Technical Support Document (TSD) for the Cross State Air Pollution Rule Supplemental Rulemaking

Docket ID No. EPA-HQ-OAR-2009-0491

Determination of State Budgets for the 

Final Ozone Supplemental of the 

Transport Rule

U.S Environmental Protection Agency

Office of Air and Radiation

December 2011
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EPA finalized the Transport Rule in July of 20111

. At the same time, EPA also issued a Supplemental Notice of Proposed Rulemaking (SNPR) 

proposing to bring six states into the Transport Rule ozone-season NOX program. In this final rulemaking, EPA is finalizing FIPs to address significant 

contribution to nonattainment and interference with maintenance in Iowa, Michigan, Missouri, Oklahoma, and Wisconsin. For two of these states (Iowa and 

Missouri), the state budgets in this final rule are unchanged from those budgets as quantified at proposal. For three of these states (Michigan, Oklahoma, and 

Wisconsin), EPA is finalizing state budgets that reflect adjustments in certain unit-level assumptions that result in changes from the budgets presented for 

these states in the proposal. See Section III.E of the preamble for an explanation of these adjustments. This technical support document (TSD) shows the 

underlying data and calculations used to determine the amount by which each of these three states have their budget adjusted from proposal. The first 

section below summarizes final budgets for all of the states for which EPA is finalizing a FIP under this rule. The second section identifies each specific 

unit-level adjustment and quantifies its impact on the relevant state budget and the number of allowances put into the relevant new unit set-aside (NUSA),

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as well as the impact to the relevant assurance level3

Section A: Summary of State Emission Budgets

for that state, using the methodologies described in the final Transport Rule.

EPA is finalizing FIPs to control ozone-season NOX emissions from five states. The state budgets determined for these states maintain a consistent

application of the methodology described in the final Transport Rule to quantify and eliminate emissions that significantly contribute to nonattainment and 

interfere with maintenance of the NAAQS assessed in that rulemaking. EPA’s regulatory impacts analysis (RIA) of the July 2011 final Transport Rule 

included coverage of these states for ozone-season NOX reductions using their state budgets as quantified in the proposal of this supplemental rulemaking. 

As shown in further detail below, the final ozone-season NOX budgets for these states in 2014 (the year of analysis in that RIA) vary collectively by less than 

3,500 tons from the budgets as originally modeled.4

Final Ozone-Season NOX Budgets (thousand tons)

Final Budget

State 2012 2014

Michigan 28.041 27.016

Oklahoma 36.567 21.8355

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 Federal Implementation Plans: Interstate Transport of Fine Particulate Matter and Ozone and Correction of SIP Approvals (76 FR 48208). 2 The “Total NUSAs” presented for each state in section B of this document include allowances under both the State NUSA and the Indian Country NUSA (where the latter 

exists in the given state).

3 EPA has also proposed in a separate action to amend the effective date of the assurance provisions in all states to start in 2014 instead of in 2012. Please see 76 FR 63860 

for more information on that proposal. 4 For more information, please see the final Transport Rule Regulatory Impact Analysis in the docket for this rulemaking (EPA-HQ-OAR-2009-0491-4409). 5 Budget effective in 2013 and thereafter.
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Wisconsin 14.784 14.296

Iowa 16.532 16.207

Missouri 22.762 21.073

Section B: Quantification of State Emission Budgets, Assurance Levels, and NUSAs Affected by Unit-Level Adjustments

1)

As described in the preamble, EPA is finalizing Michigan’s 2012 and 2014 ozone-season (OS) NOX budget with an adjustment to account for no 

SCR being installed at Monroe Unit 2. This results in a 2,289 ton increase to the state’s ozone-season NOX budgets in 2012 and 2014. 

Michigan

Table 1.a: Calculation to Determine Michigan Ozone Season Budget Increase Assuming No SCR at Monroe Unit # 2

A B C D E F

Plant Unit

Emissions from 

TR_Remedy 

Final_2012 (1000 

tons)

HI from 

TR_Remedy_Final_2012 

(Tbtu)

Remedy Emission Rate 

from from 

TR_Remedy_Final_2012 

(lbs/mmBtu)

Adjusted 

Emission Rate 

(lbs/mmBtu)

Adjusted 

Emissions

Budget 

Adjustment 

(1000 tons)

Calculation A/B D x B E - A

Monroe 2 0.675 19.46356305 0.07 0.3046 2.964300653 2.289

Columns A, B, and C show the OS NOX emissions, heat input, and emission rate from the TR_Remedy_Final_2012 modeling when an SCR is 

assumed to be present at Monroe Unit 2. Because no SCR is present, EPA modified the emission rate to reflect the “controlled NOX policy rate” in the 

NEEDS version from the September 1, 2010 TR Notice of Data Availability (NODA) (column D).

