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 EIGHT-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 the 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 Source 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 the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix J Recommendations for Best Management Practices to Control and 

Reduce Inadvertent Cargo Vapor Emissions in the Tank Barge 

Community 
APPENDIX E 

REASONABLY AVAILABLE CONTROL MEASURE ANALYSIS 

APPENDIX E 

REASONABLY AVAILABLE 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 NOX 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 Mobile 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 
REASONABLY AVAILABLE CONTROL MEASURE ANALYSIS 

1.0 Introduction 

The Houston-Galveston-Brazoria eight-hour ozone nonattainment 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 the 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 expeditiously 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 requirement 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 implementation in light of local circumstances. In the general 

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

reasonably available: 

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

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

from further consideration... the resulting available control measures should then be 

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

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

control measures, this evaluation should consider 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 evaluated during the RACM analysis. First, the TCEQ 

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

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

(NOX) in the HGB area. The EPA allows states the option to consider control measures outside the ozone 

nonattainment area that can be shown advance attainment; 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 

NOX within 200 km of the HGB area were also considered 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 stakeholders 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 strategies 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 the 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 the process used for the stationary sources. A draft 

list of potential control strategy concepts was presented 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 well 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 control 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. Once 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 stakeholder 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 Voluntary Mobile Emission Reduction 

Measures. 

3.0 RACM Evaluation Approach 

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

determine if the measure would meet established criteria to be considered 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 potential control measure for application to point, 

area, on-road and non-road emission source categories 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 whether 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 modeling sensitivity runs. 

E-3 
The TCEQ also considered whether the potential control measure could be implemented before and 

reduce emissions prior to the beginning of the ozone season 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 expeditiously 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 measure 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 detail on the RACM analysis of reducing the HRVOC cap 

for Harris County. All other potential control measures 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 determination are included in Table E-1: HGB Area Stationary Source 

RACM Analysis of this appendix. 

4.2 NOX RACM Analysis 

4.2.1 Mass Emission Cap and Trade (MECT) Program and Chapter 117 NOX Rules RACM 

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

comprehensive NOX control strategies in the nation and was the primary control measure the HGB onehour ozone attainment demonstration. The NOX MECT program encompasses the majority of stationary 

NOX sources in the HGB area. In determining whether 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 NOX 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 NOX control technological advances that have occurred since 2000. The TCEQ 

evaluated further NOX reductions through the MECT program on an economic, technological, and 

practicality basis. Practicality is considered a RACM evaluation criterion by the EPA. Revising NOX

allowances under the MECT program presents significant practicality issues because the program has 

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

program. Reallocation of NOX 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 NOX MECT allowances would be possible from a technological feasibility perspective. 

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

those categories that further NOX control was determined to be potentially technologically feasible. 

Based on this approach, the TCEQ estimates that the NOX 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 NOX 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 NOX control was determined to not be technologically feasible 

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

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

in the HGB area are all equipped with SCR and the reported historic NOX emissions data for these units 

indicates that further NOX reductions may not be technologically feasible. 

The TCEQ then evaluated the economic impact of implementing controls necessary to reduce the NOX

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. Total 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 NOX controls. The number and type of units potentially needing NOX 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 NOX control 

technology. Additionally, based on the TCEQ's research, ultra-low NOX burners are only available for 

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

NOX 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 effectiveness estimate cannot be directly compared to the 

historic costs of MECT allowance stream trades, i.e., permanent trades of annual NOX allowances, 

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

MECT NOX allowances made at $100,000 per ton when evaluated on a five-year basis would only be 

$20,000 per ton. The installation of NOX 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 turbines used in the economic analysis were the high 

cost per ton estimate and exceeded $111,000 per ton on five year basis. The cost 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 NOX 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 NOX 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 NOX MECT program. Less than 3 tpd reduction in NOX

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

E-5 
further NOX 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 NOX Reductions from Sources Currently Exempt from the MECT Program

The TCEQ evaluated the potential benefits and costs 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 NOX controls are already in place for glass furnaces and nitric acid manufacturing units, and 

further NOX reductions from these categories are not technologically feasible. The glass furnace located 

in the HGB area already has stringent NOX 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 NOX 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 possible 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, space heaters, kilns, calciners, 

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

sources of NOX emissions in the HGB ozone nonattainment area. The total NOX emissions from all these 

categories in the 2006 point source emissions inventory were approximately 0.6 tpd. Implementing NOX

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 NOX emissions 

from emissions inventory sources that are exempt the MECT program and Chapter 117. However, NOX

control on flares is not technologically feasible at this time and any reduction in NOX emissions from 

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

area represent an insignificant source of NOX emissions and the total NOX emissions from this category 

in 2006 was only 0.6 tpd. Additionally, the installation of NOX control technology such as SCR an

selective non-catalytic reduction (SNCR) on sulfuric 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 through requirements such as the prohibition on operation for testing and maintenance 

between 6:00 A.M. and noon, and requiring 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 NOX controls on chemical processing gas turbines, 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 NOX

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

implementing retrofit NOX 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 NOX 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 TCEQ 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 insensitive 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 reductions are needed to reduce ozone at the Bayland 

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

reduction control measures would not advance attainment 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 for 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 Park, 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. Additionally, 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 substantial 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 maintenance events as well as allow for future economic 

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

E-7 
Harris County is included in Chapter 4: Control Strategies and Required Elements, Section 4.6: New 

Control Measures. 

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

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

for the one-hour ozone attainment demonstration showed 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 prior 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 NOX Reductions in Attainment Counties 

Multiple modeling runs with NOX reductions outside the nonattainment area were performed to test 

different levels of NOX reductions in different sectors around the nonattainment area. The sensitivity 

runs show that any potential benefit from reductions in NOX emissions outside the nonattainment area 

would only result from reductions made east and northeast of the HGB area. A 32 tpd NOX reduction 

modeled for the counties east and northeast of the HGB 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 Deer Park and Bayland Park monitors was modeled 

between making a 32 tpd reduction in the east and northeast counties and a 62 tpd reduction in all the 

counties within 200 km surrounding the HGB area. This 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 

ties was too substantial to make 

plementing these control measures economically reasonable. 

GB 

uction in 

th

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

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

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

nonattainment area. The TCEQ evaluated extending the 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 NOX reduction and would not be sufficient to benefit the 

nonattainment area. The TCEQ estimates that to make the 32 tpd NOX reductions modeled in the 

sensitivity run, stringent NOX controls would be required on stationary 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 NOX control requirements in the East 

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

in Hardin, Jefferson, and Orange Counties to meet NOX control requirements equivalent to low-NOX

burner controls was estimated to cost 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 NOX or VOC from 

sources outside the nonattainment area would have sufficient 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 guidance 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 shows 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

M
Table E-1: HGB Area Stationary Source RACM Analysis

Control Measure Description Pollutant Point/Area Source RACM (Y/N) RACM Ana

TCEQ Initial Control Strategy Concepts 

HGB 8-County Region Controls 

Additional NOX reductions through Chapter 117 and the Chapter 101 

MECT program by revising emission specifications, revoking exemptions, expanding applicability, and resetting baseline activity years. 

