(2007)

Total:

417

354

241

196

176

158

Point:

34

87

17

48

17

39

Area:

178

8

148

9

30

-1

On-road:

127

176

30

77

97

99

Non-road:

78

83

46

62

32

21

1 These are differences in the nonattainment area total emissions (1990 emissions minus attainment year emissions). Some States are getting additional emission
reductions outside the nonattainment area. These additional reductions are not reflected in the table.

17


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ATTACHMENT 1-MOBILE SOURCE ANALYSIS

18


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Table 1. Attainment Year Emissions and Vehicle Miles Traveled (VMT)

Nonattainment Area

(attainment year or
requested attainment year)

Mobile
Source
Category

Attainment Year
Emissions

Emissions from
Light-Duty Vehicles

(VOC = 80%)
(Nox = 70%)

Attainment Year
Daily VMT

Daily Tons
per Mile (from
Light-Duty
Vehicles)

Atlanta, GA







132,000,000



(2003)

On-road VOC

132 TPD

106 TPD



.0000008



On-road NOx

224 TPD

157 TPD



.0000012













Greater Connecticut







75,590,000



(2007)

On-road VOC

31 TPD

24 TPD



.0000003



On-road NOx

91 TPD

51 TPD



.0000007













Springfield, MA
(Western MA)











(2003)

On-road VOC

24 TPD

19 TPD

23,570,000

.0000008



On-road NOx

49 TPD

34 TPD



.0000014













Washington, DC-MD-VA







133,300,000



(2005)

On-road VOC

105 TPD

84 TPD



.0000006



On-road NOx

178 TPD

125 TPD



.0000009

Table 2. Atlanta, GA - Potential Emission Reductions from Transportation Control Measures (TCMs)

19


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TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Emplover-based TDM
-Van/Car Pools
-Mid-day Shuttles
-Parking Cash-Out
-Guaranteed Ride Home
-Transit Subsidy
-Telecommuting

0.2-3.5

264,000 - 4,620,000

VOC: 0.211 -3.696
NOx: 0.317 - 5.544

Area-Wide Rideshare
-Park and Ride
-Ride Matching
-Transportation Management
Assoc.

-Van-Pool Subsidy/Insurance

0.1 -0.2

132,000 -264,000

VOC: 0.106-0.211
NOx: 0.158-0.317

Parkins Management
-Preferential Parking for HOV
-Parking Pricing
-Zoning Requirements
-Commercial Vehicle
Management

0.5-4.2

660,000 - 5,544,000

VOC: 0.528 -4.435
NOx: 0.792 - 6.653

Bicvcle/Pedestrian Programs
-Designated Lanes/Routes
-Safety Enhancements
-Transit Support Facilities

<0.1

< 132,000

VOC: <0.106
NOx: <0.158

20


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TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Improved Public Transit
-Express Bus
-Paratransit
-Shuttle Circulators
-Coordinated Fare

o

CO

tr,

O

660,000 - 3,960,000

VOC: 0.528 -3.168
NOx: 0.792 - 4.752

Activity Centers
-Multi-modal Transfer Centers
-Remote Parking
-Incident/Congestion Response

0.1 -0.2

132,000 -264,000

VOC: 0.106-0.211
NOx: 0.158-0.317

Smart Growth
-Infill Development
-Transit Oriented Development
-Mixed-Use Development

0.1 - 8.8

132,000 - 11,616,000

VOC: 0.106-9.293
NOx: 0.158 - 13.939



Total

VOC: 1.638 - 21.12
NOx: 2.454-31.680

21


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Table 3. Greater Connecticut - Potential Emission Reductions from Transportation Control Measures (TCMs)

TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Emplover-based TDM
-Van/Car Pools
-Mid-day Shuttles
-Parking Cash-Out
-Guaranteed Ride Home
-Transit Subsidy
-Telecommuting

0.2-3.5

151,000 -2,646,000

VOC: 0.045 -0.794
NOx: 0.106 - 1.852

Area-Wide Rideshare
-Park and Ride
-Ride Matching
-Transportation Management
Assoc.

