## Rhode Island Attainment Plan

for the 8-Hour Ozone National Ambient Air Quality Standard

Rhode Island Department of Environmental Management

Office of Air Resources

Posted for Public Comment: February 12, 2008 Submitted as SIP Revision: April 30, 2008TABLE OF CONTENTS

Tables and Figures .......................................................................................................................... 5

1.0 INTRODUCTION AND BACKGROUND ....................................................................... 6

1.1 Summary and Purpose of Document .............................................................................. 6

1.2 Ozone Formation and Health Impacts ............................................................................ 7

1.3 1-Hour Ozone NAAQS ................................................................................................... 7

1.4 8-Hour Ozone NAAQS ................................................................................................... 8

1.5 Rhode Island’s 8-Hour Ozone NAAQS Compliance ..................................................... 9

2.0 EMISSIONS INVENTORIES .......................................................................................... 11

2.1 2002 Emissions Inventory ............................................................................................. 11

2.2 2008 Projected Inventory .............................................................................................. 11

2.3 2009 Projected Inventory .............................................................................................. 12

3.0 CONTROL MEASURES ................................................................................................. 13

3.1 Purpose of Section ........................................................................................................ 13

3.2 Post -2002 Emissions Reductions ................................................................................. 13

3.2.1 Control Programs in the 1-Hour Ozone Standard SIP .......................................... 14 3.2.2 Adopted New Control Measures........................................................................... 15

3.3 Planned Emissions Controls ........................................................................................... 18

4.0 REASONABLE FURTHER PROGRESS ANALYSIS ................................................... 21

4.1 Purpose of Section ........................................................................................................ 21 4.3 2002 Adjusted Base Year Inventory............................................................................. 21

4.4 Target Level of Emissions ............................................................................................ 23

4.5 2008 Projected Emissions Inventory ............................................................................ 23

4.6 Results of RFP Analysis ............................................................................................... 23

5.0 ATTAINMENT DEMONSTRATION ............................................................................ 25 5.1 Purpose of Section .............................................................................................................. 25 5.2 Ozone Conceptual Model ................................................................................................... 25 5.2.1 Conceptual Description for Ozone Episodes in Rhode Island ..................................... 25 5.2.2 Geographical Considerations....................................................................................... 25 5.2.3 Transport...................................................................................................................... 26 5.2.4 Primary Meteorological Regimes for Rhode Island .................................................... 26 5.3 OTC Modeling Protocol ..................................................................................................... 29 5.3.1 Modeling Protocol (2002)................................................................................................ 29 5.3.2 Modeling Protocol (2006)............................................................................................ 29 5.4 Review of 2002 Ozone Episodes ........................................................................................ 29 5.4.1 Episode Selection Criteria ............................................................................................ 29 5.4.2 Episode Selection Procedure ........................................................................................ 29 5.5 Modeling Domain ............................................................................................................... 30 5.5.1 Description ................................................................................................................... 30

5.5.2 Horizontal Grid Size .................................................................................................... 30 5.5.3 Number of Vertical Layers .......................................................................................... 30 5.6 Photochemical Grid Modeling System ............................................................................... 31 5.6.1 Photochemical Grid Modeling System ........................................................................ 31 5.6.2 CMAQ Modeling System Source Codes ......................................................................... 32 5.6.2 CMAQ Modeling System Source Codes ..................................................................... 32

25.6.3 CMAQ Model Setup for the OTR Domain .................................................................. 33

5.7 Meteorological Modeling System ................................................................................. 33

5.7.1 MM5 Meteorological Model ................................................................................. 33 5.7.2 MM5 Meteorological Fields ........................................................................................ 33

5.7.3 MM5 Model Performance ............................................................................................ 33 5.8 Biogenic emissions ............................................................................................................. 34 5.8.1 BEIS Modeling System ................................................................................................ 34 5.8.2 OTR Modeling Domain Biogenic Emissions .............................................................. 35 5.9 Boundary and Initial Conditions ......................................................................................... 35 5.9.1 Generation of Boundary Conditions ............................................................................ 35 5.9.2 OTR Modeling Domain Boundary Conditions ............................................................ 35 5.10 CMAQ Emission Files for 2002 ....................................................................................... 35 5.10.1 Regional Planning Organization Annual Emission Inventories for 2002 .................. 35 5.10.2 MANE-VU Annual Emission Inventory for 2002 ..................................................... 36

5.10.3 Emission files for the OTR Domain .......................................................................... 38

5.11 New OTR Control Measures for 2009 .............................................................................. 39 5.11.1 Potential Beyond On the Way (BOTW) Control Measures ....................................... 39 5.11.2 Final OTC Beyond On the Wa y (BOTW) Control Measures .................................... 39 5.12 CMAQ Emission Files for 2009 with OTC BOTW Control Measures ............................ 40 5.12.1 Regional Planning Organization Annual Emission Inventories for 2009 .................. 40 5.12.2 MANEVU Annual Emission Inventory w ith BOTW Control Measures for 2009.... 41 5.13 Quality Assurance of CMAQ Databases .......................................................................... 43 5.14 CMAQ Model Simulation for 2002 Base Case ................................................................ 44 5.14.1 CMAQ Model 2002 Application ............................................................................... 44 5.14.2 CMAQ Input Files for 2002 ....................................................................................... 44 5.14.3 CMAQ Output Files................................................................................................... 45

5.15 Performance Evaluation of 2002 Simulation .................................................................... 45 5.15.1 NY DEC Performance Evaluation for OTR Modeling Domain ................................ 45 5.15.2 CMAQ Spatial Performance in New England States ................................................ 45 5.15.3 CMAQ Selected Model Metr ics for New England States ......................................... 49 5.16 CMAQ Model Simulation for 2009 Control Strategy ...................................................... 52 5.16.1 CMAQ Model 2009 Application ............................................................................... 52 5.16.2 CMAQ Input Files for 2009. ...................................................................................... 52 5.16.3 CMAQ Output Files................................................................................................... 52 5.17 Predicted Design Values for 2009 .................................................................................... 53 5.17.1 Design Values for 2002 Base Case ............................................................................ 53 5.18 Estimating Design Values at Unmonitored Locations ...................................................... 56 5.18.1 Rhode Island Ozone Monitoring Network ................................................................. 56 5.18.2 Future Year Design Values at Unmonitored Locations ............................................. 57

5.19 Weight of Evidence ................................................................................................... 57

5.19.1 Air Quality Trends ................................................................................................ 57

5.19.3 Extra Ozone Reductions ............................................................................................ 59

5.20 Conclusions ....................................................................................................................... 59

6.0 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ......................... 61

6.1 Purpose of Section ........................................................................................................ 61

6.2 1-Hour Ozone Standard RACT .................................................................................. 61

36.2.1 Pre-1990 VOC RACT Requirements ................................................................. 61

6.2.2 1990 CAA Amendments (CAAA) ........................................................................ 62

6.2.3 Rhode Island 1-Hour RACT Compliance ............................................................. 62

6.3 8-Hour Ozone Standard RACT Requirements ............................................................. 63

6.3.1 Required Analysis ................................................................................................. 63

6.4 VOC RACT Analysis ................................................................................................... 64

6.4.1 CTGs ..................................................................................................................... 64

6.4.2 New CTGs ................................................................................................................ 65

6.4.3 Non-CTG Major VOC Sources ............................................................................ 66

6.5 NOx RACT Analysis .................................................................................................... 66

6.6 RACT Revisions ........................................................................................................... 67

6.6.1 Solvent Degreasing ............................................................................................... 67

6.6.2 Asphalt Paving ...................................................................................................... 68

6.6 Conclusions ................................................................................................................... 69

7.0 REASONABLY AVAILABLE CONTROL MEASURES (RACM) .............................. 79

7.1 Purpose of Section ........................................................................................................ 79 7.4 Point and Nonpoint Source RACM Analysis for Rhode Island ...................................... 81 7.5 Mobile Source RACM Analysis for Rhode Island .......................................................... 84

7.6 Overall RACM Conclusions .............................................................................................. 85

8.0 CONTINGENCY MEASURES .......................................................................................... 86 8.1 Purpose of Section ............................................................................................................ 86 8.3 RFP Contingency ............................................................................................................... 86 8.4 Attainment Contingency .................................................................................................. 87

8.5 Conclusions ................................................................................................................... 88

9.0 TRANSPORTATION CONFORMITY .......................................................................... 89

9.1 Purpose of Section ........................................................................................................ 89

9.2 Background ................................................................................................................... 89

9.3 Methodology ................................................................................................................. 90

9.4 Mobile Source Budgets ................................................................................................. 90

4

### Tables and Figures

Table 2-1 Rhode Island Anthrop ogenic Ozone Precursor Emissions ............................................. 12

Table 3-1 Control Measures in the Rhode Island 1-Hour Ozone Standard Attainment

Demonstration SIP ........................................................................................................................ 14

Table 3-2 RI DEM Control Technology Regulatory Action Commitments......................... 20

Table 4-1 Rhode Island Base Year a nd Adjusted Base Year Emissions (tpsd) .............................. 22

Table 4-2 RFP Calculations .................................................................................................... 24 Figure 5-1: July 2, 20 02 Ozone and Isobar Maps ........................................................................... 27 Figure 5-2: August 12, 2002 Ozone and Isobar Maps .................................................................. 28

Table 5-1 Rhode Island Ozone Concentrations on 8-Hour Exceedance Days in 2002 (ppb) .......... 28 Figure 5-3: OTR Photochemical Grid Mode ling Domain (Eastern Modeling Domain) .............. 31 Figure 5-4: Regional Haze Regiona l planning Organizations (RPOs) ......................................... 32 Figure 5-5: MM5 Modeling Domains (36 km and 12 km ............................................................ 34

Table 5-2: MANE-VU 2002 Anth ropogenic Emissions (Tons/Year ........................................... 36 Table 5-3 Comparison of RIDEM and MARAMA 2002 Emissions Inventory for Rhode Island (tons per year) ............................................................................................................................... 37 Table 5-3A Status of Adoption of Rhode Island BOTW Control Measures .................................. 41

Table 5-4: MANE-VU 2009 Anth ropogenic Emissions with BOTW Controls (Tons/Yr) .......... 42 Figure 5-6: Maximum 8-Hour Values on August 8, 2002 ............................................................ 46 Figure 5-7: Maximum 8-Hour Values on August 8, 2002 ............................................................ 47 Figure 5-8: Maximum 8-Hour Values on June 21, 2002 .............................................................. 47 Figure 5-9: Maximum 8-Hour Values on July 18, 2002 ............................................................... 48 Figure 5-10: Hourly Ozone Values for 2002 Ozone Season ........................................................ 48

Table 5-5: Mean Normalized Gross Error and Mean Normalized Bias for RI Ozone Monitors ...... 49

Table 5-6: Mean Normalized Gross Error and Mean Normalized Bias for Other New England

Ozone Monitors ............................................................................................................................ 50 Table 5-7: 2009 Design Values (DVF) in R hode Island for 2009 BOTW Emission Scenario .... 54 Table 5-8: 2009 Design Values (DVF) in Ma ssachusetts for 2009 BOTW Emission Scenario .. 54 Table 5-9: 2009 Design Values (DVF) in Ne w Hampshire for 2009 BOTW Emission Scenario 55 Table 5-10: 2009 Design Values (DVF) in C onnecticut for 2009 BOTW Emission Scenario .... 55 Table 5-11: 2009 Design Values (DVF) in Maine for 2009 BOTW Emission Scenario ............. 56 Table 5-12: 2009 Design Values (DVF) in Vermont for 2009 BOTW Emission Scenario ......... 56 Figure 5-11: Design Value Trends for Rhode Island.................................................................... 58 Table 5-13: MANE-VU Anthropoge nic Emissions for 2002 and 2009 ....................................... 59

Table 6-1 RI DEM 1-hour Ozone Standard RACT Regulations and 8-Hour Ozone Standard RACT

Certification

............................................................................................................................... .... 70 Table 6-2 RI DEM Single S ource 1-Hour Ozone Standard RACT Determinations and 8-Hour

Ozone Standard RACT Certification ............................................................................................ 77

Table 7-1 OTC Recommended Control Meas ures and RI RACM Analysis ........................ 82 Table 7-2 CMAQ Program Projects in 2006-2007 Transportation Implementation Plan .......... 85 Table 9-1 2007 Emissions Budget, Projecte d 2008 and 2009 Inventory and Requested 2008 and 2009 Emissions Budgets (tons per summer day) ......................................................................... 90

51.0 INTRODUCTION AND BACKGROUND

1.1 Summary and Purpose of Document

The Rhode Island Department of Environmenta l Management (RI DEM) is submitting this document, the “State Implementation Plan (SIP) to Demonstrate Attainment of the Eight-Hour National Ambient Air Quality Standard for Ozone in the Rhode Island Nonattainment Area” to the U.S. Environmental Protection Agency (E PA) to demonstrate that the Rhode Island nonattainment area, which is the entire State of R hode Island, will be in attainment of the eighthour National Ambient Air Quality Standard (N AAQS) for ozone by the end of the 2009 ozone

season. This document also demonstrates that, by 2008, Rhode Island will achieve the Reasonable Further Progress (RFP) goals that ar e prescribed by the Clean Air Act (CAA) and subsequent EPA guidance.

. This submission includes the following:

• Rhode Island 2002 Emissions Inventory, which qu antifies emissions of ozone precursors and other air pollutants in Rhode Island in 2002, consistent with CAA requirements for the development of periodic emissions inventories. The 2002 inventory served as the base year

for the attainment demonstra tion and RFP analysis and was used to develop projected emissions estimates for 2008 and 2009 for use in those analyses.

• The RFP demonstration, which demonstrates th at ozone precursor emissions in Rhode Island will be reduced by 15% in 2008 from 2002 baselin e levels, as required by the CAA.

• A demonstration that Rhode Island sources are subject to emissions limitations consistent with the Reasonably Available Control Tec hnology (RACT) requirements in the CAA.

• The attainment demonstration, which shows that Rhode Island will attain the 8-hour ozone NAAQS by the end of the 2009 ozone season

• An analysis consistent with EPA’s Reas onable Available Control Measure (RACM) guidance that demonstrates that there ar e no additional reasonabl y available control requirements that could be a dopted that would result in ear lier attainment of the 8-hour NAAQS in Rhode Island.

• A demonstration that Rhode Island has contingenc y measures in place that will result in additional reductions in ozone pr ecursor emissions if Rhode Island fails to meet its RFP or attainment requirements.

• On-road mobile source Transportation Confor mity Budgets for Rhode Island for the 2008 RFP year and for the 2009 attainment demonstration year.

61.2 Ozone Formation and Health Impacts

Ground level ozone is formed when oxides of nitrogen (NOx), volatile organic compounds (VOCs) and, to a lesser extent, carbon monoxide (CO) interact in the atmosphere in the presence of sunlight and elevated temperatures. NOx and VOCs, the primary ozone precursors, are emitted from many types of sources, including power plants, boilers, automobiles and the use of consumer and industrial products. VOCs are al so emitted from vegetation. Because airborne VOCs and NOx, as well as ozone itself, are transported over l ong distances, sources emitting ozone precursors in states upwind of Rhode Island contribute to ground level ozone levels in the State. Ozone levels in Rhode Island generally are highest on hot sunny summer days when the

winds are from the west or southw est. Variations in annual weat her patterns contribute to yearto-year differences in ozone concentrations.

Exposure to elevated ozone levels causes eye, nose and throat irritation; coughi ng; chest pain; shortness of breath; decreased lung function; headache; and fatigue. Repeated exposures can increase susceptibility to respiratory infection and l ung inflammation and can aggravate preexisting respiratory diseases, such as asthma. Long-term expos ures can cause irreversible changes in the lungs, leading to chronic respiratory illnesses such as emphysema and chronic bronchitis and to premature aging of the lungs.

Children are at a particularly high risk for oz one-related health effects because they have developing lungs and are frequently active outsid e during the summertime when ozone levels are at their highest. Adults who work or exercise outside and people with respiratory and heart

diseases are also at an increased risk. Elev ated ozone levels also reduce agricultural and commercial forest yields; reduce the growth and survivability rates of tree seedlings; increase tree and plant susceptibility to disease, pests and other environmental stresses; and have longterm effects on forests and ecosystems.

1.3 1-Hour Ozone NAAQS

In 1979, EPA adopted a NAAQS for ozone of 0.12 parts per million (ppm) averaged over a 1- hour period (the 1-hour ozone stan dard). Nonattainment areas we re required to attain the standard by 1987. Rhode Island was in violati on of that NAAQS and, as required by the CAA and EPA regulations, adopted regulations and prog rams to reduce emissions of ozone-precursors. Despite significant improvement in measured oz one levels, Rhode Island, along with many other areas in the northeast, continue d to violate the 1-hour ozone standard throughout the 1980s.

The 1990 CAA Amendments (CAAA) required EPA to classify the severity of ozone nonattainment areas and imposed additional control requirements on areas that had not attained the 1-hour ozone NAAQS. EPA classified the Rh ode Island nonattainment area, which is the entire State of Rhode Island, as a serious nonatt ainment area for the 1-hour standard. In March 2003, RI DEM submitted an attainment demonstra tion showing that Rhode Island had adopted all emissions reductions measures required by the CAAA and would attain the 1-hour ozone

7NAAQS by 2007. In December 2004, RI DEM subm itted a Mid-Course Review analysis demonstrating that Rhode Island continued to be on track to attain the 1-hour standard by 2007.

Rhode Island has been in monitored a ttainment of the 1-hour NAAQS since 2004 1 . However, on June 15, 2005, EPA revoked the 1-hour standard as part of its implementation of a new ozone NAAQS, the 8-hour ozone standard. Therefor e, the 1-hour ozone NAAQS is no longer applicable.

1.4 8-Hour Ozone NAAQS

In 1997, based on evidence that exposures to ozone concentrations below the 1-hour NAAQS

can cause adverse health effect s, the EPA issued a new ozone standard of 0.08 ppm averaged over eight hours (the 8-hour ozone standard). 2 Legal challenges ensued but, in 2001, the U.S. Supreme Court upheld the standard and implem entation of the 8-hour ozone NAAQS began. In 2004, EPA designated every county in the United States as attainment, non-attainment or

unclassifiable and classified 8-hour ozone standard nonattainment areas acco rding to the severity

of their ozone violations. Rhode Island was clas sified as moderate non-attainment area under the 8-hour standard, based on monitored ozone readings for the 2001 – 2003 period. (69 FR 23858, April 30, 2004)

EPA promulgated implementation rules for the 8- hour ozone standard in two phases; Phase 1 was promulgated on April 30, 2004 3 and Phase 2 was promulgated on November 29, 2005. 4 The Phase I Rule delineates procedures for classi fication of nonattainment areas and transitioning

from the 1-hour to the 8-hour ozone standard. The Phase 2 Rule requires that moderate nonattainment areas, like Rhode Island, submit revisions to their Stat e Implementation Plans (SIPs) to EPA by June 15, 2007 demonstrating that the area will attain the 8-hour standard by the end of the 2009 ozone season (the year prior to the June 15, 2010 a ttainment deadline) and will reduce ozone precursor emissions by at least 15% by 2008 in order to meet Reasonable Further Progress (RFP) requirements. The Phase 2 rule also requires that nonattainment areas submit a SIP addressing 8-hour ozone RACT requirements.

The SIP for moderate nonattainment areas must include the elements listed below. This SIP submittal addresses all of the required elements in the Sections noted.

1 The 1-hour ozone NAAQS was violated when l-hour c oncentrations of 0.125 ppm were measured at a monitor in the area on 4 or more days in a three year period. The last year 3-year period in which more than 3 1-hour exceedances days occurred was 2001 – 2003.

2 The 8-hour ozone standard is met when the 3-year average of the 4 th -highest daily maximum 8-hour average does not exceed 0.08 parts per million (ppm ) at any one monitor (effectively, 0.084 ppm, given accepted rounding conventions).

3 “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard - Phase 1

, ” 69 FR 23951 April 30, 2004.

4 “Final Rule to Implement the 8-Hour Ozone Nati onal Ambient Air Quality Standard – Phase 2”, 70 FR 71612, November 29, 2005.

8• Reasonable Further Progress demonstration of a 15% reduction in in -state VOC and/or NOx emissions within 6 years after the baseli ne year of 2002 (i.e., by 2008). (Section 4)

• Attainment demonstration that uses modeling and other technical anal yses to demonstrate that attainment of the 8-hour NAAQS is pr ojected by the end of the 2009 ozone season. (Section 5)

• Reasonably Available Contro l Technology (RACT) for RACT source sectors and for major sources of VOC and NOx . (Section 6)

• Reasonably available control measures (RACM) for all sources. (Section 7)

• Contingency measures to be implemented upon failure to meet RFP or attainment milestones. (Section 8)

• Transportation conformity budgets for RFP mile stone and attainment years. (Section 9)

• Inspection and Maintenance (I /M) program for light-duty mo tor vehicles. (Adopted in

Rhode Island under the 1-hour oz one standard; see Table 3-1)

• Stage II vapor recovery for gas stations . (Adopted in Rhode Island under the 1-hour ozone standard; see Table 3-1)

• New Source Review (NSR) program for majo r sources, including offsets for VOC and NOx at a 1.15 to 1 ratio and a permit program for new or modified sources. (Adopted in

Rhode Island under the 1-hour oz one standard; see Table 3-1)

In December 2006, the U.S. Court of Appeals for th e D.C. Circuit issued a ruling vacating EPA’s Phase 1 rule, holding that parts of the rule violated provisions of the CAAA. On June 8, 2007,

the Court clarified its decision st ating that it was vacating only pa rts of the rule, while leaving

other sections in effect. It urged EPA to promptly promulgate a revised rule. It is unclear how the future resolution of this litigation may impact 8-hour ozone SIP requirements. This SIP is based on the requirements of the published EPA rule th at remain in effect and a memo from EPA concerning the implications of the June 15, 2007 opinion of the court. 5 Revisions to this SIP may be required upon resolution of the litigation and/or promulgation by EPA of a revised implementation rule.

1.5 Rhode Island’s 8-Hour Ozone NAAQS Compliance

In Section 5, Attainment Demonstration, RI DEM has demonstrated through modeling that

Rhode Island will attain the 8-hour ozone stan dard in 2009. The modeling predicts that ozone

concentrations will be below the attainment cu toff of 0.085 ppm at all Rhode Island monitors in 2009 (see Section 5, Table 5-6). In fact, since th e 2009 design values for all of the Rhode Island monitors are below 0.082 ppm, RI DEM is not requi red to submit a detailed weight of evidence demonstration, but is submitting a basic supplemental analysis to confirm the conclusion from the modeling that the State will be in attainment by 2009 6 . RI DEM has provided that support

evidence in Section 5.

5 U.S. EPA, Memorandum from Robert J. Meyers, Acting Assistant Administrator, June 15, 2007, “Decision of the U.S. Court of Appeals for the Distri ct of Columbia Circuit on our Petition for Rehearing of the Phase 1 Rule to Implement the 8-Hour Ozone NAAQS”

. 6 U.S. EPA, “Guidance on the Use of Models and Othe r Analyses in Attainment Demonstrations for the 8-hour Ozone NAAQS.”

9In addition to demonstrating attainment in th e attainment year through modeling, the actual monitored design value for ozone must meet the st andard in the attainment year. Rhode Island is on track to achieving monitored attainment by 2009; design values for the most recent 3-year period (2005-2007) were 0.084 ppm, slightly belo w the NAAQS, at the Narragansett and East Providence sites and 0.085 ppm, slig htly above the standard, at th e West Greenwich site. While year to year ozone concentrati ons are influenced by meteorological conditions, it is likely that concentrations will continue to drop and that attainment will be achieved by 2009, given the

substantial emissions reductions that will take place in Rhode Island and upwind states during that period.

