1



# Technical Support Document

Houston

- Galveston

- Brazoria Redesignation Substitute

Background

Evaluation

Conclusion



# June 2015

FOR FURTHER INFORMATION CONTACT: Tracie Donaldson, United States Environmental Protection Agency Region 6, Air Quality Section (6PD

- A). 1445 Ross Avenue, Dallas, TX 75202

- 2733, 214

- 665

- 66332

Background

The EPA is proposing to approve a demonstration provided by Texas that the Houston

Galveston

- Brazoria 1

- hour ozone nonattainment area (HGB area) has attained the revoked 1

- hour ozone National Ambient Air Quality Standards (NAAQS) due to permanent and enforceable emission reductions, and that it will maintain that NAAQS for ten years from the date of the EPA’s approval of this demonstration. The demonstration was provided to EPA in a report titled “Redesignation Substitute Report for the Houston

- Galveston

- Brazoria One

- Hour Ozone Standard Nonattainment Area” (Redesignation Substitute Report) submitted to EPA on July 22, 2014.

Th e determination that the area has attained the 1

- hour ozone NAAQS is based upon three years of compl ete, quality

- assured and state

- certified ambient air monitoring data that show the area
has monitored attainment of the 1

- hour ozone NAAQS for the 2011

– 2013 monitoring peri od. The ozone monitoring d ata for 2014 in AQS indicate that the area continues in attainment for the
1

- hour standard. Available data for 2015 shows that the area continues to attain the 1

- hour standard ( http://www.tceq.state.tx.us/cgi

- bin/compliance/monops/ozone_exceedance.pl ). The
determination that the area attained the 1

- hour ozone NAAQS due to permanent and enforceable emission reductions, and that it will maintain that NAAQS for ten years from the da te of the EPA’s approval of this demonstration is based on the EPA review of the demonstration provided by Texas and the evaluation of ozone monitoring data

. In 1979, the EPA promulgated the revised 1

- hour ozone standard of 0.12 parts per million (ppm) (44 FR 8202, February 8, 1979). For ease of communication, many reports of ozone concentrations are given in parts per billion (ppb); ppb = ppm × 1000. Thus, 0.12 ppm becomes 120 ppb or 124 ppb when rounding is considered.

An area exceeds the 1

- hour ozone sta ndard each time an ambient air quality monitor records a 1

- hour average ozone concentration above 0.12 ppm in any given day. Only the highest 1

- hour ozone concentration at the monitor during any 24

- hour day is considered when determining the
number of exce edance days at the monitor. An area violates the 1

- hour ozone standard if, over a
consecutive 3

- year period, more than 3 expected exceedances occur at the same monitor. For more information, please see ‘‘National 1

- hour primary and secondary ambient air qu ality standards for ozone’’ (40 CFR 50.9) and ‘‘Interpretation of the 1

- Hour Primary and Secondary National Ambient Air Quality Standards for ozone’’ (40 CFR Part 50, Appendix H).

The fourth

- highest daily ozone concentration over a 3

- year period is called the design value (DV). The DV indicates the severity of the ozone problem in an area; it is the ozone level around which a state designs its control strategy for attaining the ozone standard. A monitor’s DV is the fourth highest ambient concentration reco rded at that monitor over the previous 3 years. An area’s DV is the highest of the design values from the area’s monitors.

The Act, as amended in 1990, required the EPA to designate as nonattainment any area that was violating the 1

- hour ozone standard, ge nerally based on air quality monitoring data from the 1987 through 1989 period (section 107(d)(4) of the Act; 56 FR 56694, November 6, 1991). The3

Houston area was designated nonattainment with a severe classification at that time and an
attainment date of no later than November 15, 2007

.
The EPA revoked the 1

- hour ozone standard on April 30, 2004 in favor of the 1997 8

- hour ozone
standard (69 FR 23951)

, and

, on March 6, 2015

, the EPA revoked the 1997 8

- hour standard in favor of the more stringent 2008 8

- hour ozone standard (80 FR 12264 ). As explained more fully
in the March 6, 2015 rulemaking the EPA also adopted a provision allowing states to seek a redesignation substitute for revok ed standards . The regulations allow that if a redesignation substitute is approved the state may seek to have “anti

- backsliding” requirements for areas that were designated as nonattainment for the revoked standard shifted to contingency measures if
such action is consistent with sections 110(l) and 193 of the CAA (40 CFR 51.1105 (b) (2) ). The regulations authorize EPA to approve a redesig n ation substitute upon a showing by the state that :

1. The area has attained that revoked NAAQS due to permanent and enforceable emission
reductions
2. The area will maintain that revoked NAAQS for 10 years from the date of the EPA’s approval of the showing.