-Van-Pool Subsidy/Insurance

0.1 -0.2

76,000 - 151,000

VOC: 0.023 - 0.045
NOx: 0.053 -0.106

Parkins Management
-Preferential Parking for HOV
-Parking Pricing
-Zoning Requirements
-Commercial Vehicle
Management

0.5-4.2

378,000 -3,175,000

VOC: 0.113 -0.953
NOx: 0.265 - 2.223

Bicvcle/Pedestrian Proerams
-Designated Lanes/Routes
-Safety Enhancements
-Transit Support Facilities

<0.1

< 76,000

VOC: < 0.023
NOx: < 0.053

22


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TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Improved Public Transit
-Express Bus
-Paratransit
-Shuttle Circulators
-Coordinated Fare

o

CO

tr,

O

378,000 - 2,268,000

VOC: 0.113 -0.680
NOx: 0.265 - 1.588

Activity Centers
-Multi-modal Transfer Centers
-Remote Parking
-Incident/Congestion Response

0.1 -0.2

76,000 - 151,000

VOC: 0.023 - 0.045
NOx: 0.053 -0.106

Smart Growth
-Infill Development
-Transit Oriented Development
-Mixed-Use Development

0.1 - 8.8

76,000 - 6,652,000

VOC: 0.023 - 1.996
NOx: 0.053 - 4.205



Total

VOC: 0.352 - 4.536
Nox: 0.822 - 10.133

Table 4. Springfield, MA (Western MA) -Potential Emission Reductions from Transportation Control Measures (TCMs)

23


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TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Emplover-based TDM
-Van/Car Pools
-Mid-day Shuttles
-Parking Cash-Out
-Guaranteed Ride Home
-Transit Subsidy
-Telecommuting

0.2-3.5

47,000 - 825,000

VOC: 0.038 - 0.660
NOx: 0.066 - 1.155

Area-Wide Rideshare
-Park and Ride
-Ride Matching
-Transportation Management
Assoc.

-Van-Pool Subsidy/Insurance

0.1 -0.2

24,000 - 47,000

VOC: 0.019-0.038
NOx: 0.034 - 0.066

Parkins Management
-Preferential Parking for HOV
-Parking Pricing
-Zoning Requirements
-Commercial Vehicle
Management

0.5-4.2

118,000 -990,000

VOC: 0.094 - 0.792
NOx: 0.165 - 1.386

Bicvcle/Pedestrian Programs
-Designated Lanes/Routes
-Safety Enhancements
-Transit Support Facilities

<0.1

< 24,000

VOC: < 0.019
NOx: < 0.034

24


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TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Improved Public Transit
-Express Bus
-Paratransit
-Shuttle Circulators
-Coordinated Fare

o

CO

tr,

O

118,000 -707,000

VOC: 0.094-0.566
NOx: 0.165 -0.990

Activity Centers
-Multi-modal Transfer Centers
-Remote Parking
-Incident/Congestion Response

0.1 -0.2

24,000 - 47,000

VOC: 0.019-0.038
NOx: 0.034-0.066

Smart Growth
-Infill Development
-Transit Oriented Development
-Mixed-Use Development

0.1 - 8.8

24,000 - 2,074,000

VOC: 0.019- 1.659
NOx: 0.034-2.904



Total

VOC: 0.293 - 3.772
NOx: 0.515 - 6.601

25


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Table 5. Washington, DC-MD-VA - Potential Emission Reductions from Transportation Control Measures (TCMs)

TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Emplover-based TDM
-Van/Car Pools
-Mid-day Shuttles
-Parking Cash-Out
-Guaranteed Ride Home
-Transit Subsidy
-Telecommuting

0.2-3.5

267,000 - 4,666,000

VOC: 0.160 -2.800
NOx: 0.240-4.199

Area-Wide Rideshare
-Park and Ride
-Ride Matching
-Transportation Management
Assoc.

