# Bryan W. Shaw, Ph.D., 

# Chairman

Buddy Garcia, 

# Commissioner

Carlos Rubinstein, Commissioner 

# -



# .

:

# ~~·.-> .:.\ \ .: 

# I·

# !d:~ 

# fJLr.;·u:i: . !·



# Mark R. 

# Vickery, P.G., 

# Executive Director 

# 10 APR -9 Pii 

# 1:55

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Protecting Texas bg Reducing and Preventing Pollution 

# April6,2010

Docket No. 2009-0802-SIP, Project No. 2009-017-SIP-NR**~** 

# Docket No. 2009-0932-RUL, Rule Project No. 2009-006-101-EN

·

Docket No. 2009-0867-RUL, Rule Project No. 2009-019-101-EN

A1 Armendariz, PhD, Regional Administrator

U.S. Environmental Protection Agency- Region 6



# 1445 Ross Avenue

Dallas, Texas 75202-2733

.

Dear Dr. Armendariz:

On March 10, 2010, the Texas Commission on Environmental Quality (Commission) adopted revisions to 

# the

State Implementation Plan (SlP) for the control of ozone air pollution for the Houston-Galveston-Brazoria

(HGB) 

# area.

The Commission adopted amendments to 

# 30 Texas Administrative Code (TAC) Chapter 101, Subchapter A,

General Rules, Section 101.1; and Subchapter H, Emissions Banking and Trading, Division 6, Highly Reactive

Volatile Organic Compound Emissions Cap and 

# Trade Program, 

# Sections 101.390

- 101.394, 101.396, and



# 101.399

- 101.401; 30 TAC Chapter 101, Subchapter H, 

# Emissions Banking and Trading, Division 3, Mass

Emissions C and 

# Trade Pro 

# Sections 101.350 101.351 and 

# 101.353 and co · revisions to the

SlP; and 

# GB Attsinment Demonstration SlP Revision for the 1997 Ei t-Hour Ozone Standard. These rule

changes and SIP revisions demonstrate that the HGB area 

# will attain the 

# 1997 eight-hour ozone National

Ambient Air 

# Quality Standard by June 15, 2019.

Enclosed are 

# the proposed revisions to the SlP, a public hearing certification, a 

# complete record of the public

hearings, and the accompanying orders.· I 

# look forward to your expeditious approval of these SlP revisions.

Sincerely, 

# B**~,;ktw.--·**

# B~haw,PhD.

Chairman

BWS/jmm

Enclosures

cc: The Honorable Rick Perry, Governor ofTexas

Mr. Toby Baker, Office ofBudget, Planning and Policy, Office of the Governor

Mr. Mark 

# R Vickery, P.G., Executive Director, Texas Cor!unission on Environmental Quality

P.O. Box 13087 Austin, Texas 78711-3087 512-239'1000 1ntemet address: www.tceq.state.tx.us

# Texas Commission on Environmental Quality

Public Hearings

Odober 28-29, 2009

Houston-Galveston-Brazoria (HGB)

Attainment Demonstration SIP Revision

for the 1997 Eight-Hour Ozone Standard

Projed Number 2009-017-SIP-NR

Volume 2 of2

# REVISION TO THE STATE IMPLEMENTATION PLAN

FOR THE CONTROL OF OZONE AIR POLLUTION

HOUSTON-GALVESTON-BRAZORIA 1997 EI GHT-HOUR OZONE STANDARD

NONATTAINMENT AREA

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

P.O. BOX 13087

AUSTIN, TEXAS 78711-3087

Houston-Galveston-Brazoria Attainment Demonstration

State Implementation Plan Revision for the 1997 Eight-Hour Ozone Standard

PROJECT NO. 2009-017-SIP-NR

Adopted

March 10, 2010

# xv LIST OF APPENDICES

Appendix Appendix Name

Appendix A Meteorological Modeling for the HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix B Emissions Modeling for th e HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix C Photochemical Modeling for the HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix D Reasonably Available Control Technology Analysis

Appendix E Reasonably Available Control Measure Analysis

Appendix F Evaluation of Mobile Sour ce Control Strategies for the HoustonGalveston-Brazoria State Implementation Plan (With Detailed

Strategies), Prepared for Houston-Galveston Area Council, Prepared by

ENVIRON International Corporation

Appendix G Transportation Control Measures for the HGB Attainment

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

(Excerpt from Evaluation of Mobile Source Control Strategies for the

Houston-Galveston-Brazoria State Implementation Plan), Prepared for

Houston-Galveston Area Council, Prepared by ENVIRON International

Corporation

Appendix H Voluntary Mobile Emission Reduction Program for the HGB Attainment

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

(Excerpt from Evaluation of Mobile Source Control Strategies for the

Houston-Galveston-Brazoria State Implementation Plan), Prepared for

Houston-Galveston Area Council, Prepared by ENVIRON International

Corporation

Appendix I Corroborative Analysis for th e HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix J Recommendations for Best Ma nagement Practices to Control and

Reduce Inadvertent Cargo Vapor Emissions in the Tank Barge

Community

# APPENDIX E

REAS ONAB LY AVAIL ABLE CONTROL MEASURE ANALYSIS

# APPENDIX E

REAS ONAB LY AVAIL ABLE CONTROL MEASURE ANALYSIS

INDEX

Description Page

Section 1.0 Introduction 3

Section 2.0 Control Strategy Development Process 3

2.1 Stationary Sources 3

2.2 On-Road and Non-Road Mobile Sources 4

Section 3.0 RACM Evaluation Approach 4

Section 4.0 Stationary Source RACM Determination and Discussion 5

4.1 General Discussion 5

4.2 NO X 

# RACM Analysis 5

4.3 VOC RACM Analysis 7

4.4 RACM Analysis on Control Measures Outside the HGB Area 8

Section 5.0 On-Road and Non-Road M obile Source RACM Determination 10

Table E-1 HGB Area Stationary Source RACM Analysis 11

Table E-2 HGB Area On-Road and Non-Road Mobile Source RACM Analysis 42

Attachment 1 Control Strategy Planning Draft Initial Concept Lists Presented to Stakeholders 55

E-1

# REASONAB LY AVAIL ABLE CONTROL MEASURE ANALYSIS

1.0 Introduction

The Houston-Galveston-Brazoria eight-hour ozone nonatta inment area (HGB area) is currently classified

as a severe nonattainment area for the United States Environmental Protection Agency (EPA) eight-hour

ozone National Ambient Air Quality Standards (NAAQS ). Under the eight-hour ozone standard, the

HGB area is required to meet the mandates of th e Federal Clean Air Act (FCAA) under §§172(c)(1),

182(b)(2), and 182(f). Section 172(c)(1) of the FCAA requires states to provide for implementation of all

reasonably available control measures (RACM) as ex peditiously as practicable and to include RACM

analyses in the state implementation plan (SIP). In the General Preamble for implementation of the

FCAA Amendments published in the April 16, 1992, issue of the Federal Register (57 FR 13498), the

EPA explains that it interprets FCAA, §172(c)(1) as a re quirement that states incorporate into their SIP all

RACM that would advance a region’s attainment date. However, states are obligated to adopt only those

measures that are reasonably available for implementati on in light of local circumstances. In the general

preamble, the EPA provided guidelines to help stat es determine which measures should be considered

reasonably available:

If it can be shown that one or more meas ures are unreasonable because emissions from

the sources affected are insignificant (i.e. de minimis), those measures may be excluded

from further consideration... the resulting av ailable control measures should then be

evaluated for reasonableness, considering their technological feasibility and the cost of

control in the area to which the SIP app lies...In the case of public sector sources and

control measures, this evaluation should c onsider the impact of the reasonableness of the

measures on the municipal or other government entity that must bear the responsibility

for their implementation.

On July 2, 2002, the United States Court of Appeals upheld the EPA’s definition of RACM, including the

consideration of economic and technological feasibility , ability to cause substantial widespread and longterm adverse impacts, collective ability of the measures to advance a region’s attainment date, and

whether an intensive or costly effort will be required to implement the measures.

2.0 Control Strategy Development Process

2.1 Stationary Sources

The Texas Commission on Environmental Quality (TCEQ) used a two-step process to develop the list of

potential stationary source control strategies evalua ted during the RACM analysis. First, the TCEQ

compiled a list of potential control strategy concepts based on an initial evaluati on of the existing control

strategies in the HGB area and existing sources of volatile organic compounds (VOC) and nitrogen oxides

(NO X 

# ) in the HGB area. The EPA allows states the opti on to consider control measures outside the ozone

nonattainment area that can be shown advance attain ment; however, consideration of these sources is not

a requirement of the FCAA. Sources of VOC within 100 kilometer (km) of the HGB area and sources of

NO X 

# within 200 km of the HGB area were also consider ed for this initial evaluation. A draft list of

potential control strategy concepts was developed from this initial evaluation. The draft list of potential

control strategy concepts was presented to stakeholde rs for comment at stakeholder meetings held in the

HGB area on March 25 and 26, 2008. The TCEQ requested comment on the potential control strategies

and invited stakeholders to suggest any additional st rategies that might help advance attainment of the

HGB area. The final list of potential control strategy concepts for RACM analysis includes the strategies

presented to stakeholders in March 2008 and the strategies suggested by stakeholders during the informal

E-2

# stakeholder comment process. Table E-1: HGB Area RACM Analysis presents t h e final list of potential

control measures for stationary sources as well as the RACM determination for each measure.

2.2 On-Road and Non-Road Mobile Sources

The control strategy development process to identify potential control strategies for RACM analysis of

on-road and non-road mobile sources was similar to th e process used for the stationary sources. A draft

list of potential control strategy concepts was pres ented to stakeholders for comment at stakeholder

meetings held in the HGB ozone nonattainment area on March 25 and 26, 2008. The TCEQ requested

comment on the potential control strategies and invited stakeholders to suggest any additional strategies

that might help advance attainment in the HGB area. The final list of potential control strategy concepts

for RACM analysis includes the strategies presented to stakeholders in March 2008 and the strategies

suggested by stakeholders during the informal stakeholder comment process. Table E-2: HGB Area OnRoad and Non-Road Mobile Sources RACM Analysis presents the final list of potential control measures

for on-road and non-road mobile sources as we ll as the RACM determination for each measure.

In addition to the draft list developed by the TCEQ, the Houston-Galveston Area Council (H-GAC) and

its subcontractor developed a master list of mobile c ontrol strategies. This master list was narrowed down

to those deemed of most interest to H-GAC and its stakeholders, and additional measures were suggested.