EPA indicated in the revised Phase 1 rule that these criteria w ere based on the provisions of CAA section 107(d)(3)(E). Specifically, t he first criterion for a redesignation substitute is the same as two redesignation criteria found in CAA section 107(d)(3)(E)(i) and (iii). The second criterion for a redesignation su bstitute is similar to the c riterion for a maintenance plan which provides for maintenance of the NAAQS for at least 10 years after redesignation (CAA sections 107(d)3(E)(iv) and 175A)

. EPA provided guidance on the approach to evaluating state compliance with these provisions in EPA’s September 4, 1992 memo “Procedures for Processing Requests to Redesignate Areas to Attainment” from John Calcagni . For this reason, EPA believes it is appropriate to consider that guidance when evalu ating state compliance wi th the redesig n ation substitute requirements

. (1992 redesignations guidance, www.epa.gov/ttn/oarpg/t5/memoranda/redesignmem090492.pdf ).

On July 22, 2014, the Texas Commission on Environmental Quality (TCEQ) provided the “Redesignation Substitute Report for the Houston

- Galveston

- Brazoria One

- Hour Standard Nonattainment Area” for use by the EPA in evaluating the request for approval of a redesignation substitute for the 1

- hour ozone standard obligations for the area. This Technical Support Document evaluat es whether the Texas Report supports a determination by the EPA that redesignation substitute criteria in the above referenced ru le has been met for the HGB area

.
Evaluation

(1) The area has attained the revoked NAAQS due to permanent and enforceable emission reduction s

. a.) Is the HGB area attaining the 1

- hour ozone NAAQS?

Table 1 contains the 1

- hour ozone data for the HGB 1

- hour ozone nonattainment area monitors
that show that the area is currently attaining the 1

- hour ozone NAAQS, consistent with 40 CFR
Part 50, Appendix H.4

Table 1 : Current 1

- hour Ozone NAAQS Design Values for the HGB Area

Years 1

- Hour Ozone Design Value
2011

- 2013 121 ppb
2012

- 2014 111 ppb Preliminary 2013

- 2015 ( 6/8/15) 107 ppb

Figure 1: One

- Hour Ozone Design Values for the HGB Area

For the one

- hour ozone NAAQS, the design value was used to determine the classification of a nonattainment area but was not used for designating an area as attainment or otherwise. Designation is based on the maximum number of expected exceedances over all the monitors in5

an area 1 . To show that the HGB area no longer violates the one

- hour ozone NAAQS, the remainder of this section will be based on expected exceedances, calculated as per 40 CFR Part 50, Appendix H.

The expected number of exceedances of record in a metropolitan area is the maximum expected number of exceedances of all the area’s regulatory monitors’ individual expected number of exceedances. Because ozone concentrations vary spatially, it is also prudent to investigate trends at all regul atory monitors in a n area. Table 2 : One

- Hour Ozone Expected Exceedances by
Monitor contains one

- hour ozone expected number of exceedances at all regulatory monitors in
the HGB area from 20 11 through 201 4 . More monitor s than those listed in Table 2 operate in the HGB area, but expected number of exceedances at those additional monitors are not appropriate for compliance determinations because the monitors’ data do not meet EPA’s quality assurance criteria and cannot be used for regulatory purposes. In 2013, all monitors in the HGB area had expected exceedances less than the threshold of 1.0 per year and only one monitor in the HGB area, the Houston East monitor (C1), had more than 1.0 expected exceedance in 2011 and 2012.