NOX Point & 

Area 

N Further reduct

MECT prograsources are nofeasible. Redsources are eitechnologicalleconomically 4.2 of this app

Expand the definition of HRVOC in §115.10 to include additional VOC species under the requirements of Chapter 115 HRVOC rules and Chapter 101 HECT program. 

VOC Point & 

Area 

N Modeling indi

reductions wilattainment. 

In lieu of expanding the definition of HRVOC, create separate rules to address other VOC emissions from vents, flares, and cooling towers. 

VOC Point N Modeling indi

reductions wilattainment. 

Reduce HECT cap for Harris County in §101.394(a)(1). VOC Point Y Modeling indi

HECT cap for help advance Section 4.3.2 more detail. 

E-10
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Revoke exemptions (§§115.727(f), 115.767(6), and 101.392(c)) from site-wide caps in HRVOC rules for sources in the 7-surrounding counties and reduce cap in §101.394(a)(2). 

VOC Point N HRVOC sour

emission soursurrounding cCounty are alr§101.394(a)(2Prior modelinthe one-hour odemonstration additional HR7-surrounding advance attain

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 Area N Modeling indi

reductions wilattainment. 

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

NOX

Point N Modeling indi

reductions wilattainment. The commissievaluate flareTask Force. SSIP revision f

E-11 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Require monitoring of steam/air assist rates on assisted flares to help ensure proper operation and prevent decreased efficiency from improper operation such as over-steaming. 

VOC Point N Modeling indi

reductions wilattainment. TCEQ has insat this time to monitoring of meets RACM The potential air assist are bthrough the FlChapter 6 of tmore detail. 

General VOC monitoring rules with enhanced monitoring for flares, cooling towers, process vents, and pressure relief valves. 

VOC Point N Modeling indi

reductions wilattainment. The commissievaluate flareTask Force. SSIP revision f

Additional VOC controls for wastewater systems. VOC Point & 

Area 

N Modeling indi

reductions wilattainment. 

Additional VOC controls for upstream oil and gas VOC emissions. VOC Point & 

Area 

N Modeling indi

reductions wilattainment. 

Energy efficiency measures associated or in conjunction with MECT revisions. 

NOX Area N Not quantifiab

Not enforceab

E-12 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Eliminate certain storage tank exemptions in Chapter 115 rules. VOC Point N Modeling indi

reductions wilattainment. Reasonable coplace. 

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

VOC Point N Modeling indi

reductions wilattainment. Reasonable coplace. 

Increase control efficiency requirements in Chapter 115 rules such as vent gas control, loading, and storage. 

VOC Point & 

Area 

N Modeling indi

reductions wilattainment. Reasonable coplace. 

Best Management Practices via agreed orders or other mechanisms. NOX & 

VOC 

Point & 

Area 

N Reasonable co

place. Voluntpractices alrea

Controls for portable engines such as portable generators and other engines considered non-stationary due to temporary service. 

NOX Area N Unknown tech

economic feasEmission reduquantifiable. 

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

VOC Area N Modeling indi

reductions wilattainment. Lightering in typically only basis. Most lioffshore. 

E-13 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

VOC controls for salt dome storage facilities for brine handling/degassing and fugitive LDAR. 

VOC Point & 

Area 

N Modeling indi

reductions wilattainment. 

Refinery coker VOC emission controls. VOC Point & 

Area 

N Modeling indi

reductions wilattainment. Field studies iemissions from significant (20Absorption Li

Engine registration program for stationary and/or portable engines to help ensure better enforcement of applicable requirements, improve rule effectiveness, and proper accounting of engines in the emissions inventory. 

NOX Area N Not quantifiab

Consumer and commercial products control techniques guidelines (CTG). 

 Group II - lithographic printing materials, letterpress printing 

materials, flexible packaging printing materials, flat wood paneling coatings, industrial cleaning solvents. 

 Group III - paper, film, and foil coatings, metal furniture 

coatings, large appliance coatings. 

 Group IV - miscellaneous metal products coatings, fiberglass 

boat manufacturing materials, miscellaneous industrial adhesives, plastic parts coatings, auto and light duty truck original equipment manufacturer coatings. 

VOC Point & 

Area 

N Modeling indi

reductions wilattainment. Insignificant VPortions of ofrecommendatimplemented available cont(RACT) requiappendix D of more detail. 

Transport Controls (Outside HGB Area) 

E-14 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

NOX controls on major sources for selected source categories within 200 

km range that impact the HGB area. 

NOX Point N Not economic

Attainment coruns show insNOX reductio

justify econom

NOX controls on minor sources for selected source categories within 200 

km range that impact the HGB area. 

NOX Area N Not economic

Attainment coruns show insNOX reductio

justify econom

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 HRVOC (ethylene and propylene) or additional VOC. 

VOC Point & 

Area 

N Attainment co

runs show VOHGB will not 

Extend new upstream oil and gas flash emission, degassing, storage tank rules to sources within 100 km range that impact the HGB area. 

VOC Point & 

Area 

N Attainment co

runs show VOHGB will not 

NOX controls on engines within 200 km range that impact the HGB area. NOX Point & 

Area 

N Attainment co

runs show wilattainment. EChapter 117 Erule to countieof the HGB oarea would retpd reductions benefit would Insufficient be

reductions outeconomic impnonattainmen

E-15 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

NOX controls on power plants within 200 km range that impact the HGB 

area. 

NOX Point N Attainment co

runs show insNOX reductio

justify economattainment couCoal-fired uniproximity or dbenefit to HGarea. Turbines in Ealready well cGas-fired unitreasonable co

VOC and NOX controls on paper mills within 100 or 200 km range that 

impact the HGB area. 

VOC & 

NOX

Point N Attainment co

runs show VOHGB will not Insufficient N

to advance att

General VOC enhanced monitoring rules for flares, cooling towers, process vents, and pressure relief valves at sources within 100 km range that impact the HGB area. 

VOC Point & 

Area 

N Attainment co

runs show VOHGB will not 

Potential Measures/Concepts Suggested by Stakeholders 

Manage livestock wastes by transporting them out of the HGB nonattainment area for management and or requiring the use of air pollution control systems. 

VOC Area N Modeling indi

reductions wilattainment. Transport of wwould likely rNOX emission

vehicles. 

E-16 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Require the use of air pollution control systems at feedlots and animals waste lagoons. 

VOC Area N Modeling indi

reductions wilattainment. 

Provide incentives for improved management techniques to reduce the frequency and quantity of pesticide applications. 

VOC Area N Modeling indi

reductions wilattainment. 

Limit the allowable VOC content of pesticides. Identify lowest achievable limits through review of California and Ozone Transport Commission regulations. 