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The final values for the state’s ozone-season NOX budget, assurance level, and new unit set-asides are given in the preamble.

 This value reflects the NOX emission rate assumed in 

EPA’s modeling of the Transport Rule as originally proposed, when EPA did not assume an SCR to be present at the unit. This value approximates the 

emission rate expected at the unit at a cost threshold of $500/ton when no SCR is present at the unit. EPA multiplied this NOX rate (shown in column D) by 

the remedy heat input shown in column B to obtain a revised emission projection for the unit (column E). The difference between this revised emission 

projection (no SCR assumed) and the final Transport Rule remedy analysis emission projection (SCR assumed) determines the amount of the adjustment to 

the state’s ozone-season NOX budget as compared to the budget presented at proposal (column F).

 6 See National Electric Energy Data System (NEEDS) v4.10 available at http://www.epa.gov/airmarkets/progsregs/epa-ipm/BaseCasev410.html
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2) Oklahoma

As explained in the preamble section III of the final supplemental rule, EPA has recalculated Oklahoma’s state budget for the 2012 ozone season 

such that it does not reflect the installation or upgrade of any new combustion controls (see Appendix). This recalculation demonstrates that ozone-season 

NOX emissions would be 9,522 tons higher in the 2012 ozone season without the new and upgraded combustion controls previously assumed; EPA has 

adjusted the final state budget for the 2012 ozone season only to reflect these emissions. The table below shows the values and calculations used to derive 

the 9,522 figure.

Table 2a. Oklahoma Ozone Season NOX Budget Adjustment for the 2012 Ozone Season Reflecting No Combustion Control 

Upgrade or Installation 

(1000 tons)

A B C D E F G H I

Plant Name

ORIS 

Plant 

Code Unit ID

2012 OS 

NOX

Remedy 

Emissions 

(1000 

tons)

2012 Heat 

Input

(Tbtu)

Emission 

Rate with 

LNB 

Upgrade

Base 

Emission 

Rate 

(lbs/mmBtu)

Adjusted 

Emissions 

(1,000 tons) 

Adjustment 

Amount 

(1,000 

tons)

Muskogee 2952 6 1.036 14.216 0.146 0.347 2.466710049 1.430

Muskogee 2952 4 1.045 14.613 0.143 0.321 2.343145371 1.298

Sooner 6095 1 1.071 14.939 0.143 0.319 2.386135045 1.315

Muskogee 2952 5 1.042 14.647 0.142 0.314 2.301435722 1.260

Sooner 6095 2 1.111 15.580 0.143 0.314 2.445420837 1.334

GRDA 165 1 1.465 14.507 0.202 0.349 2.528559526 1.063

Northeastern 2963 3314 1.704 13.160 0.259 0.394 2.594200981 0.890

Northeastern 2963 3313 1.649 13.137 0.251 0.382 2.511937905 0.863

Hugo 6772 1 1.269 14.103 0.180 0.190 1.336456463 0.067

Total 9.522

Columns A, B, and C provide unit level information about the facility. Columns D, E, and F provide projected emissions, heat input and ozone season NOX

emission rates from EPA’s 2012 TR_Remedy_Final modeling. The emission rate in column F, which formed the basis for the column D expected 

emissions, was based on the assumption that the facilities would make certain upgrades or installations with respect to combustion controls. Column G 

reflects the ozone-season NOX emission rate at these facilities assuming no combustion control upgrades or installation. That is, column G reflects emission 

rates that are typical to that unit’s historic operations. This value is obtained from “controlled NOX Base rate” in the NEEDS v.410 used for the Final 
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Transport Rule . Column H reflects the emission values expected for each unit when the projected heat input (column E) is multiplied by the historic 

emission rate (column G). The difference between column H and column D (when summed) reflects the total amount by which the Oklahoma ozone-season 

NOx budget is adjusted as compared to the budget presented at proposal. 

Also, as explained in preamble section III, EPA is finalizing an Oklahoma state budget specifically for the 2012 ozone season that reflects revised 

projected emissions at oil/gas steam generators consistent with an immediate-term dispatch pattern that maintains the firm power supply arrangements 

already in place to serve local electricity demand. The table below illustrates the calculations used to derive the adjustment to the Oklahoma state budget for 

the 2012 ozone season assuming a dispatch pattern of oil/gas steam generation in 2012 consistent with recently observed operational data at those units.