102.0 EMISSIONS INVENTORIES

2.1 2002 Emissions Inventory

EPA’s Consolidated Emissions Reporting Rule (C ERR) requires states to inventory air pollution emissions within their borders every three years. The emissions inventory for 2002 is particularly important; because the EPA has desi gnated 2002 as the base year for attainment

demonstrations and RFP calculations for the 8-hour ozone NAAQS and the NAAQS for particulate matter smaller than 2.5 microns (PM 2.5 ). The “Rhode Island 2002 Emissions Inventory”, which is attached as Appendix 2A of this document, sa tisfies this requirement for the

Rhode Island nonattainment area.

The inventory includes emissions from stationary point , stationary nonpoint, on-road mobile and

non-road mobile sources and covers all areas of Rhode Island, since th e entire State is a

nonattainment area for ozone. Because high ozone concentrations are generally associated with warmer weather and emissions may vary seasona lly, the inventory includes emissions estimates of VOCs, NOx, and CO for a typical summer day, as well as on an annual basis. The inventory

document describes methods used for data coll ection, calculation of emissions and quality assurance/quality control in the preparation of the inventory. RI DEM submitted a draft of the 2002 inventory to EPA Region I for comment in December 2006. The attached version of this document incorporates comments received from EPA on the draft in February 2007

2.2 2008 Projected Inventory

Nonattainment areas must also estimate emissi ons in future milestone years. Moderate nonattainment areas like Rhode Island must develop a projected emissions inventory for 2008 in order to show, in the RFP, that emissions in the area will decrease by 15% between the base year, 2002, and the RFP milestone year, 2008.

Growth factors from the Emissions Growth Anal ysis System (EGAS) were used to calculate projected 2008 emissions for stationary point and nonpoint sources from the 2002 base year inventory. The EGAS configurations used were Default REMI 6.0 SCC for nonpoint sources and Default REMI 5.5 SIC for point sources. Emissions from poi nt sources that permanently ceased operations between 2002 and 2008 were recorded as zero in the projected 2008 inventory, consistent with EPA guidance. Point and nonpoi nt growth factors and 2002 and 2008 emissions are attached as Appendix 2B.

2008 emissions from non-road mobile sources we re calculated using the same methodology as

that used to derive the 2002 estimates. N onpoint 2002 and 2008 emissions and growth factors

used for commercial vessels and loco motive are shown in Appendix 2C.

On-road mobile source emissions factors were generated from EPA’s MOBILE model, version 6.2. Model inputs reflect air quality programs in effect in Rhode Island in 2008 and the latest registration distribution. Vehicl e Miles Traveled (VMT) data were generated by the Travel Demand Model (TDM), which utilizes the mo st recent highway performance monitoring

11(HPMS) data, roadway network information, curre nt planning assumptions, seasonal adjustment factors, peak/off-peak period speed characteri stics and 2000 census land use data The VMT generated by the TDM were then multiplied by the Mobile 6.2 emission factors by speed and roadway type, adjusted for seasonality and aggr egated by functional clas s to calculate typical summer day emission for each pollutant for 2008. MOBILE and TDM inputs and outputs and

emissions calculations are included in Appendix 2D.

2.3 2009 Projected Inventory

Projected emissions for the year for which atta inment must be demonstrated, which is 2009 for moderate areas like Rhode Island, are needed as inputs to the models used to demonstrate attainment. A discussion of how 2002 emissions were projected to 2009 for the modeling inventory is included in Section 5, “Attainment Demonstration” of th is document. The 2009 projections were calculated regi onally and the methodology used was not the same for all source categories as that used for the 2008 inventory.

A 2009 on-road mobile source i nventory was developed using the same methodology as that used for the 2008 on-road inventory. The 2008 and 2009 on-r oad mobile source inventories will be used as budgets for transportation conformity analyses.

2.4 Emissions Inventory Trends

Table 2-1 shows 2002 and 2008 anthropogenic emissions inventor ies by source type for Rhode Island, in tons per summer day.

Table 2-1 Rhode Island Anthropoge nic Ozone Precursor Emissions in tons per summer day (tpsd)

SOURCE TYPE 2002 VOC 200 8 VOC 2002 NOx 2008 NOx Stationary Point 10.3 11.0 7.0 7.3 Stationary Nonpoint 47.9 56.8 3.4 3.7
Non-road Mobile 26.8 21.0 19.7 16.0
On-road Mobile 7 32.3 24.6 42.4 28.3
Total 117.3 113.5 72.5 55.3

Projected 2008 emissions are 3% lower than those in 2002 for VOC and 24% lower for NOx. Most of the projected emissions reductions are associated with the non-road and on-road mobile

source sectors. Emissions reductions are discusse d further in the RFP anal ysis in Section 4 of

this document.

7 At the request of the Rhode Island Department of Administration, Statewide Planning Program, which is the Metropolitan Planning Organization for Rhode Island, the 2008 mobile source inventories for VOC and NOx listed above are actually 0.5 tpsd higher than those calculate d. See Section 9, “Transportation Conformity.”

123.0 CONTROL MEASURES

3.1 Purpose of Section

This section identifies and brie fly describes the Rhode Island and federal control measures that

will result in reductions of VOCs and/or NOx emissions from Rhode Island sources by 2008, for purposes of demonstrating Reasonable Further Pr ogress (RFP) towards attainment (see Section 4,”Reasonable Further Progress” ), and by 2009, for purposes of dem onstrating attainment of the ozone standard (see Section 5, “Attainment Demons tration”). Some of the measures delineated have already been promulgated. For other meas ures, RI DEM is committing to adopt regulations according to the schedule included in this section. This section also provides background for the discussions in Section 6, “R ACT” and Section 7, “RACM.”

3.2 Post -2002 Emissions Reductions

For the RFP analysis, Rhode Island is allowed to take credit for reductions of VOC and NOx emissions that will take place in the State be tween the 2002 base year and the 2008 target year for the RFP. Reductions that occur by 2009 are relevant for the attainment demonstration, Reductions may be from state or fe deral control measures that are not yet in place, provided that

the reductions from such measures will be ta ke place after 2002, but before the years by which

RFP and attainment must be demonstrated.

Air quality in Rhode Island is si gnificantly impacted by the transport of emissions from upwind states. Therefore, significant reductions the em issions of ozone precursors in upwind states are

essential to Rhode Island’s abil ity to attain the ozone standa rd, as discussed in Section 5, “Attainment Demonstration.” For the RFP, how ever, Rhode Island can only take credit for

emissions reductions that occur within the State

In May 2005, the EPA promulgated the Clean Air Interstate Transport Rule (CAIR) (70 FR 25162), which established a cap and trade pr ogram to reduce emissions of NOx and SO 2 , primarily from electric generating units. The rule applied to 28 states and the District of Columbia, which had been iden tified, through modeling, as contri buting significantly to poor air quality in downwind areas that were in nonattai nment of the 8-hour ozone or fine particulate (PM2.5) NAAQS. NOx budgets set by this rule will be effec tive beginning in 2009. Although Rhode Island is not a CAIR state, emissions reduc tions from upwind states associated with this program will benefit air quality in the State.

In addition to CAIR, a number of other regulato ry programs, discussed below, will result in emissions reductions between 2002 and 2009/2010. However, in 2004, the Ozone Transport Commission (OTC) 8 recognized that some stat es would not be able to attain the 8-hour ozone

standard without more reductions than will be achieved under CAIR and other state and federal control measures expected to be in place by th e 2009 attainment year. The OTC compiled a set

8 The Ozone Transport Commission comprises Connecticut, De laware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York , Pennsylvania, Rhode Island, Vermont, and northern Virginia. The OTC was created under the CAAA to addres s ozone transport issues within the Ozone Transport Region.

13of recommended additional control measures that could be adopted by stat es to yield additional

emissions reductions. 9 A list of these measures is include d in Section 7 as Table 7-1. The OTC went through a similar process under the 1-hour ozone standard and, in 2001, recommended new controls to help member states attain the 1- hour ozone standard. As part of its 8-hour ozone attainment strategy, RI DEM is adopting a numbe r of OTC recommended control measures, as

discussed below.

3.2.1 Control Programs in the 1-Hour Ozone Standard SIP

The control measures adopted in Rhode Island under the 1-hour ozone standard attainment demonstration SIP are listed in Table 3-1. A larg e part of the emissions reductions associated

with those control measures o ccurred prior to 2002 a nd are therefore reflected in the Rhode Island 2002 Base Year Inventory. However, some of the mobile sources emissions control programs adopted for the 1-hour SIP, such as th e federal emissions limits on certain types of non-road engines, continue to generate additional emissions reductions as older equipment and vehicles are replaced by lower-e mitting, newer models and as phased-in emissions limits tighten.

Those reductions are reflected in the RFP analysis.

Table 3-1 Control Measures in the Rhode Island 1-Hour Ozone Standard Attainment

Demonstration SIP

Name of Control Measure Type of Measure Approval Status On-board Refueling Vapor Recovery Federal rule Promulgated at 40 CFR 86

Federal Motor Vehicle Control program (Tier 0) Federal rule Promulgated at 40 CFR 86 (pre-1990)

National Low Emission Vehicle (NLEV) Federal voluntary rule, State opt-in Federal rule promulgated at 40 CFR 86 State commitment to program SIP approved (65 FR 12480 ; 3/9/00) Heavy Duty Diesel Engines (On-road) Federal rule Promulgated at 40 CFR 86

Federal Non-road Heavy Duty diesel engines Federal rule Promulgated at 40 CFR 89

Federal Non-road Gasoline Engines Federal rule Promulgated at 40 CFR 90

Federal Marine Engines Federal rule Promulgated at 40 CFR 91

Rail Road Locomotive

Controls Federal rule Promulgated at 40 CFR 92

AIM Surface Coatings State Initiative Contingency Regulation SIP approved (61 FR 55903; 10/30/96)

9 The OTC regional 8-hour ozone pla nning process is discussed in greater detail in Section 5, “Attainment Demonstration” and Section 7, “Reasona bly Available Control Measures”.

14Name of Control Measure Type of Measure Approval Status

Consumer & commercial products State Initiative Contingency Regulation SIP approved (61 FR 55903; 10/30/96)

Automotive Refinishing State InitiativeRegulation No. 30 SIP approved (61 FR 3827; 2/2/96)

Enhanced Motor Vehicle Inspection CAA SIP requirementDMV Regulation No. 1 SIP approved (66 FR 9663; 2/9/01)

NOx RACT CAA SIP requirementRegulation No. 27 SIP approved (62 FR 46202; 9/2/97)

VOC RACT pursuant to sections 182(a)(2)(A) and 182(b)(2)(B) of CAA CAA SIP requirement SIP approved (59 FR 52429;10/18/94)

VOC RACT pursuant to section 182(b)(2)(A) and (C) of CAA CAA SIP requirement Partially SIP Approved (64 FR 67500, 12/2/99). EPA approval pending for

certain non-CTG RACT determinations. Marine Vessel SIP Approved (61 FR 14975, 4/4/96) Stage II Vapor Recovery CAA SIP requireme nt SIP Approved (58 FR 65933; 12/17/93)

Reformulated Gasoline State opt-in SIP approved (65 FR 12476, 3/9/00)

Clean Fuel Fleets CAA SIP requirement SIP approved (65 FR 12476, 3/9/00)

Rhode Island used RFG reductions to meet the Clean Fuel Fleet requirement.

OTC NOx MOU Phase II State initiative regulation SIP approved (64 FR 29567; 6/2/99)

NOx SIP Call EPA requirement SIP approved (65 FR 81748, 12/27/00)

New Source Review EPA requirement SIP approved (64 FR 67495, 12/2/99)

3.2.2 Adopted New Control Measures

As discussed above, EPA’s CAIR rule is expected to result in emissions reductions in states upwind of Rhode Island by 2009, but will not affect emissions from Rhode Island sources. A

discussion of Federal and State emissions contro ls programs that have been promulgated since the 1-hour SIP was prepared and that will result in emissions reductions in Rhode Island between

2002 and 2009/2010 follows.

3.2.2.1 Federal On-Road Mobile Source Control Measures

The EPA adopted Tier 2 Vehicle and Gasoline Sulf ur Program in 2003 which set stricter tailpipe emission standards (Tier 2) for all new passenger vehicles, including cars, sport utility vehicles, minivans, vans, and pick-up trucks and which re duce the limits on sulfur content in gasoline over

15a 2004-2007 phase-in periods. The Tier 2 vehicle st andards do not apply in Rhode Island, which has adopted the stricter California Low Emissi on Vehicle Program tailpipe standards discussed below. However, the low sulfur fuel require ments will reduce post-2002 motor vehicle emissions

in the State.

Federal Heavy-Duty Engine and Fuel Standard s promulgated in 2000 set more stringent NOx and hydrocarbon (HC) emission standards for heavy-duty diesel engines and vehicles starting with the 2004 vehicle model year and for heavy-duty gasoline engi nes and vehicles starting with the 2005 vehicle model year. The rules also requires that certain heavy-du ty vehicles (HDVs) be equipped with on-board gasoline vapor recovery systems phased-in over 2004 – 2006 model year

vehicles.

In 2001, EPA published a second phase of heav y-duty motor vehicle and fuel emission standards. The rule requires additional, sign ificant reductions of NOx and HC (as well as particulate matter) emissions from heavy-duty engines and vehicles, beginning with vehicle model year 2007. It also requires lowering the su lfur content of diesel fuel to 15 parts per million (ppm) from previous leve ls of 500 ppm, beginning in 2006.

3.2.2.2 Rhode Island On-Road Mobile Source Control Measures

In June 1996, RI DEM Adopted APC Regula tion No. 37, “Rhode Island’s Low Emissions Vehicle Program,” which requires adherence to EPA’s National Low Emissions Vehicles (NLEV) program in Rhode Island for passenger cars and light duty trucks beginning with model year 1999. In December 2005, RI DEM modified Regulation No. 37, to require the more stringent California Low Emissi on Vehicle (CAL-LEV) standards for passenger cars and light duty trucks beginning with mode l year 2008 and for medium duty trucks with model year 2009. The Rhode Island program includes 1) the Cali fornia fleet-wide emission average for nonmethane organic gases (NMOG); 2) the second generation of California emission standards known as “LEV II”; 3) the LEV I & II emission standards for medium-duty vehicles (including diesel vehicles and engines); and 4) Zero Emissions Vehicles (ZEV ) specifications. This program will provide control benefits in 2009 estimated at 0.2% additional reductions of NOx and VOC as compared to those that would be re alized from the NLEV program. Reductions will

be more substantial in late r years (additional reductions of 0.6% NOx and 0.9% VOC in 2012 and 5.2% NOx and 6.6% VOC in 2020, as compared to NLEV). 10

3.2.2.3 Federal Non-Road Mobile Source Control Measures

EPA has adopted national regula tions that impose emission and fuel standards on new non-road engines. The regulations establish four tier s of emission standards for new non-road diesel engines. Tier 1 emission standards were issu ed in 1994 for most larg e (greater than 50 horsepower (hp)), land-based non -road diesel engines used in agricultural a nd construction equipment. These were phased-in between 1996 and 2000. In 1998, EPA promulgated Tier 1 standards for smaller (< 50 hp) diesel engi nes, which were phased-in between 1999 and 2000. At that time, EPA also issued more stringent Ti er 2 emission standards for all non-road diesel

10 Calculations by Cambridge Systematics, April 9, 2004.

16engine sizes, with a 2001- 2006 phase-in, and Tier 3 standards for new diesel engines between 50 and 750 hp, with a 2006 - 2008 phase-in.

In 2004, EPA promulgated regulations that inte grate new non-road diesel engine emission standards (Tier 4 standards) with requirements to decrease the allowable levels of sulfur in nonroad diesel fuel. The regulations set emission st andards for engines used in most construction, agricultural, industrial, and air port equipment beginning in 2008. Fuel requirements will decrease the sulfur levels in non-road diesel fuel to pr event damage to emission-control systems. Current sulfur levels of about 3,000 ppm will be redu ced to a maximum of 500 ppm in 2007. The second phase will reduce sulfur levels in non-road di esel fuel to 15 ppm in 2010, except for locomotive and marine diesel fuel, which w ill be reduced to 15 ppm in 2012.

In 1995, EPA issued Phase 1 standards for model year 1997 and newer small (< 25 hp) non-road spark-ignited engines, which are used primarily in lawn and garden equipment. In 1999, EPA issued more stringent Phase 2 emission standa rds for small non-handheld engines (e.g., lawn mowers, generator sets, air compressors) and, in 2000, for small handheld engines (e.g., leaf blowers, chain saws, augers). Phase 2 sta ndards were phased-in from 2001 to 2007 for nonhandheld engines and from 2002 to 2007 for handheld engines. In 1996, EPA finalized emission standards for new gasoline spark-ignition mari ne engines to be phase d-in between 1998 and 2000. These engines are used for outboard engi nes, personal watercra ft, and jet boats.

In 2002, EPA promulgated new engine emission sta ndards for large spark- ignition engines rated over 19 kilowatts (kW), or >25 hp. These are used in a variety of commercial and industrial settings, including forklifts, elect ric generators, airport baggage transport vehicles, farming and construction. The standards were implemented in two tiers - Tier 1 starte d in 2004 and Tier 2 in 2007. EPA’s 2002 rulemaking also include exha ust emission standards for engines in recreational vehicles including s nowmobiles, off-highway motorcyc les, and all-terrain-vehicles (ATVs). These standards are phased-in in 2006 and 2007, except for snowmobiles, which have until 2009 to be fully phased-in. Plastic fuel ta nks and rubber hoses av ailable on recreational vehicles will also be subject to permeation standards effective in 2008.

In 1999, EPA promulgated regulations setting em ission standards for certain classes of new commercial marine diesel engi nes starting in 2004 and for other classes in 2007. In 2002, EPA promulgated new emission standards for recreationa l marine diesel engines, which are used in yachts, cruisers, and other types of pleasure cr aft. The standards are phased-in, beginning in 2006, depending on the size of the engine. By 2009, em ission standards will be in effect for all new recreational, marine diesel engines.

3.2.2.4 New Federal Portable Fuel Containers Regulation

In 2001, the OTC developed a model rule for redu cing emissions for portable fuel containers (PFCs), gas cans, based on the California PFC regulation. In 2006, the OTC developed a revised model rule for this category, based on revisions to the California regulation. RI DEM did not adopt a PFC regulation for 1-hour ozone standard a ttainment, but intended to do so as part of its 8-hour attainment strategy. However, in Febr uary 2007, EPA finalized a national regulation to reduce hazardous air pollutant em issions from mobile sources, which includes standards to

17reduce PFC emissions from evaporation, pe rmeation, and spillage (72FR 8428, February 26, 2007). The standards apply to containers ma nufactured on or after January 1, 2009. Emission reductions will be realized incrementally as consumers replace older PFCs with new ones.

Because EPA’s rule has been finalized with a 20 09 effective date and will achieve reductions equivalent to the OTC model rule, RI DEM no l onger intends to adopt a state rule for this

category.

3.3 Planned Emissions Controls

Among the control strategies developed by th e OTC in 2001 were model rules for the Architectural and Industrial Maintenance (A IM) coatings and Consumer Products source categories. Those model rules were based on regulations in place for those source categories in California. In 2006, OTC produced an updated model rule for Consumer Products, which corresponds to newer California requirements. RI DEM planned to adopt rules for those categories as part of its 8-hour attainment strategy. Howeve r, on May 30, 2007 EPA issued a memo committing to adopt federal rules consis tent with the OTC model rules for AIM and

Consumer Products with emissions limits that would be effective by January 1, 2009. 11 . Based on that commitment, RI DEM decided not to prom ulgate state-specific regulations for those source categories. If, however, EPA does not pr opose those rules by July 1, 2008, RI DEM will adopt state rules consistent with the OTC models that will be effective by January 1, 2009. Those rules will be submitted to the EPA as a SIP revision by October 1, 2008.

The 2001 OTC model rule for consumer products contains VOC limits for adhesives and sealants. However, with the ex ception of aerosol adhesives, th e definitions of these products generally exempt products sold in larger c ontainers. The OTC identified industrial and commercial use of adhesives as a category wher e additional reductions could be achieved and developed a 2006 OTC Adhesives model rule, based on a reasonably available control technology determination prepared by the Ca lifornia Air Resources Board in 1998. RI DEM commits to submit a new regulation for this categ ory based on the OTC model rule by October 1, 2008 with an effective date of January 1, 2009.

The OTC 2001 model rules included a rule fo r limiting emissions from Solvent Cleaning operations. The 2006 OTC recommendations include d a rule prohibiting the use of cutback asphalt and substantially restricting the use of emulsified asph alt. Rhode Island already has rules in place that are, for the most part, equivale nt to the model rules. However, RI DEM had

identified areas where the Rhode Island rules ar e not as stringent as the OTC recommendations and is committing to amend its existing rule s for solvent cleaning and asphalt paving, APC Regulations No. 36 and 25, respectively, to address those discrepancies. The planned regulatory changes are discussed in more detail in Secti on 6.6, “RACT Changes.” These amendments will be submitted to the EPA as SIP revisions by January 1, 2009 and will be effective by April 1,

2009.

11 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to Regional Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer and Commercial Products,” May 30, 2007.

18In addition, as discussed in Section 6, “R easonably Available Control Technology,” RI DEM plans to update APC Regulations No. 19, “Contro l of Volatile Organic Compounds from Surface Coating Operations,” and Regul ation No. 35, “Control of Vola tile Organic Compounds and

Volatile Hazardous Air Pollutants from Wood Products Manufacturing Operations,” to be consistent with the provisions of a Control Te chnique Guideline for Flat Wood Paneling Coating which was finalized by the EPA in 2006. These amendments will be submitted to the EPA as a SIP revision by January 1, 2009 and will be effective by April 1, 2009.

As discussed in Section 6, RI DEM is currently evaluating the applicability of CTGs released by the EPA in 2006 for Lithographic Printing Materials, Letterpress Printing Materials and Flexible Packaging Printing Materials to sources in Rhode Island. If it is determined that regulatory action is required for those sources, APC Re gulation No. 21, “Control of Volatile Organic Compound Emissions from Printing Operations,” will be amended accordingly. Any such

amendments will be submitted as a SIP revisi on by January 1, 2009 and will be effective by April 1, 2009. In addition, RI DEM plans to evaluate the applicab ility of new CTGs issued in October 2007 for paper, film and foil coating, meta l furniture coating and large appliance coating to Rhode Island sources. If necessary, APC Regulation No. 19, “Control of Volatile Organic Compounds from Surface Coating Operations,” w ill be amended to reflect the new CTGs on the

same schedule.

Table 3-2 lists RI DEM’s commitments for regulat ory amendments to reduce emissions in Rhode

Island.

19Table 3-2 RI DEM Control Technology Regulatory Action Commitments Source Category Affected

APC Regulation Comments SIP

Submittal

Date Effective

Date

AIM Coatings Reg. No. 33 State regulation will be

amended to be consistent

with 2001 OTC model rule only if EPA fails to propose

a federal rule for this category by 7/1/08 10/1/08 1/1/09

Consumer Products Reg. No. 31 State regulation will be

amended to be consistent

with 2006 OTC model rule only if EPA fails to propose

a federal rule for this category by 7/1/08 10/1/08 1/1/09

Adhesives and Sealants new regulation Consistent with 2006 OTC

model rule 10/1/08 1/1/09

Industrial Solvents Reg. No. 36 Consistent with 2001 OTC

model rule and 2006 CTG. 1/1/09 4/1/09

Asphalt Paving Reg. No.25 Consistent with 2006 OTC

recommendations as

feasible in Rhode Island 1/1/09 4/1/09

Flat Wood Paneling Reg. Nos. 19

and 35 Consistent with 2006 CTG 1/1/09 4/1/09

Lithographic Printing Materials, Letterpress Printing Materials, Flexible Packaging Printing Materials Reg. No. 21 State regulation will be

amended to be consistent

with 2006 CTG if determined to be applicable

and feasible in Rhode

Island 1/1/09 4/1/09

Paper, Film and Foil coating; Metal Furniture coating; Large Appliance Coating Reg. No. 19 State regulation will be

amended to be consistent

with 2007 CTG if determined to be applicable

and feasible in Rhode

Island 1/1/09 4/1/09

RI Low Emission Vehicle Program Reg. No. 37 Submit updated regulation

as SIP revision 6/1/08

RI Motor Vehicle Inspection/Maintenance Program Reg. No. 34 Finalize updated regulation

and submit as SIP revision 6/1/08

204.0 REASONABLE FURTHER PROGRESS ANALYSIS

4.1 Purpose of Section

This section demonstrates that Rhode Island will meet the Reasonable Further Progress (RFP) requirement in EPA’s Phase 2 Rule. That rule requires that, by the end of 2008, emissions of VOC, NOx, or a combination of VOC and NOx mu st be at least 15% lower than the 2002 baseline. As discussed in Section 2.2, RI DE M developed a 2008 projecte d emissions inventory

for VOC and NOx that took into account anti cipated growth in the economy and control measures expected to be in effect by that date . The projections demonstrate that emissions will decrease in the State by an amount greater than the required 15% reduction by 2008.