VOC Area N Modeling indi

reductions wilattainment. 

Increase the stringency of existing control requirements for asphalt paving and roofing (30 TAC 115, Subchapter F, Division 1). 

VOC Area N Modeling indi

reductions wilattainment. 

Provide incentives to convert from cutback asphalt to low-emission emulsion asphalt and hot-mix asphalt. 

VOC Area N Modeling indi

reductions wilattainment. 

Adopt South Coast Air Quality Management District (SCAQMD) content limit for emulsified asphalt (50 percent reduction). 

VOC Area N Modeling indi

reductions wilattainment. 

Restrict or prohibit the use of VOC-based parking lot sealers. VOC Area N Modeling indi

reductions wilattainment. 

Require the use of emission controls on cutback asphalt application equipment used by commercial roofers, etc. Controls could include the use of close fitting lids and restrictions on operating temperatures and or require the use of afterburners on the kettles. 

VOC Area N Modeling indi

reductions wilattainment. 

Increase stringency of existing surface coating VOC limits. Identify lowest achievable limits through review of California and Ozone Transport Commission regulations. 

VOC Area N Modeling indi

reductions wilattainment. 

E-17 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Eliminate or reduce the scope of the surface coating emission limitation exemptions (30 TAC §115.427). 

VOC Area N Modeling indi

reductions wilattainment. 

Require the use of or provide incentives for using ozone-destroying catalyst coatings. 

Ozone Area N Not quantifiab

Not demonstrfeasible to actmanner to advPotential smalcitizen economPotential advequality. 

Consider VOC reactivity in establishing VOC coating content or requiring the use of air pollution controls. 

VOC Area N Modeling indi

reductions wilattainment. 

Review existing list regulated sources (30 TAC 115, Subchapter E, Solvent-Using Processes, Division 2, Surface Coating Processes) and establish emission limits for those sources currently excluded. 

VOC Area N Modeling indi

reductions wilattainment. 

Establish recording and reporting requirements for industrial and nonindustrial chlorine use for possible opportunities to reduce chlorine emissions. 

Chlorine Point & 

Area 

N Not an actual 

control measuUnknown whecontrols on chcurrent permittechnologicallReduction in aemissions wilattainment. Nchlorine (e.g., expected to faanthropogenic 

E-18 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Provide financial assistance for performing energy audits and or implementation of energy saving measures that reduce demand and emissions from electric generating units (EGUs) and/or heating systems. 

NOX Area N Not enforceab

have legislativimplement. Afor such incenpermanent; thprograms do nSIP creditable Not quantifiab

Revise building codes to require energy efficient designs and materials that reduce demand and emissions from EGUs and or heating systems. Measures could include more insulation, use of reflective glass, use or reflective paints, use of multi-paned glass, use of white or reflective roofs (International Energy Conservation Code (IECC)). 

NOX Area N Not enforceab

authority to imNot quantifiab

Mandatory public building compliance with IECC. NOX Area N Not enforceab

authority to imNot quantifiab

Require that a certain percentage of power purchased for public facilities come from renewable or non-emitting sources. 

NOX Area N Not enforceab

authority to imNot quantifiab

Provide incentives for energy conservation measures such as timed lighting for parking lots, outdoor advertisements and buildings, occupancy sensors for office lighting, and for turning off computers. 

NOX Area N Not enforceab

authority to imAny legislativincentive progpermanent; thprograms do nSIP creditable Not quantifiab

E-19 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Provide incentives for using energy efficient PC networks (shutdown of computers when not in use). 

NOX Area N Not enforceab

authority to imAny legislativincentive progpermanent; thprograms do nSIP creditable Not quantifiab

Prohibit or restrict the burning of leaves and yard clippings or require the application of emission controls. 

VOC Area N Modeling indi

reductions wilattainment. Outdoor burniestablished un111, Subchap

Establish new consumer product VOC limits (California Air Resources Board (CARB) – Cons 1 and 2). 

VOC Area N Modeling indi

reductions wilattainment 

Adopt SCAQMD Phase III VOC limits. VOC Area N Modeling indi

reductions wilattainment 

Adopt CARB rules regarding mid-term and or long-term limits on VOC content of consumer products. 

VOC Area N Modeling indi

reductions wilattainment 

Provide incentives for the substitution on non-VOC based cleaners for VOC based cleaners. 

VOC Area N Modeling indi

reductions wilattainment 

Require the use of or provide incentives for the reformulation of VOC bearing commercial products such as paints, cleaners, etc. 

VOC Area N Modeling indi

reductions wilattainment. 

E-20 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Limit automotive windshield washer fluid to less than the 23.5 percent VOC currently allow by 30 TAC 115, Subchapter G, Division 1. 

VOC Area N Modeling indi

reductions wilattainment. Reasonable co

Adopt Ozone Transport Commission Model Rule with additional product coverage and more stringent VOC limits. 

VOC Area N Modeling indi

reductions wilattainment. 

Increase stringency of existing control requirements in 30 TAC 115, Subchapter E, Division 1. This could include measures requiring the use of low VOC solvents for cold cleaning operations or replacement with wipe cleaning. 

VOC Area N Modeling indi

reductions wilattainment. 

Put one-hour ozone contingency rules in 30 TAC 115, Subchapter F, Division 4 into effect. 

VOC Area N Modeling indi

reductions wilattainment. 

Increase solvent recovery requirement in 30 TAC §115.552(a) from 85 percent to 90 percent or greater. Contingency rules must be put into effect first. 

VOC Area N Modeling indi

reductions wilattainment. 

Lower or eliminate the 2,000 gallon per year use exemption in 30 TAC §115.557. Contingency rules must be put into effect first. 

VOC Area N Modeling indi

reductions wilattainment. 

Establish emission control requirements for food product manufacturing and processing operations. 

VOC Area N Modeling indi

reductions wilattainment. 

Require the use of catalytic oxidizers or equivalent controls on chain drive char-broilers. 

VOC Area N Modeling indi

reductions wilattainment. 

E-21 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Establish limits for the VOC content of charcoal lighter fluid. VOC Area N Modeling indi

reductions wilattainment. 

Replace fuel dispensing hoses to reduce permeation. VOC Area N Modeling indi

reductions wilattainment. 

Extend Stage I vapor recovery system requirements to counties outside of the HGB nonattainment area. 

VOC Area N Attainment co

runs show VOHGB will not 

Eliminate or reduce the Stage I vapor recovery exemptions in 30 TAC §115.227. 

VOC Area N Modeling indi

reductions wilattainment. 

Adopt CARB enhanced vapor recovery Stage I requirements (98 percent control) in HGB area and potentially surrounding counties. 

VOC Area N Modeling indi

reductions wilattainment. 

Extend the transport vehicle leak test provisions of 30 TAC 115, Subchapter C, Division 3, to counties outside of the HGB area. 

VOC Area N Attainment co

runs show VOHGB will not 

Eliminate or reduce the transport vehicle leak test exemptions in 30 TAC §115.237. 