1 The expected exceedances for a monitor is defined as the number of exceedances that occurred in the calendar year plus an increment that accounts for missing data, averaged across three consecutive years (for example, expected exceedances for 2013 is averaged across 20 11, 2012, and 2013). The increment is calculated by finding the number of days without an associated ozone measurement that may not be assumed to be less than the standard, multiplied by the number of observed exceedances, then divided by the number of obs ervations. This is done for each year and then averaged across three years to get the expected exceedances for that individual monitor. Note that unlike the calculation for expected exceedances, design values are not adjusted for data completeness.6

Table 2. One

- Hour Ozone Expected Exce edances by Monitor for the HGB Area

The air quality data provided by Texas is consistent with that found in the quality assured data found in the EPA Air Quality System (AQS), therefore, EPA proposes to find that the HGB area
is meeting the 1

- hour ozone standard.

b.) Are the air quality improvements in the HGB area due to permanent and enforceable
emissions reductions?

Because Texas reasonably attributed the improvement in air quality to emission reductions which are permanent and enforceabl e, t he EPA proposes to find that Texas has demonstrated that the
observed ozone air quality im provement in the HGB area is due to permanent and enforceable reductions in emissions resulting from implementation of the EPA approved SIP and Federal

measures

. The EPA approved SIP includes state and local measures can be found in 40 CFR
52.2270.

Texas presented data to show the long term decrease in ozone concentrations in the HGB area

a nd showing that this long term decrease in ozone levels can be attributed t o a suite of nitrogen
oxide ( NOx ) controls and volatile organic chemical ( VOC ) controls with a particular emphasis on control of highly reactive VOCs.

In making this demonstration, the State presented several sets of data. First, the State provided
emiss ions inventory data for 2002 through 2011. Secondly, t he State provided a n ambient
concentration trend analysis for ozone precursors ( NO X and VOC) in the HGB area between7

2002 and the period in which the standard was attained , 2011

- 2013 . Finally, the State
documented the VOC and NO X emission control measures that have been implemented in the HGB area over the past 25 years.

A. Emissions Reductions as Shown by Emissions Inventory (EI) Data

The attainment EI base year is 2011 because it is the year of the most recent periodic emissions inventory (PEI) and one of the three years used to determine the design value (DV) for the 2013 attainment year. 2011 emissions were compared to 2002 VOC and NO X emissions when the DV was 178 ppb , to show tha t emission reductions have occurred in the area, and have resulted in the ozone air quali ty improvement in the area. 2011 is the first three

- year period demonstrating attainment. By 2011, NO X emissions were estimated to have dropped by 30% and VOC emissions by 46 % from 2002 levels.

These significant decreases resulted in the improvement in ozone levels seen at the monitors. The emissions for both years were d erived from periodic VOC and NO X emission inventories,
which are prepared every three years. Based on the estimated emissions, the TCEQ has
documented several emission trends to show that permanent and enforceable emission controls in
various source sectors are responsible for significant downward trends in VOC and NO X emission totals in the HGB area leading to attainment . For a discussion of emission inventory preparation methods, see the discussion of the preparation of the 2011 base year emission
inventories below.

To demonstrate that VOC and NO X emissions decreased between one of the violation years ( 2002) and the attainment year (2011 ), the TCEQ has documented HGB ’s VOC and NO X emissions for 2002 and 2011 for all anthropogenic source sectors. Table 3 lists these emissions
for the 2002 , 2005, 2008 PEI and 2011 EI.

Table 3 : HGB Eight

- County Nonattainment Area Historical Emissions

Emissions Source Category 2002 2005 2008 2011 VOC Emissions (tpd)

Area 422.14 425.83 449.6 308.74

Non

- Road Mobile 82.79 72.28 62.65 49.92

On

- Road Mobile 115.34 106.58 96.37 85.05

Point 149.37 140.08 108.1 96.11

VOC Total 769.64 744.77 716.72 539.82

NO X Em i ssions (tpd)

Area 27.79 16.04 25.41 21.15

Non

- Road Mobile 145.25 156.04 149.24 121.11

On

- Road Mobile 322.67 260.98 190.58 213.57

Point 339.49 194.52 111.38 108.48

NO X Total 835.2 627.58 476.61 464.318

Based on the 2002 , 2005, 2008 and 2011 HGB area emissions information provided by the TCEQ, the EPA concludes that VOC and NO X emission totals have significantly declined in the nonattainment area during the 2002

– 2011 period. These emission reductions have led to attainment of the 1

- hour ozone standard in this area. The EPA concurs with Texas’ conclusions that the emission controls, emissions inventories, and emissions trends support the conclusion
that attainment in the area is due to permanent and enf orceable emission reductions.