4.2 Reasonable Further Progress Requirements and Methodology

Since Rhode Island is a moderate nonattainment area, the Phase 2 Rule requires the State to demonstrate that emissions of VOC, NOx or a combination of VOC and NOx will be reduced by at least 15% by 2008 from the 2002 baseline . The procedures and methodology for demonstrating compliance with th e 1-hour ozone standard Rate of Progress requirements were established in a 1992 EPA guidance document; these procedures are still applicable for purposes

of the 8-hour ozone standard RFP. 12 EPA’s method for demonstra ting that RFP requirements are

met calls for:

1. Developing a 2002 base year inve ntory for a nonattainment area;

2. Adjusting that inventory to subtract emissions reductions determined to be noncreditable;

3. Establishing a target level of emissions for 2008 that reflects the required 15% reduction from the adjusted base year inventory;

4. Developing a projected i nventory of VOC and NOx emissions for 2008; and

5. Demonstrating that the projected 2008 emi ssions of NOx, VOC or a combination of NOx and VOC will be less than or equal to the target level for that year.

Using this methodology, RI DEM will demonstrate in the calculations below that the Rhode Island nonattainment area has met the RFP requirements.

4.3 2002 Adjusted Base Year Inventory

Estimates of typical summer day Rhode Isla nd anthropogenic emissions of VOC and NOx for the 2002 base year were obtained from the 2002 Em issions Inventory discussed in Section 2 and attached as Appendix 2A. That inventory does not include organic com pounds that are excluded

from the EPA definition of “VOC.” Pursuant to EPA’s RFP methodology, for the purpose of the RFP, RI DEM adjusted this inventory by s ubtracting from the VOC and NOx base year

12 Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15 Percent Rate of Progress Plans , U.S. EPA, Office of Air Quality Planni ng and Standards, EPA-452/R-92-005, October

1992.

21emissions non-creditable emissions reductions, which are those realiz ed from the pre-1990 federal limits on the Reid Vapor Pressure (RVP) of gasoline (RVP of 9.0 ) and the Federal Motor Vehicle Control Program (FMVCP). 13 Consistent with EPA guida nce, non-creditable emissions

reductions of VOC and NOx were calcu lated using the following methodology:

1. EPA’s MOBILE model, version 6.2, was run for 2002 using the same highway vehicle activity inputs used to calculate the actua l 2002 emissions but with FMVCP and RVP = 9.0 as the only control measures (all other control measures turned off).

2. Similarly, MOBILE 6.2 was run for 2008 using the same highway vehicle activity inputs used to project 2008 emissions fo r the 2008 projected inventory but with FMVCP and RVP = 9.0 as the only control measures (all other control measures turned off).

3. Non-creditable emissions reductions we re calculated by s ubtracting the 2008 emissions factors calculated in Step 2 fr om the 2002 factors calculated in Step 1 and multiplying the difference by 2002 VMT.

Non-creditable emissions calculated by this method are 5.51 tpsd VOC and 3.19 tpsd NOx.

Non-creditable emissions calculations are s hown in Appendix 4A. Table 4-1 shows the 2002 Base Year and Adjusted Base Year Inventor ies of NOx and VOC, in tons per summer day

Table 4-1 Rhode Island Base Year and Adjusted Base Year Emissions (tpsd)

SOURCE TYPE 2002 Base Year

VOC 2002 Adjusted

VOC 2002 Base Year

NOx 2002 Adjusted

NOx Stationary Point 10.3 10.3 7.0 7.0 Stationary Nonpoint 47.9 47.9 3.4 3.4
Non-road Mobile 26.8 26.8 19.7 19.7
On-road Mobile 32.3 26.8 42.4 39.2
Total 117.3 111.8 72.5 69.3

13 The CAA (Section 182(b)(1)(D)) provides that reductions from the following measures are not creditable toward the required reductions: (1) Federa l Motor Vehicle Control Program (FMVCP) tailpipe and evaporative standards issued in 1990; (2) Federal regulations limiting the Reid Vapor Pressure (RVP) of gasoline in ozone nonattainme nt areas issued by June 15, 1990; (3) State regulations correcting deficiencies in reasonably available control technol ogy (RACT) rules; (4) Measures required to be enacted immediately after passage of the 1990 CAA Amendments concerning corrections to vehicle inspection and maintenance (I/M) programs. Only the FMVCP continues to generate emission reductions through 2008 in Rhode Island.

224.4 Target Level of Emissions

To fulfill RFP requirements, projected emissions for 2008 must be at least 15% lower than the 2002 Adjusted Base Year Inventory shown in Ta ble 4-2. The reductions can be VOCs, NOx or any combination of both. RI DEM is establishi ng its target levels ba sed on a 15% reduction in NOx emissions. The 2008 Target Levels and resu ltant required emissions reductions were

calculated as follows:

NOx:

Required Emissions Reductions = 2002 Adjusted Em issions (69.3 tpsd) X 0.15 = 10.4 tpsd

2008 Target = 2002 Adjusted Emissions (69.3 tp sd) – Required Reductions (10.4 tpsd) = 58.9 tpsd

VOC

Required Emissions Reductions = 2002 Adjusted Em issions (111.8 tpsd) X 0.00 = 0.0 tpsd

2008 Target = 2002 Adjusted Emissions (111.8 tp sd) – Required Reductions (0.0 tpsd) = 111.8 tpsd

4.5 2008 Projected Emissions Inventory

Projected emissions in 2008 were calculated by estimating anticipated growth in emissions between 2002 and 2008 and then adjusting for any c ontrols that will reduc e emissions during that time period. Calculations of the projected 2008 i nventory are discussed in Section 2.2 of this

document.

4.6 Results of RFP Analysis

The 2008 projections are shown in Table 4-2 below. Reductions anticipated by 2008 are compared to the reductions re quired to meet RFP. As shown, projected 2008 VOC emissions in Rhode Island are 1.5% (1.7 tons pe r day) higher than the target le vel. To compensate for the higher VOC levels, an additional 1.5% reduction in NOx emissions, for a total 16.5%, is needed to meet the RFP requirements. As shown in Table 4-2, projected 2008 NOx emissions are 20.1% lower than the 2002 adjusted baseline; th erefore RFP requirements will be met and NOx

emissions will be reduced an additional 3.6% beyond the required reductions.. These emissions reductions occur primarily in th e non-road and on-road mobile sectors. Note that the 2008 onroad mobile emissions of VOC and NOx used in these calculations are 0.5 tons per day higher

than the 2008 modeled on-road mobile source emissions to allow for a buffer in the transportation conformity budget for 2008. This issue is discussed further in section 9.4, “Mobile Source Budgets.”

23Table 4-2 RFP Calculations VOC (tpsd) NOx (tpsd)

Emissions 2002 RFP Inventory 2008 Inventory 2002 RFP Inventory 2008 Inventory Stationary Point 10.3 11.0 7.0 7.3 Stationary Nonpoint 47.9 56.8 3.4 3.7
Non-road Mobile 26.8 21.0 19.7 16.0 On-road Mobile (adjusted) 26.8 24.6 39.2 28.3
Total 111.8 113.5 69.3 55.3 2008 RFP Target Emissions 111.8 58.9

Predicted 2002-2008

Emissions Reductions (Increases) (1.6) tpsd (1.4%) of 2002 RFP inventory) 13.9 tpsd (20.1% of 2002 RFP inventory)

Required 2002-2008

Emissions Reductions 0.0 tpsd (0.0% of 2002 RFP inventory) 10.4 tpsd (15.0% of 2002 RFP inventory)

Excess Emissions

Reductions (1.7) tpsd (1.5%) of 2002 RFP inventory) 3.5 tpsd (5.1% of 2002 RFP inventory)

2008 RFP Target NOx Emissions Adjusted to

Account for Increase in

VOC Emissions 57.8 tpsd (16.5% reduction from 2002 RFP inventory)

Required Emissions Reductions Adjusted to

Account for Increase in

VOC Emissions 11.4 tpsd (16.5% of 2002 RFP inventory)

Excess Emissions Reductions Adjusted to

Account for Increase in

VOC Emissions 2.5 tpsd (3.6% of 2002 RFP inventory)

245.0 ATTAINMENT DEMONSTRATION

5.1 Purpose of Section

EPA requires states with moderate ozone nonattai nment areas to prepare and adopt SIP revisions demonstrating attainment of the 8-hour ozone standard using photochemical grid modeling and weight-of-evidence (WOE) analyses. States with moderate nonattainment areas are required to attain the 8-hour ozone NAAQS by June 15, 2010. However, because the June 15, 2010 deadline occurs in the middle of the ozone season, according to EPA modeling guidance,

modeled attainment must be based on the ozone season preceding 2010. Therefore, the target year for attainment monito ring is calendar year 2009.

The following attainment demonstration demonstrat es that, as a result of reductions in ozone precursor emissions in Rhode Island and upwind of Rhode Island, Rhode Island will attain the 8- hour ozone NAAQS by 2009. The attainment demons tration is based upon the regional ozone attainment planning process undertaken by the OT C and OTC states to develop a SIP-quality ozone modeling platform and to prepare candida te control strategies for ozone attainment

demonstrations.

5.2 Ozone Conceptual Model

5.2.1 Conceptual Description for Ozone Episodes in Rhode Island

The Northeast States for Coordinated Air Use Ma nagement (NESCAUM), on behalf of the OTC, produced a comprehensive conceptu al description of the meteorol ogical processes underlying the formation of ozone episodes. The NESCAUM report (NESCAUM, 2006) was intended as a

reference for SIP attainment demonstrations an d is contained in Appendix 5A. State-specific information for Rhode Island is presented below.

5.2.2 Geographical Considerations

Rhode Island, at about 41 degrees north latitude , lies closer to the mean position of the polar

front than more southern states in the Ozone Tr ansport Region are. For that reason, Rhode Island experiences cooling and cleansing cold frontal passages more fre quently than in areas to its south, resulting in fewer and shorter, alt hough not necessarily weaker, ozone episodes.

Although Rhode Island contributes to pollutant levels in Massachusetts, it is primarily considered to be a downwind state, being a reci pient of ozone and precurs ors from much of the

northeast corridor includ ing Baltimore, Washington D.C., Ph iladelphia, New Jersey, and New York City. Stagnation, which occasionally results in elevated ozone in southern states, is not a major factor in Rhode Island episodes. Exceedances in Rhode Island are almost always due to elevated ozone and precursors transported from up wind areas; this is particularly true for the State’s Narragansett and W. Greenwich monito ring locations, which are upwind of the highly populated Providence metropolitan area.

255.2.3 Transport

Global scale circulations, while not a direct cause of Rhode Island ozone episodes, govern the location and strength of synoptic scale features su ch as high and low pressure systems and fronts, which are normally associated with ozone epis odes. Global systems ultimately control the duration of weather patterns and ho w often they recur, thus determ ining the severity of an ozone

season. When a summertime air mass resides for a long period over the ea stern United States and this pattern becomes recurrent, Rhode Island is likely to experience an above average ozone

season.

Mesoscale features also influen ce the spatial pattern of ozone development in Rhode Island. Sea

breezes often draw cleaner air ons hore, thus lowering ozone concen trations, but they sometimes have the opposite effect. If a plume of ozone lies offshore, such circulations can bring polluted air onto the land, causing a rapid ri se in ozone readings. This is a particular issue for the coastal Narragansett monitoring site. Lee troughs, induced by mountain ranges like the Appalachians, align the southwesterly airflow with the mount ains, resulting in more highly concentrated streams of pollution entering Rhode Island’s airw ays. Low-level nocturn al jets are relative newcomers in our understanding of ozone transpor t. This rapid transit mechanism can move pollution long distances from sout hwest to northeast to spread ozone episodes hundreds of miles overnight.

Smaller microscale circulations include the whor ls and eddies that transfer heat and energy vertically. This transf er mechanism often shuts down in th e evening when the earth cools and temperature inversions form. Ozone trapped near the ground is destroyed via chemical transformation and deposition. But ozone aloft remains relatively undepleted and mixes back to the surface the following morning when heating-i nduced eddies grow and erode the inversion.

This mechanism is basic to the diurna l rise and fall of surface ozone values.

5.2.4 Primary Meteorological Regimes for Rhode Island

Two primary synoptic meteorological patterns typically trigger seve re ozone episodes in Rhode Island and result in episodes having markedly differe nt ozone signatures. The first synoptic type

affects the immediate south coast and is controlled by the Atlant ic oceanic anticyclone (high pressure area), which extends westward well into interior of the eastern United States. This results in westerly to sometimes a west-north westerly surface winds over Rhode Island, with pollution transport from the New York and Ne w Jersey area eastward across Long Island Sound, bringing ozone and precursors to coastal Conne cticut, Rhode Island and Massachusetts. The westerly flow also blocks the plume’s northward penetration, keeping the re st of the state’s air relatively clean. A good example of this episode type is shown in 5-1 with (on the left) a distinct ribbon of high ozone along the New England south co ast with (on the right) the westerly surface winds that forced the plume seaward.

26Figure 5-1: July 2, 20 02 Ozone and Isobar Maps

LEFT : EPA ozone mapping showing peak 8-hr valu es on July 2, 2002. Levels above the 8-hour NAAQS (orange and red) occurred along the south coast, while concentrations were lower

inland. RIGHT : Surface isobars (sea-level pressure) and wind vectors at 2PM EST, July 2, 2002. (NOAA Air Resources Lab)

The second synoptic type occurs when the Atlan tic anticyclone has a more northeast-southwest orientation (as opposed to the west – east orient ation in the previous example) with less

extension into the interior of the eastern Unite d States. This pattern generates a more southsouthwesterly wind across southern New England, which carries pollutants from the New York City area northeastward into Western and Central New England. This flow keeps the main pollutant plume in the interior of or to the we st of Rhode Island, since southerly coastal breezes

draw in cleaner marine air. In this case, the ozone gradient is re versed from the first episode type discussed above; ozone levels tend to be lowest along the south coas t, while levels are elevated to the north and west. An example of this sec ond flow pattern is show n in Figure 5-2 showing clean air along the south coast with higher ozone ove r more northern interior sections of southern New England. The surface flow with marine air drawn inland along south coastal locales can be seen on the right side of Figure 5-2.

These two meteorological regimes occurred ma ny times during 2002, resulting in exceedances of the 8-hour ozone NAAQS at one or more of the Rhode Island monitors on seventeen days. (See Table 5-1) Similarly, a significant number of elevated ozone days occurred in many other portions of the eastern Unite States that year. Therefore, 2002 is an appropriate ozone season for use in modeling to demonstrate ozone attainment in Rhode Island and other parts of the OTR.

27Figure 5-2: August 12, 2002 Ozone and Isobar Maps

LEFT : EPA ozone mapping showing peak 8-hr valu es on August 12, 2002. Colors range from green (good air quality) along the sout h coast to red (unhealthy) inland. RIGHT : Surface isobars (sea-level pressure) and wind vectors at 2PM EST, August 12, 2002 (NOAA Air Resources Lab)

Table 5-1 Rhode Island Ozone Concentrations on 8-Hour Ex ceedance Days in 2002 (ppb)

W. Greenwich E Providence Narragansett 17-Apr NA 69 86 24-May 69 73 86

11-Jun 89 81 73

23-Jun 92 87 76

26-Jun 86 88 79

27-Jun 92 91 84

1-Jul 101 97 98

2-Jul 76 79 112

8-Jul 66 NA 86

9-Jul 111 103 79

18-Jul 91 86 101

19-Jul 91 76 79 4-Aug 79 77 94 11-Aug 95 84 70 12-Aug 100 87 56 13-Aug 120 120 92 14-Aug 92 92 70

285.3 OTC Modeling Protocol

5.3.1 Modeling Protocol (2002)

In 2002 the Ozone Transport Commission began de veloping a SIP modeling system for using photochemical grid models to assess the impact of candidate ozone control st rategies in the OTR. EPA’s Community Multi-scale Air Quality Mo deling System (CMAQ) was selected for attainment demonstrations in the OTC states. Air quality staff from the OTC states subsequently prepared a modeling protocol for attainment dem onstrations in the OTR. The modeling protocol, entitled “Modeling Protocol for the OTC SIP Quality Modeling System For Assessment of the Ozone National Ambient Air Qual ity Standard in the Ozone Tr ansport Region”, was endorsed by OTC at the November 12-13, 2003 Fall meeting.

5.3.2 Modeling Protocol (2006)

The modeling protocol, now dated December 31, 2006, has been modified several times since then to incorporate CMAQ model modificat ions, boundary condition estimates and emission inventory improvements. The New York Depa rtment of Environmental Conservation (NY DEC), under the direction of the OTC Modeling Co mmittee, agreed to be the lead agency for developing and using the SIP qua lity ozone modeling system as specified in the modeling protocol. The subject protocol, which describes the modeling pro cedures and databases to be used for SIP attainment demonstrations in the OTR, is contained in Appendix 5B.

5.4 Review of 2002 Ozone Episodes

5.4.1 Episode Selection Criteria

Ozone-based research has shown that model perf ormance evaluations and the model response to

emissions reductions need to consider relative ly long time periods. In order to examine the response to ozone control st rategies, EPA recommends th at episode days should be meteorologically representative of typical high ozone exceedance days and so severe that any control strategies predicted to attain the ozone NAAQS for that ep isode day would also result in attainment for all other exceedance days (EPA , 2007). Time periods to be modeled should display increasing ozone concentr ations over time, followed by a ramp-down period to cleaner conditions to allow for a more complete evalua tion of model performa nce under a variety of meteorological conditions.

5.4.2 Episode Selection Procedure

Because of the large areal extent of the OTR modeling domain, the OTC Modeling Committee

decided to model the entire 5-month ozone seas on in order to investigate numerous ozone episodes and to provide for better assessment of simulated pollutant fields. The 2002 ozone season was selected since a significant number of exceedance days were recorded across the eastern United States that year. A multi-year re view (1997-2003) of elevated ozone days in the OTR indicted that associated meteorological re gimes during high ozone days in 2002 were for

29the most part very similar to those found to occur in other years. The multi-year review, prepared by Environ (Environ, 2005) is contained in Appendix 5C. Based on this work, the OTC Modeling Committee is confident that the 2002 season is representa tive for purposes of photochemical modeling for ozone SIP attainment demonstrations.

5.5 Modeling Domain

5.5.1 Description

The OTR modeling domain is displayed in Figur e 5-3. The OTR modeling domain is embedded in the national grid that was adopted by th e five U.S. Regional Haze Regional Planning Organizations (RPOs) for photochemical grid m odeling. Individual RPOs are shown in Figure 5-

4.

The OTR modeling domain was designed to both cap ture the effects of emissions transported into the OTR and to test the effectiveness of 2009 control strategies in the OTR states. OTR states consist of Connecticut, Delaware, Wa shington D.C., Maryland, Maine, Massachusetts, New Jersey, New York, New Hamp shire, Pennsylvania, Rhode Island, Vermont and Virginia. Non-OTR states in the OTR modeling domain consist of Alabama, Arkansas, Georgia, Iowa, Louisiana, Illinois, Indiana, Kentucky, Michigan, Minnesota, Mi ssouri, North Carolina, Ohio, South Caroline, Tennessee, Virginia and Wisconsi n. The horizontal grid resolution is 12 km and there are 172 grids in the east- west and 172 grids in north-south direction. Details of the modeling system grid setup are contained in Appendix 5D.

5.5.2 Horizontal Grid Size

Following EPA guidance and as noted above, a 12 km grid resolution was used for the domain. Details of the horizontal grid laye rs are contained in Appendix 5D.

5.5.3 Number of Vertical Layers

Although the definition of the vert ical structure can be adopted on a one-to-one basis with the meteorological model (which is 29 layers), it was decided not to do so. Given the available computational resources and runtime needs, it was decided to limit the number of vertical layers in the photochemical model to 22, with the lowest 16 layers (where most of the ozone chemistry takes place) set one-to-one with t hose of the meteorological model. Details of vertical grid layers are contained in Appendix 5D.

30Figure 5-3: OTR Photochemical Grid Mode ling Domain (Eastern Modeling Domain)

5.6 Photochemical Grid Modeling System

5.6.1 Photochemical Grid Modeling System

EPA’s Community Multi-scale Air Quality Mode ling System (CMAQ) was selected for ozone

attainment demonstrations in the OTR because it addresses multiple pollutants and different spatial scales ( http://www.epa.gov/asmdnerl/CMAQ/index.html ). The CMAQ platform is also being used for regional haze applications in the OTR and for PM2.5 attainment demonstrations for those jurisdictions within the OTR desi gnated as non-attainment for the PM2.5. The CMAQ framework is an advanced computational platfo rm that provides a sophisticated and powerful modeling environment for science and regulatory communities. CMAQ has a "one atmosphere" perspective; it was specifically de signed to approach air quality as a whole by including state-ofthe-science capabilities to addr ess multiple air quality issues, including tropospheric ozone, fine particles, toxics, acid deposition, and visibility degradation. The target grid resolutions and domain sizes for CMAQ can range spatially and te mporally over several orders of magnitude. In addition, CMAQ also has temporal flexibility; simulations can be performed for long-term (annual to multi-year) polluta nt climatologies as well as short term (weeks to months) to simulate transport of precursor emissi ons from localized sources.

31Figure 5-4: Regional Ha ze Regional planning Organizations (RPOs)

5.6.2 CMAQ Modeling System Source Codes The CMAQ modeling system contains three type s of modeling components: a meteorological modeling system (MM5) for the description of atmospheric st ates and motions; an emission model (SMOKE) for man-made and natural emissions that are injected into the atmosphere; and a chemistry-transport modeling system (CMAQ) for simulation of the chemical transformation and fate. Because CMAQ is designed to handle scal e-dependent meteorological formulations and

5.6.2 CMAQ Modeling System Source Codes

The CMAQ modeling system contains three type s of modeling components: a meteorological modeling system (MM5) for the description of atmospheric st ates and motions; an emission model (SMOKE) for man-made and natural emissions that are injected into the atmosphere; and a chemistry-transport modeling system (CMAQ) for simulation of the chemical transformation and fate. Because CMAQ is designed to handle s cale-dependent meteorological formulations and a large amount of system flexib ility, CMAQ's governing equations are expressed in a generalized coordinate system. The generalized coordinate system determines the necessary grid and

coordinate transformations and can accommoda te various vertical coordinates and map projections. The SMOKE and CM AQ codes are available at http://www.cmascenter.org/ and

MM5 codes can be obtained at http://www.mmm.ucar.edu/mm5/

325.6.3 CMAQ Model Setup for the OTR Domain

The CMAQ Model (Version 4.5.1) was used to pr edict ozone concentrations in the OTR modeling domain. The CMAQ model confi guration and the MM5/SMOKE/CMAQ modeling system grid specifications employed by th e NY DEC are presented in Appendix 5D.

5.7 Meteorological Modeling System

5.7.1 MM5 Meteorological Model

The Fifth-Generation Pennsylvani a State University/NCAR mesoscale model, referred to as MM5, was used by the University of Maryland (UMD ) to generate meteorological fields for the OTR modeling domain. MM5 is a limited- area, non-hydrostatic, terrain-following sigmacoordinate model designed to simulate mesos cale atmospheric circulation. MM5 codes can be

obtained at http://www.mmm.ucar.edu/mm5/ . The set of options used by UMD for running MM5 (Version 3.6) in consultation with NY DEC are listed in Appendix 5E.