VOC Area N Modeling indi

reductions wilattainment. 

Extend Stage II vapor recovery system requirements to counties outside of the HGB nonattainment area. 

VOC Area N Attainment co

runs show VOHGB will not 

Eliminate or reduce the Stage II vapor recovery exemptions in 30 TAC §115.247. 

VOC Area N Modeling indi

reductions wilattainment. 

E-22 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Implement a “stop at the click” awareness program to discourage overfilling of vehicles during refueling. 

VOC Area N Modeling indi

reductions wilattainment. Not quantifiab

Implement an off-road equipment fuel tank program. VOC Area N Modeling indi

reductions wilattainment. 

Develop and implement emission control measures for hair and nail salons. 

VOC Area N Modeling indi

reductions wilattainment. 

Extend municipal landfill emission control requirements to counties outside of HGB nonattainment area. 

VOC Area N Attainment co

runs show VOHGB will not 

Regulate emissions from the excavation of landfills. VOC Area N Unknown tech

controlling emexcavation. Modeling indireductions wilattainment. 

Require the use of co-composting operations to limit VOC emissions. Includes the mixing of bio-solids or manure with bulking agents. 

VOC Area N Modeling indi

reductions wilattainment. 

Establish emission limits or control requirements for glycol dehydration units (oil and gas production). Emission limits could build upon emission limits established by 40 CFR 63, Subpart HH, to control hazardous air pollutants emissions from glycol dehydration units. 

VOC Area N Modeling indi

reductions wilattainment. 

E-23 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Require implementation of instrument based fugitive emissions monitoring and leak repair programs at oil and gas production facilities. 

VOC Area N Modeling indi

reductions wilattainment. Reasonable coplace. 

Establish requirements or provide incentives for the use of NOX

emission reduction software. 

NOX Area N Not enforceab

Not quantifiab

Provide additional incentives for the use of low-emitting, distributed power generating systems such as wind, solar, micro-turbines, fuel cells, etc., reducing the demand and associated emissions from EGUs. 

NOX Area N Not enforceab

Not quantifiabAny legislativincentive progpermanent; thprograms do nSIP creditable 

Provide additional incentives for the capture of landfill gas for use in combustion turbines to generate electricity, reducing the demand and associated emissions from EGUs. 

NOX Area N Not enforceab

Not quantifiabMay actually 

emissions due 

technology limgas. Siloxanecontaminant c

control technofiring landfill Any legislativincentive progpermanent; thprograms do nSIP creditable 

E-24 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Explore technologies and opportunities to reduce transmission in losses with resulting reductions in demand and associated emissions from EGUs. 

NOX Area N Not enforceab

Not quantifiabNot demonstrfeasible. 

Establish more stringent VOC content limitations and or emission control requirements for rotogravure and flexographic printing operations than specified in 30 TAC 115, Subchapter E, Division 3. 

VOC Area N Modeling indi

reductions wilattainment. 

Eliminate or reduce the rotogravure and flexographic printing emission control exemptions in 30 TAC §115.437. 

VOC Area N Modeling indi

reductions wilattainment. 

Eliminate or reduce the offset lithographic printing emission control exemptions in 30 TAC §115.437. 

VOC Area N Modeling indi

reductions wilattainment. Portions of ofrecommendatimplemented 

Partner with local governments in efforts to reduce urban heat island effects and thus reduce EGU demand and associated emissions. 

NOX Area N Not enforceab

Not quantifiab

Investigate opportunities to improve local policies toward energy efficiency. 

NOX Area N Not enforceab

Not quantifiab

Implement efficiency based natural gas rates to reward conservation NOX Area N Not enforceab

authority to im

E-25 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Provide incentives for companies to buy energy efficient products. NOX Area N Not enforceab

Not quantifiabAny legislativincentive progpermanent; thprograms do nSIP creditable 

Provide incentives for companies and individual consumers to replace older, energy inefficient appliances with new Energy Star products. 

NOX Area N Not enforceab

Not quantifiabAny legislativincentive progpermanent; thprograms do nSIP creditable 

Provide incentives for companies and individual consumers to replace energy inefficient heating and air conditioning systems with new, more efficient units. 

NOX Area N Not enforceab

TCEQ has no implement. Any legislativincentive progpermanent; thprograms do nSIP creditable Not quantifiab

Implement public awareness campaigns for energy efficiency. NOX Area N Not enforceab

Not quantifiab

E-26 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Provide incentives for cities and counties to promote and encourage development patterns that reduce emissions of air pollutants. 

NOX & 

VOC 

Area N Not enforceab

Any legislativincentive progpermanent; thprograms do nSIP creditable Not quantifiab

Implement a ban on new developments that would result in any increase in air pollutants. 

NOX & 

VOC 

Area N Not enforceab

Clean Air Act allow TCEQ tapplication bait is a new sou

Establish mitigation fees for land development and other projects that result in additional area source emissions that are proportional to the anticipated increase in NOX and or VOC emissions. 

NOX & 

VOC 

Area N Not quantifiab

reduction ben

Promote or require the planting trees (reduce EGU demand and emissions) and the use of plants that require less maintenance (reduce emissions from landscape maintenance equipment). 

NOX & 

VOC 

Area N Not enforceab

Not quantifiab

Require mitigation of trees removed during development. NOX Area N Not enforceab

Not quantifiab

Provide financial incentives to developers and homeowners to use or convert to plants that require less maintenance (reduced emissions from landscape maintenance equipment). 

NOX Area N Not enforceab

Any legislativincentive progpermanent; thprograms do nSIP creditable Not quantifiab

E-27 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Establish emission control requirements for publicly owned wastewater treatment facilities. 

VOC Area N Modeling indi

reductions wilattainment. 

Establish requirements and/or provide incentives for the replacement of pilot lights on gas stoves with electronic ignitions. 

NOX Area N Potential tech

with retrofit oappliances. Not enforceabAny legislativincentive progpermanent; thprograms do nSIP creditable 

Establish requirements and/or provide incentives for the replacement of hot water heater pilot ignitions with electronic ignitions. 

NOX Area N Unknown tech

to retrofit houNot enforceabAny legislativincentive progpermanent; thprograms do nSIP creditable 

Establish requirements and/or provide incentives for the use of low NOX

hot water heaters. 

NOX Area N Not enforceab

prohibition on 

less than 40 nheaters (HB 9

2007). Currenheater rule estng/J on reside

E-28 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Establish requirements and or provide incentives for the replacement of hot water heaters with on-demand heat exchange systems. 

NOX Area N Tank-less or o

heaters are cuChapter 117 wthe incentives water heaters Any legislativincentive progpermanent; thprograms do nSIP creditable 

Prohibit or restrict the sale and use of wood burning fireplaces and wood burning stoves in the HGB nonattainment area. 