ENVIRON and its subcontractors then reviewed the remaining master list strategies to estimate their

applicability and potential for inclusion in the SIP. On ce this analysis was completed and a draft short list

of quantified mobile control measures was assembled, further meetings were held to gauge additional

stakeholder perspectives. A summary of the stak eholder meetings and written comments received, as

well as an analysis of each short list mobile measure considered for analysis and quantification can be

found in Appendix F: Evaluation of Mobile Source Control Strategies for the Houston-GalvestonBrazoria State Implementation Plan . The measures committed to by the H-GAC are found in Chapter 4

of this SIP revision under Transportation Control Measures and Vo luntary Mobile Emission Reduction

Measures

.

3.0 RACM Evaluation Approach

Each control measure identified through the contro l strategy development process was evaluated to

determine if the measure would meet established criteria to be consid ered reasonably available. The

TCEQ used the general criteria specified by the EPA in the recent proposed approval of the New Jersey

RACM analysis published in the January 16, 2009, issue of the Federal Register (74 FR 2945):

RACM is defined by the EPA as any potentia l control measure for application to point,

area, on-road and non-road emission source categor ies that meets the following criteria:

• The control measure is technologically feasible

• The control measure is economically feasible

• The control measure does not cause ‘‘substantial widespread and long-term

adverse impacts’’

• The control measure is not ‘‘absurd, unenforceable, or impracticable’’

• The control measure can advance the attainment date by at least one year.

The EPA did not provide guidance in the Federal Register on how to interpret the criteria "advance the

attainment date by at least one year." Because modeling all possible year scenarios for potential control

measures is not practical, the TCEQ evaluated whet her a potential control measure would help the HGB

area make progress toward attainment of the NAAQS based on potential eight-hour ozone reduction

benefit in terms of parts per billion (ppb) using m odeling sensitivity runs.

E-3

# The TCEQ also considered whether the potential c ont rol m easure could be implemented before and

reduce emissions prior to the beginning of the ozone s eason immediately before the attainment date. The

attainment date for the 1997 eight-hour ozone NAAQS for the HGB area is June 15, 2019, so suggested

control measures that could not be implemented by January 1, 2018, were not considered RACM because

the measures would not advance attainment. However, the HGB area must make progress toward

attainment of 1997 eight-hour ozone NAAQS as exped itiously as practicable. Therefore, if control

measures can be implemented earlier than January 1, 2018, and will help the area make progress toward

attainment of the NAAQS earlier than the attainment year, the measure should be implemented as early as

feasible.

The TCEQ also considered whether the control meas ure was similar or identical to control measures

already in place in the HGB area. If the suggested control measure would not provide substantive and

quantifiable benefit over the existing control measure, then the suggested control measure was not

considered RACM because reasonable controls were already in place.

4.0 Stationary Source RACM Determination and Discussion

4.1 General Discussion

Based on the RACM analysis, the TCEQ determined that only one potential control measure met the

criteria to be considered RACM. A reduction in the highly reactive volatile organic compounds

(HRVOC) cap for Harris County under the HRVOC Emission Cap and Trade (HECT) program was

determined to help advance attainment of the HGB area and to meet the other RACM criteria. See

Section 4.3.2 of this appendix for additional deta il on the RACM analysis of reducing the HRVOC cap

for Harris County. All other potential control measur es evaluated for stationary sources were determined

to not be RACM due to technological or economic feasibility, enforceability, adverse impacts, or ability

of the measure to advance attainment of the NAAQS. The complete list of stationary source potential

control measures and the RACM determ ination are included in Table E-1: HGB Area Stationary Source

RACM Analysis of this appendix.

4.2 NO X 

# RACM Analysis

4.2.1 Mass Emission Cap and Trade (MECT) Program and Chapter 117 NO X 

# Rules RACM

The NO X 

# MECT program and accompanying Chapter 117 rules represents one of the most

comprehensive NO X 

# control strategies in the nation and was the primary control measure the HGB onehour ozone attainment demonstration. The NO X 

# MECT program encompasses the majority of stationary

NO X 

# sources in the HGB area. In determining whet her further reductions through the MECT program

were feasible and satisfied the criteria to be considered RACM, the TCEQ first evaluated the

technological feasibility of additional NO X 

# reductions from sources currently subject to the MECT

program. This evaluation included reviewing the original emission specifications for attainment

demonstration (ESAD) adopted by the commission in December 2000 as part of the nominal 90 percent

control level planned for the HGB one-hour ozone attainment demonstration SIP revision. The TCEQ

also considered any new NO X 

# control technological advances that have occurred since 2000. The TCEQ

evaluated further NO X 

# reductions through the MECT program on an economic, technological, and

practicality basis. Practicality is considered a RACM evaluation criterion by the EPA. Revising NO X 

# allowances under the MECT program presents signi ficant practicality issues because the program has

been in place since 2002 and allowance streams have b een traded and relied upon for compliance with the

program. Reallocation of NO X 

# allowances would be necessary if allowance streams were reduced

through implementing this potential control measure.

E-4

# The TCEQ's evaluation of sources currently subject to the MECT program indicates that further

reductions in the NO X 

# MECT allowances would be possible from a technological feasibility perspective.

Allowances for specific source categories could be re duced by lowering the emission specifications for

those categories that further NO X 

# control was determined to be potentially technologically feasible.

Based on this approach, the TCEQ estimates that the NO X 

# MECT cap for existing sources might be

reduced by approximately 53 tons per day (tpd). The control technologies assumed depended on the

specific category of equipment; however, ultra-low NO X 

# burners, selective catalytic reduction (SCR), and

low-temperature oxidation (LoTOxTM) are the primary control technologies that would be necessary to

achieve the required reductions. Further NO X 

# control was determined to not be technologically feasible

for some source categories in the MECT program, su ch as coal-fired boilers, liquid-fired boilers, and

lean-burn gas-fired stationary internal combustion engi nes. For example, the four coal-fired utility boilers

in the HGB area are all equipped with SCR and the reported historic NO X 

# emissions data for these units

indicates that further NO X 

# reductions may not be technologically feasible.

The TCEQ then evaluated the economic impact of implementing controls necessary to reduce the NO X 

# MECT cap by the estimated 53 tpd. The total capital cost was estimated to be at least $2.2 billion. This

is a conservative estimate for capital costs; using higher range estimates for capital costs would raise the

total capital costs to approximately $3.2 billion. Tota l costs for the first five years, including increased

annual operating costs, were estimated to range from $4.1 to $5.4 billion. The overall cost effectiveness

of this potential control measure would be at least $41,700 per ton on a five year basis and could exceed

$55,000 per ton. This economic analysis is based on the number and type of units estimated to need

installation of NO X 

# controls. The number and type of units potentially needing NO X 

# controls was

determined using the active units in the 2006 point source emissions inventory and the reported emission

factors. The TCEQ used cost information from EPA documents, vendor information, and cost estimates

used in prior TCEQ rule proposals to estimate the capital and annual operating costs of the NO X 

# control

technology. Additionally, based on the TCEQ's research, ultra-low NO X 

# burners are only available for

natural gas-fired units. This represents a technologica l feasibility problem for the installation of ultra-low

NO X 

# burners on any boilers or process heaters that use alternative gaseous fuels such as recovered waste

gas streams.

It is important to note that this economic cost e ffectiveness estimate cannot be directly compared to the

historic costs of MECT allowance stream trades, i.e., permanent trades of annual NO X 

# allowances,

because the costs of allowance stream trades represent one time costs. For example, a stream trade of

MECT NO X 

# allowances made at $100,000 per ton when ev aluated on a five-year basis would only be

$20,000 per ton. The installation of NO

X 

# control technology has recurring annual operating costs that

continue out in the future and can be extremely high for some technologies such as selective catalytic

reduction. The cost estimates for gas fired utility tu rbines used in the economic analysis were the high

cost per ton estimate and exceeded $111,000 per ton on fi ve year basis. The co st effectiveness for the

same category was $101,000 per ton on a 15-year basis, and $81,000 per ton on a 25-year basis. The

annualized cost effectiveness of a one time cost of a MECT allowance stream decreases rapid when

annualized over time. The same $100,000 per ton MECT allowance stream trade on a 15-year and 25-

year basis would be $6,667 per ton and $4,000 per ton, respectively.

Based on this analysis, further NO X 

# reductions were not economically feasible for the majority of sources

subject to the MECT program. Some individual source categories in the MECT program were more cost

effective than the overall estimate of $41,700 per ton. However, reductions in NO X 

# allowances from

those categories considered to be cost effective on a category by category basis were not sufficient to

have a measurable impact on advancing attainment of the area while still considering the practical

implications of reallocating of portions of the NO X 

# MECT program. Less than 3 tpd reduction in NO X 

# allowances, or about a two percent reduction in th e cap, would be possible from source categories that

E-5

# further NO X 

# reductions could reasonable be expected to have a cost effectiveness less than $10,000 per

ton. Therefore, the TCEQ determined that this potential control measure was not RACM.

4.2.2 NO X 

# Reductions from Sources Currently Exempt from the MECT Program

The TCEQ evaluated the potential benefits and cost s associated with revoking exemptions for certain

source categories in the Chapter 117 rules and requiring reductions from those categories. The categories

of exempt units considered include:

 Flares

 Incinerators with design capacities less than 40 million British thermal units per hour

(MMBtu/hr)

 Chemical processing gas turbines

 Ovens, dryers, and heaters

 Glass furnaces

 Nitric acid manufacturing units

 Sulfuric acid manufacturing units

 Metallurgical furnaces with design capacities less than 20 MMBtu/hr

 Electric arc furnaces

 Space heaters

 Kilns and calciners

 Emergency engines

 Engine testing facilities and test cells

 Miscellaneous other (vents, fugitives, etc)

Reasonable NO X 

# controls are already in place for glass fu rnaces and nitric acid manufacturing units, and

further NO X 

# reductions from these categories are not tec hnologically feasible. The glass furnace located

in the HGB area already has stringent NO X 

# emission limits established through the site's TCEQ New

Source Review permit (see Appendix D: Reasonably Available Control Technology Analysis , Section

3.2.2). The nitric acid facilities are an insignificant source of NO X 

# emissions with less than 0.3 tpd

reported in the 2006 point source emissions inventory. These nitric acid facilities are already equipment

with SCR technology, which represents the best possi ble control level for nitric acid manufacturing.

Therefore, additional reductions from nitric acid manufacturing facilities in the HGB ozone

nonattainment area are not technologically feasible.