5.7.2 MM5 Meteorological Fields

The National Weather Service NCEP ETA 40 km resolution-forecasting model was employed to initialize the MM5 model and to provide outer edge boundary conditions for the MM5 model. To minimize model error, the model app lied four-dimensional data assimilation nudging techniques employing National Weather Servi ce surface wind and upper air data (Zheng and Zheng, 2004). The model was applied in a Lambert conformal map projection over two-way nested domains. The coarse grid (36 km) domain and the fine grid (12 km) domain are shown in Figure 5-5. MM5 was used to produce hourly mete orological fields for th e calendar year 2002.

Since there are a variety of options that can be exercised with MM 5, initial testing was performed for a high ozone event of 2002 with commonly used default options as well as with modified boundary layer schemes (Zhang and Zh eng 2004). Based on this work, a modified Blackadar scheme was employed in order to pro duce more accurate diurnal cycles of surface winds and temperatures. A description of the pr eparation of MM5 meteorological fields for the OTR modeling domain is contained in 5F.

5.7.3 MM5 Model Performance

NY DEC and UMD tested several MM5 configurations before se ttling on one that included a modification to the Blackadar planetary boundary scheme in order to obtain an accurate rendering of three-dimensional me teorological fields over the OTR modeling domain. This work was coordinated through the OTC Modeling Committee.

33Figure 5-5: MM5 Modeling Domains (36 km and 12 km )

After MM5 hourly meteorological fields were prep ared, the simulated meteorological fields for 2002 ozone season (May 1 to September 30) were compared to National Weather Service (NWS) and CASTNet surface temperature, wind speed, and humidity observations. CASTNet is the nation’s primary source of rural ground-level ozone measurements and associated meteorological data. Comparisons with CASTNet data provid e a more independent assessment of the MM5 model since CASTNet data, unlike NWS data, is not used to in the MM5 application to improve model performance (model nudging). MM5 results were also compared w ith wind profiler data and cloud data derived from satellite images to diagnose if the MM5 simulation is yielding the right type of dynamics in the vertical. Thes e analyses (Appendix 5F) indicate that the performance of MM5 is reasonable across the OTR both at the surface and in the vertical, thereby providing confidence in the use of MM5 results for the CMAQ simulations.

5.8 Biogenic emissions

5.8.1 BEIS Modeling System

Biogenic emissions of VOCs, NOx and CO from natural sources for the time period from January 1, 2002 – December 31, 2002 were calcu lated by the NY DEC using the Biogenic

34Emissions Inventory System (BEIS version 3.12 ) integrated within SMOKE2.1. The procedures used to calculate biogenic emissi ons are contained in Appendix 5G.

5.8.2 OTR Modeling Domain Biogenic Emissions

NY DEC used gridded land use data and emi ssions factors to produce gridded normalized biogenic emissions for 34 species/compounds in the OTR modeling domain. The gridded land use file utilized by NY DEC included the fractiona l coverage of 230 different land use types for each of the 12-km grid cells in the OTR modeling domain. MM5/MCIP meteorological variables were then used to compute hour-specifi c, gridded biogenic emissions, which were then converted to CO, NO, and the Carbon Bond IV ( CB-IV) VOC species utilized in CMAQ Model.

5.9 Boundary and Initial Conditions

5.9.1 Generation of Boundary Conditions

NY DEC prepared boundary conditions for th e OTR 12 km domain by performing a CMAQ simulation for a continental U.S. grid with a 36 km grid spacing. The simulation utilized the 2002 emissions data provided from the five U.S. RPOs and the 2002 MM5 me teorological fields developed by the UMD (Section 7). Clean initial conditions were employed, and boundary

conditions for the continental USA simulation we re extracted from a simulation of the GEOSCHEM global chemical model. The interface prog ram used to extract 36 km boundary conditions from the GEOS-CHEM global model was develope d by University of Houston (Moon and Byun, 2004). The CMAQ 36km simulation ran from December 15, 2001 to December 31, 2002 with the first 15 days in December 2001 as ramp up period. The boundary conditions simulation is described in more detail in Appendix 5H.

5.9.2 OTR Modeling Domain Boundary Conditions

The hourly boundary fields for the 12km CMAQ domain were obtained by using a boundary condition program (BCON) to extract the 3-D con centration fields from the NY DEC continental CMAQ run at the boundaries of th e OTC 12 km modeling domain. Boundary conditions were obtained for the ozone season simulation period (M ay 1 through September 30) with the first 14 days of May set as a ramp-up period to minimize the propagation of the boundary fields into the

areas of concern. Clean initial conditions were employed at th e start of the ramp-up period.

5.10 CMAQ Emission Files for 2002

5.10.1 Regional Planning Organization Annual Emission Inventories for 2002

The OTR modeling domain (previously shown on Figur e 5-3) contains states from 4 of the 5

U.S. RPOs: Mid-Atlantic/North east Visibility Union (MANE -VU), Central Regional Air Planning Association (CENRAP), Midwest Regi onal Planning Organization (MRPO) and the Visibility Improvement State and Tribal Associ ation of the Southwest (VISTAS). These RPOs

35were established by EPA to support regional haze planning activities, in cluding the development of coordinated multi-purpose emission inventorie s. Each RPO has prepared detailed emission inventories for calendar year 2002 that are be ing used for ozone, PM2.5 and regional haze SIP

attainment demonstrations. RPO boundaries were previously shown in Figure 5-4.

5.10.2 MANE-VU Annual Emission Inventory for 2002

The OTR states, except for Virginia, are member s of the MANE-VU RPO (Virginia is in the VISTAS RPO). The Mid-Atlantic Regional Air Management Association (MARAMA) directed the preparation of the 2002 MANE-VU emission i nventory. The MANE-VU states consist of Connecticut, Delaware, the Di strict of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont. A detailed technical support document describing the deve lopment of 2002 MANE-VU emission inventory is contained in Appendix 5I.

The 2002 MANE-VU emission inventory was based upon point, nonpoint, on-road, and nonroad emission inventory data submitted by MANE -VU states to EPA in 2004 as a requirement of the Consolidated Emissions Reporting Rule. Under contract to MARAMA, E.H. Pechan & Associates (Pechan) collected this information a nd ran EPA format and content quality assurance programs and other checks to identify format and data content issues. Data gaps were filled in accordance with a Quality Assurance Project Plan prepared for this project (MANE-VU, 2004a).

After making corrections and filling data ga ps, emission files for sulfur dioxide (SO 2 ), oxides of nitrogen (NO

x ), volatile organic compounds (VOC), carbon monoxide (CO), ammonia (NH 3) and particles with aerodynamic diameters less than or equal to a nominal 10 and 2.5 micrometers (primary PM 10 and PM 2.5 ) were prepared in National Emissi ons Inventory Input Format (NIF 3.0) and placed on the MARAMA ftp site.

Several versions of the emission inventory were prepared by Pechan to address corrections, improvements and ongoing state-of-the-art changes (for example, the non-road inventory was completely redone in Version 3 due to EPA modifications to the NONROAD2005 model). The

most current version of the MANE-VU emission inventory (Version 3) wa s used for OTR state

attainment demonstrations. MANE-VU state emission totals are s hown in Table 5-2.

Table 5-2: MANE-VU 2002 Anthro pogenic Emissions (Tons/Year )

2002 Version 3

Base Case CO NOx VOC NH 3 SO 2 PM10 PM2.5 PMC

Connecticut 992201 125208 162492 8598 32077 27061 15795 11266

Delaware 273433 58764 41120 14376 79868 15214 7931 7284

District of Columbia 101372 15389 14893 415 2939 2889 1276 1613

Maine 759882 94932 166501 11060 39362 64103 28458 35645 Maryland 1905406 283387 265220 31712 315251 72234 34805 37428

Massachusetts 1838763 276530 294703 25737 164112 89984 40667 49317 New Hampshire 594257 67326 111333 3678 55295 25796 19479 6316

36New Jersey 2276006 303053 378877 24931 91273 47021 29350 17671

New York 5223096 655774 921593 83801 448322 229391 90977 138413 Pennsylvania 4448357 806061 594355 91842 1077658 228459 82467 145992

Rhode Island 312263 29418 57200 1789 8022 5058 2486 2571

Vermont 351716 28290 50461 10608 6022 21218 8330 12888

Total 19076752 2744133 3058749 308548 2320202 828427 362022 466405

Note that the Rhode Island emissions in the MA NE-VU inventory are slightly different from those in Rhode Island’s 2002 Emissions Inventory, which is Appendix 2A of this document, due to the timing of the preparation of the inventor ies. However, as shown in Table 5-3, these differences are minor and would not affect the modeling results.

Table 5-3 Comparison of RIDEM and MARAMA 2002 Emissions Inventory for Rhode Island (tons per year)

VOC NOx

RI DEM MARAMA RIDEM MARAMA

Point 3,095 1,928 2,225 2,764 Nonpoint 16,809 31,402 3,045 3,886

On-Road 8,763 7,780 5,934 5,001

Non-Road 12,827 12,538 16,720 16,677 Biogenic 18,120 19,233 158 211

Total 59,614 72,881 28,082 28,539

The only substantial difference between the MARA MA and RI DEM emissions estimates is in emissions of VOC from nonpoint sources, specifi cally the nonpoint source surface coating and degreasing categories. MARAMA ’s nonpoint source surface coati ng and degreasing emissions

estimates came from 1999 EPA data based on ou tdated emissions factors, grown to 2002. RI DEM updated emissions estimates for both of these categories based on comments received on the draft inventory from EPA Region I The updated RI DEM emissions estimates for those categories are, as recommended, from an the EP A report “Solvent Mass Balance Approach for Estimating VOC Emissions from Eleven Point Source Categories.” Those emissions are much

lower than the older EPA estimates for th e nonpoint source surface coating and degreasing categories.

RI DEM also modified its estimates of emissions from process solvents, graphic arts, gasoline distribution and asphalt paving after the MARAMA inventory wa s developed. Since, the RI DEM emissions estimates are, overall, lower th an those in the MARA MA inventory, modeling done to show attainment, which used the MARAMA data, would actually slightly overestimate

Rhode Island’s contribution to ozone leve ls in and downwind of the State.

375.10.3 Emission files for the OTR Domain

CMAQ-ready emission files for each RPO in the OTR domain (MANE-VU, CENRAP, MRPO, and VISTAS) were prepared by NY DEC. Emissi on files for portions of Canada in the OTR domain were also prepared by NY DEC. Emissi on processing procedures are summarized below and described in more detail in Appendix 5J.

5.10.3.1 MANE-VU Emission Files for 2002

Point, nonpoint, and non-road source emissi ons for MANE-VU states (MANE-VU Version 3 emission inventory) were obtained from the MA RAMA ftp site and mobile emissions were

obtained from the NESCAUM ftp site. NY DEC processed these emission files with SMOKE2.2 to prepare CMAQ-ready hourly emission input files

5.10.3.2 CENRAP Emission Files for 2002

CENRAP states in the OTR modeling domain cons ist of Arkansas, Iowa, Louisiana, Minnesota, and Missouri. Point, nonpoint, mobile and non-road source emissions for CENRAP states (CENRAP Version BaseB emission inventory) were obtained from the CENRAP ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files.

5.10.3.3 MRPO Emission Files for 2002

MRPO states in the OTR modeling domain consis t of Illinois, Indiana, Michigan Ohio, and Wisconsin. Point, nonpoint, mobile and non-road emissions for MRPO states were generated by Alpine Geophysics through a contract from MA RAMA to convert the MRPO BaseK emission inventory to IDA format. The files were then obtained from the MARAMA ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files.

5.10.3.4 VISTAS Emission Files for 2002

VISTAS states in the OTR modeling domain c onsist of Alabama, Geor gia, Kentucky, North Carolina, South Caroline, Tennessee and Virgin ia. Point, nonpoint, mobile and non-road emission files for VISTAS states (VISTAS BaseG emission inventory) were obtained from the Alpine Geophysics ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files.

5.10.3.5 Canadian Emissions Files for 2002

Canadian non-road and mobile source emission files were obtained from EPA and processed with SMOKE2.1 by NY DEC. Non-EGU and EGU poi nt source emissions were obtained from Canadian National Pollutant Release Inventory (NPRI) database. NY DEC inserted SCC code estimates (NPRI has no SCC codes) and then processed the emission files with SMOKE2.2 to prepare CMAQ-ready hourly emission input files.

385.11 New OTR Control Measures for 2009

5.11.1 Potential Beyond On the Way (BOTW) Control Measures

Preliminary ozone modeling efforts (EPA, 2004) to support the proposed Clean Air Interstate Air Quality Rule (CAIR) indicated that additional controls beyond federal and state CAA control

measures would be needed to attain the 8-hour ozone NAAQS in several portions of the OTR. Accordingly, OTC staff and memb er states formed several OTC workgroups to identify and evaluate potential contro l measures. Control measures were identified through published sources

such as the U.S. Environmental Protecti on Agency’s Control Technique Guidelines, STAPPA/ALAPCO Menu of Options documents, th e AirControlNET database, emission control

initiatives in member states , state/regional consultations , and stakeholder input. OTC workgroups compiled and reviewed a list of ap proximately 1,000 candidate control measures

from which 30 control measures were selected for deta iled analyses.

5.11.2 Final OTC Beyond On the Wa y (BOTW) Control Measures

The OTC workgroups discussed th e candidate control measures during a series of conference calls and workshops from the spring of 2004 through the autumn of 2006. OTC workgroups collected and evaluated information regardi ng emission benefits, co st-effectiveness, and implementation issues, and stakeholders were prov ided opportunity to review and provide input. The procedures used to develop and evaluate these control measures (MACTEC, 2007b) are contained in Appendix 5K.

Based on this information, the OTC recommended th at States consider em ission reductions from the following source categories: Consumer Products, Portable Fuel Containers, Adhesives and Sealants Application, Diesel Engine Chip Reflash, Cutback and Emulsified Asphalt Paving, Asphalt Production Plants, Cement Kilns, Gl ass Furnaces, Industrial, Commercial, and Institutional (ICI) Boilers and Regional Fuels. Th ese control measures are collectively referred to as beyond on the way (BOTW) control measures.

As part of its 8-Hour Ozone Attainment Demonstration SIP, RI DEM plan s to adopt a regulation

to limit emissions from adhesives and sealants and to modify its regulations for Asphalt Paving (APC Regulation No. 25) and Solvent Metal Degreasing (APC Regulation No. 36) to be

consistent with control measures recommended in the BOTW measures.

The EPA’s Mobile Source Air Toxics rule, wh ich was adopted in February 2007 (72 FR 8428, February 26, 2007), contains specif ications for Portable Fuel Cont ainers effective in 2009 similar to the OTC BOTW recommendations. Similarly, the EPA issued a memo on May 30, 2007 committing to adopt federal rules consistent with the OTC BOTW limits for the Architectural and Industrial Maintenance(AIM) coatings category that woul d be effective by January 1,

392009. 14 . Therefore, RI DEM plans to adopt state-sp ecific regulations for those source categories only if EPA fails to fulfill its commitment in this area..

Rhode Island also does not plan to adopt rule s for the source categorie s corresponding to the remaining BOTW categories. In January 2007, in response to a court ruling invalidating the California Chip Reflash regulati on, which was the basis for the OTC recommendations for that source category, the California Air Resources Board announced that it would no longer enforce that regulation. Rhode Island has no major sources in the Asphalt Production Plant source category and has no Cement Kilns. The one Rhode Island Glass Furnace facility has permitted

emissions limits lower than those in the OTC BOTW recommendations. Rhode Island already requires reformulated gasoline statewide, and thus would not benefit from the OTC Regional Fuels measure. The larger Industrial, Commer cial, and Institutional (ICI) Boilers in Rhode Island are currently regulated under APC Regula tion No. 27; RI DEM believes that further regulation of this source category at this time is unlikely to yield signifi cant additional emissions

reductions.

In summary, Rhode Island will adopt all of the OTC BOTW measures that would feasibly yield

additional emissions reductions in the State in 2009. BOTW measur es included in the 2009 modeling for Rhode Island are listed in Table 5-3A, along with the st atus of the adoption of those

measures in Rhode Island.

5.12 CMAQ Emission Files for 2009 with OTC BOTW Control Measures

5.12.1 Regional Planning Organization Annual Emission Inventories for 2009

The CENRAP, MRPO, VISTAS and MANE-VU RP Os prepared future year emission inventories for 2009 by applying growth and contro l measures to the 2002 base year emission

inventories. The control measures reflected all control programs that ar e already on the way and in effect by 2009. These emission inventories, referre d to as “on the way” em ission inventories, reflect NOx SIP Call and CAIR requirements ( http://www.epa.gov/inte rstateairquality/ )

, federal on-road and off-road fuels, federal motor vehicl e standards and state LEV (low emission vehicle) programs, federal MACT rules, 2001 OTC mode l rules for consumer products, architectural coatings, distributed generation and any other state-specific ru les in effect by 2009. The interRPO work group utilized the Inte grated Planning Model (IPM) to develop state and unit-level EGU emissions reflecting EPA’s Clean Air Inte rstate Rule (CAIR) in the CENRAP, MRPO, VISTAS and MANE-VU RPOs (ICF, 2005).

14 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to Regional Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer and Commercial Products,” May 30, 2007.

40Table 5-3A Status of Adoption of Rhode Island BOTW Control Measures

Control Measure Status

Consumer Products Will submit by 10/1/08 if EPA has not proposed by 7/1/08 AIM Coatings (OTB/OTW) Will submit by 10/ 1/08 if EPA has not proposed by 7/1/08

Portable Fuel Containers Equivalent re quirements adopted in EPA Mobile Source

Air Toxics rule Mobile Equipment Repair & Refinishing (OTB/OTW) Equivalent rule (APC Regulation No. 30) adopted 1994

Solvent Cleaning (OTB/OTW) Will submit update to APC Regulation No. 36 by 1/1/09

Adhesives and Sealants Will submit new rule by 10/1/08 Asphalt Paving Will submit update to APC Regulation No. 25 by 1/1/09

5.12.2 MANEVU Annual Emission Inventory with BOTW Control Measures for 2009

The Mid-Atlantic Regional Air Management Association (MARAMA) contracted MACTEC to prepare 2009 emissions for non-EGU point sources , nonpoint sources and non-road sources that

reflected control measures that were already on the way and in effect by 2009. MACTEC in

consultation with MANE-VU stat es developed the necessary growth and control factors and applied them to the 2002 MANE-VU emission inve ntory (Version 3) previously described in

Section 10. Details of this work effort are contained in Appendix 5L (MACTEC, 2007a). Mobile source emissions were prepared by VA DEQ and NESCAUM, using MOBILE 6 input files and projected 2009 VMTs s upplied by the MANE-VU states.

MACTEC then calculated “beyond on the way” (B OTW) emission reductions reflecting the new OTC 2006 model rules for non-EGU point sources a nd several nonpoint source categories in the OTR states (previously described in Secti on 5.11). The BOTW control measures were developed because preliminary ozone modeling e fforts indicated additional controls would be needed to attain the 8-hour ozone NAAQS in portions of the OTR. Emission reduction calculations are presented in Appendix 5K (MACTEC, 2007b). State totals for the MANE-VU 2009 emission inventory reflecting BOTW control measures are shown in Table 5-4. BOTW emission reductions were incorporated into the 2009 MANE-VU 2009 emission inventory and all emission files were placed on the MARAMA ftp site

5.12.3 Emission files for the OTR Domain

CMAQ-ready emission files for 2009 for each RP O in the OTR modeling domain (MANE-VU, CENRAP, MRPO, and VISTAS) we re prepared or obtained by NY DEC. Emission files for portions of Canada in the OTR domain were also prepared by NY DEC. Emission processing procedures are summarized below and de scribed in more detail Appendix 5M.

41Table 5-4: MANE-VU 2009 Anth ropogenic Emissions with BOTW Controls (Tons/Yr)

2009 Version 3

BOTW CO NOx VOC NH 3 SO 2 PM10 PM2.5 PMC

Connecticut 751975 82139 122353 9255 22796 26481 15037 11443

Delaware 231392 49658 32109 14695 42569 15372 7694 7679

District of Columbia 67904 10433 10403 436 2297 2006 1124 882

Maine 579671 60201 141619 12974 38737 64881 27633 37247 Maryland 1373959 147710 205097 38971 114046 80496 39550 40946

Massachusetts 1290133 180391 229386 26513 64733 93839 42428 51411 New Hampshire 443286 44339 94330 4266 18597 26087 19511 6577 New Jersey 1778637 185314 285559 27935 49535 46183 28753 17430

New York 3730881 456457 710567 100682 325621 242237 98945 143293 Pennsylvania 3422688 518109 477042 113344 403150 259116 107315 151801

Rhode Island 240906 21900 44612 2144 8359 5410 2608 2802

Vermont 236142 17793 43063 13038 5966 22103 8099 14004

Total 14147574 1774443 2396138 364252 1096404 884212 398696 485516

5.12.3.1 MANE-VU Emission Files for 2009

Non-EGU point source and nonpoint source emi ssions for MANE-VU states (2009 MANE-VU Version 3 emission inventory) reflecting BOTW control measur es were obtained from the MARAMA ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready emission input files. Mobile source emissions for MANE-VU states were obtained from the MARAMA ftp site by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready emission input files. Non-road source emissions (2009 MANE-VU Version 3 emission inventory) were obt ained from the MARAMA ftp s ite by VA DEQ and processed with

SMOKE2.2 to prepare CMAQ-ready emission input files. EGU emissions (IPM2.1.9) were obtained from ICF (ICF, 2005) by VA DEQ and processed with SMOKE2.2 to prepare CMAQready hourly emission input files.

5.12.3.2 CENRAP Emission files for 2009

Non-EGU point, nonpoint, mobile and non-road emissions for CENRAP states in the OTR domain (2009 CENRAP BaseB emis sion inventory) were obtained from the CENRAP ftp site by VA DEQ and processed with SMOKE2.2 to prepare CMAQ-ready emission input files for the 2009 simulation. EGU emissions (IPM2.1.9) were obtained from ICF (ICF, 2005) by VA DEQ and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files.

5.12.3.3 MRPO Emission files for 2009

Nonpoint and non-road emissions for MRPO st ates in the OTR domain (2009 MRPO BaseK emission inventory) were obtained fr om the MRPO by NY DEC and processed with SMOKE2.2 to prepare CMAQ-ready emission files for the 20 09 simulation. Non-EGU and mobile emissions

42were obtained from the 2009 MRPO BaseK em ission inventory by VA DEQ and processed with

SMOKE2.2 to prepare CMAQ-ready emission input f iles. EGU emissions (IPM2.1.9) were obtained from ICF (ICF, 2005) by VA DEQ and processed with SMOKE2.2 to prepare CMAQready hourly emission input files.

5.12.3.4 VISTAS Emission Files for 2009

Non-EGU point, nonpoint, mobile and non-road em ission files for VISTAS states in the OTR domain (2009 VISTAS BaseG em ission inventory) were obtain ed from the Alpine Geophysics ftp site by VA DEQ and processed with SMOKE2.2 to prepare CMAQ-ready emission input

files for the 2009 simulation. VISTAS EGU emi ssions were obtained from ICF (ICF, 2005) by VA DEQ and processed with SMOKE2.2 to prepare CMAQ-ready hourly emission input files.

5.12.3.5 Canadian Emission Files for 2009

NY DEC obtained nonpoint, non-road and mobile source emission files for 2010 from EPA and obtained EGU point source emissions for 2010 from Environment Canada. These were considered to be a reasonable surrogate for 2009. Non-EGU point source emissions for 2002 (Section 10.3) were used as a surrogate for 2009. NY DEC processed th ese Canadian emission

files with SMOKE2.2 to prepare CMAQ-ready hourly emission input files.

5.13 Quality Assurance of CMAQ Databases

All air quality, emissions, and meteorological da ta were reviewed to ensure completeness, accuracy, and consistency before proceeding w ith modeling. Any errors, missing data or inconsistencies were addressed using standa rd practices. All modeling was benchmarked through the duplication of a set of standard modeling results in cluding benchmark runs with five modeling centers in the OTR (New York Department of Environm ental Conservation, University of Maryland, NESCAUM, Rutgers University, and Virginia Department of Environment Quality).