VOC Area N Modeling indi

reductions wilattainment. De minimis emlikely only duozone months

Establish requirements and or provide incentives for the replacement of residential combustion sources with lower emitting sources (replacing natural gas fired units with electric units, for example). 

NOX Area N Not enforceab

TCEQ does nmandate the inequipment typAny legislativincentive progpermanent; thprograms do nSIP creditable 

E-29 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Eliminate NOX MECT program and revert to source-by-source emission 

limitations with limits set equal to Lowest Achievable Emission Rate technology or other. 

NOX Point N NOX MECT p

efficient meaneffective reduAdditional NO

MECT sourcefeasible. See appendix for m

Establish source-by-source emission limits (not cap and trade) on HRVOC and or other VOCs for sources located outside of the HGB nonattainment area. 

VOC Point N Attainment co

runs show VOHGB will not 

Eliminate HRVOC cap and trade program and control emissions exclusively through source by source emission limitations in the HGB nonattainment area. 

VOC Point N HECT progra

effective meanreductions. 

Revise or eliminate some or all exemptions (30 TAC §117.203) for NOX

MECT applicability, including temporary sources (such as engines in test cells), sources in limited use applications (exemptions for emergency generators and diesel engines installed prior to October 1, 2001), heat treat and reheat furnaces rated less than 20 MMBtu/hr, incinerators rated less than 40 MMBtu/hr, boilers and process heaters rated 2 MMBtu/hr or less, dryers and ovens, chemical processing gas turbines and flares. 

NOX Point N Not economic

See Section 4more detail. 

Extend NOX MECT program to stationary sources that are currently not 

subject to program requirements (facilities where no ESAD has been established). 

NOX Point N Not technolog

some currentleconomically See Section 4more detail. 

E-30 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Eliminate the distinction between major and small sources, applying the ESAD found in 30 TAC §117.206 to all sources regardless of site-wide potential to emit. 

NOX Point N Chapter 117 H

Rule already eemission limitengines, boileturbines at miAdverse econholding small stringent stand

Eliminate the exemption for sources with uncontrolled emissions at design capacity of less than 10 tons per year. 

NOX Point & 

Area 

N Chapter 117 H

Rule already eemission limitengines, boileturbines at mi

Provide financial incentives for demand side management. NOX Point N Not enforceab

Any legislativincentive progpermanent; thprograms do nSIP creditable Not quantifiab

Provide additional financial incentives for reducing emissions by increasing the annual fee paid on NOX emissions. 

NOX Point N Not quantifiab

tons of reductemissions feereduction in a

Include engines located at EGUs in NOX MECT program. NOX Point N Will not adva

De minimis emat EGU sites, NOX emission 

E-31 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Provide financial incentives for investment in lower polluting or nonpolluting power generation technologies. NOX Point N Not quantifiab

Any legislativincentive progpermanent; thprograms do nSIP creditable 

Extend NOX MECT program to combustion sources located outside of 

the HGB area. Inclusion could be limited to larger, more numerous industrial sources (industrial, commercial, institutional boilers, process heaters, large engines, large turbines, smelter furnaces, cement and brick kilns, etc.) or could include the same source categories covered by the HGB SIP. 

NOX Point N Attainment co

runs show ecoNOX reductio

nonattainmenattainment. 

Implement separate NOX cap and trade program for sources located 

outside of the HGB nonattainment area. 

NOX Point N Attainment co

runs show ecoNOX reductio

nonattainmenattainment. 

Lower NOX MECT cap by reallocating allowances based on lower 

ESAD (1999 SIP values or other). 

NOX Point N Not economic

See Section 4more detail. 

Lower NOX MECT cap reallocating allowances through across-theboard reductions. NOX Point N Not economic

See Section 4more detail. 

Extend NOX MECT program to include non-stationary engines. NOX Point N Unknown tech

economic feasEmission reduquantifiable. 

E-32 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Extend NOX MECT program to EGUs outside of the HGB 

nonattainment area. 

NOX Point N Attainment co

runs show ecoNOX reductio

not advance aCoal-fired uniproximity or dbenefit to HGarea. Turbines in Ealready well cGas-fired unitreasonable co

Expand applicability of the HRVOC cap and trade program beyond flares, process vents, cooling towers and process fugitive emissions. 

VOC Point N The suggested 

quantifiable bprogram alrearelevant sourcto emit HRVOFugitive HRVcontrolled sepTAC Chapter Division 3. 

Extend current HRVOC cap and trade program to other VOC species and trade emissions based on reactivity. 

VOC Point N Modeling indi

reductions wilattainment. 

Expand application of cap and trade concept to others sources of VOC storage tanks, loading racks, wastewater treatment operations, barge/ship loading operations 

VOC Point N Modeling indi

reductions wilattainment 

E-33 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Eliminate the HRVOC cap and trade exemption for sources with potential emissions of less than 10 tons per year. 

VOC Point N HRVOC sour

subject to Charules but less exempt but limHECT site, noare not a signiHRVOC emisHECT/non-fuemissions for estimated to b

Revoke the HRVOC cap and trade exemption for sources located in the 

HGB area outside of Harris County. 

VOC Point N Modeling indi

reductions outwill not advan

Extend HRVOC cap and trade program to sources located outside of the HGB area. 

VOC Point N Attainment co

runs show VOHGB will not 

Lower HRVOC cap. Reallocate allowances using existing allocation procedures but lower annual emission caps. 

VOC Point Y Modeling indi

HECT cap for help advance Section 4.3.2 

Extend 1,200 lb/hr HRVOC emission limit to sources located outside of the HGB area. 

VOC Point N Attainment co

runs show redHGB area wilattainment. 

Implement HRVOC program type monitoring requirements for other VOC emissions from flares, cooling towers, and or process vents. 

VOC Point N Modeling indi

reductions wilattainment. 

E-34 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Expand HRVOC fugitive monitoring requirements to other VOC species. VOC Point N Modeling indi

reductions wilattainment. 

Expand applicability of the industrial wastewater regulations beyond the list of affected source categories in 30 TAC §115.140(1). 

VOC Point N Modeling indi

reductions wilattainment, 

Make existing industrial wastewater regulations more stringent (revise VOC reduction requirement form 90 percent to 95 percent). 

VOC Point N Modeling indi

reductions wilattainment 

Provide additional financial incentive for reducing emissions by increasing the annual fee paid on VOC emissions. 

VOC Point N Modeling indi

reductions wilattainment 

Develop and implement more stringent guidance on Best Available Control Technology (BACT) requirements for New Source Review (NSR) authorization issued to sources in the HGB nonattainment area and potentially sources outside the HGB nonattainment area. 

VOC & 

NOX

Point N Not quantifiab

of NOX or VO

BACT cannot because the Twhether existiBACT in the fsources requirpermitted. BACT is a seprequirement oModeling indioutside the nonot advance a

Manage composting operations. Potential control measures could include registration of composting, chipping, and grinding facilities; establish holding and or processing time requirements for green waste; and establish VOC emission control requirements. 