Electric arc furnaces, metallurgical furnaces less than 20 MMBtu/hr, sp ace heaters, kilns, calciners,

engine testing facilities, engine test cells, and miscellaneous other sources all represent insignificant

sources of NO X 

# emissions in the HGB ozone nonattainment area. The total NO X 

# emissions from all these

categories in the 2006 point source emissions invent ory were approximately 0.6 tpd. Implementing NO X 

# controls on these insignificant emission sources would not be economically feasible, in some cases is not

technically feasible, and would not result in sufficient reductions to advance attainment.

Based on the 2006 emissions inventory, flares represent approximately 45 percent of total NO X 

# emissions

from emissions inventory sources that are exempt the MECT program and Chapter 117. However, NO X 

# control on flares is not technologically feasible at this time and any reduction in NO X 

# emissions from

flares could only be made by a reduction in flarin g. Sulfuric acid manufacturing processes in the HGB

area represent an insignificant source of NO X 

# emissions and the total NO X 

# emissions from this category

in 2006 was only 0.6 tpd. Additionally, the installation of NO X 

# control technology such as SCR an

selective non-catalytic reduction (SNCR) on sulfur ic acid manufacturing units has technological

limitations due to the sulfur emissions associated with these processes. Regarding emergency engines,

the TCEQ has already adopted control measures to address NO d

X 

# emissions from emergency engines in

E-6

# Chapter 117 th roug h requirements such as the prohi bition on operation for testing and maintenance

between 6:00 A.M. and noon, and requ iring stationary diesel engines that are new, modified, relocated, or

reconstructed after October 1, 2001, to meet the EPA tier standards in 40 Code of Federal Regulations

(CFR) §89.112(a), Table 1 in order to meet exemption criteria.

Potential further NO X 

# controls on chemical processing gas tu rbines, incinerators smaller than 40

MMBtu/hr, ovens, dryers, and heaters currently exempt from Chapter 117 in the HGB area might be

technologically feasible for some unit types. The TCEQ estimated that approximately 2 tpd NO X 

# reductions would be the maximum possi ble benefit in total for all these categories. However, the cost of

implementing retrofit NO X 

# controls on these sources was estimated to be approximately $30 million and

the maximum potential ozone reduction benefit at the Deer Park monitor was less than 0.1 ppb.

Therefore, the TCEQ determined further NO X 

# controls from these exempt sources would not help

advance attainment of the NAAQS and were not RACM.

4.3 VOC RACM Analysis

4.3.1 General VOC Control Measures

Based on modeling sensitivity matrix analyses, the TC EQ determined that reductions in general VOC

emissions, i.e., non-highly reactive volatile organic compounds (HRVOC), will not advance attainment of

the HGB area. The 2018 future year matrix modeling sensitivity runs indicate that even substantial

reductions in general VOC emissions will not have a significant enough impact on ozone reduction to be

considered as RACM. The two regulatory monitors that still exceed the eight-hour ozone NAAQS in the

2018 future base case, Deer Park and Bayland Park, are insensitiv e to general VOC reductions.

Approximately 130 tpd of general VOC reductions are needed to reduce ozone at the Deer Park monitor

by 1 ppb. Approximately 230 tpd of general VOC redu ctions are needed to reduce ozone at the Bayland

Park monitor by 1 ppb. Based on this modeling an alysis, the TCEQ determined that general VOC

reduction control measures would not advance atta inment and were not RACM because even large

reductions of general VOC emissions would only result in a small ozone reduction benefit in the HGB

area. Chapter 3: Photochemical Modeling provides further information on the modeling sensitivity runs.

4.3.2 HRVOC Control Measures

The TCEQ determined that a reduction in the HRVOC cap for Harris County under the HRVOC

Emission Cap and Trade (HECT) program would help advance attainment of the HGB area and does meet

the other RACM criteria. Modeling demonstrates that a 25 percent reduction in the HRVOC cap for

Harris County will help the HGB area make progress toward attainment of the 1997 eight-hour ozone

NAAQS. Based on modeling done for proposal, the 25 percent reduction would reduce the 2018 future

eight-hour ozone design value by 0.11 ppb on average fo r all monitors and by 0.24 ppb at the Deer Park

monitor. The final modeling done for adoption shows an average ozone decrease of 0.13 ppb for the three

monitoring sites with 2018 projected eight-hour ozone design values greater than the 1997 eight-hour

ozone NAAQS, Deer Park, Bayland Pa rk, and Wallisville. The Deer Park monitor’s design value was the

highest in the HECT sensitivity modeling and the HECT sensitivity modeling showed a decrease in the

Deer Park monitor design value from 86.49 ppb to 86.36 ppb ozone. Add itionally, reported HRVOC

emissions from sources in the HECT program during the first two years of the program, calendar years

2007 and 2008, averaged approximately 56 percent of the total allocated HRVOC allowances for Harris

County. Because there is a demonstrated substantia l surplus in the HRVOC cap, a 25 percent reduction in

the cap for Harris County is technologically feasible and should have minimal economic impact. A 25

percent reduction would leave a buffer of approximately 600 tpy, or more, in the cap that should be

sufficient to account for any significant variations in HRVOC emissions in future years due to emission

events and scheduled startup, shutdown, and mainte nance events as well as allow for future economic

growth. Additional discussion regarding the propo sed control measure to reduce the HRVOC cap for

E-7

# Harris County is included in Chapter 4: Control Strat e gies and Required Elements , Section 4.6: New

Control Measures

.

The TCEQ determined that HRVOC reductions in th e seven counties surrounding Harris County were not

RACM because the measure would not advance atta inment. Prior modeling sensitivity runs conducted

for the one-hour ozone attainment demonstration show ed that HRVOC reductions in all eight counties of

the HGB area only resulted in a maximum difference of 0.1 ppb from HRVOC reductions in just Harris

County. Additional information concerning these pr ior modeling runs is available in Chapter 3:

Photochemical Modeling, Section 3.7.1: Future Case Modeling Results , of the HGB area one-hour ozone

attainment demonstration SIP revision adopted December 1, 2004.

4.4 RACM Analysis of Control Measures Outside the HGB Area

4.4.1 NO X 

# Reductions in Attainment Counties

Multiple modeling runs with NO X 

# reductions outside the nonattainment area were performed to test

different levels of NO X 

# reductions in different sectors around the nonattainment area. The sensitivity

runs show that any potential benefit from reductions in NO X 

# emissions outside the nonattainment area

would only result from reductions made east and northeast of the HGB area. A 32 tpd NO X 

# reduction

modeled for the counties east and northeast of the HG B area was projected to reduce ozone design valu

at the Deer Park and Bayland Park monitors by 0.4 and 0.2 ppb respectively. Less than 0.04 ppb

difference in future ozone design values for the D eer Park and Bayland Park monitors was modeled

between making a 32 tpd reduction in the east and nor theast counties and a 62 tpd reduction in all the

counties within 200 km surrounding the HGB area. Th is demonstrates that emissions from areas north,

northwest, west, and southwest of the nonattainment area do not have a substantive impact on ozone es

in

e HGB area.

e

ion

gy would

nd

lers

CEQ

ti es was too substantial to make

plem enting these control measures economically reasonable.

GB

uction in th

While NO X 

# emissions from sources in the counties east and northeast of the HGB appear to have som

impact on ozone in the nonattainment area, the TC EQ determined that the potential ozone reduct

benefit in the HGB area was not sufficient to ju stify the economic impact to sources outside the

nonattainment area. The TCEQ evaluated extending th e East Texas Combustion rule in 30 TAC Chapter

117 (§§117.3400 - 117.3445) to the counties east of the HGB area. This possible control strate

only result in approximately 5 tpd in NO X 

# reduction and would not be sufficient to benefit the

nonattainment area. The TCEQ estimates that to make the 32 tpd NO X 

# reductions modeled in the

sensitivity run, stringent NO X 

# controls would be required on stat ionary rich-burn gas-fired internal

combustion engines (smaller sizes than the current East Texas Combustion rule) and on industrial,

commercial, and institutional (ICI) boilers in the eastern counties closest to the nonattainment area,

specifically Hardin, Jefferson, and Orange. Requiring stationary rich-burn gas-fired engines down to 50

horsepower in the eight counties (Hardin, Jefferson, Jasper, Newton, Orange, Sabine, San Augustine, a

Tyler Counties) east and northeast of the HGB area to meet the NO X 

# control requirements in the East

Texas Combustion rule was estimated to cost approxima tely $8 million. The cost of requiring ICI boi

in Hardin, Jefferson, and Orange Counties to meet NO X 

# control requirements equivalent to low-NO X



# burner controls was estimated to co st approximately $134 million. Based on this evaluation, the T

determined that capital cost impact to sources in attainment coun

im

4.4.2 VOC Reductions in Attainment Counties

The TCEQ conducted modeling sensitivity runs to evaluate whether reductions of NO X 

# or VOC from

sources outside the nonattainment area would have suffi cient benefit to advance attainment of the H

area. A reduction of approximately 273 tpd in VOC was made in the model from selected source

classification codes of counties within 200 km of the HGB area perimeter to test the potential red

E-8

# E-9 km

k

lly feasible VOC reductions outside the nonattainment

rea would advance attainment of the HGB area.

.0 On-Road and Non-Road Mobile Source RACM Determination and Discussion

in Table E-2: HGB Area On-Road and Non-Road

obile Source RACM Analysis of this appendix. ozone inside the HGB area. While EPA guidan ce allows VOC reductions within 100 km of the

nonattainment area, the modeling sensitivity run was conducted with VOC reductions out to the 200

range to test the maximum possible benefit. Even with this significant reduction in VOC emissions

outside the nonattainment area, the sensitivity test sh ows that the ozone design values at the Deer Par

and Bayland Park monitors would only decrease by 0.09 and 0.06 ppb, respectively. Therefore, the