Table 2b. Oklahoma Ozone Season NOX Budget Adjustment Reflecting No Major Curtailment of O/G Steam Generating Units

A B C D E F G H I J

Plant Name Plant Type

ORIS 

Code

Unit 

ID

2012 OS 

NOX

Remedy 

Heat Input 

(mmBtu)

2012 OS NOX

Remedy 

Emissions 

(1,000 tons)

2010 Heat Input 

(mmBtu)

NEEDS 

Controlled NOX

Base Rate 

(lbs/mmBtu)

Emissions 

Assuming 2010 

Heat Input 

(1,000 tons)

Emission 

Adjustment for 

2012 

(1,000 tons)

Anadarko Plant O/G Steam 3006 3 0 0 1,917 0.22 0.000 0.000 

Horseshoe Lake O/G Steam 2951 6 0 0 3,022,970 0.28 0.427 0.427 

Horseshoe Lake O/G Steam 2951 8 0 0 5,904,903 0.14 0.405 0.405 

Mooreland O/G Steam 3008 1 0 0 52,018 0.34 0.009 0.009 

Mustang O/G Steam 2953 1 0 0 648,384 0.20 0.066 0.066 

Mustang O/G Steam 2953 2 0 0 636,546 0.15 0.048 0.048 

Mustang O/G Steam 2953 3 0 0 1,700,657 0.24 0.200 0.200 

Mustang O/G Steam 2953 4 0 0 1,884,097 0.35 0.325 0.325 

Northeastern O/G Steam 2963 3302 0 0 8,298,493 0.40 1.644 1.644 

Ponca O/G Steam 762 2 0 0 1,895 0.19 0.000 0.000 

Riverside O/G Steam 4940 1502 0 0 6,559,178 0.23 0.742 0.742 

Southwestern O/G Steam 2964 8002 0 0 457,715 0.33 0.075 0.075 

Southwestern O/G Steam 2964 8003 0 0 4,603,800 0.44 1.005 1.005 

Southwestern O/G Steam 2964 801N 0 0 244,030 0.25 0.031 0.031 

Southwestern O/G Steam 2964 801S 0 0 244,058 0.21 0.025 0.025 

Tulsa O/G Steam 2965 1402 0 0 1,029,085 0.18 0.094 0.094 
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Tulsa O/G Steam 2965 1403 0 0 112,296 0.28 0.015 0.015 

Tulsa O/G Steam 2965 1404 0 0 1,058,014 0.19 0.099 0.099 

Total 0 0 36,460,055 5.210 5.210

Columns A, B, C and D provide unit level information about the facility. Columns E, and F provide projected ozone season heat input and emissions from 

EPA’s 2012 TR_Remedy_Final modeling. The heat input in column E, which formed the basis for the column E expected emissions, was based on the 

assumption that the facilities would reduce uneconomic generation from these less efficient sources under the Transport Rule market incentives. Column G 

reflects the 2010 ozone-season NOX heat input at these facilities. Column H reflects emission rates that are typical to that unit’s historic operations and 

assumed as the “controlled NOX Base rate” in the NEEDS IPM version 4.10 used for the final Transport Rule. Column I reflects the emission values 

expected for each unit when the 2010 heat input (column E) is multiplied by the emission rate (column H). The difference between column I and column F

(when summed) reflects the total amount by which the Oklahoma ozone-season NOX budget is adjusted as compared to the budget presented at proposal.

The final values for the state’s ozone-season NOX budget, assurance level, and new unit set-asides are given in the preamble.
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3) Wisconsin

As explained in the preamble section III.E of the final supplemental rule, EPA has recalculated Wisconsin’s 2012 and 2014 ozone-season budget 

such that it does not reflect the installation of SCR control technology at J P Madgett. This results in a 1,080 ton increase to the state’s ozone-season NOX

budget relative to what was proposed in the SNPR. The table below details the values and calculations used to arrive at that amount.