VOC Point N Modeling indi

reductions wilattainment. 

E-35 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Control emissions from airport terminals. VOC & 

NOX

Point N Chapter 117 M

establishes coNOX sources. 

General confoapply to federSee Table E-2 more detail on sources. 

Control emissions through facility energy conservation programs. NOX Point N Not enforceab

Not quantifiab

Control emission from aircraft maintenance operations. NOX Point N Chapter 117 M

establishes coNOX sources. 

General confoapply to federSee Table E-2 more detail on sources. 

Revise control requirements for bakeries in 30 TAC §115.122 from 80 percent to 90 percent or greater. 

VOC Point N Modeling indi

reductions wilattainment. De minimis emtpd total emissource emissio

Lower or eliminate the 25 tons per year threshold for requiring controls for bakeries. 

VOC Point N Modeling indi

reductions wilattainment. 

Implement housekeeping practices in breweries to minimize spillage during filling, keg cleaning and waste beer processing. 

VOC Point N Modeling indi

reductions wilattainment. 

E-36 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Develop and implement brewery source specific wastewater treatment requirements. Alternatively, brewery sources would be subject to industrial wastewater regulations. 

VOC Point N Modeling indi

reductions wilattainment. 

Establish VOC emission limitation from brewery fermentation tanks. VOC Point N Modeling indi

reductions wilattainment. 

Require the control of emissions from dryers and heaters for cutback asphalt processes. 

NOX 

&VOC 

Point N Technologica

feasibility for heaters and drModeling indireductions wilattainment. NOX emission

heaters in 200inventory are 

Adopt emission limits based on retrofit BACT level of 0.07-0.1 lb/MMBtu. 

NOX Point N No quantifiab

More stringenplace either thlimits or MECESAD for boiheaters and msources in HG0.07 - 0.1 lb/M

Adopt 90 percent reduction from uncontrolled emissions for EGUs. NOX Point N Additional NO

EGUs are not See Section 4more detail. 

Make requirements of 30 TAC 115, Subchapter D, Division 3 (equipment leaks) more stringent (similar to HRVOC monitoring). 

VOC Point N Modeling indi

reductions wilattainment. 

E-37 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Lower leak detection limits for equipment leaks. VOC Point N Modeling indi

reductions wilattainment. Reasonable coplace. 

Require instrument monitoring of connectors for equipment leaks. VOC Point N Modeling indi

reductions wilattainment. Rules already 115 general Vfugitive rules. 

Require that existing flares be retrofitted to conform to 40 CFR §60.18 design standards. 

VOC Point N No quantifiab

§60.18 does nstandards, onl

Review various California air quality district rules and regulations to identify additional emission reduction opportunities. 

NOX & 

VOC 

Point N The suggestio

potential contCalifornia rulepart of researcstrategies. 

Revise control requirements in 30 TAC §115.212 for VOC loading operations from 90 percent to 95 percent or greater. 

VOC Point N Modeling indi

reductions wilattainment. 

Require the use of low volume quick disconnects from railcar and tanker truck loading and unloading operations. 

VOC Point N Modeling indi

reductions wilattainment. 

Require the implementation of work practices in metal production to minimize VOC in furnace charge material or require use of gas fired preheater where the flame directly contacts the scrap charge. 

VOC Point N Modeling indi

reductions wilattainment. 

E-38 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Limit repair, maintenance, cleaning and other non-production related activities on ozone alert days. 

NOX & 

VOC 

Point N Measure is im

these activitiescheduled in anotification of typically 24 hnot provide surescheduling tModeling indireductions wilattainment. 

Restrict the testing of emergency generators and other support equipment on ozone alert days. 

NOX Point N Already addre

prohibition of maintenance obetween 6:00 everyday, not 

Revise process vent control requirements in 30 TAC §115.122(a)(1) to require at least 95 percent control. 

VOC Point N Modeling indi

reductions wilattainment. 

Lower allowable VOC content of surface coatings in 30 TAC 115, Subchapter E, Division 2. 

VOC Point N Modeling indi

reductions wilattainment. 

Additional control of VOC emissions based on new EPA CTGs. VOC Point & 

Area 

N Modeling indi

reductions wilattainment. Portions of thCTG recommimplemented requirements. 

E-39 
Table E-1: HGB Area Stationary Source RACM Analysis

Point/Area RACM Control Measure Description Pollutant RACM Ana

Source (Y/N) 

Implementation of additional monitoring of steam and air assist flares, especially flares in HRVOC service. 

VOC Point N TCEQ has ins

at this time to monitoring of meets RACM The potential air assist are bthrough the FlChapter 6 of tmore detail. 

Implementation of additional monitoring of flares in general VOC services to improve VOC inventory. 

VOC Point N Modeling indi

reductions wilattainment. The commissievaluate flareTask Force. SSIP revision f

For flares: 

 Rigorously and consistently, enforce existing flare operation 

requirements. 

 Expand and accelerate research on factors that affect flare 

burning efficiency, alternatives to flares, and flare monitoring. 

 Revise TCEQ policies and guidelines for estimating flare 

emissions for rulemaking, permitting, enforcement, reporting, and planning activities to take into account the effects of steam and crosswinds. 

 Require more extensive monitoring/reporting of flare emissions.  Increase flare gas recovery system use or other technologies, 

like enclosed ground flares or thermal oxidizers, to control emissions. 

 Use elevated flares only in emergencies and start-ups and 

shutdowns of equipment. 

VOC Point N Modeling indi

reductions wilattainment. TCEQ has insat this time to monitoring of rates meets RAThe commissievaluate flareTask Force. SSIP revision f

E-40 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

Control Measure Description Pollutant 

OnRoad/NonRoad RACM (Y/N) RAC

TCEQ Draft Initial Control Strategy Concepts

HGB 8-County Region Controls 

Ban Segways from use on sidewalks and hike/bike trails. NOX and 

VOC 

On-Road N Not quantifiab

Safer bike routes with better signs marking lanes and routes. NOX and 

VOC

On-Road N Not quantifiab

Inclusion of bicycle lanes on state/federal funded thoroughfare projects. 