-Van-Pool Subsidy/Insurance

0.1 -0.2

133,000 -267,000

VOC: 0.080 -0.160
NOx: 0.120-0.240

Parkins Management
-Preferential Parking for HOV
-Parking Pricing
-Zoning Requirements
-Commercial Vehicle
Management

0.5-4.2

667,000 - 5,599,000

VOC: 0.400 -3.359
NOx: 0.600 - 5.039

Bicvcle/Pedestrian Proerams
-Designated Lanes/Routes
-Safety Enhancements
-Transit Support Facilities

<0.1

< 133,000

VOC: < 0.080
NOx: <0.120

26


-------
TCM Category

Regional VMT Reduction
(% Range)

Regional Daily
VMT Reduced

Emissions Reduced
(Tons per Day)

Improved Public Transit
-Express Bus
-Paratransit
-Shuttle Circulators
-Coordinated Fare

o

CO

tr,

O

667,000 - 3,999,000

VOC: 0.400-2.399
NOx: 0.600 - 3.599

Activity Centers
-Multi-modal Transfer Centers
-Remote Parking
-Incident/Congestion Response

0.1 -0.2

133,000 -267,000

VOC: 0.080-0.160
NOx: 0.120-0.240

Smart Growth
-Infill Development
-Transit Oriented Development
-Mixed-Use Development

0.1 - 8.8

133,000 - 11,730,000

VOC: 0.080-7.038
Nox: 0.120- 10.557



Total

VOC: 1.240 - 15.996
NOx: 1.860 - 23.994

27


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Table 6. Comparison of Potential TCM Emission Reductions to Emission Reductions Needed for Attainment

Nonattainment Area

Reductions Needed

Potential Reductions

TCM reductions as a Percent



for Attainment (TPD)

from TCMs (TPD)

of Total Reductions Needed

Atlanta, GA

VOC - 331

VOC - 11.38

VOC-3.4%



NOx- 156

NOx - 17.07

NOx - 11%

Greater Connecticut

VOC - 176

VOC-2.21

VOC - 1.3%



NOx - 158

NOx - 5.48

NOx-3.5%

Springfield, MA

VOC - 62

VOC - 2.03

VOC-3.3%

(Western MA)

NOx - 44

NOx - 3.56

NOx-8.1%

Washington, DC-MD-VA

VOC - 167

VOC - 8.62

VOC - 5.2%



NOx - 191

NOx - 12.93

NOx - 6.8%

28


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ATTACHMENT 2
STATIONARY SOURCE ANALYSIS

29


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September 14, 2000

This attachment contains the results of an analysis of pollutant emissions and control measures for the
Atlanta, Georgia; Greater Connecticut; Springfield, Massachusetts; and Washington, DC serious
ozone nonattainment areas.

The purpose of this analysis is to evaluate ozone season oxides of nitrogen (NOx) and volatile organic
compounds (VOC) emission levels and their relationships to the application of current and anticipated
control measures expected to be implemented in each of these four areas. This analysis was performed
to provide EPA with data to support their determination if additional Reasonably Available Control
Measures (RACM) are available in these areas after adoption of the control measures required by the
Clean Air Act (CAA) or proposed in State Implementation Plans (SIPs).

The 2007 emission estimates used in this analysis were developed by E.H. Pechan & Associates, Inc.
(Pechan) under a contract for EPA to support the Tier 2 motor vehicle rulemaking. These national
inventories contain emission estimates for electricity generating units (EGUs), on-road mobile,
non-EGU point, stationary area, and nonroad sources. The 2007 projection year inventory was
prepared by applying growth and control assumptions to the 1996 National Emissions Trends (NET)
base year inventory. For all the non-EGU point source and stationary area sectors, emissions growth
was estimated utilizing Bureau of Economic Analysis Gross Product growth factors at the State level by
2-digit Standard Industrial Classification code. Controls assumptions included implementation of all
federal CAA required programs as applicable including: Title m Maximum Achievable Control
Technology (MACT), Title I Reasonably Available Control Technology (RACT), and Control
Technique Guidelines (CTG). Controls for the Tier 2 motor vehicle standards and the NOx

30


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SIP Call are also included in the 2007 emission estimates. The details of the development of the
emission inventories (including growth and control assumptions) are provided in Procedures for
Developing Base Year and Future Year Mass and Modeling Inventories for the Tier 2 Final
Rulemaking, E.H. Pechan & Associates, Inc., September 1999.