Quality assurance activities were carried out for the various emissions, meteorological, and photochemical modeling components of the mode ling study. Emissions inventories obtained from all RPOs (CENRAP, MANE-VU, MWRPO a nd VISTEAS) were examined to check for

errors in the emissions estimates. When such er rors were discovered, th e problems in the input

data files were corrected.

The MM5 meteorological and CMAQ air quality model inputs and outputs were plotted and examined by NY DEC to ensure accurate represen tation of the observed da ta in the model-ready fields, and temporal and spatial consistenc y and reasonableness. Both MM5 and CMAQ underwent operational and scie ntific evaluations by NYDEC a nd the OTC Modeling Committee to facilitate the quality assura nce review of meteorol ogical and air quality modeling procedures.

435.14 CMAQ Model Simulation for 2002 Base Case

5.14.1 CMAQ Model 2002 Application

The CMAQ 2002 base case simulation was perf ormed by NY DEC using a one-way nesting approach for the 12 km OTR modeling domai n. The OTR modeling domain was previously described in Section 4. CMAQ (version 4.5.1) was used with CB-IV chemistry, the aerosol

module for PM 2.5 and the Regional Air Deposition Model (RADM) cloud scheme. The simulation ran from May 1 to September 30, with the first 14 days of May used as a ramp-up period to minimize the propagation of boundary fiel ds into areas of concern. The CMAQ results used for the performance evaluation were from May 15 through September 30. Details of the CMAQ setup and application are listed in Appendix 5N.

5.14.2 CMAQ Input Files for 2002

5.14.2.1 Emission Files for 2002 simulation

The CMAQ-ready hourly emission files described in Sub-Section 10 for all RPO states and Canadian Provinces in the OTR modeling dom ain were used for the 2002 CMAQ base case

simulation. As described in Section 8, NY DEC used the BEIS model to prepare gridded normalized biogenic emission files for CO, NO, and the CB-IV VOC species for the 2002

simulation.

5.14.2.2 Boundary and Initial Conditions for 2002 simulation

As described in Sub-Section 9, hourly boundary fields for the 12km CMAQ domain were obtained by NY DEC using the BCON program to extract the 3-D concentration fields from the NY DEC continental USA CMAQ run at the four edges of the OTR m odeling domain. Clean initial conditions were employed.

5.14.2.3 Meteorological Files for 2002 simulation

The meteorological data for the 2002 simulation were based on the MM5 modeling described in Sub-Section 7. The MM5 fields for the May 1 to September 30 MM5 simulation were processed with Meteorology Chemistry Inte rface Processor (MCIP Version 3.0) obtained from the CMAS Modeling Center ( http://www.cmascenter.org ) in order to provide CMAQ model-ready hourly meteorological input files.

5.14.2.4 Photolysis Rates

Photolysis rate lookup tables were generated by NY DEC for each day using CMAQ’s Photolysis Rates Processor (JPROC) software ( http://www.cmascenter.org ). Daily ozone column measurements from NASA’s Earthpr obe Total Ozone Mapping Spectrometer (TOMS) instrument ( ftp://toms.gsfc.nasa.gov/pub/eptoms/data/ozone/Y2002/ ) were downloaded and used as input to the JPROC processing software.

445.14.3 CMAQ Output Files

Predicted hourly ozone concentrations for each ozone monitoring stati on location in all OTR states are listed in Appendix 5O. Daily ozone maps for the 2002 ozone season are contained in Appendix 5P. All input and output files for th e 2002 Base Case CMAQ simulation for the OTR modeling domain are listed in Appendix 5U. File s are available in electronic format from NY DEC for use with the SMOKE/CMAQ system. Pl ease contact Gopal Sistla at 518-402-8402 data file requests.

5.15 Performance Evaluation of 2002 Simulation

5.15.1 NY DEC Performance Evaluation for OTR Modeling Domain

NY DEC conducted a detailed performance eval uation of the OTC CMAQ modeling platform simulation for the 2002 ozone season (Appendix 5Q ). The CMAQ simulation ran from May 1 to September 30; May 1 through May 14 was the ramp up period to minimize effects of boundary conditions and the results for May 15 though Se ptember 30 were used for the performance evaluation. Air quality predictions for O 3 , CO, NO, NO2, SO2, C 2 H 4 , C 5 H 8 , HCHO, PM 2.5 and several regional haze aerosol spec ies were compared to measurements in every grid cell where air quality data were available. Hourly ozone measurements from 234 monitors were available to assess CMAQ model performance in the OTR.

A variety of model performance metrics for each of these pollutants - observed average, predicted average, correlation coefficient (R2), no rmalized mean error, root mean square error (RMSE), mean absolute gross er ror (MAGE), mean normalized gross error (MNGE), mean bias (MB), mean normalized bias (MNB), mean fracti onalized bias (MFB), normalized mean bias (NMB), along with temporal plots and daily ozone maps were prepared in order to help assess model performance. In general, the obser ved and predicted com posite average ozone concentrations track well, alt hough there was fairly substantial under-prediction during the midAugust period. Model performance was better in the vicinity of urban areas and along the northeastern corridor, compared to the performa nce in rural areas where the model tended to under-predict daily maximum concentrations. A co mplete set of model performance statistics for all OTR monitoring locations is contained in Appendix 5R.

5.15.2 CMAQ Spatial Performance in New England States

In assessing spatial performance of the CMAQ mode l, two elements are critical: (1) the model’s ability to replicate th e general spatial pattern of ozone across most of the domain and, in particular, the New England region, and (2) wh ether the model can re produce concentration gradients often observed along and within a few miles of the New England coast. A review of side-by-side maps of observed and predicted peak ozone values for the 2002 ozone season indicate the CMAQ model is do ing a fairly good job of rep licating spatia l patterns and concentration gradients. A complete set of daily maps is contained in Appendix 5P.

45Figures 5-6 – 5-9 reveal good consistency between predicted a nd observed daily peak 8-hour ozone values. The simulations in Figure 5-6 an d 5-7, for example, capture the narrow strip of elevated ozone from around Maryland northeastw ard to southern New England. The CMAQ model reproduced the splotchy areas of high ozone from the Midwest down across Tennessee (Figure5-7), as well as the clean areas near the Carolina coasts. In Figure 5-8, not only are the New England plume and broad Midwest region of high ozone captured, but the area of relative minimum ozone across Pennsylvania a nd New York is also replicated.

In addition, and perhaps most importantly for Ne w England, it appears that the model correctly handles the effect of slight wi nd trajectory differences on ozone patterns across the southern New England coast. Figure 5-8 shows that the CM AQ model correctly predic ted high ozone values across southern New England, along with a clean area on the south coast caused by marine air blowing onshore. A reverse of that pattern is shown in Figure 5-9, in which south coastal New England has elevated ozone while values in interi or southern New England are low. This typical westerly (as opposed to southwes terly) flow scenario draws polluted air from the New York City/New Jersey areas eastward along the New England south coast. Air reaching interior sections of New England had earlier crossed centra l New York and thus arri ved fairly clean. That the model discerned these two episode types and reproduced the north -south gradient is encouraging, and gives confidence that the CM AQ model can replicate daily maximum 8-hour

ozone concentrations in New England.

Figure 5-6: Maximum 8-Hour Values on August 8, 2002

46Figure 5-7: Maximum 8-Hour Values on August 8, 2002

Figure 5-8: Maximum 8-Hour Values on June 21, 2002

47Figure 5-9: Maximum 8-Hour Values on July 18, 2002

Finally, the CMAQ model appears to do a reas onable job of simulating ground level ozone diurnal buildup and decay. Figure 5-10 is a time series of observed and modeled peak 8-hour ozone values averaged over the domain for the entire modeling period (NYDEC, 2006).

Figure 5-10: Hourly Ozone Va lues for 2002 Ozone Season

Observed and Predicted averages 208 SLAMS/NAMS sites; 40 ppb threshold

0 10 20 30 40 50 60 70 80 90 100

20020515 20020523

2 002

0531 2002 0608 20020616 2002 0624 2002 0702 20020710 20020718 20020726 20020803 20020811 20020819 2002 0827 2002 0904 20020912 2002 0920 2002 092

8ppb obs avg, ppb

CMAQ avg, ppb

48Although an under prediction is ev ident, it is consistent, a nd the predictions do track the

observations well. The model’s under prediction of ozone is not a big concern since CMAQ modeling results are to be used in a relative se nse, and because the under-prediction is consistent over the modeling period and across the modeling domain.

5.15.3 CMAQ Selected Model Metr ics for New England States

EPA recommends that several statistical metr ics be developed for air quality modeling (EPA, 2007). Two metrics that are most often used to assess performance are mean normalized gross error (MNGE) and the mean normalized bias (MNB ). The mean normalized gross error provides

an overall assessment of model performance and can be interp reted as precision, and the mean normalized bias parameter measures a model's abili ty to reproduce observed spatial and temporal patterns, and can be interpreted as accuracy. EPA suggests a MNGE of less than 35% above a threshold ozone level of 40-60 ppb and a MNB of less than ±15% as a reasonable test for acceptable model performance. The MNGE and the MNB for maximum daily 8-hour concentrations at or above 60 ppb at Rhode Island ozone monitors for the 2002 CMAQ

simulation are shown in Table 5-5.

Table 5-5: Mean Normalized Gross Error and Mea n Normalized Bias for RI Ozone Monitors

State AIRS-ID Location Observed ppb CMAQ ppb MNGE % MNB %

RI 440030002 W. Greenwich 77.9 75.7 10.5 -1.8

RI 440071010 E. Providence 77.6 74.0 10.8 -4.3

RI 440090007 Narragansett 76.9 83.3 14.9 9.4

AVERAGE 12.1 1.1

Recommended <35% < + 15%

Both of the metrics, MNGE and MNB, are well w ithin the acceptable range at all three of Rhode

Island’s monitors.

The MNGE and the MNB for maximum daily 8-hour concentrations at or above 60 ppb at all other New England state ozone monitors are liste d in Table 5-6. The other New England state

ozone monitors also meet the MNGE criteria of 35%. The MNB values are above the ±15%

criteria at two sites in Massachusetts and at several ozone monitoring locations in Vermont and New Hampshire. This under-prediction at these monitors is not considered to be a significant concern since the 2002 design values at these mon itors (Table 5-9 and Ta ble 5-12) are already below or close to the ozone NAAQS. In additi on, CMAQ modeling results are being used in a relative way which helps minimize the under-pre diction of peak ozone concentrations.

49Table 5-6: Mean Normalized Gross Error and Mean Normalized Bias for Other New England Ozone Monitors

State AIRS-ID Location Observed ppb CMAQ ppb MNGE % MNB %

MA 250010002 Truro 76.3 82.8 14.0 9.1

MA 250034002 Adams 73.6 61.2 16.4 -16.0

MA 250051002 Fairhaven 74.3 74.6 11.5 1.6

MA 250090005 Lawrence 80.0 72.3 14.6 -8.0

MA 250092006 Lynn 80.8 71.6 13.7 -10.7

MA 250094004 Newbury 79.4 87.6 14.7 10.3

MA 250130003 Agawam 76.6 67.1 15.1 -11.7

MA 250130008 Chicopee 76.4 65.2 15.3 -14.0

MA 250150103 Amherst 73.8 65.6 12.9 -10.9

MA 250154002 Ware 76.0 66.7 14.9 -11.7

MA 250171102 Stow 76.3 66.2 13.7 -12.8

MA 250213003 Milton 79.6 68.3 15.4 -13.7

MA 250250041 Boston (Long I) 76.7 76.1 17.1 0.2

MA 250250042 Boston (Harris) 72.4 65.8 12.9 -8.4

MA 250270015 Worcester 82.7 65.9 19.8 -19.8

MA AVERAGE 14.8 -7.8

CT 090010017 Greenwich 78.2 77.8 13.8 0.3

CT 090011123 Danbury 80.9 73.4 13.4 -8.7

CT 090013007 Stratford 80.8 80.0 17.1 -0.1

CT 090019003 Westport 80.7 78.9 12.2 -1.8

CT 090031003 E. Hartford 77.8 78.6 13.8 2.3

CT 090050005 Cornwall 78.8 64.5 20.2 -17.8

CT 090070007 Middletown 80.5 77.9 10.7 -3.7

CT 090093002 Madison 83.1 83.8 14.5 1.7

CT 090099005 Hamden 79.4 78.0 13.0 -1.0

CT 090110008 Groton 75.5 94.4 30.3 28.1

CT 090131001 Stafford 78.2 71.1 12.2 -8.7

CT AVERAGE 15.6 -0.9

NH 330012004 Laconia 70.1 52.7 24.6 -24.6

NH 330031002 Conway 67.5 52.8 21.8 -21.3

NH 330050007 Keene 75.9 64.5 15.9 -14.5

NH 330074001 Mt Washington top 72.3 50.5 30.0 -30.0

NH 330074002 Mt Washington base 66.7 57.0 17.4 -14.5

50State AIRS-ID Location Observed ppb CMAQ ppb MNGE % MNB %

NH 330074003 Pittsburg 68.7 54.7 20.5 -20.5

NH 330090008 Haverhill 68.0 52.8 22.1 -22.1

NH 330110020 Manchester 74.5 62.9 15.5 -15.0

NH 330111010 Nashua 76.1 66.0 13.9 -12.3

NH 330115001 Peterborough 80.9 60.3 24.7 -24.7

NH 330130007 Concord 74.2 58.5 20.9 -20.7

NH 330150012 Rye 78.2 69.6 13.4 -11.1

NH 330150013 999 73.9 61.9 16.7 -15.3

NH 330150015 Portsmouth 79.1 72.4 9.7 -8.5

NH 330173002 Rochester 74.7 64.0 15.5 -14.0

NH 330190003 Claremont 72.1 55.9 22.2 -22.2

NH AVERAGE 19.0 -18.2

VT 500030004 Bennington 70.9 59.2 16.5 -15.7

VT 500070007 Underhill 74.8 56.1 24.2 -24.2

VY AVERAGE 20.3 -19.9

ME 230052003 Cape Elizabeth 76.0 72.4 13.6 -3.1

ME 230090102 ANP Cadillac M 79.0 70.3 12.8 -10.7

ME 230090103 ANP McFarland 76.4 69.4 11.6 -8.5

ME 230090301 Castine 72.3 73.7 10.2 2.8

ME 230112005 Gardiner Pray 77.3 65.4 17.2 -14.8

ME 230130004 Port Clyde 73.1 77.1 15.6 5.6

ME 230173001 North Lovell 67.6 51.8 24.0 -24.0

ME 230194008 Holden Rider B 74.1 58.7 21.1 -20.3

ME 230230004 Georgetown 75.6 83.4 12.5 11.0

ME 230310038 West Buxton 76.8 62.1 19.0 -19.0

ME 230313002 Kittery 82.3 71.6 15.9 -11.8

ME 230312002 Kennebunkport 80.3 70.1 13.8 -12.3

ME 239010001 Scotia Prince Ferry 73.0 64.7 17.8 -11.6

ME AVERAGE 15.8 -9.0

515.16 CMAQ Model Simulation for 2009 Control Strategy

5.16.1 CMAQ Model 2009 Application

The CMAQ 2009 base case simulation was performe d by NY DEC in the same manner as the CMAQ 2002 base case simulation. Th e simulation period ran from May 1 to September 30, with the first 14 days of May as a ramp-up period to minimize the propagation of the boundary fields into areas of concern. The actual CMAQ result s for the CMAQ control strategy evaluation were from May 15 through September 30.

5.16.2 CMAQ Input Files for 2009.

5.16.2.1 Emission Files for 2009 simulation

The CMAQ 2009 control strategy simulation em ployed the 2009 CMAQ-ready hourly emission

files described in Sub-Section 12 for RPO states and Canadian Provinces in the OTR modeling domain. These emission files reflect “beyond on the way” (BOTW) controls in all OTR states and “on the way controls” (OTW) controls in CENRAP, MRPO and VISTAS states in the OTR modeling domain

. The 2002 hourly biogenic were also used for 2009 CMAQ simulations since significant change in land use would not be expected to occur between 2002 and 2009.

5.16.2.2 Boundary and Initial Conditions for 2009 simulation

The 2002 hourly boundary condition f iles (Section 14) were used for the 2009 future year CMAQ simulation. This was considered to be a reasonable and conservative approach since air pollution levels and emissions are expected to be lower in 2009.

5.16.2.3 Meteorological Files for 2009 simulation

The 2002 hourly meteorological files (Section 14) were used for the 2009 simulation.

5.16.2.4 Photolysis Rates

The photolysis rate tables generated for 2002 (Section 14) were used for 2009 simulation.

5.16.3 CMAQ Output Files

All input and output files for 2009 BOTW CMAQ simulation for the OTR modeling domain are listed in Appendix 5S. Files are available in electronic format for the 12km domain from NYSDEC for use with the SMOKE/CMAQ system. Please contact NY DEC Gopal Sistla at 518- 402-8402) for data file requests.

525.17 Predicted Design Values for 2009

5.17.1 Design Values for 2002 Base Case

Design values at each monitoring site were calculated in accordance with 40 CFR Part 50.10, Appendix I. The design value for a three-year period of time is calculated as the 3-year average of the fourth highest monitored daily 8-hour maximum value. For example, the design value for the 2000-2002 periods is the aver age of the fourth highest m onitored daily 8-hour maximum values in 2000, 2001 and 2002.

For the modeled attainment test, EPA guidance (EPA, 2007) recommends averaging three design

values that straddle the baseline inventory year (the baseline inve ntory year is 2002). Therefore, the 2002 design value for the attainment demonstr ation is the average of the “2002 design value” (determined from 2000-2002 observations), th e “2003 design value” (determined from 2001- 2003 observations), and the “2004 design value” (d etermined from 2002-2004 observations).

The 2002 design value (DVC) was calc ulated in ppb, and carried to 1 significant digit. The 2002 design values for Rhode Island ozone monitors ar e listed in Table 5-7 and the 2002 design values for the other New England states are shown in Ta ble 5-8 to 5-12. The design values for all other ozone monitors in the OTR are listed in Appendix 5T.

5.17.2 Relative Response Factor for 2009 (RRF)

In order to minimize the under-pre diction or over-prediction of p eak ozone concentrations, EPA recommends that photochemical grid models be used in a relative way for modeled attainment demonstrations (EPA, 2007). Instead of using the absolute modeled results for 2009, EPA recommends that the change in predicted ozone concentrations between 2002 and 2009 be used

for the attainment demonstration. EPA recomm ends that the 2009 design value be determined by multiplying the 2002 design value by a quantity re ferred to as a relative response factor (RRF). The RRF is the ratio of the 2009 oz one prediction divided by the 2002 ozone prediction.

The EPA guidance requires that an average daily RRF be determined for each monitor using the CMAQ model results from grid cells that are at a nd near a monitor with near being defined as a 3 by 3 grid array centered on the monitoring station location. For each day, the maximum predicted 2002 base case concentration and the maximum predicted 2009 BOTW emission scenario concentration are selected from the 3 X 3 grid ar ray surrounding for each monitor.

Because photochemical models are less responsi ve to emission reductions on days of lower ozone concentrations, EPA guidance recommends applying screening cr iteria minimize using low ozone days when calculating RRFs (EPA, 2007) . At least 10 days above 85 ppb are required to calculate the RRF at each monitoring location; if 10 days above 85 ppb are not available, EPA guidance allows for a smaller number of days at lower ozone concentrations. The minimum criterion is 5 days at or a bove 70 ppb for calculating a meaningful average daily RRF value.

The detailed criteria for selec ting high ozone days and calculati ng RRFs (to 3 significant digits) are described in Appendix 5T.

53The 2009 relative response factors (RRFs) calcula ted for each Rhode Island ozone monitor for

the 2009 BOTW emission scenario are listed in Table 5-7, and the 2009 RRFs for all other New England states are shown in Table 5-8 – 5-12. The RRFs for each ozone monitor in the OTR are contained in Appendix 5U.

5.17.3 Design Values for 2009

The 2009 future case design value (DVF) for th e BOTW emission scenario was determined by multiplying the 2002 DVC for each monitor by the 2009 relative response factor (RRF)

determined for each monitor. After the DVF was calculated, the DVF was truncated at the decimal point and then compared to the ozone 8-hour NAAQS. A truncated value at or below 84 ppb is considered to be a demonstration of modeled attainment (EPA, 2007).

The 2009 DVFs for Rhode Island monitors are show n in Table 5-7. The highest predicted 2009 DVF is 81 ppb at the Narragansett site, which is below the modeled attainment test of 84 ppb. The 2009 DVFs for other New England states are shown in Table 5-8 – 5-12. The highest 2009 DVFs in Massachusetts, New Hampshire and Main e, areas that are downwind of Rhode Island, are 82 ppb, 74 ppb and 79 ppb, also below the mode led attainment test of 84 ppb. The 2009

DVFs for all ozone monitors in the OTR for th e 2009 BOTW emission scenario are contained in Appendix 5U.

Table 5-7: 2009 Design Values (DVF) in Rh ode Island for 2009 BOTW Emission Scenario

State AIRS-ID Location DVC RRF 2009 DVF 2009

RI 440030002 West Greenwich 93.3 0.862 80

RI 440071010 East Providence 89.7 0.868 77

RI 440090007 Narragansett 93.3 0.876 81

Table 5-8: 2009 Design Values (DVF) in Ma ssachusetts for 2009 BOTW Emission Scenario

State AIRS-ID Location DVC RRF 2009 DVF 2009

MA 250010002 Truro 92.0 0.877 80

MA 250034002 Adams 83.3 0.877 73

MA 250051002 Fairhaven 91.0 0.878 79

MA 250090005 Lawrence 70.0 0.880 61

MA 250092006 Lynn 90.0 0.916 82

MA 250094004 Newbury 86.0 0.882 75

MA 250130003 Agawam 83.0 0.873 72

MA 250130008 Chicopee 92.0 0.872 80

MA 250150103 Amherst 74.7 0.874 65

MA 250154002 Ware 86.3 0.873 75

54MA 250171102 Stow 85.7 0.870 74

MA 250213003 Milton 91.0 0.911 82

MA 250250041 Boston (Long I) 88.7 0.909 80

MA 250250042 Boston (Harris) 73.0 0.908 66

MA 250270015 Worcester 84.0 0.863 72

Table 5-9: 2009 Design Values (DVF) in New Hampshire for 2009 BOTW Emission

Scenario

State AIRS-ID Location DVC RRF 2009 DVF 2009

NH 330012004 Laconia 76.5 be low criteria below criteria

NH 330031002 Conway 67.0 below criteria below criteria

NH 330050007 Keene 74.3 0.865 64

NH 330090008 Haverhill 70.3 belo w criteria below criteria

NH 330111010 Nashua 86.0 0.867 74

NH 330115001 Peterborough 84.0 0.873 73

NH 330130007 Concord 74.7 below criteria below criteria

NH 330150012 Rye 83.5 0.869 72

NH 330150013 Rockingham 80.0 0.858 68

NH 330150015 Portsmouth 68.0 0.869 59

NH 330173002 Rochester 78.5 0.860 67

NH 330190003 Claremont 74.3 below criteria below criteria

Table 5-10: 2009 Design Values (DVF) in Co nnecticut for 2009 BOTW Emission Scenario

State AIRS-ID Location DVC RRF 2009 DVF 2009

6 7

CT 090010017 Greenwich 95.7 0.913 87

CT 090011123 Danbury 95.7 0.897 85

CT 090013007 Stratford 98.3 0.919 90

CT 090019003 Westport 94.0 0.909 85

CT 090031003 E. Hartford 88.0 0.876 77

CT 090050005 Cornwall 89.0 0.870 77

CT 090070007 Middletown 95.7 0.888 84

CT 090093002 Madison 98.3 0.905 88

CT 090099005 Hamden 93.3 0.912 85

CT 090110008 Groton 90.0 0.879 79

CT 090131001 Stafford 92.3 0.867 80

55Table 5-11: 2009 Design Values (DVF) in Maine for 2009 BOTW Emission Scenario

State AIRS-ID Location DVC RRF 2009 DVF 2009

ME 230038001 Ashland135 64.0 below criteria below criteria

ME 230052003 Cape Elizabeth 84.3 0.873 73

ME 230090102 ANP Cadillac M 91.7 0.869 79

ME 230090103 ANP McFarland 83.7 0.871 72

ME 230090301 Castine 75.0 0.879 65

ME 230112005 Gardiner Pray 78.0 0.869 67

ME 230130004 Port Clyde 83.7 0.871 72

ME 230173001 North Lovell 60.7 below criteria below criteria

ME 230194007 Howland 66.7 below criteria below criteria

ME 230194008 Holden Rider B 79.0 below criteria below criteria

ME 230310038 West Buxton 75.0 0.860 64

ME 230312002 Kennebunkport 88.3 0.875 77

ME 230313002 Kittery 85.3 0.869 74

Table 5-12: 2009 Design Values (DVF) in V ermont for 2009 BOTW Emission Scenario

State AIRS-ID Location DVC RRF 2009 DVF 2009

VT 500030004 Bennington 79.7 0.883 70

VT 500070007 Underhill 77.0 below criteria below criteria

5.18 Estimating Design Values at Unmonitored Locations

5.18.1 Rhode Island Ozone Monitoring Network

Based on our understanding of ozone formation, tran sport, and destruction and the size of the State, RI DEM considers Rhode Island’s netw ork of ozone monitors to be adequate for measuring the highest ozone values occurring in the State. .