NOX and 

VOC

On-Road N Not quantifiab

Bicycle route signalization. NOX and 

VOC

On-Road N Not quantifiab

E-41 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

Bicycle lanes on every arterial/frontage road. NOX and 

VOC

On-Road N Not quantifiab

Bicycle lane/path repaving. NOX and 

VOC

On-Road N Not quantifiab

Bicycle route lighting. NOX and 

VOC

On-Road N Not quantifiab

Increased bicycle/pedestrian outreach to immigrant communities. NOX and 

VOC

On-Road N Not quantifiab

Media coverage/promotion of bicycle facilities. NOX and 

VOC

On-Road N Not quantifiab

Bicycle education. NOX and 

VOC

On-Road N Not quantifiab

Region-wide mandatory bicycle racks at work sites. NOX and 

VOC

On-Road N Not quantifiab

Address security concerns of pedestrians/cyclists. NOX and 

VOC

On-Road N Not quantifiab

Showers and clothing lockers. NOX and 

VOC

On-Road N Not quantifiab

Bicycle lockers, rack, and other storage facilities. NOX and 

VOC

On-Road N Not quantifiab

Biking/hiking patrols to ensure safety. NOX and 

VOC

On-Road N Not quantifiab

Integration of bicycle/pedestrian facilities with transit. NOX and 

VOC

On-Road N Not quantifiab

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

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

Permit bicycles on rail transit. NOX and 

VOC

On-Road N Not quantifiab

Bicycle racks on buses. NOX and 

VOC

On-Road N Not quantifiab

Street level shops. NOX and 

VOC

On-Road N Not quantifiab

Give bicyclists/pedestrians the right-of-way. NOX and 

VOC

On-Road N Not quantifiab

Cyclist/pedestrian sidewalk furniture. NOX and 

VOC

On-Road N Not quantifiab

Sidewalks and walkways. NOX and 

VOC

On-Road N Not quantifiab

Crosswalks. NOX and 

VOC

On-Road N Not quantifiab

Additional pedestrian access and circulation. NOX and 

VOC

On-Road N Not quantifiab

Pedestrian signals. NOX and 

VOC

On-Road N Not quantifiab

Connected street system and pedestrian pass-throughs. NOX and 

VOC

On-Road N Not quantifiab

Pedestrian design improvements. NOX and 

VOC

On-Road N Not quantifiab

Mid-block pedestrian connections. NOX and 

VOC

On-Road N Not quantifiab

E-43 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

Wide, unobstructed sidewalks on both sides of all arterials, major roads, and other streets. 

NOX and 

VOC

On-Road N Not quantifiab

Fuel cell school buses. NOX On-Road N Technology is 

and is cost pro

Airport use of Ultra Low Emitting Vehicle (ULEV) or electric vehicles instead of diesel for ground transportation. 

NOX and 

VOC

On-Road N Measure is be

implemented memorandum(MOAs) in th

Propane school buses. NOX On-Road N Reductions to

attainment. 

Use solar cells to run air conditioning and other electrical equipment on Metro buses. 

NOX On-Road N Not quantifiab

Locate hazardous freeway areas for possible improvements, sharp turns, clover leafs, etc. 

NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Limit road and highway improvements to those benefiting transit and high occupancy vehicle lanes. 

NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Shift highway funds to transit. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

No new peripheral highways or loops. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

E-44 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

California diesel fuel. NOX On-Road N Texas Low Em

(TxLED) is an under Texas' SPlan (SIP) and California die

Reformulated fuels for off-road vehicles. NOX On-Road N Federal Refor

required in the Brazoria nona

Educate public about fuel savings from properly inflated tires, regular tune-ups, and driving speed. 

NOX and 

VOC 

On-Road N Not quantifiab

Celebrity volunteers for ozone alert announcements. NOX and 

VOC

On-Road N Not quantifiab

Air quality public outreach. NOX and 

VOC

On-Road N Not quantifiab

Designated truck routes. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Dedicate truck lanes. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Require short-haul trucks to use alternative fuels. NOX On-Road N Not quantifiabBan the use of High Occupancy Vehicle (HOV) lanes by trucks. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

More aggressive HOV enforcement. NOX and 

VOC 

On-Road N Legislative ac

mandate.

E-45 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

HOV service on all freeways with increased access. NOX and 

VOC 

On-Road N Legislative ac

mandate.

Focus on finding extreme high emitters with emphasis on finding and replacing, not penalizing. 

NOX and 

VOC 

On-Road N Not quantifiab

Roadside pullovers. 

 Portable inspection/maintenance measures. 

NOX and 

VOC 

On-Road N Not quantifiab

High-emitting vehicle repair assistance. NOX and 

VOC

On-Road N Not quantifiab

Accelerated vehicle retirement program. NOX and 

VOC

On-Road N The Drive a C

is implementearea/reductionattainment. 

Dedicated funding for school bus replacement. 

 This should require alternative fueled vehicles. 

NOX On-Road N Reductions to 

attainment. 

Buy vehicles older than model year 1975 to retire from use. NOX and 

VOC

On-Road N The Drive a C

is implementearea/reductionattainment. 

Expanded repair and replacement assistance program. NOX and 

VOC

On-Road N The Drive a C

is implementearea/reductionattainment/exwould require implement. 

E-46 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

New vehicle discounts for old vehicle trade-ins. NOX and 

VOC

On-Road N The Drive a C

is implementearea/reductionattainment. 

Transit passes/credit in exchange for old vehicle scrappage. NOX and 

VOC

On-Road N Not quantifiab

Ban sale of high-emitting vehicles. NOX and 

VOC

On-Road N Legislative ac

mandate. 

Deny registration to vehicles with repeated emission failures. NOX and 

VOC

On-Road N The TCEQ's V

Denial programotorists to reozone nonattavehicle failed has not passelast twelve mo

Increase parking at transit centers or stops. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Provide parking at all major transit stations. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Cheaper gasoline prices during evening hours. VOC On-Road N Legislative ac

mandate. 

Discourage people to have multiple cars. NOX and 

VOC

On-Road N Not quantifiab

E-47 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

State and local exemptions for pooling/transit subsidies. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

No tolls for buses and vanpools. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Manage location of new growth to limit additional sprawl. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Mixed use development ordinance and zones. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Encourage or require complementary uses in close proximity in all developments or development areas. 

NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Stop freeway bottleneck improvements that add lanes instead of focusing on transit. 

NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Prohibit truck use of right lanes for loading on bus and bike routes. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Pedestrian mall route diversion. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Require two or more occupants per vehicle to enter designated congested activity centers during am and pm peak traffic periods. 

NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

E-48 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

More transit access near universities and airports. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Light rail. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Commuter rail. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

High-speed rail. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Encourage the use of jitneys. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Encourage putting METRO and other public buses on propane or other lower polluting fuels. 

NOX On-Road N Consideration 

the region's trprocess. 

Subsidize transit service. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Implement seamless public transit, connectivity. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

E-49 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

Mandatory employer trip reduction programs for all employers who employ 20 or more people. 

NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. Would require implement. 

Restrict student drivers to high schools. NOX and 

VOC 

On-Road N Would require 

implement. 

Engine software upgrade (DHV4) or low NOX software upgrade. NOX On-Road N TCEQ follow

Environmentaguidance/no n

School bus idling Airborne Toxic Control Measure. NOX On-Road N Not quantifiabStatewide emissions testing. NOX and 

VOC 

On-Road N Would require 

and legislative 

Centralized IM-240 test with repairs done separately. NOX and 

VOC 

On-Road N Texas utilizes 

testing which IM-240 testin

benefit. 

Raise the driving age. NOX and 

VOC 

On-Road N Would require 

implement. 