In essence, the analysis provides an assessment of the source categories that are not controlled in each
area by 2007, either through adoption of the control measures required by the CAA or through those
proposed in the SIPs. The emission source categories evaluated in this study include all categories
except electric generating units (EGU), point source combustion, on-road mobile, nonroad, and
biogenics sources (i.e., the analysis focuses on stationary area sources and non-combustion point
sources only). The analysis considers only 2007 ozone season daily NOx and VOC emission estimates
since these pollutants are the main precursors of ozone. Note that 2007 is not the proposed attainment
date for the four areas and the NOx and VOC emission estimates utilized for this analysis do not match
the post-control emission inventories provided in the State submitted SIPs for each area.

Table 1 provides a listing of the stationary area source and non-combustion point source categories that
were determined to have either CAA or SIPs control requirements by 2007. Control measures are
required in these categories in severe ozone nonattainment areas through federal rules, MACT, RACT,
CTG, and anticipated SIP requirements. In most cases, the controlled categories were defined at the
tierl+tier2+tier3 level. Where necessary and/or possible, control categories were defined at the SCC
and/or nonattainment area level.

The results are presented in nine summary tables. Tables 2 through 5 present Tier 3 emission
summaries for ozone season daily tons of NOx and VOC for each of the four areas. The columns
labeled "1996 " provide emission estimates from the 1996 National Emissions Trends Inventory (NET)
developed by EFIG. The columns labeled "2007 " provide 2007 emission estimates that include
emissions from ALL sectors. The columns labeled "2007 Sectors" include ONLY emissions from the
source sectors under consideration in this analysis (all except: EGU, combustion non-EGU, on-road
mobile, nonroad, and biogenic). The columns labeled "2007 Uncontrolled" include emissions from the
source sectors that are under consideration in this analysis AND are not listed as controlled in the
"2007 " summaries (see Pechan 1999 above for details of the controls included in the 2007 emission
inventory).

The columns labeled "2007 % Remaining " show the percentage of VOC and NOx emissions that
remain in uncontrolled categories. For example, the two right most columns in Table 2 shows that in
the Atlanta ozone nonattainment area 19% of VOC and 10% of NOx are emitted from source
categories that are expected to be uncontrolled in 2007. Similar results are found in the Greater
Connecticut and the Springfield Massachusetts nonattainment areas (about 20% VOC and 10% NOx
remaining). The Washington, DC nonattainment area shows that in total 8% of VOC and 7% of NOx
are expected to be remaining. The largest uncontrolled VOC category in all areas is solvent utilization
surface coating.

31


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Tables 6 and 7 list the Tier 3 categories and emissions in each area that account for 80% of the
uncontrolled VOC and NOx emissions, respectively. Tables 8 and 9 provide emissions by source
classification code (SCC) for the Tier 3 categories shown in Table 6 and 7 (i.e., source categories in
each area that account for 80% of the uncontrolled emissions).

Tables 10 through 17 provide the detailed VOC and NOx emission estimates for the "2007
Uncontrolled" sources listed in Table 6 and 7. These tables provide point source level details and
include sector type (stationary area or point source), state codes, county codes, plant names, plant and
point id's, SCC, and SCC descriptions. Tables 10 through 13 provide this information for VOC for
Atlanta, Georgia; Greater Connecticut; Springfield, Massachusetts; and Washington DC, respectively.
Tables 14 through 17 provide the detailed information for NOx for the same four areas.

[The tables cited above are found in separate Excel spreadsheet file; name: result_tables.xls]

32


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ATTACHMENT 3

GEORGIA ANALYSIS OF ADDITIONAL MEASURES IN SUPPORT OF GASOLINE

FUEL WAIVER.

