### 12/7/06 TECHNICAL SUPPORT DOCUMENT FOR PHASE 2 OF THE FINAL RULE TO IMPLEMENT THE 8-HOUR OZONE NATIONAL AMBIENT AIR QUALITY STANDARD –NOTICE OF RECONSIDERATION

NO x

### RACT for EGUs in CAIR States-- Supplemental Technical Analysis

Analysis Data and Method

To conduct this analysis, EPA used the Integrated Planning Model (IPM) 1 

### and National Electric Energy Data System (NEEDS) 2 

### to project EGU emissions reductions that will be obtained in the year 2010 under two scenarios: (1) implementation of the Clean Air Interstate Rule (CAIR), assuming all States in the CAIR ozone region participate in the CAIR seasonal NO x

### trading program and all States in the CAIR PM 2.5 

### region (except Delaware and New Jersey) participate in the CAIR annual NO x

### trading program 3 

### and; (2) application, on a source-by-source basis, of an assumed level of RACT to all CAIR-affected EGUs in areas for which a RACT SIP, separate from an attainment SIP, must be prepared.

This analysis was conducted for each State in the OTR because all parts of States in the OTR have an obligation under sections 182(f) and 184(b) of the Clean Air Act (CAA) to meet the requirements, including RACT, for major sources of NO x

### as if the area were a moderate ozone nonattainment area. 42 U.S.C. section 7511a(f), 42 U.S.C. section 7511c(b); also 40 CFR 51.916.

1 

### IPM provides forecasts of least-cost capacity expansion, electricity dispatch, and emission control strategies for meeting energy demand given certain environmental, transmission, dispatch, and reliability constraints. IPM can be used to evaluate the cost and emissions impacts of proposed policies to limit emissions of sulfur dioxide (SO 2 

### ), nitrogen oxides (NO x 

### ), carbon dioxide (CO 2 

### ), and mercury (Hg) from the electric power sector. IPM is used by the EPA to project the impact of emissions policies on the electric power sector in the 48 contiguous States and the District of Columbia, and the model is able to capture detailed information regarding the power sector, including representations of the operating characteristics of individual electric boilers and generators while also considering a long-term horizon. The model is capable of providing detailed regional, state, and local projections, and EPA feeds emissions projections from IPM into air quality modeling. IPM has been used in support of Title IV of the CAA, the NOx SIP call, the CAIR, The Clean Air Mercury Rule (CAMR), and the Clean Air VisibilityRule (CAVR). Documentation for IPM may be found in the CAIR docket [EPA-HQ-OAR2003-0053-1901] and online at http://www.epa.gov/airmarkets/epa-ipm/. 2 

### See CAIR docket [EPA-HQ-OAR-2003-0053-1686] or http://www.epa.gov/airmarkets/epaipm/#needs.

3 

### The analysis, which was based on modeling conducted before March 2006, assumed that Delaware and New Jersey would participate in the seasonal NO x

### trading program but not in the annual NO x 

### trading program. EPA added Delaware and New Jersey to the CAIR region for PM 2.5 

### in March 2006 and, therefore, anticipates that they will also join the annual NO x

### trading program. For this reason, the modeling may underestimate the reductions to be achieved from the implementation of CAIR.

### 2 The analysis under the two scenarios described above was also conducted for each 8-hour ozone nonattainment area for which a RACT SIP is required separate from the attainment demonstration. Under 40 CFR 51.912(a), States must submit a RACT SIP separate from the attainment demonstration for all subpart 2 8-hour ozone nonattainment areas classified moderate or higher. 4 

### In addition, 40 CFR 51.912(c)(2) requires States to submit a RACT SIP separate from the attainment demonstration for all subpart 1 areas with attainment dates beyond 5 years after their 8-hour designation. This separate RACT SIP must address major sources of NO x 

### – including EGUs. EPA expects that States may wish to rely on EPA’s NO x

### RACT determination for EGUs in CAIR States when submitting these RACT SIPs.

The EGUs in subpart 1 areas with attainment dates of 5 years or less are subject to the NO x

### RACT requirement, but for these areas, the RACT requirement is satisfied by submission of a SIP that ensures attainment as expeditiously as practicable. Because States are not required to submit separate RACT SIPs for these areas, EPA does not expect States to rely on EPA’s NO x 

### RACT determination in SIP submissions covering these areas. In these areas the RACT requirement does not ensure any emissions reductions beyond those required for attainment purposes. As a result, the quantitative emissions reduction comparison below for the CAIR scenario and the source-by-source RACT scenario does not include these areas.