TCEQ determined that no amount of technologica

a

5

The complete list of on-road and non-road mobile source potential control measures and the specific

details for each RACM determination are included

MTable E-1: HGB Area Stationary Source RACM AnalysisControl Measure DescriptionPollutantPoint/AreaSourceRACM(Y/N)RACM Analysis / JustificationTCEQ Initial Control Strategy ConceptsHGB 8-County Region ControlsAdditional NOXreductions through Chapter 117 and the Chapter 101MECT program by revising emission specifications, revokingexemptions, expanding applicability, and resetting baseline activityyears.NOXPoint &AreaNFurther reductions in the NOXMECT program from existingsources are not economicallyfeasible. Reductions from exemptsources are either nottechnologically feasible or noteconomically feasible. See Section4.2 of this appendix for more detail.Expand the definition of HRVOC in §115.10 to include additional VOCspecies under the requirementsof Chapter 115 HRVOC rules andChapter 101 HECT program.VOCPoint &AreaNModeling indicates general VOCreductions will not advanceattainment.In lieu of expanding the definition of HRVOC, create separate rules toaddress other VOC emissions from vents, flares, and cooling towers.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Reduce HECT cap for Harris County in §101.394(a)(1).VOCPointYModeling indicates that reducing theHECT cap for Harris County willhelp advance attainment. SeeSection 4.3.2 of this appendix formore detail.E-10Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Revoke exemptions (§§115.727(f), 115.767(6), and 101.392(c)) fromsite-wide caps in HRVOC rules for sources in the 7-surrounding countiesand reduce cap in §101.394(a)(2).VOCPointNHRVOC sources (non-fugitiveemission sources) in the 7-surrounding counties outside HarrisCounty are alreadybelow the cap in§101.394(a)(2).Prior modeling conducting duringthe one-hour ozone attainmentdemonstration indicates thatadditional HRVOC reductions in the7-surrounding counties will notadvance attainment.Revise general VOC fugitive rules in Chapter 115 Subchapter D,Division 3 and apply more stringent leak detection and repair (LDAR)requirements from HRVOC rules.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Require sources to develop and implement flare minimization plans.VOC &NOXPointNModeling indicates general VOCreductions will not advanceattainment.The commission is continuing toevaluate flaresthrough the FlareTask Force. See Chapter 6 of thisSIP revision for more detail.E-11Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Require monitoring of steam/air assistrates on assisted flares to helpensure proper operation and prevent decreased efficiency from improperoperation such as over-steaming.VOCPointNModeling indicates general VOCreductions will not advanceattainment.TCEQ has insufficient informationat this time to determine ifmonitoring of steam/air assist ratesmeets RACM criteria.The potential impacts of steam andair assist are being evaluatedthrough the Flare Task Force. SeeChapter 6 of this SIP revision formore detail.General VOC monitoring rules with enhanced monitoring for flares,cooling towers, process vents, and pressure relief valves.VOCPointNModeling indicates general VOCreductions will not advanceattainment.The commission is continuing toevaluate flaresthrough the FlareTask Force. See Chapter 6 of thisSIP revision for more detail.Additional VOC controls for wastewater systems.VOCPoint &AreaNModeling indicates general VOCreductions will not advanceattainment.Additional VOC controls for upstream oil and gas VOC emissions.VOCPoint &AreaNModeling indicates general VOCreductions will not advanceattainment.Energy efficiency measures associated or in conjunction with MECTrevisions.NOXAreaNNot quantifiable.Not enforceable.E-12Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Eliminate certain storage tank exemptions in Chapter 115 rules.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Reasonable controls are already inplace.Storage tank design improvements such as hanging roof in lieu of roofsupported by legs.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Reasonable controls are already inplace.Increase control efficiency requirements in Chapter 115 rules such asvent gas control, loading, and storage.VOCPoint &AreaNModeling indicates general VOCreductions will not advanceattainment.Reasonable controls are already inplace.Best Management Practices via agreed orders or other mechanisms.NOX&VOCPoint &AreaNReasonable controls are already inplace. Voluntary best managementpractices already in place.Controls for portable engines such as portable generators and otherengines considered non-stationary due to temporary service.NOXAreaNUnknown technological andeconomic feasibility at this time.Emission reduction benefit notquantifiable.Controls to reduce VOC emissions from lightering on barges and marinevessels.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Lightering in ship channel istypically only done on emergencybasis. Most lightering occursoffshore.E-13Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)VOC controls for salt dome storage facilities for brinehandling/degassing and fugitive LDAR.VOCPoint &AreaNModeling indicates general VOCreductions will not advanceattainment.Refinery coker VOC emission controls.VOCPoint &AreaNModeling indicates the general VOCreductions will not advanceattainment.Field studies indicate VOCemissions from coker units are notsignificant (2007 DifferentialAbsorption Lidar Study).Engine registration program for stationary and/or portable engines tohelp ensure better enforcement of applicable requirements, improve ruleeffectiveness, and proper accounting of engines in the emissionsinventory.NOXAreaNNot quantifiable.Consumer and commercial products control techniques guidelines(CTG).Group II - lithographic printing materials, letterpress printingmaterials, flexible packaging printing materials, flat woodpaneling coatings, industrial cleaning solvents.Group III - paper, film, and foil coatings, metal furniturecoatings, large appliance coatings.Group IV - miscellaneous metal products coatings, fiberglassboat manufacturing materials, miscellaneous industrialadhesives, plastic parts coatings, auto and light duty truckoriginal equipment manufacturer coatings.VOCPoint &AreaNModeling indicates general VOCreductions will not advanceattainment.Insignificant VOC reductions.Portions of offset lithographic CTGrecommendations are beingimplemented to satisfy reasonableavailable control technology(RACT) requirements. Seeappendix D of this SIP revision formore detail.Transport Controls (Outside HGB Area)E-14Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)NOXcontrols on major sources for selected source categories within 200km range that impact the HGB area.NOXPointNNot economically feasible.Attainment county matrix sensitivityruns show insufficient benefit fromNOXreductions outside HGB tojustify economic impact.NOXcontrols on minor sources for selected source categories within 200km range that impact the HGB area.NOXAreaNNot economically feasible.Attainment county matrix sensitivityruns show insufficient benefit fromNOXreductions outside HGB tojustify economic impact.HRVOC controls for flares, vents, cooling towers, and fugitives atsources within 100 km range that impact the HGB area using the currentlist of HRVOC (ethylene and propylene) or additional VOC.VOCPoint &AreaNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Extend new upstream oil and gas flash emission, degassing, storage tankrules to sources within 100 kmrange that impact the HGB area.VOCPoint &AreaNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.NOXcontrols on engines within 200 kmrange that impact the HGB area.NOXPoint &AreaNAttainment county matrix sensitivityruns show will not advanceattainment. Expanding the currentChapter 117 East Texas Combustionrule to counties East and North Eastof the HGB ozone nonattainmentarea would result in approximately 5tpd reductions but ozone reductionbenefit would be less than 0.1 ppb.Insufficient benefit from NOXreductions outside HGB to justifyeconomic impact outsidenonattainment area.E-15Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)NOXcontrols on power plants within 200 km range that impact the HGBarea.NOXPointNAttainment county matrix sensitivityruns show insufficient benefit fromNOXreductions outside HGB tojustify economic impact toattainment counties.Coal-fired unit not located inproximity or direction to providebenefit to HGB ozone nonattainmentarea.Turbines in East sector (BPA) arealready well controlled with SCR.Gas-fired units in BPA already havereasonable controls.VOC and NOXcontrols on paper mills within 100 or 200 km range thatimpact the HGB area.VOC &NOXPointNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Insufficient NOXreduction potentialto advance attainmentGeneral VOC enhanced monitoring rules for flares, cooling towers,process vents, and pressure relief valves at sources within 100 km rangethat impact the HGB area.VOCPoint &AreaNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Potential Measures/Concepts Suggested by StakeholdersManage livestock wastes by transporting them out of the HGBnonattainment area for management and or requiring the use of airpollution control systems.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Transport of waste out of the areawould likely result in increasedNOXemissions from transportvehicles.E-16Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Require the use of air pollution control systems at feedlots and animalswaste lagoons.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Provide incentives for improved management techniques to reduce thefrequency and quantity of pesticide applications.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Limit the allowable VOC content of pesticides. Identify lowestachievable limits through review of California and Ozone TransportCommission regulations.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Increase the stringency of existing control requirements for asphaltpaving and roofing (30 TAC 115, Subchapter F, Division 1).VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Provide incentives to convert from cutback asphalt to low-emissionemulsion asphalt and hot-mix asphalt.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Adopt South Coast Air Quality Management District (SCAQMD)content limit for emulsified asphalt (50 percent reduction).VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Restrict or prohibit the use of VOC-based parking lot sealers.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Require the use of emission controlson cutback asphalt applicationequipment used by commercial roofers, etc. Controls could include theuse of close fitting lids and restrictions on operating temperatures and orrequire the use of afterburners on the kettles.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Increase stringency of existing surface coating VOC limits. Identifylowest achievable limits through review of California and OzoneTransport Commission regulations.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.E-17Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Eliminate or reduce the scope ofthe surface coating emission limitationexemptions (30 TAC §115.427).VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Require the use of or provide incentives for using ozone-destroyingcatalyst coatings.OzoneAreaNNot quantifiable.Not demonstrated technologicallyfeasible to actually reduce ozone inmanner to advance attainment.Potential small business/privatecitizen economic impact.Potential adverse impacts to waterquality.Consider VOC reactivity in establishing VOC coating content orrequiring the use of air pollution controls.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Review existing list regulated sources (30 TAC 115, Subchapter E,Solvent-Using Processes, Division 2, Surface Coating Processes) andestablish emission limits for those sources currently excluded.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Establish recording and reporting requirements for industrial and nonindustrial chlorine use for possible opportunities to reduce chlorineemissions.ChlorinePoint &AreaNNot an actual emission reductioncontrol measure.Unknown whether additionalcontrols on chlorine sources beyondcurrent permitting requirements aretechnologically feasibility.Reduction in anthropogenic chlorineemissions will not advanceattainment. Natural sources ofchlorine (e.g., Gulf of Mexico) areexpected to far exceedanthropogenic sources.E-18Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Provide financial assistance for performing energy audits and orimplementation of energy saving measures that reduce demand andemissions from electric generating units (EGUs) and/or heating systems.NOXAreaNNot enforceable. TCEQ does nothave legislative funding toimplement. Any legislative fundingfor such incentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Not quantifiable.Revise building codes to require energy efficient designs and materialsthat reduce demand and emissions from EGUs and or heating systems.Measures could include more insulation, use of reflective glass, use orreflective paints, use of multi-paned glass, use of white or reflectiveroofs (International Energy Conservation Code (IECC)).NOXAreaNNot enforceable. TCEQ has noauthority to implement.Not quantifiable.Mandatory public building compliance with IECC.NOXAreaNNot enforceable. TCEQ has noauthority to implement.Not quantifiable.Require that a certain percentage ofpower purchased for public facilitiescome from renewable or non-emitting sources.NOXAreaNNot enforceable. TCEQ has noauthority to implement.Not quantifiable.Provide incentives forenergy conservation measures such as timedlighting for parking lots, outdoor advertisements and buildings,occupancy sensors for office lighting, and for turning off computers.NOXAreaNNot enforceable. TCEQ has noauthority to implement.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Not quantifiable.E-19Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Provide incentives for using energy efficient PC networks (shutdown ofcomputers when not in use).NOXAreaNNot enforceable. TCEQ has noauthority to implement.