Generally, ozone production via chemical transf ormation occurs some distance downwind of areas containing significa nt precursor emissions. What happe ns still farther downwind depends on the number and size of precursor emission sources in that area. If it lack s such sources, ozone will eventually be depleted because of its high re activity (provided transport is over land). It would then follow that, in areas where ozone levels drop off, additional monitoring would be

unnecessary.

The primary source of ozone in Rhode Island is th e stream of pollution from upwind states to the southwest. This is evidenced by the fact that oz one levels at the W. Greenwich monitor, which is in a rural area in the southwest portion of th e State, upwind of the high population density, high

56emissions areas of Rhode Island, generally records higher ozone concentrati ons than those at the E. Providence site, which is downwind of the Providence metropolitan areas. Therefore, RI DEM believes that additional monitoring cove rage in Rhode Island is unnecessary.

5.18.2 Future Year Design Values at Unmonitored Locations

Since VOC and NOx emissions ar e trending lower in Rhode Isla nd and elsewhere in the region, RI DEM believes that using design values from the 2002 network to construct future year design values provides a reasonable estimate of maximum predicted de sign values in Rhode Island for 2009 and beyond.

5.19 Weight of Evidence

EPA modeling guidance provides that a state include in its attain ment demonstration additional evidence to support its modeling anal ysis and to better assess the likelihood of attainment. EPA

will review all of the evidence and make its dete rmination as to the like lihood that the area will attain the ozone standard in the attainment y ear based on the entire “weight of evidence”(WOE). A WOE analysis must be included in the attain ment demonstration when the modeling is deemed “inconclusive”. EPA’s guidance establishe s the “inconclusive” range for 8-hour ozone modeling results at 82 ppb through 87 ppb for the required attainment year. If all predicted future design values for a State are less than 82 ppb, only a basic supplemental analysis is required to confirm the outcome of the modeling. Since the highest modeled design value for 2009 in Rhode Island is 81 ppb, Rhode Island falls into the la tter category, and only a basic supplemental analysis is required.

5.19.1 Air Quality Trends

Figure 5-11 displays Rhode Island ozone desi gn values from 2002-2007. For comparison, the predicted design values for the 2009 BOTW emission scenario were inserted on the chart. The graphs suggest that Rhode Island is on track to meet the ozone NAAQS (85 ppb) by 2009.

57Figure 5-11: Design Value Trends for Rhode Island

5.19.2 Emission Trends

The principal precursors for ozone are NOx a nd VOCs. Substantial NOx and VOC emission reductions will take place between 2002 and 2009 in the OTR. Most of these reductions are associated with the NOx SIP Call, CAIR

, federal on-road and non-road fuels, federal motor vehicle standards and state LEV (Low Emission Vehicle) programs, federal MACT rules, 2001 OTC model rules for consumer products, architect ural coatings, distributed generation and many state-specific rules in effect by 2009. In addition to these reductions, new 2006 OTC recommended control measures previously disc ussed in Section 11 (BOTW emission scenario) will provide for additional reductions by 2009. Finally, on-road and non-road federal motor vehicle control measures will provide substa ntial additional reducti ons between 2009 and 2012.

MANE-VU state emission inventor y totals for 2002 and 2009 are shown in Table 5-13. NOx and VOC emissions for MANE-VU states (which in clude all of OTR states except for Virginia)

trend downward between 2002 and 2012. Rhode Is land’s annual NOx and VOC emissions are estimated to go down by 26% and 22%, respec tively, between 2002 and 2009. Similar emission reductions are taking place in states upwind of Rhode Island. NOx and VOC emissions in Connecticut, New York and New Jersey are estimated to go down by 33% and 24%, respectively, in that time period. .

58Table 5-13: MANE-VU Anthropoge nic Emissions for 2002 and 2009

NOx VOC
2002 (tpy) 2009 (tpy) % decrease 2002 (tpy) 2009 (tpy) % decrease

Connecticut 125,208 82,139 34 162,492 122,353 25

Delaware 58,764 49,658 15 41,120 32,109 22

District of Columbia 15,389 10,433 32 14,893 10,403 30

Maine 94,932 60,201 37 166,501 141,619 15
Maryland 283,387 147,710 48 265,220 205,097 23

Massachusetts 276,530 180,391 35 294,703 229,386 22
New Hampshire 67,326 44,339 34 111,333 94,330 15
New Jersey 303,053 185,314 39 378,877 285,559 25

New York 655,774 456,457 30 921,593 710,567 23
Pennsylvania 806,061 518,109 36 594,355 477,042 20

Rhode Island 29,418 21,900 26 57,200 44,612 22

Vermont 28,290 17,793 37 50,461 43,063 15

Total 2,744,133 1,774,443 35 3,058,749 2,396,138 22

5.19.3 Extra Ozone Reductions

Rhode Island will be in monitored attainment of the 8-hour ozone NAAQS if design values at all three of the State’s monitors are 84 ppb or le ss in 2009. The model predicts design values for that year that are significantly below that target (80 ppb for W. Greenwich, 77 ppb for E. Providence and 81 ppb for Narragansett). This pr ovides a margin of safety for attaining the standard, even if monitored va lues are somewhat higher than those predicted by the model.

5.20 Conclusions

The above attainment demonstration demonstrates that reductions in ozone precursor emissions in Rhode Island and upwind of Rhode Island will result in statewide attainment of the 8-hour ozone NAAQS by 2009. The attainment demons tration was based on SIP-quality CMAQ ozone modeling results for 2002 and 2009. The attainment demonstration consisted of choosing a base year (2002) to test model performance and then rerunning the model using a future year emission scenario (2009) in order to dete rmine the predicted reductions in ozone calculated levels in and

downwind of Rhode Island.

The 2002 ozone season was selected as the base year for OTR attainment demonstrations because a significant number of exceedance days were recorded that year over the eastern United States. A multi-year review of elevated ozone days in the OTR indicted that meteorological regimes associated with high ozone levels al so occurred during 2002. In other words, 2002 meteorology contained a good set of meteorological conditions for testing the effectiveness of ozone control strategies. The 2002 CMAQ model run results indicated that the CMAQ model was performing adequately and was acceptable for simulating future year emission scenarios in

and downwind of Rhode Island.

59In 2006, all states in the OTR m odeling domain prepared future year emission inventories for 2009 by applying growth and control measures to 2002 base year emission inventories. The control measures reflected controls programs that were already on the way and in effect by 2009. These emission inventories, referred to as “on the way” emission inventories, reflect the NOx SIP Call and CAIR requirements, federal on-road and non-road fuels, federal motor vehicle standards and state LEV (Low Emission Ve hicle) programs, 2001 OTC model rules for consumer products, architectural coatings, distributed generati on and any other state-specific rules in effect by 2009. In addition, OTC stat es prepared a “beyond on the way” (BOTW) emission inventory for selected non-EGUs a nd nonpoint sources in the OTR. The BOTW

emissions reflect new OTC 2006 model rules for several source categories in OTR states. The BOTW control measures were developed because preliminary ozone modeling efforts indicated

additional controls would be needed to attain the 8-hour ozone NAAQS in portions of the OTR.

The CMAQ model was run using em ission input files prepared for the 2009 emission scenario (“on the way” emissions throughout the OTR m odeling domain and “beyond on the way” control measures in OTC states). The 2009 and 2002 modeli ng results were then compared to determine the percent reduction in ozone levels between 2002 and 2009. Th e percent reduction was applied to the 2002 ozone design value at each ozone monitoring location in the OTR in order to calculate a design value for 2009. The maximu m 2009 design value in Rhode Island was 81 ppb, indicating that Rhode Island will attain the ozone NAAQS (85 ppb) with “on the way” control measures throughout the OTR modeling domain a nd “beyond on the way” control measures in

OTC states.

Ozone air quality trends and ozone precursor tren ds also indicate that Rhode Island will be in attainment with the 8-hour ozone NAAQS. Based upon ozone modeling results, ozone air quality trends and ozone precursor trends, RI DEM expects that the State of Rhode Island will attain the 8-hour ozone NAAQS by 2009.

606.0 REASONABLY AVAILABLE CO NTROL TECHNOLOGY (RACT)

6.1 Purpose of Section

The CAA requires moderate and above ozone nona ttainment areas to adopt rules that require Reasonably Available Control Tech nology (RACT) for applicable sources. To facilitate this process, EPA issued three sets of Control Te chniques Guideline (CTG) and Alternate Control Techniques (ACT) documents, which delineate measures for controlling VOC and NOx emissions from stationary sources. Under the C AAA, RACT is required in moderate and above nonattainment areas for sources covered by a CTG and for non-CTG major sources. RI DEM

demonstrated in its March 2003 attainment de monstration for the one-hour ozone NAAQS that Rhode Island had fulfilled that requirement.

The Phase 2 8-Hour Ozone Implementation rule requi res states to assure th at RACT continues to be met in nonattainment areas, either through a certification that previ ously adopted one-hour ozone SIP approved RACT controls represent RACT for 8-hour implementation purposes or through adoption of more stringent regulations consistent with RACT . In this section RI DEM is certifying that all RACT measures adopted and in effect in R hode Island pursuant to the 1-hour

ozone standard continue to constitute RACT under the 8-hour ozone standard, except for the following categories: solvent metal degreasing an d asphalt paving. For these categories, RI DEM has concluded that RACT measures previously adopted no longer constitute RACT and is committing to promulgate revised regulations that will further reduce emissions from applicable sources. Rhode Island RACT source categories a nd point sources for which source-specific

RACT determinations have been made are listed in Tables 6-1 and 6-2.

6.2 1-Hour Ozone Standard RACT

6.2.1 Pre-1990 VOC RACT Requirements

Prior to the 1990 CAAA, RACT requirements were governed by CAA Section 172(c), which provides that non-attainment areas must implemen t ... “all reasonably available control measures [RACM]...including such reductions in emissions from existing sources in the area as may be obtained through the adoption ... of reasonably av ailable control techno logy [RACT].” EPA

defined RACT as “the lowest emission limit that a polluting source is ca pable of meeting if it uses pollution contro l equipment and/or material or proces s changes that are reasonably available considering costs and current techno logy.” (44 FR 53762, September 17, 1979)

To assist states with implementation of RA CT, EPA issued Control Technique Guidelines (CTGs) for several categ ories of VOC sources. 15 CTGs establish a ``presumptive norm'' for RACT for the VOC source category addr essed. Some CTGs cover only major 16 sources of VOC

15 . Prior to the 1990 CAA Amendments, EPA issued three sets of CTG documents: Group 1: 15 CTGs issued before January 1978; Group 2: 9 CTGs issued in 1978; and Group III: 5 CTGs issued in the early 1980s. (A list of all CTGs, as compiled by EPA, is in Table 6-1.)

16 . The emission threshold for a major source varies. Prio r to the 1990 CAA Amendmen ts, major VOC sources were those with a potential to emit > 100 tons of VOCs per year. After the 1990 Clear Air Act amendments, major source

thresholds for VOC and NOx were tied to a non-attainment areas classification and whether the state is located

61emissions. Other CTGs apply at thresholds belo w the major source level. In addition, states were required to adopt RACT controls for all ma jor sources of VOCs, whet her or not they were within a CTG source category.

6.2.2 1990 CAA Amendments (CAAA)

The 1990 CAAA made the general Section 172 RACT requirements more specific. Amendments to section 182(a)(2)(A) re quired that ozone non-attainment areas classified as marginal or above “fix” any deficient VOC RACT rules by Ma y 1991. A new provision, Se ction 182(f), required states to adopt RACT for all major stationary NOx sources. Amendments to Section 184, which

addresses control of ozone in an Ozone Trans port Region, lowered the ma jor source applicability

threshold of RACT for states within the OTR from sources with a potential to emit 100 tons of VOC per year to sources with a potential to emit 50 tons per year.

To assist states with NOx RACT implementa tion, EPA issued Alternative Control Technology Documents (ACTs), which provide an alyses of the reductions that can be achieved with various

controls at various levels of st ringency, and the costs per ton to ach ieve those levels of control. Unlike CTGs, ACTs do not establish a pres umptive RACT level of control.

6.2.3 Rhode Island 1-Hour RACT Compliance

During the late 1970s and the 1980s, RI DEM adopted and from time-to-time amended Air Pollution Control (APC) regulations which limited emissions from VOC sources consistent with EPA’s pre-1990 CTGs. Those regul ations include: APC Regulati on No. 11, “Petroleum Liquids Marketing and Storage,” No. 18 (later supers eded by APC Regulation No. 36), “Control of Organic Solvent Cleaners,” No. 19, “Control of Volatile Organic Compounds from Surface Coating Operations,” and No. 21, “Control of Volatile Organic Compound Emissions from Printing Operations.” EPA approved these regula tions as meeting RACT and incorporated them

into the Rhode Island ozone SIP. 17

The CTGs issued by EPA and the Rhode Island regulation that was adopted to meet the presumptive level of RACT established in the CTG for RACT is listed in Table 6-1. If there were no facilities within a CTG source category in the State, RI DEM submitted a “negative declaration” to EPA. The nega tive declaration categories are al so listed in Table 6-1.

For major sources not in a CTG category, RI DEM adopted APC Regulation No. 15, “Control of Organic Solvent Emissions,” which requires RA CT controls for major non-CTG sources through single-source RACT SIPs. EPA approved RI DEM’s single-source RACT determinations pursuant to APC Regulation No. 15 as part of th e Rhode Island SIP. Th e facilities subject to single-source RACT agreements are liste d in Table 6-2. The 1990 CAAA required states to adopt “fix up” and “catch up” measures to ensure that all

areas classified as moderate or above nonattainment areas are subj ect to requirements equivalent

within an ozone transport region. In Rhode Island, sources th at have the potential to emit at least 50 tons per year of VOC or NOx are considered major sources.

17 See 40 CFR 52.2062 for a complete list of the EPA-approved Rhode Island SIP revisions, including those related to RACT regulations and determinations.

62to those specified in the CTGs and to redu ce the non-CTG RACT majo r source applicability threshold form 100 tons to 50 tons of VOC emissions per year. To comply with these requirements, RI DEM adopted or amended th e following regulations: APC Regulation No. 15, “Control of Organic Solvent Emissions,” No. 19, ``Control of Volatile Organic Compounds from Surface Coating Operations,'' No. 21, “Control of Volatile Organic Compound Emissions from Printing Operations,” No. 25, ``Control of Vola tile Organic Compound Emissions from Cutback and Emulsified Asphalt,'' and No. 26, ``Control of Volatile Organic Compound Emissions from Manufacture of Synthetic Pharmaceutical Products,'' No. 30, “Control of VOCs from Automotive Refinishing Operati ons,” No. 35, “Control of VOC and Volatile Hazardous Air

Pollutants from Wood Products Ma nufacturing Operations” and No. 36, “Control of Emissions from Organic Solvent Emissions.” These amende d and new regulations were submitted to the EPA and approved as amendments to the SIP (see dates in Table 6-1).

To address the 1990 CAAA NOx RACT requireme nt, RI DEM adopted APC Regulation No. 27, “Control of Nitrogen Oxide Emissions,” on Febr uary 1, 1994. That regulation, which required sources which have the potential to emit 50 tons or more per year of NOx to submit RACT plans, was approved by EPA as a SIP revision in 1997 (62 FR 42602). RACT plans prepared to comply with this requirement were submitted as single-source SIP revisions and are listed in

Table 6-2.

Rhode Island has adopted all RACT rules and su bmitted all RACT determin ations necessary to comply with 1-hour ozone standard RACT requirements.

6.3 8-Hour Ozone Standard RACT Requirements

6.3.1 Required Analysis

EPA’s Phase 2 Rule states that:

Where a State has adopted, and EPA has approved, a control measure as RACT for a specific major stationary source or source category for the 1-hour ozone NAAQS and absent data indi cating that the previous RACT determination is no longer appropriate, the State may submit a certification that th e source is subject to a SIP-approved RACT requirement (70 FR 71652).

Subsequent to the issuance of the Phase 2 Rule , EPA developed a set of questions and answers (Q&A) to further explain 8-hour ozone standa rd RACT SIP requirements. The Q&A document states that, in order for a state to certify that previously required RACT controls or newly applied controls represent RACT for 8-hour ozone standa rd purposes, a state should evaluate RACT for a source or source category by examining EPA gui dance and other information. When a state

concludes that the existin g level of control is RACT and that no control is required beyond what was required for the 1-hour standard, it must submit its conclusions in its RACT SIP.

The state may address RACT through adoption of rules, submission of permits or through negative declarations stating that there are no sources subject to RACT. If the state determines

63that additional controls are needed to meet 8-hour ozone standard RACT requirements, the controls must be made federally enforceable through a SIP revision. Any new RACT requirements must be implemented no later than May 1, 2009.

As required by the Phase 2 Rule, RI DEM has revi ewed its current RACT requirements. It has determined that VOC controls previously a dopted as RACT for CTG source categories and nonCTG major sources still constitute RACT for 8-hour ozone standard purposes, except for two source categories - solvent metal degreasing and asphalt paving. It has also determined that RACT controls adopted for major sources of NOx continue to constitute RACT. RI DEM has, therefore, certified in Tables 6-1 and 6-2 that its current RA CT requirements are consistent with 8-hour RACT, except for the categories of solv ent metal degreasing and asphalt paving. RI DEM is committing to submit revisions to the regula tions for solvent metal degreasing and asphalt paving (APC Regulations No. 36 and 25, respectively) by January 1, 2009 and that the amended regulations will be effective by April 1, 2009.

6.4 VOC RACT Analysis

6.4.1 CTGs

As noted under the 1-hour RACT discussion, a st ate regulation imposing VOC controls that met EPA’s presumptive CTG control levels met 1-hour RACT requirements. Table 6-1 lists the VOC source categories for which EPA issued CTGs and the corresponding RI DEM APC regulation for each of these categories

. For all CTG categories for which there are applicable sources in Rhode Island, RI APC regulations eith er incorporated the CTG recommended controls

or achieved a level of control e quivalent to those specified in the CTGs and were, as such, approved by EPA as meeting 1-hour RACT. Note that Regulations No. 11 and 25 were amended in 2001 to update control requirements. Those amendments were submitted to the EPA in January 2001 but have not as yet been approved as SIP revisions. Note also that virtually all of the APC regulations were modified in 2007; these modifications were primarily administrative in nature, e.g. the removal of the definitions of certa in terms previously defined in more than one regulation to a separate definitions regulation. The updated versions of these regulations will be

submitted as SIP revisions to the EPA in 2008.

RI DEM has reviewed the APC regulations for al l sources subject to CTGs and has determined that, with two exceptions, the levels of contro l required by these regulations continue to

constitute VOC RACT under the 8-hour ozone st andard. Pursuant to the requirement of the Phase 2 Rule, RI DEM certifies in Table 6-1 that the level of control in the current regulatory requirements for all CTG categories for which th ere are Rhode Island so urces except solvent metal degreasing and asphalt paving are c onsistent with 8-ho ur RACT.

Table 6-1 also lists the CTG categories for whic h there are no Rhode Is land sources; RI DEM is making a negative declaration for those CTG categor ies. In making this determination, RI DEM reviewed its 2002 stationary point source inventory database for f acilities with North American Industrial Classification System (NAICS) codes that correspond to the CTG categories and consulted relevant inspection and permitting records.

646.4.2 New CTGs

In October 2006, EPA adopted new CTGs for the following five source categories: Lithographic Printing Materials, Letterpress Printing Materials, Flexible Packaging Pr inting Materials, Flat Wood Paneling Coatings and Industrial Clean ing Solvents. (71 FR 58745, October 5, 2006) States are required to submit SIP revisions inco rporating requirements of a new CTG for which there are sources in the state within one year of EPA’s promulgation of the final CTG.

RI DEM has identified one source in Rhode Isla nd that is subject to the Flat Wood Paneling CTG. The coating lines at that facility received preconstructi on permits from RI DEM in 2000. Although the emissions limits established in th at permit reflected Best Available Control Technology (BACT) at that time, they are not as stringent as those recommended in the CTG. Therefore, RI DEM is committing to revise AP C Regulations No. 19, “Control of Volatile Organic Compounds from Surface Coating Opera tions,” and Regulation No. 35, “Control of Volatile Organic Compounds and Volatile H azardous Air Pollutants from Wood Products Manufacturing Operations,” to make the requirem ents for flat wood paneling sources in Rhode Island consistent with the provisions of th e 2006 Control Technique Guideline. These amendments will be submitted to the EPA as a SIP revision by January 1, 2009 and will be effective by April 1, 2009.

The CTG for Industrial Cleaning Solvents contains VOC conten t, operations and equipment requirements for all industrial cleaning categories and operations 18 that have VOC emissions of at least 15 lb/day. The requirements in APC Regu lation No. 36 are, for the most part, consistent with the requirements in the new CTG, with th e exception of a solvent vapor pressure limit for cold cleaners, which is in the CTG but not in Regulation No. 36. RI DEM plans to amend APC Regulation No. 36 to include that requirement. W ith that amendment, the requirements in APC Regulation No. 36 will be consistent with the new CTG. That amendment will be submitted to the EPA as a SIP revision by January 1, 2009 and will be effective by April 1, 2009. This source category is discussed further in Section 6.6.1.

RI DEM has not yet determined whether its ex isting regulations includ e controls that are equivalent to the new CTGs for the three pr inting categories. RI DEM plans to survey potentially applicable sources in these categories in the first qu arter of calendar year 2008 to define the universe of sources applicable to these CTGs in the State and to determine, in consultation with the EPA, whether the existing Rhode Island regulations provide for controls equivalent to those specified in the new CTGs. If deficiencies are identified, RI DEM will amend its existing regulations to ensure that require ments for sources in those categories meet the presumptive RACT limits established in these ne w CTGs Amended regulations, if needed, will be submitted to the EPA as a SIP revision by January 1, 2009 to be effective by April 1, 2009.

18 EPA states that all operations evaluated to date by EPA can be categorized under one of the nine “Unit Operations” (UO) identified in the CTG: Spray Gun Cleaning; Spray Booth Cleaning; Large Manufactured Components Cleaning; Parts Cleaning; Equipment Cleaning; Line Cleaning; Floor Cleaning; Tank Cleaning; and
Small Manufactured Components Cleaning

.

65On October 9, 2007, EPA issued new CTGs for the fo llowing source categories: paper, film, and foil coatings; metal furniture coatings, and large appliance coatings. RI DEM will analyze the CTGs to determine whether there are applicable sources in Rhode Island and will amend its regulations as necessary so that control re quirements for applicable Rhode Island source categories are consistent with those in the CTG. All regulatory amendments will be submitted to the EPA as SIP revisions by January 1, 2009 to be effective by April 1, 2009.