For these reasons, EPA’s analysis projected emission reductions for the following 8-hour ozone nonattainment areas, regardless of whether they are in an OTR State:

 Moderate subpart 2 areas in the CAIR region (there are currently no areas in the CAIR region classified higher than moderate).

 The Buffalo-Niagara Falls subpart 1 area. (Buffalo-Niagara Falls is the only subpart 1 area in the CAIR region that is projected to remain in nonattainment in 2010 without further control programs. Because 8-hour attainment SIPs are not yet due and we cannot reliably predict whether the state will submit a SIP demonstrating attainment for the Buffalo-Niagara Falls area within five years of designation, EPA is including this area in the analysis.

In comparing the projected emissions reductions from EGUs under the CAIR and source-bysource RACT scenarios, we start from a 2010 EGU emissions baseline (See EPA-OAR-2003- 0053-1904). This baseline reflects the impact of existing controls and other controls projected to result from existing rules, (including the NO x 

### SIP call, but notincluding CAIR implementation or 8-hour ozone RACT implementation). Then, we estimate the emissions reductions that CAIR would achieve and the emissions reductions that source-by-source RACT would achieve, relative to this baseline.

The analysis under the CAIR scenario relied on the IPM using the NEEDS data base, both described above. The emission projections for the source-by-source RACT scenario relied on IPM modeled projections and, to simulate the assumed level of control, RACT policy rates based on the "NEEDS Adj." worksheet (in the supporting technical analysis) for coal units in SIP call States, the NEEDS database and base case annual NO x

### rates for other coal units, and

4 

### To meet this requirement, a State may submit a certification that their current SIP provisions meet the RACT requirement. (See 70 FR 71655.)

### 3 assumed RACT rates of 0.20 and 0.30 lbs/MMBtu for tangential/other and wall-fired oil/gas steam units, respectively. All NO x 

### rates were rounded to three significant figures for consistency.

Assumptions Used in Analysis

For purposes of this analysis, EPA used conservative assumptions about the level of control that EPA believes would be RACT for EGUs, resulting in a likely overstating of RACT emissions reductions. The level of controls we assumed for any particular unit does not imply that EPA has made a RACT determination for that unit. Our assumptions regarding RACT for EGUs are outlined below:For EGUs that have already installed post-combustion controls (i.e., SCR or SNCR) or state-ofthe-art combustion controls or that are projected to have such controls by 2010 under existing rules (e.g., NO x 

### SIP Call and/or State rules), EPA’s analysis assumes that no further controls or emissions reductions would be required to meet NO x



###  RACT. For purposes of this analysis, state-of-the-art combustion controls for EGUs are defined as: 1) low NO x

### burners with overfire air for wall-fired units and 2) low NO x

### coal-and-air nozzles with close-coupled and separated overfire air for tangentially-fired units.

 For EGUs that have no emission controls or that are projected to have no emissioncontrols by 2010, or for EGUs that will have some level of control less than state-ofthe-art combustion controls, EPA assumed “NO x

### RACT” to be any additionalcontrols needed to achieve state-of-the-art combustion control levels (e.g., a wallfired unit with low NO x 

### burners would need to install overfire air).

 For oil and gas steam EGUs, the RACT-level of control was assumed to be the level specified in previous EPA guidance (values are in pounds of NO x

### per million Btu): 0.20 for tangentially-fired gas or oil burning; 5 

### 0.30 for wall-fired gas or oil burning. 6



###  For coal-fired units, we used a unit-by-unit technology requirement (rather than an emission rate criterion) to determine what constitutes “state-of-the-art” combustion controls for each EGU as described above. Thus, emission reduction rates vary by unit. The assumption that all uncontrolled EGUs will install state-of-the-art combustion controls likely overstates the number of units that would, in fact, install such controls because RACT is determined on a source-by-source basis, and certain units may have unique constraints that could lead a State to determine that combustion controls are not RACT for that unit. Thus, these assumptions lead to a more conservative estimate of emissions reductions from the application of RACT (i.e., these assumptions lead to predictions of greater reductions than would likely occur through individual State RACT programs).