B. Impact of Emissions Controls Implementation: Trend Analysis

To assess the impact of emission control implementation, the TCEQ determined the VOC and
NO X ambient conc entration trends in the HGB area from 2000 to 2013

. Annual maxima, annual
90 th percentile and annual average daily peak 1

- hour NO X values were analyzed. All three measures decreased markedly over the time period from 2000 to 2013, falling 25% (maximum), 24% (90 th percentile) and 28% (average). Strong downward tre nds in ambient NO X concentrations are evidence of the effectiveness of emission controls.

The other major class of ozone precursors is VOC. Since the mid

- 1990s, the TCEQ has collected
40

- minute measurements, on an hourly basis, of over 40 species of VOC us ing a uto

- GC
instruments. The TCEQ focused on two prevalent compounds, ethylene and propylene, that are associated with rapid and efficient ozone formation. Since the majority of VOC production occurs along the Houston Ship Channel, the eight auto

- GC instruments near the area were examined. Yearly geometric means were computed from vali d ambient hourly measurements.
The TCEQ calculated the geometric mean by taking the natural logarithm of each measurement, averaging these logs, and then calculating the antilog of this mean log value. The geometric mean is a preferable statistic to median or arithmetic (ordinary) mean for evaluating the central tendency of data when the data are skewed, i.e., when the data are not symmetrically, or normally, distributed, but instead clustered around extreme high or l ow values. A geometric mean is more robust than an ordinary average, in that its value is not greatly influenced by one or a few very high or very low values. Many distributions of pollutant measurements, especially VOC, in the HGB area are skewed.

Prior t o 2004, only three of the eight monitors had enough valid data to calculate annual geometric mean ethylene. Generally, the geometric mean ethylene concentrations at all of the

auto

- GC monitors have decreased. Ethylene at the Channelview monitor (C15) stead ily decreased until 2013 when the geometric mean ethylene increased. Ethylene at the Houston Regional Monitoring Corporation (HRM) 3 Haden Road non

- regulatory, industry

- sponsored monitor (C603) began increasing in 2011 and 2012 but resumed its decreasing t rend in 2013. Ethylene is a highly reactive VOC shown to disproportionately impact ozone levels. This ambient data demonstrates the effectiveness of the State’s controls in reducing ethylene levels

C. Permanent and Enforceable Emissions Controls Imple mented

A broad range of control measures have been implemented for each emission source category. In
section 3.2 of the R edesignation S ubstitute R eport Texas identified the permanent and
enforceable measures that led to attainment of the 1

- hour ozone NAAQS

. T able 4 below from the report lists existing ozone control strategies that have emissions reductions in the attainment9

demonstrations for both the 1

- h our and the 1997 8

- h our ozone standards. These measures are permanent and enforceable and are included in the EPA approved SIP (40 CFR 52.2270)

. EPA approved the HGB 1

- hour ozone attainment demonstration in 2006 (71 FR 52670, September 6,
2006 ) and the HGB 1997 8

- hour ozone a ttainment demonstration in 2014 ( 79 FR 57, January 2, 2014).

Table 4

. Existing Ozone Control Measures Applicable to the HGB Eight

- County
Nonattainment Area (from section 3.2 of the Redesignation Substitute Report)

Measure Description Start Date(s)

NO X Mass Emissions Cap and Trade (MECT) Program
30 Texas Administrative Code (TAC) Chapter 101, Subchapter H, Division 3 Overall 80% NO X reduction from existing industrial sources and utility power plants, implemented through a cap and trade program
Affects utility boilers, gas turbines, heaters and furnaces, stationary internal combustion engines, industrial boilers, and many other
industrial sources April 1, 2003 and phased in through April 1, 2007

HRVOC Rules and Highly Reactive Volatile Organic Compounds Emissions Cap and Trade (HECT) Program 30 TAC Chapter 101, Subchapter H, Division 6 Affects cooling towers, process vents, and flares, and establishes an annual emissions limit with a cap and trad e for each applicable site in Harris County Seven perimeter counties subject to permit allowable limits and monitoring requirements Monitoring requirements began January 31, 2006 Cap and trade program implemented January 1,
2007 HECT cap incrementally

s tepped

- down from 2014 through 2017 for a total 25% cap reduction HRVOC Fugitive Rules 30 TAC Chapter 115, Subchapter D, Division 3 More stringent leak detection and repair (LDAR) requirements for components in HRVOC service Additional components include d in LDAR program: more stringent repair times, lower leak detection, and third