6.4.3 Non-CTG Major VOC Sources

As previously discussed, States must requi re RACT controls for all non-CTG major VOC sources. APC Regulation No. 15, “Control of Organic Solvent Emissions,” established requirements for major facilities not covered by a CTG. RACT specifications for each such facility are delineated in an emission control pl an specific to that faci lity. RI DEM issued a number of single-source RACT determinations pursuant to APC Regulation No. 15. The singlesource VOC RACT determinations, which were a pproved by EPA as part of the Rhode Island SIP, are listed in Table 6-2 along with the date of approval and the current st atus of the facility. For facilities that are still operating, RI DEM has concluded that the controls specified in the single-source agreements constitute RACT under the 8-hour standard.

6.5 NOx RACT Analysis

RI DEM’s APC Regulation No. 27, “Control of N itrogen Oxide Emissions,” requires RACT for stationary sources emitting 50 or more tons per year of NOx. The regulation includes specific emissions limits for utility boilers, industrial-commercial-institutional boilers and internal combustion engines and requires all applicable s ources to submit RACT plans to RI DEM which, after review, are incorporated into an enforceable agreement. Th e enforceable agreement is then submitted to the EPA as a single-source RACT determination. Single-source NOx RACT determinations issued by RI DEM pursuant to APC Regulation No. 27 and submitted to the EPA as source-specific SIP revisions are listed in Table 6-2. RI DE M certifies that APC Regulation No. 27 and the single-source NOx RACT SIP revisi ons listed in Table 6-2 are consistent with RACT requirements for the 8-hour ozone NAAQS.

In addition to the requirements in APC Regul ation No. 27, electric gene ration units (EGUs) and large industrial boilers in Rhode Island are also subject to APC Regulation No. 41, “NOx Budget Trading Program,” which caps emissions of NOx from covered sources for the 2003 through 2008 ozone seasons. This regulation was adopted in 1999 to meet the requirements of EPA’s NOx SIP Call (63 CFR 61712). EPA’s Phase 2 Rule provides that compli ance with the NOx SIP Call, regardless of the manner of compliance by individual sources (e.g. control equipment installation or purchase of allowances from othe r sources), constitutes RACT. States need not submit 8-hour RACT analyses for sources in comp liance with a SIP meeting the NOx SIP Call.

EPA determined that the Rhode Island NOx Budget Program met the NOx SIP Call and approved it as part of the Rhode Island 1-hour Oz one SIP. Therefore, RI DEM certifies that all NOx sources regulated by APC Regulation No. 41 meet 8-hour ozone RACT requirements for

2003 - 2008.

66These sources and the NOx allowances allocated to each source in APC Regulation No. 41 for the control periods (May 1 – September 30) in 2003 through 2008 are as follows:

Ocean State Power 275 tons

Pawtucket Power 42 tons

Manchester Street 262 tons

Tiverton Power 46 tons Rhode Island State Energy Center 52 tons

Total allocation: 677 tons

The quantity of allowances allocated to each of the above sources is equal to the potential to emit for that source for the control period. Th erefore for 2009 and beyond the nitrogen oxides emissions from the five existing power plants cannot exceed the 677 ton cap that had been in place from the NO

x Budget Trading program.

These five power plants are the only sources in Rhode Island that are subject to the NO

x Budget Trading Program. No new EGUs have b een permitted since the promulgation of APC Regulation No. 41. RI DEM has not yet determin ed how it will regulate new sources to ensure

that NO

x SIP call requirements continue after 2008.

As discussed in Section 5.11.2, th e OTC identified potential additi onal control measures for ICI boilers at major sources in its February 2007 docum ent entitled “Identific ation and Evaluation of Candidate Control Measures, Final Technical Support Document,” which is attached as Appendix 5k. RI DEM examined the OTC recommendations and determined that adoption of

additional controls for that s ource category would yield minima l emissions reductions in Rhode

Island and are not cost effective. The OTC estim ated in the above document that implementation

of its recommended ICI boiler control measures would reduce summer day NOx emissions in Rhode Island by 0.5 tons. Almost all of the ICI boilers located at major sources in Rhode Island are currently equipped with low-NO

x burners with flue gas re circulation. Replacing that equipment to meet the recommended OTC limits w ould require the facilities to incur substantial expenses while only marginally reduce emissions. Such a requirement would also create a

substantial administrative burden for RI DEM w ith minimal effect. Therefore, it is not economically reasonable to require this measure in Rhode Island.

6.6 RACT Revisions

RI DEM has determined that its existing solven t metal degreasing and asphalt paving regulations

do not constitute RACT under the 8-hour ozone standard and will revise its regulations for these categories to require addi tional VOC controls, as discussed below.

6.6.1 Solvent Degreasing

The CTG covering solvent metal degreasing applies to units that clean/degrease metal in three types of systems - cold cleaning, open top vapor degreasers and conveyorized degreasers. The control measures specified in the CTG for th is sector are largely equipment and operating

67practice specifications rather than emission limits. APC Regulation No. 36 is consistent with, or more stringent than, those requirements.

However, APC Regulation No. 36 does not include vapor pressure limits on solvents used in cold cleaning consistent with the CTG and w ith the model rule for this source category developed by OTC and adopted by several OTC stat es. Therefore, RI DEM has determined that APC Regulation No. 36 is not currently consistent with RACT and is committing to amend that regulation accordingly. The amendment will be submitted to the EPA as a SIP revision by January 1, 2009 and will be effective by April 1, 2009. With this revision, Rhode Island will meet 8-hour RACT control requirem ents for this source category.

6.6.2 Asphalt Paving

Asphalt paving is used to pave, seal and repair surfaces such as roads, parking lots, and walkways. Asphalt paving is grouped into thr ee general categories: hotmix, cutback, and emulsified. Hot-mix asphalt, the most commonl y used paving asphalt, produces minimal VOC emissions. Cutback asphalt is prep ared by blending asphalt cement w ith a diluent, typically from 25 to 45 percent by volume of petroleum distillates. Emulsified asphalt is a lower emitting alternative to cutback asphalt; emulsified aspha lts use a blend of asphalt cement, water and an emulsifying agent, such as soap. Some emulsi fied asphalts may contai n virtually no VOCs; others may contain up to 12% VOC by volume.

The EPA published a CTG for the use of cutback asphalt in December 1977. The CTG recommended replacing cutback asphalt binders with emulsified asphalt during the ozone season. In 1979, EPA added a specification for emulsified asphalt to the CTG recommendations to limit

the content of oil distillate in emulsified asphalt to no higher than 7 percent oil distillate. APC Regulation No. 25, “Control of Volatile Or ganic Compound Emissions from Cutback and Emulsified Asphalt,” which was adopted in November 1992, contains requi rements that are at least as stringent as those in the CTG for this source category and which met 1-hour RACT. It bans the use of cutback asphalt during the ozone season, but with a number of exceptions, and limits the VOC content of emulsified asphalt to 3 – 12%, depending on the type of application. .

During its review of additional c ontrol measures that states shoul d consider adopting as part of the OTC regional 8-hour ozone attainment stra tegy, the OTC identified asphalt paving as a category where further VOC emission reductions c ould be achieved. It developed a model rule for this source category that prohibits the use of cutback asphalt duri ng the ozone season and limits the use of emulsified asphalt to that which contains not more than 0. 5 mL of oil distillate from a 200 mL sample (as determined using American Society for Testing and Materials Methods) regardless of application. This is equivalent to a VOC content of 0.25 percent.

RI DEM will propose an amendment to APC Regulati on No. 25 to eliminate all exceptions to the

ozone season ban on use of cutback. It will also propose to limit the VOC content of emulsified asphalt to the level proposed in the OTC model rule, or to the most stringent level that is determined to be feasible in Rhode Island. Upon completion of this rule amendment process,

Rhode Island will meet 8-hour RACT contro l requirements for this source category. RI DEM

6869 will submit the amended regulation to the EPA as a SIP revision by January 1, 2009. The revised requirements will be effective by April 1, 2009.

6.6 Conclusions

By complying with 1-hour ozone standard RA CT requirements, emissions of VOCs and NOx from stationary point and nonpoint sources have decreased significa ntly over the past 30 years.

In order to meet the 8-hour ozone standard RACT requirements, RI DEM is committing to

further reduce VOC emissions for the source cat egories solvent metal degreasing and asphalt paving by adopting revised regulations that will be submitted as SIP revision to the EPA by January 1, 2009 with an effective da te no later than April 1, 2009.

RI DEM intends to review the three printing CTGs finalized by EPA in October 2006 and, if necessary, to propose new regulat ory requirements for these source categories. Amendments

would be submitted to the EPA as SIP revision s by January 1, 2009 and would be effective by April 1, 2009. RI DEM will also review the CT Gs for paper, film and foil coating, metal furniture coating and large appl iance coating issued in Octobe r 2007 and, if applicable, submit appropriate SIP revisions rela tive to these source categorie s by January 1, 2009 with any amended control requirements effective on Ap ril 1, 2009. For each CTG for which RI DEM determines that are not applicable in Rhode Is land, RI DEM will submit a negative declaration.

With respect to all other CT G RACT categories and major no n-CTG sources of VOC and NOx emissions, RI DEM certifies that current RACT controls, as adopted and approved by EPA under the 1-hour ozone standard, constitute RACT under the 8-hour ozone standard.Table 6-1 RI DEM1-hour Ozone StandardRACT Regulations and8-Hour Ozone StandardRACT CertificationEPA Control TechnologyGuidelines (CTGs)Corresponding RI DEMAPC RegulationMost Recent SIPApproval of APCRegulationDate APCRegulationLast AmendedRI DEM Certification:8-hour Ozone Standard RACTPre-1990 CTGs: Group 11. Stage I Vapor ControlSystems (1975)Regulation No. 11,“Petroleum LiquidsMarketing and Storage”2/17/93, 58 FR 65933(1/31/93 version ofregulation)7/18/07Current regulation meets 8-hourRACT2. Surface Coating of Cans,Coils, Paper, Fabrics,Automobiles, and Light-dutytrucks (1977)Regulation No. 19, “Controlof Volatile OrganicCompounds form SurfaceCoating Operations”12/2/99, 64 FR 67495(3/7/96 version ofregulation).7/18/07Current regulation meets 8-hourRACT for all categories withsources in RI.There are no applicable can,automobile or truck surfacecoaters in RI.3. Refinery VacuumProducing Systems,Wastewater Separators, andProcess Unit Turnarounds(1977)Negative DeclarationThere are no applicable sources inRI4. Solvent Metal Cleaning(1977)Regulation No. 36, “Controlof Emissions from OrganicSolvent Cleaning”(superseded Regulation No.18 in 1996)12/2/99, 64 FR 67495(4/18/96 version ofregulation)7/18/07RI DEM commits to reviseRegulation No. 36 to incorporate asolvent vapor pressure limit of 1.0mm Hg to meet 8-hour RACT.5. Tank Truck GasolineLoading Terminals (1977).Regulation No. 11,“Petroleum LiquidsMarketing and Storage”2/17/93, 58 FR 65933(1/31/93 version ofregulation)7/18/07Current regulation meets 8-hourRACT6. Surface Coating MetalFurniture (1977)Regulation No. 19, “Controlof Volatile OrganicCompounds form SurfaceCoating Operations”12/2/99, 64 FR 67495(3/7/96 version ofregulation). 7/18/07Current regulation meets 8-hourRACT70EPA Control TechnologyGuidelines (CTGs)Corresponding RI DEMAPC RegulationMost Recent SIPApproval of APCRegulationDate APCRI DEM Certification:Regulation8-hour Ozone Standard RACTLast Amended7. Surface Coating MagnetWire (1977)Regulation No. 19, “Controlof Volatile OrganicCompounds form SurfaceCoating Operations”12/2/99, 64 FR 67495(3/7/96 version ofregulation). 7/18/07Current regulation meets 8-hourRACT8. Surface Coating LargeAppliances (1977)Regulation No. 19, “Controlof Volatile OrganicCompounds form SurfaceCoating Operations”12/2/99, 64 FR 67495(3/7/96 version ofregulation). 7/18/07Current regulation meets 8-hourRACT9. Bulk Gasoline Plants(1977)Regulation No. 11,“Petroleum LiquidsMarketing and Storage”2/17/93, 58 FR 65933(1/31/93 version ofregulation)7/18/07Current regulation meets 8-hourRACT10. Fixed Roof PetroleumTanks (1977)Regulation No. 11,“Petroleum LiquidsMarketing and Storage”2/17/93, 58 FR 65933(1/31/93 version ofregulation)7/18/07Current regulation meets 8-hourRACT11. Use of Cutback Asphalt(1977)Regulation No. 25, “Controlof VOC Emissions fromCutback and EmulsifiedAsphalt12/2/99, 64 FR 67495(4/8/96 version ofregulation)7/18/07RI DEM will submit amendmentsto Regulation No. 25 by 1/1/09 tobe effective by 4/1/09. Amendedregulation will meet 8-hourRACT.Pre-1990 CTGs: Group II12. Surface Coating Misc.Metal Parts (1978)Regulation No. 19, “Controlof Volatile OrganicCompounds form SurfaceCoating Operations”12/2/99, 64 FR 67495(3/7/96 version ofregulation). 7/18/07Current regulation meets 8-hourRACT13. Surface Coating FlatWood Paneling (1978)Regulation No. 19, “Controlof Volatile OrganicCompounds form SurfaceCoating Operations”12/2/99, 64 FR 67495(3/7/96 version ofregulation). 7/18/07RI DEM will submit amendmentsto Regulations No.19 and 35 by1/1/09 to be effective by 4/1/09 inresponse to 2006 CTG. Amendedregulation will meet 8-hour RACT71EPA Control TechnologyGuidelines (CTGs)Corresponding RI DEMAPC RegulationMost Recent SIPApproval of APCRegulationDate APCRI DEM Certification:Regulation8-hour Ozone Standard RACTLast Amended14. Leaks from PetroleumRefinery Equipment (1978)Negative Declaration.There are no applicable sources inRI15. Manufacture of SyntheticPharmaceutical Product(1978)Regulation No. 26, “Controlof Organic SolventEmissions from Manufactureof SynthesizedPharmaceutical Products”12/2/99, 64 FR 67495(4/8/96 version ofregulation)7/18/07.Current regulation meets 8-hourRACT16. Manufacture of PneumaticRubber Tires (1978)Negative DeclarationThere are no applicable sources inRI17. Graphic Arts –Rotogravure & Flexography(1978)Regulation No. 21, “Controlof Volatile OrganicCompounds from PrintingOperations:12/2/99, 64 FR 67495(4/8/96 version ofregulation)7/18/07.Current regulation meets 8-hourRACT18. Petroleum Storage inExternal Floating Roof Tanks(1978)Regulation No. 11,“Petroleum LiquidsMarketing and Storage”2/17/93, 58 FR 65933(1/31/93 version ofregulation)7/18/07Current regulation meets 8-hourRACT19. Perchloroethylene DryCleaning Systems (1978)Regulation No. 23, “Controlof PerchloroethyleneEmissions from DryCleaning Operations”7/18/07.No certification required.Perchloroethylene has beendelisted as a VOC.20. Leaks from Gasoline TankTrucks and Vapor CollectionSystem (1978)Regulation No. 11,“Petroleum LiquidsMarketing and Storage”2/17/93, 58 FR 65933(1/31/93 version ofregulation)7/18/07Current regulation meets 8-hourRACTPre-1990 CTGs: Group III21. Large Petroleum DryCleaners (1982)Negative Declaration.There are no applicable sources inRI22. Manufacture of HighDensity Polyethylene,Polypropylene andPolystyrene Resins (1983)Negative DeclarationThere are no applicable sources inRI72EPA Control TechnologyGuidelines (CTGs)Corresponding RI DEMAPC RegulationMost Recent SIPApproval of APCRegulationDate APCRI DEM Certification:Regulation8-hour Ozone Standard RACTLast Amended23. Natural Gas/GasolineProcess Leaks (1983)Negative DeclarationThere are no applicable sources inRI24. Synthetic OrganicChemical Mfg EquipmentFugitive Emissions (1984)Negative Declaration12/2/95, 64 FR 67495(submitted 4/5/95)There still are no applicablesources in RI25. Synthetic OrganicChemical Mfg Air OxidationProcesses (1984)Negative Declaration12/2/95, 64 FR 67495(submitted 4/5/95)There still are no applicablesources in RIPost-1990 CTGs1. Synthetic OrganicChemical ManufacturingIndustry (SOCMI) DistillationOperations and ReactorProcesses (1993)Negative Declaration12/2/95, 64 FR 67495(submitted 4/5/95)There still are no applicablesources in RI2. Wood FurnitureManufacturing (1996)Regulation No. 35, “Controlof VOCs and VolatileHazardous Air Pollutantsfrom Wood ProductsManufacturing Operations”12/2/99, 64 FR 67495(7/7/96 version ofregulation)7/18/07Current regulation meets 8-hourRACT3. Ship Building and Repair(1996)2 applicable sources (Senesco andGeneral Dynamics), both subjectto federally enforceable permitlimits consistent with CTGSenesco: Approval Nos.1991-93,General Dynamics: Approval No.1882 and Title V Permit No. RI32-03.4. Aerospace Coatings (1996draft)Negative Declaration7/10/00, 65 FR 42290(submitted 3/28/00)There still are no applicablesources in RI73EPA Control TechnologyGuidelines (CTGs)Corresponding RI DEMAPC RegulationMost Recent SIPApproval of APCRegulationDate APCRI DEM Certification:Regulation8-hour Ozone Standard RACTLast Amended5. Flat Wood Paneling (2006)RI DEM will submit amendmentsto Regulations No. 19 and 35 as aSIP revision by 1/1/09;amendments will be effective by4/1/09. Amended regulation willmeet 8-hour RACT.6. Industrial CleaningSolvents (2006)RI DEM intends to proposeamendments to RegulationNo. 36, “Control ofEmissions from OrganicSolvent Cleaning.” Theamended regulation will beconsistent with the 2006CTG.RI DEM will submit amendmentsto Regulation No. 36 as a SIPrevision by 1/1/09; amendmentswill be effective by 4/1/09.Amended regulation will meet 8-hour RACT.7. Lithographic printmaterials (2006)RI DEM will survey sourcesthat may be applicable to thisCTG and, if necessary, toamend APC Regulation No.21 to be consistent with theCTGSurvey will be sent to printers by4/15/08. If it is determined that itis necessary, regulations will besubmitted as SIP revisions by1/1/09 to be effective by 4/1/09.8. Letterpress printingmaterials (2006)See #7.9. Flexible packagingprinting materials (2006)See #7.NOx RACT CategoriesEPA’s NOx AchievableControl Technology (ACT)documents are listed belowonly to illustrate NOx RACTsource categories. ACTs doRegulation No. 27, “Controlof Nitrogen OxideEmissions,” applies to allsources with a potential toemit >50 tons per year of9/20/97, 62 FR 46202(1/16/96 version ofregulation).7/18/0774EPA Control TechnologyGuidelines (CTGs)Corresponding RI DEMAPC RegulationMost Recent SIPApproval of APCRegulationDate APCRI DEM Certification:Regulation8-hour Ozone Standard RACTLast Amendednot establish presumptivelevels of control; therefore RIDEM is not requiredto certifythatRACT is consistent withthe ACTs.NOx, with certainexceptions. Applicability toan individual unit at a sourceis based on exceedance of aminimum capacity rating.1. Nitric and Adipic AcidPlants (1991)Negative Declaration.There are no sources in RI2. Combustion Turbines(1993)Regulation No. 27, “Controlof Nitrogen OxideEmissions”9/20/97, 62 FR 46202(1/16/96 version ofregulation).7/18/07Current regulation meets 8-hourRACT3. Process Heaters (1993)Regulation No. 27, “Controlof Nitrogen OxideEmissions”9/20/97, 62 FR 46202(1/16/96 version ofregulation).7/18/07Current regulation meets 8-hourRACT4. Internal CombustionEngines (1993)Regulation No. 27, “Controlof Nitrogen OxideEmissions”9/20/97, 62 FR 46202(1/16/96 version ofregulation).7/18/07Current regulation meets 8-hourRACT5. Utility Boilers (1994)Regulation No. 27, “Controlof Nitrogen OxideEmissions”Regulation No. 41, “NOxBudget Trading Program”9/20/97, 62 FR 46202(1/16/96 version ofregulation)12/27/00, 65 FR 81743,(10/1/99 version ofregulation7/18/077/18/07Current regulations meet 8-hourRACT.6. Cement Manufacturing(1994, updated 2000). Negative Declaration.There are no sources in RI.7. ICI Boilers (1994)Regulation No. 27, “Controlof Nitrogen OxideEmissions”9/20/97, 62 FR 46202(1/16/96 version ofregulation).7/18/07Current regulation meets 8-hourRACT75EPA Control TechnologyGuidelines (CTGs)Corresponding RI DEMAPC RegulationMost Recent SIPApproval of APCRegulationDate APCRI DEM Certification:Regulation8-hour Ozone Standard RACTLast Amended8. Glass Manufacturing(1994)Regulation No. 27, “Controlof Nitrogen OxideEmissions”9/20/97, 62 FR 46202(1/16/96 version ofregulation).7/18/07Current regulation meets 8-hourRACT9.Iron and Steel (1994)Negative Declaration.There are no sources in RI.10.Municipal WasteCombustors(no ACT)Negative Declaration.There are no sources in RI.76Table 6-2 RI DEM Single Source 1-Hour Ozone Standard RACT Determinations and 8-Hour Ozone Standard RACTCertificationSingle Source VOC RACT determinations were made formajor VOC sources not covered by a CTG pursuant to APCRegulation No. 15.Single Source NOx RACT determinations were made for major NOx sources pursuant to APC Regulation No. 27.FACILITYEPA Approval ofSingle-Source SIPRevisionCurrentFacilityStatusMajor for VOC orNOx?Certification of 8-hour RACTCommentsKeene Corp (Arlon)8/31/87, 52 FR32793ClosedVOCNot requiredTech Industries3/10/89, 54 FR10145OpenVOCCurrent requirementsmeet 8-hour RACT.University of RhodeIsland9/20/97, 62FR46202OpenNOxCurrent requirementsmeet 8-hour RACT.ProvidenceMetalizing9/6/90, 55 FR 36635OpenVOCCurrent requirementsmeet 8-hour RACT.Tillotson-Pearson(now PearsonComposites)8/31/90, 55 FR35623OpenVOCCurrent requirementsmeet 8-hour RACT.Updated RACTApproval submitted asSIP revision on 6/18/03Rhode IslandHospital9/20/97, 62 FR46202OpenNOxCurrent requirementsmeet 8-hour RACTUpdated requirementsin Title V permitOsram Sylvania9/20/97, 62 FR46202OpenNOxCurrent requirementsmeet 8-hour RACTAlgonquin GasTransmission Co.9/20/97, 62 FR46202OpenNOxCurrent requirementsmeet 8-hour RACTBradford DyeingAssoc.9/20/97, 62 FR46202OpenNOxCurrent requirementsmeet 8-hour RACT.Hoechst CelaneseCorp. (nowClariant)9/20/97, 62 FR46202OpenNOxCurrent requirementsmeet 8-hour RACT.Plant scheduled toclose 12/087778Naval Educationand Training Center9/20/97, 62 FR46202OpenNOxCurrent requirementsmeet 8-hour RACT.Updated requirementsin Title V permit.Rhode IslandEconomicDevelopment6/02/99, 64 FR29567ClosedNOxNot requiredCranston PrintWorks12/02/99, 64 FR67495ClosedVOCNot requiredCCL Custom Mfg.12/02/99, 64 FR67495OpenVOCCurrent requirementsmeet 8-hour RACT.Updated RACT Plansubmitted as SIPrevision 1/19/05.Victory FinishingTechnologies12/02/99, 64 FR67495OpenVOCCurrent requirementsmeet 8-hour RACT.Quality Spray andStenciling12/02/99, 64 FR67495OpenVOCCurrent requirementsmeet 8-hour RACT.Guild Music12/02/99, 64 FR67495ClosedVOCNot required.7.0 REASONABLY AVAILABLE CO NTROL MEASURES (RACM)

7.1 Purpose of Section

This section consists of an analysis to determine whether any reasonably available control measures (RACM) could be adopted in Rhode Isla nd that would result in the State attaining the

8-hour ozone standard earlier th an the required 2009 attainment date. Consistent with EPA guidance, RI DEM has examined potential contro l measures for point and nonpoint sources and potential Transportation Control Measures (TC Ms) for mobile sources to determine whether such measures: 1) would provide emissions reducti ons sufficient to accelerate attainment; and 2) are feasible both economically a nd technically. RI DEM concl udes that there are no control measures that could be adopted in Rhode Island that satisfy those RACM criteria.