No IPM projections were available for 2009. Therefore, EPA projected emissions reductions for 2010 to approximate the emissions reductions expected to be achieved by 2009, which is both the last year for RACT compliance in moderate 8-hour nonattainment areas and the year the first phase of CAIR NO x 

### reductions starts. The EPA believes the 2010 data provide

5 

### EPA also conservatively assumed a 0.20 lb/MMBtu RACT rate for oil/gas steam units for which it was unclear whether the unit is tangentially- or wall-fired.
6 

### 57 FR at 55625 ( November 15, 1992).

### 4 a reasonable estimation of emissions reductions that would be achieved in 2009 under the two scenarios because we do not expect significant changes in fuel use patterns, levels of NO x 

### control, or power generation between 2009 and 2010

. The EPA analysis of projected emissions reductions under the two scenarios described above also relied on the following assumptions:

 As noted above, EPA interprets the CAA to allow NO x

### RACT to be met on an areawide basis through averaging rather than requiring every unit to meet a RACT minimum level of control. Consistent with EPA guidance, this approach to averaging ensures that actual emissions with RACT averaging are no greater than if RACT were applied without averaging. For simplicity, EPA applied an assumed RACT level of control to each uncontrolled EGU in covered areas to compute the total reductions that would result from RACT (EPA’s guidance also would allow these reductions to be achieved through averaging in which some units install beyond-RACT controls and others remain uncontrolled). This assumption is conservative because some of the uncontrolled units may be complying with previously adopted State RACT rules through averaging with other units. For this analysis, additional combustion controlswould be installed under a RACT scenario for 14 units for the "Moderate nonattainment areas + Buffalo" analysis and 18 units for the "OTR States" analysis; however, we do not have information readily available to determine if these units remained uncontrolled due to area-wide RACT averaging. 7



###  The EPA’s existing RACT guidance for EGUs indicates that EPA considers RACT for utilities to be the most effective level of combustion modification reasonably available to an individual unit. (See 57 FR at 55626; November 25, 1992.) However, the EPA analysis in support of this notice of reconsideration makes the conservative assumption that, for uncontrolled units, a level of combustion control would be employed now that is more advanced than was available in 1992. 8 

### This conservative assumption was made for purposes of this analysis only and does not imply that EPA believes in any particular case that these more advanced combustion controls are necessarily RACT.

 The OTR States and (former) moderate and above 1-hour ozone nonattainment areas were required to submit SIPs for the 1-hour standard for NO x

### RACT on EGUs (or obtain a NO x 

### waiver under section 182(g) of the CAA). The EPA has previously approved all these NO x

### SIPs (or approved waivers). The current analysis assumes control of uncontrolled EGUs that were not required to install controls under the 1- hour SIPs. This is a conservative assumption; the lack of 1-hour controls may indicate site-specific conditions that led to a determination that RACT was no control for these sources.

7 

### Note that a source that met the RACT requirement under the 1-hour NAAQS cannot be automatically assumed to meet RACT under the 8-hour NAAQS; see discussion in the Phase 2 8-hour ozone implementation rule at 70 FR 71654 and 71655 (November 29, 2005). 8 

### For instance, the November 25, 1992 notice provided RACT-equivalent values for EGUs for coal-fired utility boilers in the range of 0.45 to 0.50 lb NO x

### /MMBtu (57 FR at 55625). However, the combustion controls assumed in this analysis as RACT for coal-fired units would yield NO x 

### rates in the 0.2 to 0.4 lb NO x

### /MMBtu range.

### 5 As noted in the Federal Register reconsideration notice, the CAIR is implemented on an annual and (for ozone) a seasonal basis. Connecticut and Massachusetts are covered by the CAIR for ozone only and thus only have a summer season NO x

### cap. The other States with relevant ozone nonattainment areas in the CAIR region are covered by both an annual and a summer season NO x 

### cap under the CAIR. Therefore, the analysis comparing reductions from the CAIR and reductions from EGU-by-EGU application of RACT is also done on an annual and a seasonal basis. We believe that these averaging periods on which RACT is being implemented under the Phase 2 Rule are not in conflict with existing EPA policy. In general, the RACT requirement is applied on a short-term basis up to 24 hours. 9 

### However, EPA guidance permits averaging times longer than 24 hours under certain conditions. 10 

### Although these earlier EPA guidance documents were directed at VOC, the NO x

### Supplement to the General Preamble 11 

### provides, “While this guidance has been largely directed at application within the VOC program, much of the guidance is also applicable to RACT for stationary sources of NO x 

### .” Section 4.6 (“RACT for Certain Electric Utility Boilers”) of the NO x

### Supplement provides generally applicable NO x

### RACT emission rates for certain utility boilers on a pounds of NO x 

### per million Btu basis and indicates, “Compliance with these limits may be determined on a continuous basis through the use of a 30 day rolling average emission rate, calculated each operating day as the average of all hourly data for the pr[e]ceeding 30 operating days.”