(available electronically in separate file: RACMatt3.pdf)

33


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ATTACHMENT 4

MODEL SENSITIVITY STUDY FOR METROPOLITAN WASHINGTON AREA

(available only in docket for Metropolitan Washington Area)

34


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A.	Washington Area Ozone Sensitivity Modeling

The air quality modeling using the Urban Airshed Model (UAM-TV) was submitted with the attainment
demonstration that included modeling of the post-1996 plan and sensitivity runs that looked at the air
quality effects of reductions beyond the post-1996 plan.

Several scenarios were developed. The base case "base bs2A2b" effectively modeled the post-1996
plan with OTAG Run I boundary conditions. The sensitively run SI A2b furthered reduce NOx
emissions from point sources by 60%. In addition to a 60% reduction in NOx point source emissions
in case S1A2B, case S2A2b reduced NOx emissions from mobile and area sources by 30%. Case
S3A2b contains the emission reductions in case SI A2b plus an additional 30% reduction in both area
and mobile sources. Because point source VOC emissions are so small (less than 4% of the manmade
emissions) in the Metropolitan Washington, DC area, the UAM model would not be expected to
respond to even a 100% reduction. Therefore, no sensitivity modeling was performed for point source
VOC emissions. The results of the sensitivity modeling are located in Tables 7-2 through 7-4 starting
on page 25 in appendix C of the April 10, 1998 attainment plan submittal entitled State
Implementation Plan (SIP) Revision, Phase II Attainment Plan for the Washington DC-MD-
VA Nonattainment Area —Appendices.

B.	Analysis

Table 1 below provides a summary of the modeling results and effects of the sensitivity run case
reductions on the inventory. The modeling results include the peak ozone concentrations and grid cells
over 125 ppb in the Washington, DC sub-domain. For each episode day the following are calculated:

The peak ozone decrease in ppb.

The decrease in NOx or VOC emissions in tons per day.

The response of ozone concentrations to reductions, the "ozone response", in ppb per ton
reduced. This is the total peak ozone decrease divided by the reductions modeled.

For sensitivity case SlA2b (60% reduction in point source NOx emissions from the base case) the
"ozone response" is calculated versus the change in ozone relative to the base case bs2A2b.

For sensitivity case S2A2b (SlA2b plus an additional 30% NOx reduction from base bs2A2b in
mobile non-road and on-road and area sources) two response factors are calculated: One is relative to
the inventory and ozone predictions of sensitivity case SlA2b. the second is relative to the inventory
and change in ozone relative to the base case bs2A2b. The latter "Ozone response" considers the

35


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combined effects of the additional 60% reduction in NOx emissions from point sources and an
additional 30% reduction in NOx from area and mobile sources.

For sensitivity case S3A2b (SlA2b plus an additional 30% VOC reduction from the base case in both
area and mobile emissions) reduction the response is calculated versus the change in ozone relative to
the sensitivity case SlA2b (additional 60% reduction of NOx from point sources from the base case).

C. Results

The results are as follows:

Sensitivity case SlA2b (additional 60% reduction of NOx from point sources) shows a slight "ozone
response" relative to the base case bs2A2b in the range of 0.013 to 0.056 ppb per ton of NOx
reduced. The number of cells over 125 ppb increased or decreased slightly depending upon the
episode day.

Sensitivity case S2A2b (case SlA2b plus additional 30% reduction of mobile and area NOx sources
)results in an a "ozone response" relative to the case SlA2b in the range of 0.083 to 0.120 ppb per ton
of NOx reduced. The number of cells over 125 ppb decreased dramatically on all episode days.
Considering the effects of the overall NOX reductions (60% from point sources and 30% from other
sources) represented in case S2A2b, the "ozone response" is lower ranging from 0.048 to 0.088 ppb
per ton reduced due to the effect of less effective point source emission reductions.

Sensitivity case S3A2b (case SlA2b plus additional 30% reduction of mobile and area VOC sources
NOx from point sources) results in an a "ozone response" relative to the case SlA2b in the range of
0.021 to 0.029 ppb per ton of VOC reduced. The number of cells over 125 ppb decreased on all
episode days. The lack of modeling of just VOC emission reductions of from mobile and area sources
of 30%) from the base case bs2A2b without the additional 60% reduction from NOx point sources by
is a drawback. However, because the response to reductions from NOx point sources is relatively
small, the response to just VOC reductions of 30% from the base case bs2A2b would probably be
similar.