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Not quantifiable.Prohibit or restrict the burning of leaves and yard clippings or require theapplication of emission controls.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Outdoor burning rules are alreadyestablished under 30 TAC Chapter111, Subchapter B.Establish new consumer product VOC limits (California Air ResourcesBoard (CARB) – Cons 1 and 2).VOCAreaNModeling indicates general VOCreductions will not advanceattainmentAdopt SCAQMD Phase III VOC limits.VOCAreaNModeling indicates general VOCreductions will not advanceattainmentAdopt CARB rules regarding mid-term and or long-term limits on VOCcontent of consumer products.VOCAreaNModeling indicates general VOCreductions will not advanceattainmentProvide incentives for the substitution on non-VOC based cleaners forVOC based cleaners.VOCAreaNModeling indicates general VOCreductions will not advanceattainmentRequire the use of or provide incentives for the reformulation of VOCbearing commercial products suchas paints, cleaners, etc.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.E-20Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Limit automotive windshield washer fluid to less than the 23.5 percentVOC currently allow by 30 TAC 115, Subchapter G, Division 1.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Reasonable control already in place.Adopt Ozone Transport Commission Model Rule with additional productcoverage and more stringent VOC limits.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Increase stringency of existing control requirements in 30 TAC 115,Subchapter E, Division 1. This could include measures requiring the useof low VOC solvents for cold cleaning operations or replacement withwipe cleaning.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Put one-hour ozone contingency rules in 30 TAC 115, Subchapter F,Division 4 into effect.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Increase solvent recovery requirement in 30 TAC §115.552(a) from 85percent to 90 percent or greater. Contingency rules must be put intoeffect first.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Lower or eliminate the 2,000 gallon per year use exemption in 30 TAC§115.557. Contingency rules must be put into effect first.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Establish emission control requirements for food product manufacturingand processing operations.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Require the use of catalytic oxidizers or equivalent controls on chaindrive char-broilers.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.E-21Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Establish limits for the VOC content ofcharcoal lighter fluid.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Replace fuel dispensing hoses toreduce permeation.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Extend Stage I vapor recovery system requirements to counties outsideof the HGB nonattainment area.VOCAreaNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Eliminate or reduce the Stage I vapor recovery exemptions in 30 TAC§115.227.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Adopt CARB enhanced vapor recovery Stage I requirements (98 percentcontrol) in HGB area and potentially surrounding counties.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Extend the transport vehicle leak test provisions of 30 TAC 115,Subchapter C, Division 3, to counties outside of the HGB area.VOCAreaNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Eliminate or reduce the transport vehicle leak test exemptions in 30 TAC§115.237.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Extend Stage II vapor recovery system requirements to counties outsideof the HGB nonattainment area.VOCAreaNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Eliminate or reduce the Stage II vapor recovery exemptions in 30 TAC§115.247.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.E-22Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Implement a “stop at the click”awareness program to discourageoverfilling of vehicles during refueling.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Not quantifiable.Implement an off-road equipmentfuel tank program.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Develop and implement emission control measures for hair and nailsalons.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Extend municipal landfill emission control requirements to countiesoutside of HGB nonattainment area.VOCAreaNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Regulate emissions from the excavation of landfills.VOCAreaNUnknown technical feasibility withcontrolling emissions duringexcavation.Modeling indicates general VOCreductions will not advanceattainment.Require the use of co-composting operations to limit VOC emissions.Includes the mixing of bio-solids or manure with bulking agents.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Establish emission limits or control requirements for glycol dehydrationunits (oil and gas production). Emission limits could build uponemission limits established by 40 CFR 63, Subpart HH, to controlhazardous air pollutants emissionsfrom glycol dehydration units.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.E-23Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Require implementation of instrument based fugitive emissionsmonitoring and leak repair programs at oil and gas production facilities.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Reasonable controls already inplace.Establish requirements or provide incentives for the use of NOXemission reduction software.NOXAreaNNot enforceable.Not quantifiable.Provide additional incentives for the use of low-emitting, distributedpower generating systems such as wind, solar, micro-turbines, fuel cells,etc., reducing the demand and associated emissions from EGUs.NOXAreaNNot enforceable.Not quantifiable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Provide additional incentives for the capture of landfill gas for use incombustion turbines to generate electricity, reducing the demand andassociated emissions from EGUs.NOXAreaNNot enforceable.Not quantifiable.May actually increase NOXemissions due to NOXcontroltechnology limits specific to landfillgas. Siloxanes in landfill gascontaminant catalysts limiting NOXcontrol technology options on unitsfiring landfill gas.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.E-24Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Explore technologies and opportunities to reduce transmission in losseswith resulting reductions in demand and associated emissions fromEGUs.NOXAreaNNot enforceable.Not quantifiable.Not demonstrated technologicallyfeasible.Establish more stringent VOC content limitations and or emissioncontrol requirements for rotogravure and flexographic printingoperations than specified in 30 TAC 115, Subchapter E, Division 3.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Eliminate or reduce the rotogravure and flexographic printing emissioncontrol exemptions in 30 TAC §115.437.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Eliminate or reduce the offset lithographic printing emission controlexemptions in 30 TAC §115.437.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Portions of offset lithographic CTGrecommendations are beingimplemented to satisfy RACT.Partner with local governments in efforts to reduce urban heat islandeffects and thus reduce EGU demand and associated emissions.NOXAreaNNot enforceable.Not quantifiable.Investigate opportunities to improve local policies toward energyefficiency.NOXAreaNNot enforceable.Not quantifiable.Implement efficiency based natural gas rates to reward conservationNOXAreaNNot enforceable. TCEQ has noauthority to implement.E-25Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Provide incentives for companies to buy energy efficient products.NOXAreaNNot enforceable.Not quantifiable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Provide incentives for companiesand individual consumers to replaceolder, energy inefficient appliances with new Energy Star products.NOXAreaNNot enforceable.Not quantifiable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Provide incentives for companiesand individual consumers to replaceenergy inefficient heating and air conditioning systems with new, moreefficient units.NOXAreaNNot enforceable.TCEQ has no authority toimplement.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Not quantifiable.Implement public awareness campaigns for energy efficiency.NOXAreaNNot enforceable.Not quantifiable.E-26Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Provide incentives for cities and counties to promote and encouragedevelopment patterns that reduce emissions of air pollutants.NOX&VOCAreaNNot enforceable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Not quantifiable.Implement a ban on new developments that would result in any increasein air pollutants.NOX&VOCAreaNNot enforceable. Both the FederalClean Air Act and Texas law do notallow TCEQ to deny a permitapplication based solely on the factit is a new source.Establish mitigation fees for land development and other projects thatresult in additional area source emissions that are proportional to theanticipated increase in NOXand or VOC emissions.NOX&VOCAreaNNot quantifiable in terms of actualreduction benefit.Promote or require the planting trees (reduce EGU demand andemissions) and the use of plants that require less maintenance (reduceemissions from landscape maintenance equipment).NOX&VOCAreaNNot enforceable.Not quantifiable.Require mitigation of trees removed during development.NOXAreaNNot enforceable.Not quantifiable.Provide financial incentives to developers and homeowners to use orconvert to plants that require less maintenance (reduced emissions fromlandscape maintenance equipment).NOXAreaNNot enforceable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Not quantifiable.E-27Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Establish emission control requirements for publicly owned wastewatertreatment facilities.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.Establish requirements and/or provide incentives for the replacement ofpilot lights on gas stoves with electronic ignitions.NOXAreaNPotential technical feasibility issueswith retrofit of householdappliances.Not enforceable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Establish requirements and/or provide incentives for the replacement ofhot water heater pilot ignitions with electronic ignitions.NOXAreaNUnknown technological feasibilityto retrofit household appliances.Not enforceable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Establish requirements and/or provide incentives for the use of low NOXhot water heaters.NOXAreaNNot enforceable. Legislativeprohibition on requiring NOXlimitsless than 40 ng/J on residential waterheaters (HB 965, 80thLegislature,2007). Current Chapter 117 waterheater rule establishes limit at 40ng/J on residential water heaters.E-28Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Establish requirements and or provide incentives for the replacement ofhot water heaters with on-demand heat exchange systems.NOXAreaNTank-less or on-demand waterheaters are currently exempt fromChapter 117 water heater rules sothe incentives to purchase tanklesswater heaters are already in place.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Prohibit or restrict the sale and use of wood burning fireplaces and woodburning stoves in the HGB nonattainment area.VOCAreaNModeling indicates general VOCreductions will not advanceattainment.De minimis emissions and use islikely only during winter non-peakozone months.Establish requirements and or provide incentives for the replacement ofresidential combustion sources withlower emitting sources (replacingnatural gas fired units with electric units, for example).NOXAreaNNot enforceable.TCEQ does not have the authority tomandate the installation of specificequipment types.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.E-29Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Eliminate NOXMECT program and revert to source-by-source emissionlimitations with limits set equal to Lowest Achievable Emission Ratetechnology or other.NOXPointNNOXMECT program provides mostefficient means to achieve costeffective reductions.Additional NOXcontrol on existingMECT sources not economicallyfeasible. See Section 4.2 of thisappendix for more detail.Establish source-by-source emission limits (not cap and trade) onHRVOC and or other VOCs for sources located outside of the HGBnonattainment area.VOCPointNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Eliminate HRVOC cap and trade program and control emissionsexclusively through source by sourceemission limitations in the HGBnonattainment area.VOCPointNHECT program provides most costeffective means to achievereductions.Revise or eliminate some or all exemptions (30 TAC §117.203) for NOXMECT applicability, including temporarysources (such as engines in testcells), sources in limited use applications (exemptions for emergencygenerators and diesel engines installed prior to October 1, 2001), heattreat and reheat furnaces rated less than 20 MMBtu/hr, incinerators ratedless than 40 MMBtu/hr, boilers and process heaters rated 2 MMBtu/hr orless, dryers and ovens, chemical processing gas turbines and flares.NOXPointNNot economically feasible.See Section 4.2 of this appendix formore detail.Extend NOXMECT program to stationarysources that are currently notsubject to program requirements (facilities where no ESAD has beenestablished).NOXPointNNot technologically feasible forsome currently exempt sources. Noteconomically feasible for others.See Section 4.2 of this appendix formore detail.E-30Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Eliminate the distinction between major and small sources, applying theESAD found in 30 TAC §117.206 to all sources regardless of site-widepotential to emit.NOXPointNChapter 117 HGB Minor SourceRule already establishes unit-by-unitemission limits for non-MECTengines, boilers, process heaters, andturbines at minor sources.Adverse economic impact byholding small businesses to morestringent standards.Eliminate the exemption for sourceswith uncontrolled emissions atdesign capacity of less than 10 tons per year.NOXPoint &AreaNChapter 117 HGB Minor SourceRule already establishes unit-by-unitemission limits for non-MECTengines, boilers, process heaters, andturbines at minor sources.Provide financial incentives for demand side management.NOXPointNNot enforceable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Not quantifiable.Provide additional financial incentives for reducing emissions byincreasing the annual fee paid on NOXemissions.NOXPointNNot quantifiable in terms of actualtons of reductions. Increasingemissions fees does not ensurereduction in actual emissions.Include engines located at EGUs in NOXMECT program.NOXPointNWill not advance attainment.De minimis emissions from enginesat EGU sites, less than 0.01 tpd totalNOXemission in 2006 inventory.E-31Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Provide financial incentives for investment in lower polluting or nonpolluting power generation technologies.NOXPointNNot quantifiable.Any legislative funding for suchincentive programs is notpermanent; therefore, incentiveprograms do not meet criteria to beSIP creditable or RACM.Extend NOXMECT program to combustion sources located outside ofthe HGB area. Inclusion could be limited to larger, more numerousindustrial sources (industrial, commercial, institutional boilers, processheaters, large engines, large turbines, smelter furnaces, cement and brickkilns, etc.) or could include the same source categories covered by theHGB SIP.NOXPointNAttainment county matrix sensitivityruns show economically reasonableNOXreductions outside the HGBnonattainment area will not advanceattainment.Implement separate NOXcap and trade program for sources locatedoutside of the HGB nonattainment area.NOXPointNAttainment county matrix sensitivityruns show economically reasonableNOXreductions outside the HGBnonattainment area will not advanceattainment.Lower NOXMECT cap by reallocating allowances based on lowerESAD (1999 SIP values or other).NOXPointNNot economically feasible.See Section 4.2 of this appendix formore detail.Lower NOXMECT cap reallocating allowances through across-theboard reductions.NOXPointNNot economically feasible.See Section 4.2 of this appendix formore detail.Extend NOXMECT program to include non-stationary engines.NOXPointNUnknown technological andeconomic feasibility at this time.Emission reduction benefit notquantifiable.E-32Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Extend NOXMECT program to EGUs outside of the HGBnonattainment area.NOXPointNAttainment county matrix sensitivityruns show economically reasonableNOXreductions outside HGB willnot advance attainment.Coal-fired unit not located inproximity or direction to providebenefit to HGB ozone nonattainmentarea.Turbines in East sector (BPA) arealready well controlled with SCR.Gas-fired units in BPA already havereasonable controls.Expand applicability of the HRVOC cap and trade program beyondflares, process vents, cooling towers and process fugitive emissions.VOCPointNThe suggested measure has noquantifiable benefit. The HECTprogram already includes allrelevant sources that have potentialto emit HRVOC.Fugitive HRVOC emissions arecontrolled separately through 30TAC Chapter 115, Subchapter H,Division 3.Extend current HRVOC cap and trade program to other VOC species andtrade emissions based on reactivity.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Expand application of cap and trade concept to others sources of VOCstorage tanks, loading racks, wastewater treatment operations, barge/shiploading operationsVOCPointNModeling indicates general VOCreductions will not advanceattainmentE-33Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Eliminate the HRVOC cap and trade exemption for sources withpotential emissions of less than 10 tons per year.VOCPointNHRVOC sources in Harris Countysubject to Chapter 115 HRVOCrules but less than 10 tpy are notexempt but limited to 10 tpy. NonHECT site, non-fugitive emissionsare not a significant source ofHRVOC emissions. Total nonHECT/non-fugitive HRVOCemissions for Harris County areestimated to be less than 2 tpd.Revoke the HRVOC cap and trade exemption for sourceslocated in theHGB area outside of Harris County.VOCPointNModeling indicates HRVOCreductions outside Harris Countywill not advance attainmentExtend HRVOC cap and trade programto sources located outside of theHGB area.VOCPointNAttainment county matrix sensitivityruns show VOC reductions outsideHGB will not advance attainment.Lower HRVOC cap. Reallocate allowances using existing allocationprocedures but lower annual emission caps.VOCPointYModeling indicates that reducing theHECT cap for Harris County willhelp advance attainment. SeeSection 4.3.2 for more detail.Extend 1,200 lb/hr HRVOC emission limit to sources located outside ofthe HGB area.VOCPointNAttainment county matrix sensitivityruns show reductions outside theHGB area will not advanceattainment.Implement HRVOC program type monitoring requirements for otherVOC emissions from flares, cooling towers, and or process vents.VOCPointNModeling indicates general VOCreductions will not advanceattainment.E-34Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Expand HRVOC fugitive monitoring requirements to other VOC species.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Expand applicability of the industrial wastewater regulations beyond thelist of affected source categories in 30 TAC §115.140(1).VOCPointNModeling indicates general VOCreductions will not advanceattainment,Make existing industrial wastewaterregulations more stringent (reviseVOC reduction requirement form 90 percent to 95 percent).VOCPointNModeling indicates general VOCreductions will not advanceattainmentProvide additional financial incentive for reducing emissions byincreasing the annual fee paid on VOC emissions.VOCPointNModeling indicates general VOCreductions will not advanceattainmentDevelop and implement more stringent guidance on Best AvailableControl Technology (BACT) requirements for New Source Review(NSR) authorization issued to sources in the HGB nonattainment areaand potentially sources outside the HGB nonattainment area.VOC &NOXPointNNot quantifiable. Future reductionsof NOXor VOC from revisingBACT cannot be determinedbecause the TCEQ cannot predictwhether existing sources will triggerBACT in the future or what newsources requiring BACT may bepermitted.BACT is a separate and independentrequirement of the FCAA.Modeling indicates reductionsoutside the nonattainment area willnot advance attainment.Manage composting operations. Potential control measures couldinclude registration of composting, chipping, and grinding facilities;establish holding and or processing time requirements for green waste;and establish VOC emission control requirements.VOCPointNModeling indicates general VOCreductions will not advanceattainment.E-35Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Control emissions from airport terminals.VOC &NOXPointNChapter 117 Minor Source ruleestablishes controls for stationaryNOXsources.General conformity requirementsapply to federally funded projects.See Table E-2 of this appendix formore detail on non-stationarysources.Control emissions through facility energy conservation programs.NOXPointNNot enforceable.Not quantifiableControl emission from aircraft maintenance operations.NOXPointNChapter 117 Minor Source ruleestablishes controls for stationaryNOXsources.General conformity requirementsapply to federally funded projects.See Table E-2 of this appendix formore detail on non-stationarysources.Revise control requirements for bakeries in 30 TAC §115.122 from 80percent to 90 percent or greater.VOCPointNModeling indicates general VOCreductions will not advanceattainment.De minimis emissions less than 0.05tpd total emissions in the 2006 pointsource emissions inventory.Lower or eliminate the 25 tons per year threshold for requiring controlsfor bakeries.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Implement housekeeping practices in breweries to minimize spillageduring filling, keg cleaning and waste beer processing.VOCPointNModeling indicates general VOCreductions will not advanceattainment.E-36Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Develop and implement brewery source specific wastewater treatmentrequirements. Alternatively, brewery sources would be subject toindustrial wastewater regulations.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Establish VOC emission limitation from brewery fermentation tanks.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Require the control of emissions from dryers and heaters for cutbackasphalt processes.NOX&VOCPointNTechnological and economicfeasibility for retrofitting smallerheaters and dryers is unknown.Modeling indicates general VOCreductions will not advanceattainment.NOXemissions from all asphaltheaters in 2006 point sourceinventory are less than 0.1 tpd.Adopt emission limits based on retrofit BACT level of 0.07-0.1lb/MMBtu.NOXPointNNo quantifiable reduction benefit.More stringent controls already inplace either through unit-by-unitlimits or MECT program. AllESAD for boilers and processheaters and most ESADs for othersources in HGB are already less than0.07 - 0.1 lb/MMBtu NOX.Adopt 90 percent reduction from uncontrolled emissions for EGUs.NOXPointNAdditional NOXreductions fromEGUs are not cost effective.See Section 4.2 of this appendix formore detail.Make requirements of 30 TAC 115, Subchapter D, Division 3(equipment leaks) more stringent(similar to HRVOC monitoring).VOCPointNModeling indicates general VOCreductions will not advanceattainment.E-37Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Lower leak detection limits for equipment leaks.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Reasonable controls already inplace.Require instrument monitoring of connectors for equipment leaks.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Rules already in place in Chapter115 general VOC and HRVOCfugitive rules.Require that existing flares be retrofitted to conform to 40 CFR §60.18design standards.VOCPointNNo quantifiable benefit. 40 CFR§60.18 does not have designstandards, only performance criteria.Review various California air quality district rules and regulations toidentify additional emission reduction opportunities.NOX&VOCPointNThe suggestion is not a definedpotential control measure.California rules were reviewed aspart of research for potentialstrategies.Revise control requirements in 30 TAC §115.212 for VOC loadingoperations from 90 percent to 95 percent or greater.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Require the use of low volume quick disconnects from railcar and tankertruck loading and unloading operations.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Require the implementation of work practices in metal production tominimize VOC in furnace charge material or require use of gas fired preheater where the flame directly contacts the scrap charge.VOCPointNModeling indicates general VOCreductions will not advanceattainment.E-38Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Limit repair, maintenance, cleaning and other non-production relatedactivities on ozone alert days.NOX&VOCPointNMeasure is impractical becausethese activities are typicallyscheduled in advance andnotification of ozone alerts istypically 24 hours or less and wouldnot provide sufficient time forrescheduling the activities.Modeling indicates general VOCreductions will not advanceattainment.Restrict the testing of emergency generators and other support equipmenton ozone alert days.NOXPointNAlready addressed by 30 TAC 117prohibition of operation formaintenance or testing purposesbetween 6:00 am and nooneveryday, not just ozone alert days.Revise process vent control requirements in 30 TAC §115.122(a)(1) torequire at least 95 percent control.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Lower allowable VOC content of surface coatings in 30 TAC 115,Subchapter E, Division 2.VOCPointNModeling indicates general VOCreductions will not advanceattainment.Additional control of VOC emissions based on new EPA CTGs.VOCPoint &AreaNModeling indicates general VOCreductions will not advanceattainment.Portions of the offset lithographicCTG recommendations are beingimplemented to satisfy RACTrequirements.E-39Table E-1: HGB Area Stationary Source RACM AnalysisPoint/AreaRACMControl Measure DescriptionPollutantRACM Analysis / JustificationSource(Y/N)Implementation of additional monitoring of steam and air assist flares,especially flares in HRVOC service.VOCPointNTCEQ has insufficient informationat this time to determine ifmonitoring of steam/air assist ratesmeets RACM criteria.The potential impacts of steam andair assist are being evaluatedthrough the Flare Task Force. SeeChapter 6 of this SIP revision formore detail.Implementation of additional monitoring of flares in general VOCservices to improve VOC inventory.VOCPointNModeling indicates general VOCreductions will not advanceattainment.The commission is continuing toevaluate flaresthrough the FlareTask Force. See Chapter 6 of thisSIP revision for more detail.For flares:Rigorously and consistently, enforce existing flare operationrequirements.Expand and accelerate researchon factors that affect flareburning efficiency, alternativesto flares, and flare monitoring.Revise TCEQ policies and guidelines for estimating flareemissions for rulemaking, permitting, enforcement, reporting,and planning activities to take into account the effects of steamand crosswinds.Require more extensive monitoring/reporting of flare emissions.Increase flare gas recovery system use or other technologies,like enclosed ground flares orthermal oxidizers, to controlemissions.Use elevated flares only in emergencies and start-ups andshutdowns of equipment.VOCPointNModeling indicates general VOCreductions will not advanceattainment.TCEQ has insufficient informationat this time to determine ifmonitoring of steam or air assistrates meets RACM criteria.The commission is continuing toevaluate flaresthrough the FlareTask Force. See Chapter 6 of thisSIP revision for more detail.E-40Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisControl Measure DescriptionPollutantOnRoad/NonRoadRACM(Y/N)RACM AnalysisTCEQ Draft Initial Control Strategy ConceptsHGB 8-County Region ControlsBan Segways from use on sidewalks and hike/bike trails.NOXandVOCOn-RoadNNot quantifiable/not