7.2 RACM Analysis Criteria

Section 172(c)(1) of the CAAA requires that SIPs include RACM, as necessary, to provide for attainment as expeditiously as practicable, and th at RACM include, at a minimum, reductions in emissions from existing sources as may be obtai ned from RACT. EPA’s Phase 2 Rule provides that states must include a RACM analysis in their attainment demonstration SIPs.

EPA guidance 19 interpreting the RACM requirements of section 172(c)(1) provides that, for purposes of attainment demonstration SIPs, a potentially available c ontrol measure can be justified as not meeting RACM if the measure (a) is not technically or ec onomically feasible, or (b) does not advance the a ttainment date for the area. EPA’s gui dance further provides that states may consider local conditions, including econom ic impacts and implementation issues, in rejecting potential control meas ures. EPA does not require that all sources apply RACM if less than all RACM will suffice for reasonable further progress and attainment and application of

RACM will not advance the attainment date.

According to EPA modeling guidance, areas such as Rhode Island that have an attainment date of June 15, 2010 must implement the emission reductions needed for attainment no later than June 2009. Thus, to advance the attainment date, th e potential RACM measures would have to

achieve the emission reductions needed fo r attainment during the 2008 ozone season.

19 EPA Memorandum, “Guidance on the RACM Requirement and Attainment Demonstration Submissions for Ozone Nonattainment Areas”, from John S. Seitz, EPA Direct or, Office of Air Quality Planning and Standards to the Regional Air Division Directors, November 1999. EPA Memorandum, “Additional Submission on RACM From

States With Severe 1-hour Ozone Nonattainment Area SIPs ”, from John S. Seitz, EPA, Director Office of Air Quality Planning and Standards and Marge Oge, EPA Direct or, Office of Transportation and Air Quality, to Regional Air Division Directors, December 14, 2000.

66 Federal Register No. 2, January 3, 2001, Fina l Rule for Approval and Promulgation of Air quality Implementation Plans: Connecticut, 1-Hour Ozone Attain ment Demonstration for the Greater Connecticut Ozone

Nonattainment Area.

797.3 OTC Regional RACM Analysis

As discussed in Section 5, “Attainment Dem onstration,” the OTC conducted an extensive regional attainment planning process for the 8- hour ozone standard. That planning effort included an assessment of the nature and magn itude of the ozone problem in the region, a comprehensive review and analysis of potential additional controls within the OTC region, regional modeling under various control scenarios, and formal recommendations by the OTC to its member states to adopt selected control measures.

At the November 2004 OTC Meeting, the OTC di rected its Stationary and Area Sources Committee to review programs to address emi ssions from all stationary point and nonpoint sources. At the same meeting, it directed the Mob ile Source Committee to identify mobile source

control measures for evaluation. 20 OTC staff compiled an initia l list of over 1,000 candidate

control measures identified through published sources such as EPA’s Control Technique Guidelines, STAPPA/ALAPCO “Menu of Options” documents, emission control initiatives in other states including Califor nia, state/regional consulta tions, and stakeholder input. 21 From that list, workgroups comprised of OTC staff and member states’ air quality staff eliminated

measures that were not feasib le because of technical, economic and/or implementation issues. The list was narrowed to approximately 50 candidate control measures that were considered to have the potential to advance ozone attainment in the OTC states.

These measures were subjected to more detailed analysis of the potential for reductions of VOCs or NOx, cost effectiveness, lik elihood of implementation, and e ffectiveness in reducing ozone levels in the OTC region. After consideration of these criteria, the OTC Control Measures Workgroup identified the most promising candidate s from the list of approximately 50 measures and developed separate Contro l Measures Summary Sheets for these measures. The Control Measure Summary Sheets are in Appendix 5K 22 . They provide they the following information

for each measure:

1. A summary of potential additional controls for the sector. 2. A review of existing controls in OTC states and in other states (most often California). 3. A detailed description of the can didate control measures, includi ng estimates of cost per ton of emissions reductions, estimate of reductions that could be achieved, time in which the measure could be implemented, and technical and implementation issues. 4. A rationale for the proposed strategy and a pol icy recommendation with respect to whether it should be adopted by the OTC as a recommendation to the states.

These Control Measures Summary Sheets are a product of the comprehensive review and analysis of OTC member states’ staff with a wide range of expe rtise concerning the potential for

20 OTC Formal Actions related to the regional oz one planning process are available on the OTC website

at http://www.otcair.org/document.asp?fview=Formal

21 The initial list of control measures is on the OTC web site at http://www.otcair.org/document.asp?fview=Report# 21 under “Documents/OTC Reports/Control

Measures 2007.

22 All of the Control Measure Summary Sheets relate to cont rols for point and area sour ces, with the exception of Reformulated Gasoline, a mobile source control measure.

80control measures for point and nonpoint sources. Iterations of the proposed control measures

were made available to stake holders who commented on the tec hnical and economic feasibility of the various measures, the proposed timef rames for implementation and other issues. Frequently, the summary sheets were modified to reflect stakeholder comments. Thus, the Control Measures Summary Sheets are the outcome of a thorough analysis of the availability and feasibility of additional control measures fo r all point and nonpoint source sectors.

The OTC Workgroup made its recommendations con cerning the control measures to the Ozone Transport Commission. After further review, the Commission recommended to OTC member states that they individually consid er adoption of additional measures. 23 These measures are

listed in Table 7-1.

7.4 Point and Nonpoint Source RACM Analysis for Rhode Island

RI DEM has reviewed the applicability of the OTC recommendations to Rhode Island sources; the result of that analysis is summarized in Ta ble 7-1. The OTC regional re view and analysis of potential control measures, in combination with the RI DEM assessment of the applicability and potential for these measures to meet the RACM criteria, constitute a comprehensive point and nonpoint source RACM analysis for Rhode Island. RI DEM has determined that there are no RACM for point and nonpoint sour ces that could be adopted in Rhode Island that would advance the attainment year to 2008.

23 As noted in footnote 2, all OTC formal actions are available on the OTC website. The formal recommendations concerning control measures are at Documents/Formal Actions.

81Table 7-1 OTC Recommended Control Me asures and RI RACM Analysis Source Categories for which OTC

Recommended Controls OTC Action RI DEM RACM Analysis

Adhesives and Sealants 2006 model rule RI DEM is committing to adopt controls for this category consistent with the

OTC Model Rule. Rule will

be submitted as a SIP revision by 10/1/08 with a 1/1/09

effective date.

Architectural and Industrial Maintenance Coatings 2001 model rule If, by July 1, 2008, the EPA

has not fulfilled its

commitment 24 to adopt a federal regulation for this category which is as stringent

as the 2001 OTC Model Rule and which will be effective by 2009, RI DEM commits to submit an equivalent State regulation as a SIP revision by 10/1/08, effective on 1/1/09. Asphalt Paving (Emulsified and Cutback) 2006 control

recommendations RI DEM is committing to

submit an amended rule for this category consistent with

OTC recommendations as a SIP revision by 1/1/09, effective by 4/1/09. Asphalt Production Plants 2006 control

recommendations for major sources Not applicable No major

sources in Rhode Island

Cement Kilns 2006 control

recommendations Not applicable No sources in

Rhode Island Chip Reflash (Heavy Duty Diesel Engines) 2006 model mandatory rule, staff report See discussion in Section 7.5,

“Mobile Sources”

24 24 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to Regional Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer

and Commercial Produc ts,” May 30, 2007.

82Source Categories for which OTC

Recommended Controls OTC Action RI DEM RACM Analysis

Consumer Products 2001 model rule 2006 updated model

rule If, by July 1, 2008, the EPA

has not fulfilled its

commitment 25 to adopt a federal regulation for this category which is as stringent

as the 2006 OTC Model Rule and which will be effective by 2009, RI DEM commits to submit an equivalent State regulation as a SIP revision by 10/1/08, effective on 1/1/09.

Distributive Generation Standards 2001 model rule APC Regulation No. 43,

“General Permits for SmallerScale Electric Generating Facilities,” includes standards

for this sector effective

5/15/07. Glass and Fiberglass Furnaces 2006 control

recommendations Only 1 facility in RI, federally enforceable permitted

emissions limits are lower than those recommended by OTC (Approval 1350 andTitle V Operating Permit RI07. Industrial, Commercial, Institutional

Boilers 2006 control

recommendations RI DEM has determined that

additional emissions reductions from this category

are not feasible in the State. Mobile Equipment Repair and Refinishing 2001 model rule Sources in this category are subject to APC Regulation No. 30, “Control of VOCs from Automobile Refinishing Operations,” which is essentially equivalent to the

2001 OTC model rule. Municipal Waste Combustors No regional measure

recommended but

individual states

should evaluate

. Not applicable. No sources in

RI.

25 25 Memo from Stephen Page, Air Division Director, EPA Office of Air Quality Planning and Standards to Regional Air Division Directors, “Emission Reduction Credit for Three Federal Rules for Categories of Consumer

and Commercial Produc ts,” May 30, 2007.

83Source Categories for which OTC

Recommended Controls OTC Action RI DEM RACM Analysis

Portable Fuel Containers 2001 model rule 2006 updated model

rule EPA’s requirements for this category in its Mobile Source

Air Toxics rule will take

effect 1/1/09. It would be impractical for RI DEM to adopt a State regulation with

an earlier effective date.

Solvents and Cleaners 2001 model rule RI DEM will submit

amendments to APC Regulation No. 36, “Control of Emissions from Organic Solvent Cleaning,” by 1/1/09 to incorporate recommended vapor pressure limits for cold cleaners effective by 4/1/09.

7.5 Mobile Source RACM Analysis for Rhode Island

Emissions from non-road and on-road mobile sour ces together constitute d 51% of the daily VOC and 86% of the daily NOx anthropogenic emissi ons in Rhode Island in 2002. A number of programs are in place that will substantially re duce emissions from these sectors before the 2009 attainment date. These programs are discu ssed in Section 3.2.2.1 a nd 3.2.2.2 (on-road mobile source control programs) and 3.2.2.3 (non-ro ad mobile source control programs).

Since states are generally precl uded from regulating engines a nd fuels used in on-road and nonroad vehicles and engine, 26 Rhode Island has a limited ability to further reduce emissions from mobile sources. However, RI DEM, in conjunc tion with the State Pla nning Council, the Office of Statewide Planning, the RI Department of Transportation (RI DOT) and others, is involved with the design of the State’s Congestion Mitiga tion and Air Quality program(CMAQ program), which aims to reduce ozone precursor em issions in the transportation sector.

Table 7-2 lists the CMAQ program projects that are included in Rhode Island’s 2006-2007 Transportation Implementation Plan (TIP), along with the expected emissions reductions associated with those programs. These progr ams include measures aimed at increasing pedestrian, bicycle, ferry and public trans it travel, facilitating intermodal connections, eliminating traffic congestion through improvi ng transportation management, signalization and roadways, and reducing emissions from the insta llation of emissions controls on public transit diesel busses. Together, these programs are expected to redu ce VOC emissions in the State by 138.5 kilograms (kg), or 0.15 tons, per summer day, and to reduce NOx emissions by 123.8 kg, or 0.14 tons, per summer day.

26 The only OTC recommendation concerning mobile source controls was that states that had not already adopted reformulated gas (RFG) statewid e do so. Rhode Island alread y has RFG statewide.

84Implementation of these projects and other si milar programs that will be funded with CMAQ program monies in the coming years will not resu lt in an acceleration of the attainment date. However, it is important that su ch projects continue to be funde d, because, at the current growth rate, the increase in vehicles mile traveled in the State will eventually outstrip efforts to reduce emissions from cars with stricter inspectio ns, cleaner engines and cleaner fuels.

Since a large number of mob ile source emissions control programs are already being implemented and since additional measures funded by CMAQ program monies would not accelerate the attainment date, RI DEM did not identify any additional mobile source RACM

measures.

Table 7-2 CMAQ Program Projects in 2006-2007 Transportation Implementation Plan

Project Name VOC Reductions (kg/day) NOx Reductions (kg/day)

Transportation Management Center 59.7 9.2 South County Commuter Rail 46.3 60.9 Bicycle / Pedestrian Program 5.0 5.2 Arterial Program - Warwick Avenue 0.3 0.3

Bus Service Initiatives 8.6 6.9 Bus Operations Initiatives 0.2 0.1 Express Travel 0.5 0.5 Passenger Initiatives 0.4 0.4

Comparison of Alternative Fuels for Providence-Newport Ferry: Ultra Low

Sulfur Diesel 0.0 32.8

Comparison of Alternative Fuels for Providence-Newport Ferry: Biodiesel

Fuel 4.9 (3.6) Traffic Signal Control Center 6.9 5.3

Islander Shuttle Train 3.5 3.4 Ferry/Airport/Train Shuttle Service 0.6 0.6 Ferry Facility Improvements 1.6 1.8

Total 138.5 123.8

7.6 Overall RACM Conclusions

There are no control measures th at could be implemented in Rhode Island for any source sectors that meet the RACM feasibility criteria and that would advance the date th at the State attains the 8-hour ozone NAAQS.

858.0 CONTINGENCY MEASURES

8.1 Purpose of Section

This section demonstrates that the Rhode Island nonattainment area meets the requirements for SIP contingency measures related to both Reasonable Further Progress (RFP) and to the attainment of the ozone standard. If implemented , the contingency measures discussed in this

section would result in reductions in addition to those required to demonstrate RFP (discussed in Section 4) and in addition to those that have been taken in to account in the attainment demonstration (discussed in Section 5). Continge ncy measures ensure that if Rhode Island fails to achieve the 15% required RFP reductions by th e 2008 RFP milestone year, or fails to attain the ozone standard by 2010 27 , additional reductions will occur without further state or federal

action.

8.2 Contingency Requirements

Section 172(c)(9) of the CAA and EPA’s Phase 2 Rule require that nonattainment areas include contingency measures in their RFP and attainment SIPs. If a state receiv es a notification from

EPA that a nonattainment area within its borders has failed to achieve th e level of reductions demonstrated in the RFP SIP by the milestone year (2008 for moderate areas such as Rhode Island), or has failed to attain the standard by the attainment da te (June 2010 for Rhode Island), the area must be able to implement contingency measures within one year after EPA’s notice.

The RFP contingency and the attainment c ontingency must each provide for reductions equivalent to at least 3% of the 2002 RFP Ad justed Base Year VOC emissions inventory. 28 The contingency reductions are in addition to the 15% reduction required to demonstrate RFP and in

addition to the reductions taken into acc ount in the attainment demonstration.

8.3 RFP Contingency

As discussed in Section 4, RI DEM is meeting the requirement to reduce emissions by 15% in the 2008 RFP milestone year through reductions in NOx emissions. Since VOC emissions are projected to be 1.7 tons (1.5%) higher in 2008 th an those in the 2002 adjusted RFP inventory, NOx emissions reductions totaling 16.5% were n eeded to satisfy the RFP requirement. To satisfy the contingency requirement, RI DEM must be able to demonstrate that if Rhode Island fails to achieve the required RFP target by 2008, without further state or federal action, an

additional 3% reduction could be achieved from control measures not already taken in account in

the RFP calculations.

27 The attainment date for moderate nonattainment areas is June 15, 2010. For attainment contingency purposes, this is the milestone year. This is in contrast to the milestone year for the attainment demonstration, which is the ozone season prior to the attainment year – 2009.

28 The RFP Adjusted Base Year Inventory is based on the RI 2002 Base Year Inventory adjusted for RFP purposes,

as discussed in detail in Section 4.

86According to EPA’s interpretation of this re quirement, the RFP contingency may be met by showing reductions in the 2008 RFP milestone year of at least 3% beyond t hose required to meet

the RFP. 29 As demonstrated in Section 4, NOx emi ssions in Rhode Island will be reduced an additional 3.6% between 2002 and 2008 beyond the redu ctions required to meet the RFP target (See Table 4-2). Therefore, Rhode Island ha s met the RFP contingency requirement.

In addition, RI DEM is committing in this doc ument to adopt a number of further control

measures that will be effective before the 2009 ozone season, resulting in further emissions reductions that would qualify as contingency measures. For example, VOC limitations for consumer products and AIM coatings, which w ill be effective in Ja nuary 2009, will reduce VOC emissions by 5.0 tons per day from the 2002 base line (see calculations consistent with EPA guidance in Appendix 8A).

8.4 Attainment Contingency

EPA will assess whether Rhode Island has attained the 8-hour standard by June 2010, based on monitored ozone readings for 2007 – 2009. If the State is not meeting the standard based on readings for the 3-year period, EPA may issue a no tification of failure to attain. The notification will trigger a requirement for RI DEM to implem ent contingency reductions within one year of the notification. For purposes of this conti ngency analysis, RI DEM is assuming that the contingency measures would need to be in pla ce by June 2011. Therefore, to meet the attainment contingency requirement, RI DEM must identify control measures that will achieve reductions in

emissions after 2009 and before June 2011 from cont rol measures that will be effective without any further state or federal action.

The amount of additional reductions that must be achieved in order to meet the attainment contingency requirement is 3% of the 2002 RFP Adjusted Base Year VOC emissions. While the required reductions are calculat ed as a percentage of the 2002 VOC emissions, NOx reductions can be used as a direct substitute for up to 90% of the required reductions of 3% of VOCs Therefore, only 0.3% of the reductions achieve d by the contingency measures must be VOCs.

Calculations of the required emissions reductions for attainment contingency are as follows:

2002 Adjusted Base Year Inventory: VOC 111.80 tpsd NOx 69.26 tpsd

Required Attainment Contingency (tpsd) = VOC Adjusted Base Year Inventory * 0.03 = 111.80 tpsd * 0.03 = 3.4 tpsd

This contingency reduction can be made up of a combination of NOx and VOC reductions, as long as at least 10% (0.3 tpsd) is VOC..

29 U.S. EPA Memorandum from Michael H. Shapiro to Region 1 through 10 Air Directors, “Guidance on Issues Related to 15% Rate-of-Progress Plans,” August 23, 1993.

87RI DEM will meet this attainment contingency requirement by taking credit for emission reductions that will be achieved from the existing federal and state on-road and federal on-road

and non-road mobile source control measures de scribed in Section 7.5, “Mobile Source RACM Analysis for Rhode Island.,” including the R hode Island Low-Emission Vehicle (LEV) Program. These measures will continue to provide s ubstantial VOC and NOx emission reductions through 2011 (and beyond) as newer, less-polluting vehicles and equipment replace the older fleet. As shown in Appendix 8B, emissions from the non-road mobile source categories calculated using the Non-Road model are projected to decrease by 2.0 tpsd of VOC and 1.8 tpsd of NOx between 2008 and 2011 without the imposition of additional c ontrols. Although quantitative estimates of 2011 on-road mobile source emissions are not available, those emissions will also decrease during that period. As shown below in Section 9.0, on-road emissions of VOC are projected to decrease by 1.2 tons and NOx by 2.1 tons in the one year period between 2008 and 2009. That decline is projected to conti nue in subsequent years, as a result of fl eet turnover.

Therefore, without the need for imposition of additional controls, emissions in Rhode Island will continue to decline after the attainment year and Rhode Island will meet its attainment contingency obligations.

8.5 Conclusions

Rhode Island has met the RFP contingency by de monstrating that the reductions of VOC and NOx projected by 2008 are greater than the 18% re duction that is required (15% for RFP and 3% for RFP contingency). For the attainment conti ngency, the reductions of VOC and NOx that will be achieved during the 2009-2011 period from the on-road and non-road m obile source control measures already in effect are greater than reductions needed to meet the 3% attainment contingency requirement. Ther efore, Rhode Island meets the attainment contingency requirement.

889.0 TRANSPORTATION CONFORMITY

9.1 Purpose of Section

This section establishes Trans portation Conformity budgets for th e on-road mobile source sector for Rhode Island in the 2008 RFP milestone year and in the 2009 attainment demonstration year. The Transportation Conformity budgets set the levels of mobile sour ce emissions that may not be exceeded in the State in the budget years. Th e budget was developed using the Rhode Island Statewide Travel Demand Model using methods agreed upon by RIDEM, the Rhode Island Statewide Planning Program (RISPP) and the Rh ode Island Department of Transportation, in consultation with EPA Region 1.

Technical data files related to the Mobile 6 mode l runs used to estimate mobile source emissions in the budget years and an expl anation of the modeling methodol ogy are attached in Appendix

2D.

9.2 Background

Transportation conformity is required by section 176( c) of the CAA to ensure that transportation plans, programs and projects receiving federal funds are consistent with the SIP. Conformity to a SIP means that transportation activities will no t produce new air quality violations, worsen existing violations, or delay ti mely attainment of a NAAQS.

EPA’s Phase 2 Implementation Rule provides that nonattainment areas establish motor vehicle emissions budgets for the RFP milestone year (2008) and for the attainment demonstration year (2009). The budgets are set at the level of emissions from the on-road mobile sector projected for these years. Emissions of VOC and NOx from this sector may not exceed the budget levels. Emissions in years for which no budget is set may not exceed the budget established for the most recent prior year.

RI DEM established a conformity budgets for Rhode Island under the 1-hour ozone standard. The budget was submitted to the EPA as part of the State’s 1-hour ozone standard attainment demonstration on March 24, 2003 and was approved by the EPA on April 7, 2003. (68 FR 16724) The 2007 budget is shown in Table 9-1.

The 2008 and 2009 transportation conformity budgets presented in the document, once approved by EPA, will replace the conformity budgets previously submitted and approved.

8990 9.3 Methodology

Conformity budgets are set th rough a conformity consultation process. The 2008 and 2009 budgets were developed using the Rhode Island Statewide Travel Demand Model using methods agreed upon by RIDEM, the Rhode Island Statew ide Planning Program (RISPP) and the Rhode Island Department of Transportation, in cons ultation with EPA Region 1. The methodology used to calculate the budget is described in a docum ent entitled “Rhode Island 2008 and 2009 Mobile Source Emissions,” which was prepared for th e Rhode Island Departme nt of Administration, Statewide Planning Program, RISPP, by Vana sse, Hangen and Brustlin, Inc. and which is attached as Appendix 2D.

9.4 Mobile Source Budgets

Application of the methods described in the Va nasse et al document resulted in the projected emissions for the 2008 and 2009 years for Rhode Island shown in Table 9-1. However, the RISSP, which is the Metropolitan Planning Orga nization (MPO) for the State of Rhode Island, requested, in a letter attached in Appendix 9A, that the 2008 VOC and NOx budgets be set at a level 0.5 tons per day higher than those predicte d by the model to allow a buffer for conformity analyses.

2007 emissions budgets, projected 2008 and 2009 em issions, and the emissions budgets for 2008 and 2009 requested by the RISPP are shown in Tabl e 9-1. Since RI DEM used the requested 2008 emissions budgets in its RFP calculations , allowing the requested 2008 budget will not interfere with the State’s ability to make RFP or contingency targets. Therefore, RIDEM plans to accept the requested budgets, pending approval by the EPA.

Table 9-1 2007 Emissions Budget, Project ed 2008 and 2009 Inventory and Requested 2008 and 2009 Emissions Budgets (tons per summer day)

2007 Budget 2008 Projected Inventory 2008 Mobile Source Budget 2009 Projected Inventory 2009 Mobile Source Budget

VOC 30.68 24.14 24.64 22.75 22.75

NOx 33.97 27.76 28.26 25.29 25.29