Close loopholes in the Texas Clean Fleet Program making fewer exemptions for fleets. 

 Tier 2 light-duty and 2007 heavy-duty vehicle emissions 

standards have superseded the original proposal. 

NOX On-Road N Senate Bill 10

Legislature, 2repealed the TProgram. 

Electric vehicles. NOX and 

VOC 

On-Road N Measure is be

implemented region. 

E-50 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

Cleaner diesel fuel. 

 Some diesel fuels have improved performance beyond 

TxLED. 

NOX On-Road N TxLED is req

At this time, tfuels that are TxLED. 

Permit HOV lane use by qualifying low emission vehicles. NOX On-Road N Consideration 

the region's trprocess. 

Single Occupant Vehicles (SOV) access to HOV and transit stations. 

 Provide direct freeway access to adjoining HOV or transit 

park-and-ride facilities to encourage use and expedite access. 

NOX On-Road N Consideration 

the region's trprocess. 

Managed lanes to accommodate some SOVs in HOV lanes. 

 Permit limited use of HOV lanes by SOV using tolls or 

other limiting technique in highly congested corridors where speeds are below 20 miles per hour. 

NOX On-Road N Consideration 

the region's trprocess. 

Rewards for reporting smoking or high emitting vehicles. NOX On-Road N Not quantifiabEnforce smoking vehicle reports and require repairs. 

 Require vehicle to be retested. 

NOX On-Road N The Drive a C

offers financiavehicles that freductions too attainment. 

Low-interest financing for low income and/or old vehicle trade-ins. 

 Financing made available to vehicle owners not eligible for 

Drive a Clean Machine replacement option. 

NOX and 

VOC 

On-Road N Would require 

implement. 

Aggressive driving enforcement. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

E-51 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

Incentive for infill and redevelopment. 

 Incentives for master planned communities planned around 

lower vehicle travel. 

NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Reduce transit fares. NOX and 

VOC 

On-Road N Not quantifiab

Accelerate rail expansion. NOX and 

VOC 

On-Road N Consideration 

the region's trprocess. 

Share hybrid vehicles. NOX and 

VOC 

On-Road N Not quantifiab

Enhanced enforcement for Smoking Vehicle Program. 

 Vehicle impounding for violators. 

NOX On-Road N The Local Ini

funding to cousmoking vehicnonattainmennonattainmensmall to accel

Inspection and Maintenance (I/M) - Chambers, Liberty, and Waller Counties. 

NOX On-Road N Legislative/lo

implement.. 

Idling Reduction. NOX On-Road N Consideration 

the region's trprocess. 

Disincentives such as fines if caught mowing during Ozone Alerts. VOC Non-Road N Modeling indi

reductions wilattainment / nenforceable. 

E-52 
Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis 

On- RACM 

Control Measure Description Pollutant Road/NonRoad (Y/N) RAC

Ban equipment such as two-stroke engines. VOC Non-Road N Modeling indi

reductions wilattainment and enforceable. 

Electrification of rail. NOX Non-Road N Not quantifiabAircraft vapor recovery. VOC Non-Road N Modeling indi

reductions wilattainment. 

Use electric or cleaner technology auxiliary power units (APUs) for gate electrification. 

NOX and 

VOC 

Non-Road N Bush Intercon

William P. Hoalready impleon all gates. 

Use electric or cleaner technology APUs for preconditioned air. NOX and 

VOC 

Non-Road N Bush Intercon

William P. Hoalready impleon all gates. 

Use liquefied natural gas and compressed natural engines for locomotives. 

NOX Non-Road N Locomotive e

in Federal RegFederal regulafor additional 

Selective catalytic reduction for locomotives. NOX Non-Road N Locomotive e

in Federal RegFederal regulafor additional 

Marine TxLED in east and central Texas counties (currently only in HGB area). 

NOX Non-Road N TxLED is req

nonattainmen

E-53 
E-54 

Table E-2: HGB Area On-Road and Non-Road Mobile Sources RACM Analysis Control Measure Description Pollutant 

OnRoad/NonRoad RACM (Y/N) RAC

Green Port Initiatives. NOX and 

VOC 

On-Road 

and NonRoad 

N Consideration 

the region's trprocess. 

Texas Emissions Reduction Plan (TERP). NOX On-Road 

and NonRoad 

N TERP has bee

HGB area sin
APPENDIX E 

REASONABLY AVAILABLE CONTROL MEASURE ANALYSIS 

 

Attachment 1 

Control Strategy Planning Draft Initial Concept Lists Presented to Stakeholders 

E-55
TCEQ / CEO / AQP Section - Stationary Source Programs Team / March 25, 2008 Page 1 

Houston-Galveston-Brazoria (HGB) Eight-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 further 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 (NOX) reductions through Chapter 117 and the 

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

specifications, revoking exemptions, expanding applicability, and resetting 

baseline activity years. 

NOX

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 HRVOC, create separate rules to address 

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

VOC 

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

Revoke exemptions from site-wide caps 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 & 

NOX

Require monitoring of steam/air assist rates on assisted flares to help ensure 

proper operation and prevent decreased efficiency from improper operation such 

as over-steaming. 

VOC 

General VOC monitoring rules with enhanced monitoring for flares, cooling 

towers, process vents, and pressure 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) Eight-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 further 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. NOX

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. NOX and 

VOC 

Controls for portable engines such as portable generators and other engines 

considered non-stationary due to temporary service. 

NOX

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

VOC controls for salt dome storage facilities for brine handling/degassing and 

fugitive LDAR. 

VOC 

Refinery coker VOC emission controls. VOC 

Transport Controls (Outside HGB) 

NOX controls on major sources for selected source categories within 200 

kilometer (km) range that impact the HGB area. 

NOX

NOX controls on minor sources for selected source categories within 200 km 

range that impact the HGB area. 

NOX

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) Eight-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 further 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 

NOX controls on engines within 200 km range that impact the HGB area. NOX

NOX controls on power plants within 200 km range that impact the HGB area. NOX

VOC and NOX controls on paper mills within 100 or 200 km range that impact 

the HGB area. 

VOC & 

NOX

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

vents, and PRVs at sources within 100 km range that impact the HGB area. 

VOC 

Other Potential Measures/Concepts 

Engine registration program for stationary and/or portable engines to help ensure 

better enforcement of applicable requirements, improve rule effectiveness, and 

proper accounting of engines in EI. 

NOX
 

Houston-Galveston-Brazoria (HGB) Eight-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 further 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 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 Mobile 

Source

Pollutant(s)

Marine Texas Low Emission Diesel 

(TxLED) in east and central Texas 

counties (currently only in HGB area)

Non-Road NOX

Inspection and Maintenance (I/M) – 

Chambers, Liberty, Waller counties 

On-Road NOX

Texas Emission Reduction Plan (TERP) On-Road and Non-Road NOX

Green Port Initiatives Non-Road NOX /VOC 

Idling Reduction On-Road NOX