enforceable.Safer bike routes with better signs marking lanes and routes.NOXandVOCOn-RoadNNot quantifiable.Inclusion of bicycle lanes on state/federal funded thoroughfareprojects.NOXandVOCOn-RoadNNot quantifiable.Bicycle route signalization.NOXandVOCOn-RoadNNot quantifiable.E-41Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisBicycle lanes on every arterial/frontage road.NOXandVOCOn-RoadNNot quantifiable.Bicycle lane/path repaving.NOXandVOCOn-RoadNNot quantifiable.Bicycle route lighting.NOXandVOCOn-RoadNNot quantifiable.Increased bicycle/pedestrian outreach to immigrant communities.NOXandVOCOn-RoadNNot quantifiable.Media coverage/promotion of bicycle facilities.NOXandVOCOn-RoadNNot quantifiable.Bicycle education.NOXandVOCOn-RoadNNot quantifiable.Region-wide mandatory bicycle racks at work sites.NOXandVOCOn-RoadNNot quantifiable/not enforceable.Address security concerns of pedestrians/cyclists.NOXandVOCOn-RoadNNot quantifiable.Showers and clothing lockers.NOXandVOCOn-RoadNNot quantifiable.Bicycle lockers, rack, and other storage facilities.NOXandVOCOn-RoadNNot quantifiable.Biking/hiking patrols to ensure safety.NOXandVOCOn-RoadNNot quantifiable.Integration of bicycle/pedestrian facilities with transit.NOXandVOCOn-RoadNNot quantifiable.E-42Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisPermit bicycles on rail transit.NOXandVOCOn-RoadNNot quantifiable.Bicycle racks on buses.NOXandVOCOn-RoadNNot quantifiable.Street level shops.NOXandVOCOn-RoadNNot quantifiable.Give bicyclists/pedestrians the right-of-way.NOXandVOCOn-RoadNNot quantifiable.Cyclist/pedestrian sidewalk furniture.NOXandVOCOn-RoadNNot quantifiable.Sidewalks and walkways.NOXandVOCOn-RoadNNot quantifiable.Crosswalks.NOXandVOCOn-RoadNNot quantifiable.Additional pedestrian access and circulation.NOXandVOCOn-RoadNNot quantifiable.Pedestrian signals.NOXandVOCOn-RoadNNot quantifiable.Connected street system and pedestrian pass-throughs.NOXandVOCOn-RoadNNot quantifiable.Pedestrian design improvements.NOXandVOCOn-RoadNNot quantifiable.Mid-block pedestrian connections.NOXandVOCOn-RoadNNot quantifiable.E-43Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisWide, unobstructed sidewalks on both sides of all arterials, majorroads, and other streets.NOXandVOCOn-RoadNNot quantifiable.Fuel cell school buses.NOXOn-RoadNTechnology is not readily availableand is cost prohibitive.Airport use of Ultra Low Emitting Vehicle (ULEV) or electricvehicles instead of diesel for ground transportation.NOXandVOCOn-RoadNMeasure is being voluntarilyimplemented throughmemorandums of agreement(MOAs) in the region.Propane school buses.NOXOn-RoadNReductions too small to advanceattainment.Use solar cells to run air conditioning and other electrical equipmenton Metro buses.NOXOn-RoadNNot quantifiable / not enforceableLocate hazardous freeway areas for possible improvements, sharpturns, clover leafs, etc.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Limit road and highway improvements to those benefiting transitand high occupancy vehicle lanes.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Shift highway funds to transit.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.No new peripheral highways or loops.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.E-44Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisCalifornia diesel fuel.NOXOn-RoadNTexas Low Emission Diesel(TxLED) is an enforceable ruleunder Texas' State ImplementationPlan (SIP) and is similar toCalifornia diesel fuel.Reformulated fuels foroff-road vehicles.NOXOn-RoadNFederal Reformulated Gas is alreadyrequired in the Houston-GalvestonBrazoria nonattainment area.Educate public about fuel savingsfrom properly inflated tires,regular tune-ups, and driving speed.NOXandVOCOn-RoadNNot quantifiable / not enforceable.Celebrity volunteers for ozone alert announcements.NOXandVOCOn-RoadNNot quantifiable / not enforceable.Air quality public outreach.NOXandVOCOn-RoadNNot quantifiable / not enforceable.Designated truck routes.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Dedicate truck lanes.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Require short-haul trucks to use alternative fuels.NOXOn-RoadNNot quantifiable / not enforceable.Ban the use of High Occupancy Vehicle (HOV) lanes by trucks.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.More aggressive HOV enforcement.NOXandVOCOn-RoadNLegislative action required tomandate.E-45Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisHOV service on all freeways with increased access.NOXandVOCOn-RoadNLegislative action required tomandate.Focus on finding extreme high emitters with emphasis on findingand replacing, not penalizing.NOXandVOCOn-RoadNNot quantifiable / not enforceable.Roadside pullovers.Portable inspection/maintenance measures.NOXandVOCOn-RoadNNot quantifiable.High-emitting vehiclerepair assistance.NOXandVOCOn-RoadNNot quantifiable.Accelerated vehicle retirement program.NOXandVOCOn-RoadNThe Drive a Clean Machine Programis implemented in the HGBarea/reductions do not advanceattainment.Dedicated funding forschool bus replacement.This should require alternative fueled vehicles.NOXOn-RoadNReductions to small to advanceattainment.Buy vehicles older than model year 1975 to retire from use.NOXandVOCOn-RoadNThe Drive a Clean Machine Programis implemented in the HGBarea/reductions do not advanceattainment.Expanded repair and replacement assistance program.NOXandVOCOn-RoadNThe Drive a Clean Machine Programis implemented in the HGBarea/reductions do not advanceattainment/expansion of the programwould require legislative action toimplement.E-46Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisNew vehicle discounts for old vehicle trade-ins.NOXandVOCOn-RoadNThe Drive a Clean Machine Programis implemented in the HGBarea/reductions do not advanceattainment.Transit passes/credit in exchange for old vehicle scrappage.NOXandVOCOn-RoadNNot quantifiable.Ban sale of high-emitting vehicles.NOXandVOCOn-RoadNLegislative action required tomandate.Deny registration to vehicles with repeated emission failures.NOXandVOCOn-RoadNThe TCEQ's Vehicle RegistrationDenial program does not allowmotorists to register vehicles inozone nonattainment areas if thevehicle failed an emissions test andhas not passed a retest during thelast twelve months.Increase parking at transit centers or stops.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Provide parking at all major transit stations.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Cheaper gasoline prices duringevening hours.VOCOn-RoadNLegislative action required tomandate.Discourage people to have multiple cars.NOXandVOCOn-RoadNNot quantifiable / not enforceable.E-47Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisState and local exemptions for pooling/transit subsidies.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.No tolls for buses and vanpools.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Manage location of new growth to limit additional sprawl.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Mixed use development ordinance and zones.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Encourage or require complementary uses in close proximity in alldevelopments or development areas.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Stop freeway bottleneck improvements that add lanes instead offocusing on transit.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Prohibit truck use of right lanes for loading on bus and bike routes.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Pedestrian mall route diversion.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Require two or more occupants per vehicle to enter designatedcongested activity centers during amand pm peak traffic periods.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.E-48Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisMore transit access near universities and airports.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Light rail.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Commuter rail.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.High-speed rail.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Encourage the use of jitneys.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Encourage putting METRO and other public buses on propane orother lower polluting fuels.NOXOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Subsidize transit service.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Implement seamless public transit, connectivity.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.E-49Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisMandatory employer trip reduction programs for all employers whoemploy 20 or more people.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Would require legislative action toimplement.Restrict student drivers to high schools.NOXandVOCOn-RoadNWould require legislative action toimplement.Engine software upgrade (DHV4) or low NOXsoftware upgrade.NOXOn-RoadNTCEQ follows the U.S.Environmental Protection Agency’sguidance/no new NOXbenefit.School bus idling Airborne Toxic Control Measure.NOXOn-RoadNNot quantifiable.Statewide emissions testing.NOXandVOCOn-RoadNWould require the counties consentand legislative action to implement.Centralized IM-240 test with repairs done separately.NOXandVOCOn-RoadNTexas utilizes Onboard Diagnostictesting which is more effective thanIM-240 testing / no new NOXbenefit.Raise the driving age.NOXandVOCOn-RoadNWould require legislative action toimplement.Close loopholes in the Texas Clean Fleet Program making fewerexemptions for fleets.Tier 2 light-duty and 2007 heavy-duty vehicle emissionsstandards have superseded the original proposal.NOXOn-RoadNSenate Bill 1032, 79th TexasLegislature, 2005, Regular Session,repealed the Texas Clean FleetProgram.Electric vehicles.NOXandVOCOn-RoadNMeasure is being voluntarilyimplemented through MOAs in theregion.E-50Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisCleaner diesel fuel.Some diesel fuels have improved performance beyondTxLED.NOXOn-RoadNTxLED is required in the HGB area.At this time, there are no approvedfuels that are any cleaner thanTxLED.Permit HOV lane use by qualifying low emission vehicles.NOXOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Single Occupant Vehicles (SOV) access to HOV and transit stations.Provide direct freeway access toadjoining HOV or transitpark-and-ride facilities to encourage use and expediteaccess.NOXOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Managed lanes to accommodate some SOVs in HOV lanes.Permit limited use of HOV lanes by SOV using tolls orother limiting technique in highly congested corridorswhere speeds are below 20 miles per hour.NOXOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Rewards for reporting smoking or high emitting vehicles.NOXOn-RoadNNot quantifiable / not enforceable.Enforce smoking vehicle reports and require repairs.Require vehicle to be retested.NOXOn-RoadNThe Drive a Clean Machine Programoffers financial assistance to repairvehicles that fail the emissions test /reductions too small to advanceattainment.Low-interest financing for low income and/or old vehicle trade-ins.Financing made available to vehicle owners not eligible forDrive a Clean Machine replacement option.NOXandVOCOn-RoadNWould require legislative action toimplement.Aggressive driving enforcement.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.E-51Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisIncentive for infill and redevelopment.Incentives for master planned communities planned aroundlower vehicle travel.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Reduce transit fares.NOXandVOCOn-RoadNNot quantifiable / not enforceable.Accelerate rail expansion.NOXandVOCOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Share hybrid vehicles.NOXandVOCOn-RoadNNot quantifiable / not enforceable.Enhanced enforcement for Smoking Vehicle Program.Vehicle impounding for violators.NOXOn-RoadNThe Local Initiative Project providesfunding to counties to implementsmoking vehicle programs in ozonenonattainment and nearnonattainment areas / reductions toosmall to accelerate attainment.Inspection and Maintenance (I/M) - Chambers, Liberty, and WallerCounties.NOXOn-RoadNLegislative/local action required toimplement..Idling Reduction.NOXOn-RoadNConsideration needs to be throughthe region's transportation planningprocess.Disincentives such as fines if caught mowing during Ozone Alerts.VOCNon-RoadNModeling indicates general VOCreductions will not advanceattainment / not quantifiable / notenforceable.E-52Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisOn-RACMControl Measure DescriptionPollutantRoad/NonRoad(Y/N)RACM AnalysisBan equipment such as two-stroke engines.VOCNon-RoadNModeling indicates general VOCreductions will not advanceattainment and not quantifiable / notenforceable.Electrification of rail.NOXNon-RoadNNot quantifiable / not enforceable.Aircraft vapor recovery.VOCNon-RoadNModeling indicates general VOCreductions will not advanceattainment.Use electric or cleaner technology auxiliary power units (APUs) forgate electrification.NOXandVOCNon-RoadNBush Intercontinental Airport andWilliam P. Hobby Airport havealready implemented this technologyon all gates.Use electric or cleaner technology APUs for preconditioned air.NOXandVOCNon-RoadNBush Intercontinental Airport andWilliam P. Hobby Airport havealready implemented this technologyon all gates.Use liquefied natural gas and compressed natural engines forlocomotives.NOXNon-RoadNLocomotive engine standards existin Federal Regulations.Federal regulatory action requiredfor additional controls.Selective catalytic reduction for locomotives.NOXNon-RoadNLocomotive engine standards existin Federal Regulations.Federal regulatory action requiredfor additional controls.Marine TxLED in east and central Texas counties (currently only inHGB area).NOXNon-RoadNTxLED is required in thenonattainment area.E-53E-54Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM AnalysisControl Measure DescriptionPollutantOnRoad/NonRoadRACM(Y/N)RACM AnalysisGreen Port Initiatives.NOXandVOCOn-Roadand NonRoadNConsideration needs to be throughthe region's transportation planningprocess.Texas Emissions Reduction Plan (TERP).NOXOn-Roadand NonRoadNTERP has been implemented in theHGB area since 2001.