Other EPA guidance and policy allow for longer averaging times in certain circumstances. The EPA’s “Economic Incentive Policy” 12 

### (EIP) provides guidance on use of long-term averages for RACT and generally provides for averaging times of no greater than 30 days. However, that guidance also states, “For NO x

### sources that are required to comply with the [Ozone Transport Region] NO x

### MOU regulation or the NO x

### SIP call, the averaging time of an emission limit must not exceed a compliance period of an area’s ozone season. Sources involved with EIP trades must meet all requirements applicable to the program.” The EPA interprets this policy as applying to all trading programs and providing that the averaging time may not exceed the period for determining compliance with the trading program (e.g., one year for the CAIR annual trading programs –and the ozone season for the CAIR ozone season trading program). There is additional discussion on this matter in the Federal Register reconsideration notice.

As noted, several of these assumptions are conservative. As a result, the projections of emissions reductions under the source-by-source RACT scenario would likely exceed the emissions reductions that would actually occur.

9 

### See, e.g., 52 FR at 45108 col. 2, “Compliance Periods” (November 24, 1987). “VOC rules should describe explicitly the compliance timeframe associated with each emission limit (e.g., instantaneous or daily). However, where the rules are silent on compliance time, EPA will interpret it as instantaneous. 10 

### Memorandum from John O’Connor, Acting Director of the Office of Air Quality Planning and Standards, January 20, 1984, “Averaging Times for Compliance with VOC Emission Limits— SIP Revision Policy.” 11 

### 57 FR at 55625, col. 1 sec. 4.5 “Relation to VOC RACT Policies” (November 25, 1992). 12 

### Improving Air Quality with Economic Incentive Programs, January 2001, available at http://www.epa.gov/region07/programs/artd/air/policy/search.htm.

### 6 The spreadsheet that provides the data for the analysis is available in the docket.

Results of Analysis

The EPA used these projections to examine whether the NO x

### emissions reductions achieved as a result of the CAIR will equal or exceed those that would be achieved by application of EGU source-by-source RACT in each OTR State and each nonattainment area for which a separate RACT SIP is required. This analysis illustrates that the CAIR achieves greater overall emissions reductions across the CAIR region than would be achieved through the application of EGU source-by-source RACT controls. The results of the projections are summarized in Table A; detailed results appear in Tables B, C, D, and E.

The analysis results in Tables D (for annual emissions) and E (for summer season emissions) for Poughkeepsie need an explanation. The initial RACT projection for the Poughkeepsie, NY nonattainment area does not take into account the recent installation of low NO x

### burners on two coal-fired units. These controls were installed after the control data for these units was finalized in the IPM. Because these controls were not accounted for, we assume in our projection of emissions reductions attributable to RACT in the Poughkeepsie, NY area that these units would install state-of-the-art combustion controls. The total reductions attributed to these sources are 1,260 tons annually and 560 tons over the summer season

. As stated previously, in this analysis, NO x

### RACT is assumed to be existing control for sources with controls already in place. When the recently installed controls are considered, our analysis does not project any additional emission reductions due to application of RACT to these sources. For this reason, the combustion controls and NO x 

### rates under the CAIR program and under sourceby-source RACT for these units would be the same, and the CAIR and RACT policies would getnearly identical levels of reductions for the Poughkeepsie nonattainment area (from the 2010 preCAIR baseline). 13



### Similarly, the analysis results in Tables B (for annual emissions) and C (for summer season emissions) for the State of Connecticut need further explanation. In the 2010 baseline analysis, the IPM projects that one coal-fired EGU in Connecticut, Bridgeport Harbor, will install SCR by 2010 as a result of Connecticut’s participation in the NO x

### SIP call trading program. Therefore, there is no additional reduction attributable to the RACT scenario. 14 

### However, in the CAIR scenario, the IPM projects that this unit will not install SCR by 2010 due to projected changes in the price of NO x

### allowances due to the CAIR 15 

### Thus, the RACT scenario shows greater

13 

### While changing the assumed level of controls on these two relatively small units to slightly more advanced controls may have minor impacts on dispatch and generation patterns, such changes would be negligible in calculating emission patterns for the areas under consideration. 14 

### If this unit chooses not to install the SCR, it would still have in place its existing NOx controls (low NOx burners and overfire air), which are the level of control assumed to be RACT for this analysis. Thus, the corrected total emissions reductions attributable to the unit's compliance with the RACT requirement are 0. 15 