Table 3.a: Calculation to Determine Wisconsin Ozone Season NOX Budget Adjustment Assuming No SCR at J P Madgett 

A B C D E F

Plant Name

Unit 

ID

Emissions 

from 

TR_Remedy 

Final_2012 

(1000 tons)

Heat Input from 

TR_Remedy_Final_2012 

(Tbtu)

Remedy Emission Rate 

fromTR_Remedy_Final_2012 

(lbs/mmbtu)

Revised 

Emission 

Rate 

(lbs/mmbtu)

Revised 

Emissions 

(1000 

tons)

Net Budget Adjustment 

(1000 tons)

Calculation A/B D x B/2 E - A

J P Madgett B1 .257068143 10.28272555 .05 .26 1.337 1.080

Columns A, B, and C show the emissions, heat input, and emission rate from the 2012 remedy modeling for the J P Madgett unit. However, the 

emission rate in column C reflects the existence of a SCR. Because no SCR is present, EPA calculates the source’s expected emissions using the emission 

rate shown for this unit in the EPA’s analysis of the base case for the final Transport Rule, as found in the TR_Base_Case_Final for 2012 (column D) of 0.26 

lbs/mmBtu. This ozone-season NOX emission rate reflects generation at this unit without the operation of the assumed SCR, which did not operate in the 

final Transport Rule base case because it was modeled as a “dispatchable” control that was not found to be economic to operate in that scenario.7

The final values for the state’s ozone-season NOX budget, assurance level, and new unit set-asides are given in the preamble.

 Moreover, 

this emission rate reflects one typically observed at past operation of the facility when no SCR was present. The J P Madgett emission rate without operating

an SCR (column D) multiplied by the remedy heat input (column B) yields the projected emissions from the unit if no SCR were assumed to be in place. 

The difference between the projected emissions when no SCR is in place (column E) and the projected emissions when an SCR is assumed (column A) 

determines the amount of the adjustment to the state’s 2012 and 2014 ozone-season NOX budgets as compared to the budget presented at proposal (column 

F).

 7 See "WebReady_ParsedFile_TR_Base_Case_Final_2012" in the Transport Rule docket or on EPA's CSAPR website
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APPENDIX

Assessment of Resource Adequacy for the 2012 Ozone Season in Oklahoma

EPA is setting the Oklahoma state budget for the 2012 ozone season at a level that does not necessitate the installation of new low-NOX burners. See 

preamble section III for further discussion. At proposal, EPA quantified Oklahoma’s 2012 ozone-season NOX state budget assuming that a number of units 

representing 4,452 MW of capacity would install new low-NOX burners (LNB) before the 2012 ozone season. See Table 1 for a list of those units showing 

each unit’s net summer dependable capacity.

Table 1. Oklahoma Units Projected to Install Low 

NOX Burners under the Transport Rule

Plant Name Unit ID County

Capacity 

(MW)

GRDA 1 Mayes 490

Muskogee 4 Muskogee 511

Muskogee 5 Muskogee 522

Muskogee 6 Muskogee 515

Northeastern 3313 Rogers 450

Northeastern 3314 Rogers 450

Sooner 1 Noble 535

Sooner 2 Noble 540

Hugo 1 Choctaw 440

Total 4452

As explained in preamble section III, EPA assessed the relationship of the capacity identified in Table 1 to the relevant region’s total available capacity that 

is taken into account in resource adequacy determinations. This assessment shows that if the capacity identified in Table 1 were to be unavailable due to the 

installation of low-NOX burners during the 2012 ozone season, the ozone-season planning reserve margin in the IPM region containing Oklahoma (SPPS) 

would fall below the target planning reserve margin of 13.6% (see Table 2).
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Table 2. IPM 2012 Ozone-Season Reserve Margin Projections for 

SPPS

Including All 

Plants in IPM

With Table 1 

Capacity 

Removed

Capacity (MW) 39,093 34,641

Ozone-Season Peak Load (MW) 31,785 31,785

Margin (MW) 7,308 2,856

Reserve Margin† 23.0% 9.0%

Target Planning Reserve Margin 13.6% 13.6%

† The reserve margin is calculated as the margin (third row) divided by the 

available peak load (second row)

The potential unavailability of this capacity would only frustrate the region’s target planning reserve margin during the ozone season, because the ozone 

season period represents the highest projected load (electricity demand). Even without this capacity available, the regional reserve margin would remain 

higher than the target planning reserve margin during the remainder of the year, as shown in Table 3. Because these units would be able to complete LNB 

installation without impairing the region’s ability to meet its target planning reserve margin after the 2012 ozone season, EPA is not adjusting Oklahoma’s 

state budgets for years subsequent to 2012 from the budget as quantified at proposal.

Table 3. IPM 2012 Non-Ozone-Season Reserve Margin Projections for 

SPPS

Including All 

Plants in IPM

With Table 1 

Capacity 

Removed

Capacity (MW) 39,093 34,641

Non-Ozone-Season Peak Load (MW) 24,025 24,025

Margin (MW) 15,068 10,616

Reserve Margin† 62% 44%

Target Planning Reserve Margin 13.6% 13.6%

† The reserve margin is calculated as the margin (third row) divided by the peak 

load (second row)