# APPENDIX E

REASONABLY AVAILABLE CONTROL MEASURE ANALYSIS



# Attachment 1

Control Strategy Planning Draft Initial C oncept Lists Presented to Stakeholders

E- 55

# TCEQ / CEO / AQP Section - Stationary Source Programs Team / March 25, 2008 Page 1 

# Houston-Galveston-Brazoria (HGB) Ei ght-Hour Ozone Nonattainment Area

Stationary Source Control Strategy Planning

Draft Initial Concept List

The following is a draft list of initial control strategy concepts for the HGB eight-hour ozone attainment

demonstration. These concepts are only presented for furt her consideration as potential control strategies to help

the HGB area attain the eight-hour ozone NAAQS. Further research and evaluation of concepts is necessary to

determine ozone reduction benefit as well as technical and economic feasibility. Concepts are not listed in any

particular order of priority, effectiveness, or feasibility.



# Concept Description Pollutant

HGB 8-County Region Controls

Additional nitrogen oxides (NO X 

# ) reductions through Chapter 117 and the

Chapter 101 Mass Emission Cap & Trade (MECT) Program by revising emission

specifications, revoking exemptions, e xpanding applicabilit y, and resetting

baseline activity years. NO X



# Expand the definition of highly reactive volatile organic compounds (HRVOC) in

§115.10 to include additional volatile organic compound (VOC) species under

the requirements of Chapter 115 HRVOC rules and Chapter 101 Highly Reactive

Volatile Organic Compound Emissions Cap and Trade (HECT) Program. VOC

In lieu of expanding the definition of HR VOC, create separate rules to address

other VOC emissions from vents, flares, and cooling towers. VOC

Reduce HECT cap for Harris C ounty in §101.394(a)(1). VOC

Revoke exemptions from site-wide cap s in HRVOC rules for 7-surrounding

counties and reduce HECT program cap in §101.394(a)(2). VOC

Revise general VOC fugitive rules in Chapter 115 Subchapter D, Division 3 and

apply more stringent leak detection and repair (LDAR) requirements from

HRVOC rules. VOC

Require sources to develop and implement flare minimization plans. VOC &

NO X



# Require monitoring of steam/air assist ra tes on assisted flares to help ensure

proper operation and prevent decreased e fficiency from improper operation such

as over-steaming. VOC

General VOC monitoring rules with e nhanced monitoring for flares, cooling

towers, process vents, and pr essure relief valves (PRVs). VOC

Additional VOC controls for wastewater systems. VOC

Additional VOC controls for upstream oil/gas VOC emissions. VOC

# TCEQ / CEO / AQP Section - Stationary Source Programs Team / March 25, 2008 Page 2 

# Houston-Galveston-Brazoria (HGB) Ei ght-Hour Ozone Nonattainment Area

Stationary Source Control Strategy Planning

Draft Initial Concept List

The following is a draft list of initial control strategy concepts for the HGB eight-hour ozone attainment

demonstration. These concepts are only presented for furt her consideration as potential control strategies to help

the HGB area attain the eight-hour ozone NAAQS. Further research and evaluation of concepts is necessary to

determine ozone reduction benefit as well as technical and economic feasibility. Concepts are not listed in any

particular order of priority, effectiveness, or feasibility.



# Concept Description Pollutant

Energy efficiency measures associated or in conjunction with MECT revisions. NO X



# Eliminate certain storage tank exemptions in Chapter 115 rules. VOC

Storage tank design improvements such as hanging roof in lieu of roof supported

by legs. VOC

Increase control efficiency requirements in Chapter 115 rules such as vent gas

control, loading, and storage. VOC

Implement Best Management Practices via agreed orders or other mechanisms. NO X 

# and

VOC

Controls for portable engines such as portable generators and other engines

considered non-stationary due to temporary service. NO X



# Controls to reduce VOC emissions from lightering on barges and marine vessels. VOC

VOC controls for salt dome storage faci lities for brine ha ndling/degassing and

fugitive LDAR. VOC

Refinery coker VOC emission controls. VOC

Transport Controls (Outside HGB)

NO X 

# controls on major sources for sel ected source categories within 200

kilometer (km) range that impact the HGB area. NO X



# NO X 

# controls on minor sources for select ed source categories within 200 km

range that impact the HGB area. NO X



# HRVOC controls for flares, vents, cooling towers, and fugitives at sources within

100 km range that impact the HGB area using the current list of HRVOCs

(ethylene/propylene) or additional VOCs. VOC

Extend new upstream oil/gas flash emission, degassing, storage tank rules to

sources within 100 km range that impact the HGB area. VOC

# TCEQ / CEO / AQP Section - Stationary Source Programs Team / March 25, 2008 Page 3 

# Houston-Galveston-Brazoria (HGB) Ei ght-Hour Ozone Nonattainment Area

Stationary Source Control Strategy Planning

Draft Initial Concept List

The following is a draft list of initial control strategy concepts for the HGB eight-hour ozone attainment

demonstration. These concepts are only presented for furt her consideration as potential control strategies to help

the HGB area attain the eight-hour ozone NAAQS. Further research and evaluation of concepts is necessary to

determine ozone reduction benefit as well as technical and economic feasibility. Concepts are not listed in any

particular order of priority, effectiveness, or feasibility.



# Concept Description Pollutant

NO X 

# controls on engines within 200 km range that impact the HGB area. NO X



# NO X 

# controls on power plants within 200 km range that impact the HGB area. NO X



# VOC and NO X 

# controls on paper mills within 100 or 200 km range that impact

the HGB area. VOC &

NO X



# General VOC enhanced monitoring rules for flares, cooling towers, process

vents, and PRVs at sources within 1 00 km range that impact the HGB area. VOC

Other Potential Measures/Concepts

Engine registration pr ogram for stationary and/or por table engines to help ensure

better enforcement of applicable requirem ents, improve rule effectiveness, and

proper accounting of engines in EI. NO X

# Houston-Galveston-Brazoria (HGB) Ei ght-Hour Ozone Nonattainment Area

Mobile Source Control Strategy Planning

Draft Initial Concept List

The following is a draft list of initial control strategy concepts for the HGB eight-hour ozone attainment

demonstration. These concepts are only presented for furt her consideration as potential control strategies to help

the HGB area attain the eight-hour ozone National Ambient Air Quality Standard (NAAQS). Further research and

evaluation of concepts is necessary to determine oz one reduction benefit as well as technical and economic

feasibility. Concepts are not listed in any particular order of priority, effectiveness, or feasibility.



# Concept Description Mobile

Source Pollutant(s)

Marine Texas Low Emission Diesel

(TxLED) in east and central Texas

counties (currently only in HGB area) Non-Road NO X



# Inspection and Maintenance (I/M) –

Chambers, Liberty, Waller counties On-Road NO X



# Texas Emission Reduction Plan (TERP) On-Road and Non-Road NO X



# Green Port Initiatives Non-Road NO X 

# /VOC

Idling Reduction On-Road NO X