### This difference in projected NO x 

### control is due to the expected decrease in value of ozone season NO x 

### allowances resulting from the implementation of the CAIR program. Connecticut is

### 7 emissions reductions than the CAIR scenario at this source, but the reduction differential is attributable to the NO x 

### SIP call rather than the application of RACT. When the 930 ton annual (410 tons summer season) reduction resulting from the installation of the SCR is eliminated from the projected emissions reductions under the RACT scenario, the projections show that the total new annual or summer seasonal reductions in the State of Connecticut from the application of RACT are approximately 100 tons (in Table B, 1030 minus 930; in Table C, 520 minus 410). The remaining approximate 100 tons difference between the RACT and CAIR scenarios (for both annual and ozone season NO x 

### ) is due to a slight shift in generation pattern and utilization of a gas turbine unit.

With regard to the areas and States showing negative reductions with CAIR compared to RACT in Tables B – E, except Connecticut and Poughkeepsie (which are discussed above), (e.g., DC, MA, DE, NJ, NY, Boston, Springfield, Baltimore, Buffalo, and Chicago), the lower emissions under RACT are chiefly due to differences in utilization patterns of gas-fired units.

in the CAIR ozone region and is, therefore, expected to participate only in the CAIR ozone season NO x 

### trading program. When both the CAIR annual and ozone season NO x 

### trading programs are implemented, ozone season NO x

### allowances are projected to become relatively inexpensive. Thus, the economic benefit of installing certain controls in states participating only in the CAIR ozone season trading program may be lower than the economic benefit of installing those same controls under the NO x 

### SIP call.

### 8 TABLE A

OZONE TRANSPORT REGION STATES -- ANNUAL EMISSIONS 2010 CAIR Annual Reductions* (tons) 2010 RACT Annual Reductions* (tons) Difference between CAIR Ann'l Reductions and RACT Ann'l Reductions (tons) 170,660 7,160 163,500

OZONE TRANSPORT REGION STATES -- SUMMER EMISSIONS 2010 CAIR Summer Reductions* (tons) 2010 RACT Summer Reductions* (tons) Difference between CAIR Summer Reductions and RACT Summer Reductions (tons) 20,410 2,440 17,970

MODERATE AND ABOVE 8-HOUR OZONE NONATTAINMENT AREAS AND BUFFALO-NIAGARA FALLS NONATTAINMENT AREA--ANNUAL EMISSIONS 2010 CAIR Annual Reductions* (tons) 2010 RACT Annual Reductions* (tons) Difference between CAIR Ann'l Reductions and RACT Ann'l Reductions (tons) 94,140 5,980 88,150

MODERATE AND ABOVE 8-HOUR OZONE NONATTAINMENT AREAS AND BUFFALO-NIAGARA FALLS NONATTAINMENT AREA--SUMMER EMISSIONS 2010 CAIR Summer Reductions* (tons) 2010 RACT Summer Reductions* (tons) Difference between CAIR Summer Reductions and RACT Summer Reductions (tons) 6,020 2,150 3,870



### * “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NO x

### SIP Call and State rules) (as well as installation of state-of-the art combustion controls on currently uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the RACT-level of control was assumed to be the level specified in previous EPA guidance (see text for details).

### 9 TABLE B: OZONE TRANSPORT REGION STATES -- ANNUAL EMISSIONS

OTR State Name 2010 CAIR Annual Reductions* (tons) 2010 RACT Annual Reductions* (tons) Difference between CAIR Ann'l Reductions and RACT Ann'l Reductions (tons) Connecticut -1,030 0 -1,030 Delaware 920 0 920 District Of Columbia -40 0 -40 Maryland 43,220 730 42,480 Massachusetts -150 0 -150 New Jersey 4,720 0 4,720 New York 9,070 5,110 3,960 Pennsylvania 111,830 1,320 110,510 Virginia (Alexandria and Prince William Counties 2,130 0 2,130 Grand Total 170,660 7,160 163,500



### * “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NO x

### SIP Call and State rules) (as well as installation of state-of-the art combustion controls on currently uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the RACT-level of control was assumed to be the level specified in previous EPA guidance (see text for details).