- party audit requirements March 31, 2004

VOC Control Measures

– Storage Tanks 30 TAC Chapter 115, Subchapter B, Division 1 Requires controls for slotted guide poles and

more s tringent controls for other fittings on floating roof tanks, and control requirements or operational limitations on landing floating roof
tanks Eliminates exemption for storage tanks for crude oil or natural gas condensate, and regulates flash emissions f rom these tanks January 1, 2009 Compliance with revised monitoring and testing requirements required by March 1, 2013

VOC Control Measures

– Degassing Operations 30 TAC Chapter 115, Subchapter F, Division 3 Requires vapors from degassing to be vented to a control device for a longer time period, and removes exemption from degassing to control for tanks with capacity of 75,000 to 1,000,000 gallons Clarification of rule and monitoring and testing requirements, additional control options, and notification requirements January 1, 2009 February 17, 2011

NO X Emission Standards for Nitric Acid and Adipic Acid Manufacturing NO X emission standards for nitric acid and adipic acid manufacturing facilities in the HGB

area November 15, 199910

Measure Description Start Date(s) 30 TAC Chapter 117, Subchapter F Utility Electric Generation in
East and Central Texas 30 TAC Chapter 117, Subchapter E, Division 1 NO X control requirements (approximately 55 % ) on utility boilers and stationary gas turbines at utility electric generation sites in East and
Central Texas May 1, 2003 through May 1,
2005

VOC Control Measures 30 TAC Chapter 115 Additional control technology requirements for batch processes and bakeries by December 31,
2002 Additional VOC measures adopted earlier for reasonably available control technology (RACT) purposes: general vent gas control, industrial wastewater, loading and unloading operations, general VOC LDAR, solvent using process, etc. (see Appendix D: Reasonably Available Control Technology Analysis of the Houston

- Galveston

Brazoria Attainment Demonstration State Implementation Plan Revision for the 1997 Eight

- Hour Ozone Standard adopted March 10, 2010 (2010 HGB AD SIP Revision) for more details) December 31, 2002 and
earlier

VOC Control Measures

– Offset Lithographic Printers 30 TAC Chapter 115, Subchapter E, Division 4 Additional control technology requirements f or offset lithographic printers
Revised in 2010 to limit VOC content of solvents used by offset lithographic printing facilities and to include smaller sources in rule applicability (see Appendix D of the 2010 HGB AD SIP Revision for more details) Decemb er 31, 2002 March 1, 2011 for major

sources March 1, 2012 for minor

sources

VOC Control Measures

– Solvent

- Using Processes 30 TAC Chapter 115, Subchapter E Revised in 2011 to implement RACT requirements per control technique guidelines published by t he United States Environmental Protection Agency (EPA) Seven emission source categories in the HGB area: industrial cleaning solvents; flexible package printing; paper, film, and foil coatings; large appliance coatings; metal furniture coatings; miscellan eous metal and plastic parts coatings; and miscellaneous industrial adhesives (see Houston

- Galveston

- Brazoria Reasonably Available Control Technology Analysis Update State Implementation Plan Revision for the 1997 Eight

- Hour Ozone Standard adopted December 7, 2011 for more details) March 1, 2013

Refueling

– Stage I 30 TAC Chapter 115, Subchapter C, Division 2 Captures gasoline vapors that are released when gasoline is delivered to a storage tank Vapors returned to the tank truck as the storage tank is being filled with fuel, rather than
released into the ambient air 1990

Refueling

– Stage II Captures gasoline vapors when a vehicle is being fueled a t the pump 199211

Measure Description Start Date(s) 30 TAC Chapter 115, Subchapter C, Division 4 Vapors returned through the pump hose to the petroleum storage tank, rather than released
into the air A SIP revision authorizing the decommissioning of Stage II vapor control equipment
was submitted to the EPA on October 31, 2013. Facil ities may continue operating Stage II until August 31,
2018. Federal Area/Non

- Road

Measures Series of emissions limits, implemented by the EPA, for area and non

- road sources Examples: diesel and gasoline engine standards
for locomotives and leaf