E. Conclusions

Thus, for the Washington, DC area, the modeling indicates that NOx emission reductions are generally
more beneficial in reducing ozone concentrations, suggesting that the area my be NOx limited.

When the maximum ozone response for VOC controls (.029 ppb/ton VOC) is applied to the potential
additional VOC emission reductions in the D.C. area due to RACM (10.2 % or approximately 17
tons/day), the result is an ozone benefit of only .49 ppb.

36


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37


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Table 1: Summary of Sensistiveity Model Runs and Analysis

A.

Modeling Inventory Attainment Plan











voc

NOx













Point

12.6

174













Area

152.3

53.3













non-road

70.4

92.3













On-Road

123.5

205















358.8

524.6



























Modeling Results (Base bs2A2b)

Episode 3

Episode 3b









Iuly 19, 1991

July 20, 1991

July 16, 1991







Peak Value

138.82

178.49

150.07

ppb







Cells over 125 ppb

59

365

237



Results of sensitivity runs

B.

SI A2b Additional 60% reduction from base bs2A2b in NOx point sources









VOC

NOx













Point

12.60

69.60

Modeled Peak
Value

137.44

172.69

148.67

ppb



Area

152.30

53.30

Cells over 125 ppb

52

361

241





non-road

70.40

92.30

Ozone decrease

1.38

5.80

1.40

ppb



On-Road

123.50

205.00

Reductions

104.4

104.4

104.4

tons NOx





358.80

420.20

Ozone response

0.013

0.056

0.013

ppb/ton versus Base bs2A2b



















C.

S2A2b (SlA2b plus an additional 30% NOx reduction from base bs2A2b in mobile (non-road
and on-road) and area sources)





1. Relative to sensitivity run SlA2b











Ivor Inox 1









38


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Point

12.60

69.60

Modeled Peak
Value

125.32

160.08

139.93

ppb



Area

152.30

37.31

Cells over 125 ppb

1

216

127





non-road

70.40

64.61

Ozone decrease

13.50

18.41

10.14

ppb



On-Road

123.50

143.50

Reductions

105.18

105.18

105.18

tons NOx





358.80

315.02

Ozone response

0.115

0.120

0.083

ppb/ton of NOx versus SlA2b





















2. Relative to base bs2A2b













VOC

NOx













Point

12.60

69.60

Modeled Peak
Value

125.32

160.08

139.93





Area

152.30

37.31

Cells over 125 ppb

1

216

127





non-road

70.40

64.61

Ozone decrease

13.50

18.41

10.14





On-Road

123.50

143.50

Reductions

209.58

209.58

209.58







358.80

315.02

Ozone response

0.064

0.088

0.048

ppb/ton versus Base bs2A2b



















D.

S3A2B( SlA2b plus an additional 30% VOC reduction from base bs2A2b in mobile (non-road and on-road) and area sources





VOC

NOx













Point

12.60

69.60

Modeled Peak
Value

135.3

170.51

145.62

ppb



Area

106.61

53.30

Cells over 125 ppb

42

347

189





non-road

49.28

92.30

Ozone decrease

2.14

2.18

3.05

ppb



On-Road

86.45

205.00

Reductions

103.86

103.86

103.86

tons VOC





254.94

420.20

Ozone response

0.021

0.021

0.029

ppb/ton of VOC versus SlA2b



















ATTACHMENT 5

39


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RECALCULATION OF EMISSION REDUCTIONS NEEDED FOR ATTAINMENT FOR ATLANTA

(available electronically in separate file: RACMatt5.pdf)

40


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ATTACHMENT 6
SOUTHERN OXIDANTS STUDY
1993 DATA ANALYSIS WORKSHOP REPORT
(excerpt)

(available electronically in separate file: RACMatt6.pdf)

41


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