### 10 TABLE C: OZONE TRANSPORT REGION STATES -- SUMMER EMISSIONS

OTR State Name 2010 CAIR Summer Reductions* (tons) 2010 RACT Summer Reductions* (tons) Difference between CAIR Summer Reductions and RACT Summer Reductions (tons) Connecticut -520 0 -520 Delaware -600 0 -600 District Of Columbia -40 0 -40 Maryland 980 0 980 Massachusetts -290 0 -290 New Jersey -770 0 -770 New York 1,910 2,090 -190 Pennsylvania 19,620 350 19,280 Virginia (Alexandria and Prince William Counties 120 0 120 Grand Total 20,410 2,440 17,970



### * “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NO x

### SIP Call and State rules) (as well as installation of state-of-the art combustion controls on currently uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the RACT-level of control was assumed to be the level specified in previous EPA guidance (see text for details).

### 11 TABLE D: MODERATE AND ABOVE 8-HOUR OZONE NONATTAINMENT AREAS AND BUFFALO-NIAGARA FALLS NONATTAINMENT AREA--ANNUAL EMISSIONS

Nonattainment Area Name 2010 CAIR Annual Reductions* (tons) 2010 RACT Annual Reductions* (tons) Difference between CAIR Ann'l Reductions and RACT Ann'l Reductions (tons) Baltimore, MD 19,740 250 19,490 Boston-Lawrence-Worcester (E. MA), MA -140 0 -140 Buffalo-Niagara Falls, NY (Subpart 1) 4,290 710 3,580 Charlotte-Gastonia-Rock Hill, NC-SC 120 0 120 Chicago-Gary-Lake County, IL-IN 13,220 540 12,680 Cleveland-Akron-Lorain, OH 7,710 2,160 5,550 Dallas-Fort Worth, TX 500 0 500 Greater Connecticut, CT 0 0 0 Houston-Galveston-Brazoria, TX 20 0 20 Jefferson Co, NY 0 0 0 Milwaukee-Racine, WI 20 0 20 New York-N. New Jersey-Long Island,NY-NJ-CT 790 0 790 Philadelphia-Wilmin-Atlantic Ci,PA-NJ-MD-DE 11,550 0 11,550 Poughkeepsie, NY 0 1,260 -1,260 Sheboygan, WI 5,400 530 4,870 Springfield (Western MA), MA -20 0 -20 St. Louis, MO-IL 7,140 50 7,090 Washington, DC-MD-VA 23,790 490 23,300 Grand Total 94,140 5,980 88,150



### * “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NO x

### SIP Call and State rules) (as well as installation of state-of-the art combustion controls on currently uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the RACT-level of control was assumed to be the level specified in previous EPA guidance (see text for details).

### 12 TABLE E: MODERATE AND ABOVE 8-HOUR OZONE NONATTAINMENT AREAS AND BUFFALO-NIAGARA FALLS NONATTAINMENT AREA--SUMMER EMISSIONS

Nonattainment Area Name 2010 CAIR Summer Reductions* (tons) 2010 RACT Summer Reductions* (tons) Difference between CAIR Summer Reductions and RACT Summer Reductions (tons) Baltimore, MD -220 0 -220 Boston-Lawrence-Worcester (E. MA), MA -300 0 -300 Buffalo-Niagara Falls, NY (Subpart 1) 0 310 -320 Charlotte-Gastonia-Rock Hill, NC-SC 60 0 60 Chicago-Gary-Lake County, IL-IN 160 220 -60 Cleveland-Akron-Lorain, OH 1,980 770 1,210 Dallas-Fort Worth, TX 0 0 0 Greater Connecticut, CT 0 0 0 Houston-Galveston-Brazoria, TX 10 0 10 Jefferson Co, NY 0 0 0 Milwaukee-Racine, WI 20 0 20New York-N. New Jersey-Long Island,NY-NJCT 170 30 140 Philadelphia-Wilmin-Atlantic Ci,PA-NJ-MD-DE 880 0 880 Poughkeepsie, NY 0 560 -560 Sheboygan, WI 2,390 230 2,160 Springfield (Western MA), MA 0 0 0 St. Louis, MO-IL 170 20 150 Washington, DC-MD-VA 690 0 690 Grand Total 6,020 2,150 3,870



### * “CAIR Reductions” and “RACT Reductions” include existing advance controls. “RACT Reductions” include controls projected to be in place by 2010 under existing rules (e.g., NO x

### SIP Call and State rules) (as well as installation of state-of-the art combustion controls on currently uncontrolled sources to simulate RACT control on these units). For oil and gas EGUs, the RACT-level of control was assumed to be the level specified in previous EPA guidance (see text for details).