- blower s Through 2018

Texas Emissions Reduction Plan (TERP) 30 TAC Chapter 114, Subchapter K Provides grant funds for on

- road and non

- road heavy

- duty diesel engine replacement/retrofit January 2002

California Standards for Certain Gasoline Engines California standards for non

- road gasoline engines 25 horsepower and larger May 1, 2004

Stationary Diesel Engines 30 TAC Chapter 117, Subchapter B, Division 3 Prohibition on operating stationary diesel and
dual

- fuel engines for testing and maintenance purposes between 6:00 a.m. and noon April 1, 2002

Natural Gas

- Fired Small Boilers, Process Heaters, and
Water Heaters 30 TAC Chapter 117, Subchapter E, Division 3 NO X emission limits on small

- scale residential and industrial boilers, process heaters, and water heaters equal to or less than 2.0 million British thermal units per hour 2002

Minor Source NO X Controls
for Non

- MECT Sites 30 TAC Chapter 117, Subchapter D, Division 1 NO X emission limits on boilers, process heaters, stationary engines, and turbines at minor sites not included in the MECT program (uncontrolled design capacity to emit less than 10 tons per year) March 31, 2005

Texas Low Emission Diesel (TxLED) 30 TAC Chapter 114, Subchapter H, Division 2 Requires all diesels for both on

- road and non

road use to have a lower aromatic content and a higher cetane number Phase in began October 31,
2005

TxLED for Marine Fuels 30 TAC Chapter 114, Subchapter H, Division 2 Adds marine distillate fuels X and A, commonly known as DMX and DMA, or Marine Gas Oil, into the definition of diesel fuels, requiring them to be TxLED compliant June 24, 2007

Texas Low Reid Vapor Pressure (RVP) Gasoline 30 TAC Chapter 114, Subchapter H, Division 1 Requires all gasoline for both on

- road and non

road use to have a RVP of 7.8 pounds per square inch or less from May 1 through October 1 each year April 2000

Voluntary Mobile Emission Reduction Program Voluntary measures administered by the
Houston

- Galveston Area Council (H

- GAC) (see Appendix F: Evaluation of Mobile Source Control Strategies for the Houston

- Galveston

Brazoria State Implementation Plan (With Detailed Strategies), prepared for H

- GAC by ENVIRON International Corporation, of the 2010 HGB AD SIP Revision) Through 201812

Measure Description Start Date(s)
Federal On

- Road Measures Series of emissions limits, implemented by the EPA, for on

- road vehicles Examples: Tier 1 and Tier 2 vehicle standards, low sulfur diesel standards, National Low
Emission Vehicle stan dards, and reformulated gasoline Phase in through 2013

Vehicle Inspection/
Maintenance 30 TAC Chapter 114, Subchapter C Yearly treadmill

- type testing for pre

- 1996 vehicles and computer checks for 1996 and
newer vehicles May 1, 2002 in Harris County May 1, 2003 in Brazoria, Fort Bend, Galveston, and Montgomery Counties Speed Limit Reduction 43 TAC Chapter 25, Subchapter B Five miles per hour (mph) below what was posted before May 1, 2002, on roadways where speeds were 65 mph or higher September 2 003

Transportation Control
Measures Various measures in H

- GAC’s long

- range transportation plans (see Appendix F of the 2010 HGB AD SIP Revision for more details) Phase in through 2018

Voluntary Energy Efficiency/Renewable Energy Energy efficiency and renewable energy projects encouraged by Senate Bill (SB) 7, 76th Texas Legislature, 1999 and SB 5, 77th Texas Legislature, 2001 September 1, 1999 and September 1, 2001

Automotive Windshield
Washer Fluid 30 TAC Chapter 115, Subchapter G, Division 1 VO C content limitation on automotive windshield washer fluid sold, supplied, distributed, or manufactured for use in Texas January 1, 1995

For emissions reduction s not included in the 1997 8

- hour and 1

- hour ozone attainment
demonstrations Texas identified other permanent and enforceable control measures. These

measures were:

• Control of Volatile Organic Compounds Emissions from Storage Tanks

• Mass Emissions Cap and Trade Program for NOx

• Tier 3 Federal Motor Vehicle Emission and Fuel Standards

• Fed eral Marine Diesel Engine and Fuel Standards

In sum, the table above shows the breadth of controls that have been adopted and implement ed in the HGB area. These controls have been implanted over a period of decades. Texas has focused on the significan t reductions that have happened since 2002, demonstrating both NOx and VOCs have declined significantly. During this same time period ozone levels have also
declined. Table 2 shows that the precursor reductions have continued from 2008 forward as well

as providing the additional improvement in ozone levels necessary to reach attainment. Table s 3
and 4 show that both Federal Measures to control on

- road and off

- road emissions and State
instituted controls such as low emission diesel for marine vessels, add itional storage tank controls and storage tank degassing controls have all contributed to these additional reductions. Additionally, we note that we’ve approved SIPs for the HGB area that document continuous emissions reductions due to permanent and enforc eable measures for the 1

- hour and 1997 8

- hour13

ozone standards (70 FR 7407, February 14, 2005; 74 FR 18298, April 22, 2009; 79 FR 51, January 2, 2014). The EPA concludes that the reductions in ozone are due to a these permanent and enforceable measures.

(2) The area will maintain the revoked NAAQS for 10 years from the date of the EPA’s approval of the showing.

Consistent with the 1992 redesignations guidance, Texas provided an attainment emissions inventory and projected future emissions inventories. To demonstrate maintenance of the 1

- hour

ozone standard, the TCEQ projected VOC and NO X emissions to 2026 and to several interim years, 2014, 2017, 2020 and 2023 . These emissions were compared to the 2011 attainment year emissions to show that emissions of NO X and VOC , remain below the attainment levels for the
entire demonstrated maintenance period.

In the July 22, 2014 , ozone redesignation substitute request, the TCEQ compared the VOC and
NO X emissions for 2011 , 2014, 2017 , 2020, 2023 and 2026 for all major source s ectors, and in
total for the HGB nonattainment area. In its ozone maintenance demonstration, the TCEQ presented the NO X and VOC emission totals for the 2011 base year and all projection years for
the HGB area

. The TCEQ’s maintenance demonstration shows that in 2014, 2017, 2020, 2023
and 2026 , VOC and NO X emission totals for the HGB area are projected to be below the 2011
VOC and NO X emissions for the area.

NO X emissions in the HGB area are projected to decline by 37 percent between 2011 and 2026

. VOC emissions in the HGB are a are projected to decline by approximately 3.5 percent between
2011 and 2026. B ased on photochemical modeling analyses showing that the formation of ozone
in the HGB area is more sensitive to NO X tha n to VOC emis sions, the small decrease in VOC
emission s is expected to be much less significant than the decrease in NO X

. Based on this analysis, emissions in the HGB area are expected to remain at levels consistent
with attainment for the 1

- hour ozone standard from 2014 through 2026

. The 2011 base year and the 2014, 2017, 2020, 2023, and 2026 future year EI summaries by source categories for the HGB area are shown in Table 5 : HGB NO X Emissions by Source Category (tons per day) and Table 6 : HGB VOC Emissions by Source Category (tons per day)

. Contributions from biogenic emissions are not included in the summary because this analysis is limited to anthropogenic sources.

Table 5 : HGB area NO X Emissions by Source Category (tpd)

Category 2011 2014 2017 2020 2023 2026

Point Sources 108.48 126.31 126.82 127.01 127.20 127.39

Area Sources 21.15 22.19 22.90 23.28 23.17 23.23

On

- Road Mobile Sources 181.28 127.70 88.85 69.80 59.28 54.51

Non

- Road Mobile Sources 121.11 106.99 94.99 83.70 75.54 68.9814

Total 432.02 383.19 333.56 303.79 285.19 274.11

Table 6 : HGB area VOC Emissions by Source Category (tpd)

Category 2011 2014 2017 2020 2023 2026

Point Sources 96.11 100.81 102.86 103.29 103.71 104.12

Area Sources 308.74 321.92 332.43 339.67 342.58 346.13

On

- Road Mobile Sources 80.92 60.43 46.51 40.51 38.09 36.93

Non

- Road Mobile Sources 49.92 38.33 33.34 30.86 30.11 30.02

Total 535.69 521.49 515.14 514.33 514.49 517.20

Trend analysis using the 2026 future year emissions shows an overall decrease of 176.40 tpd in
combined NO X and VOC emissions for the HGB area. This net change includes a projected 18.49 tpd decrease in VOC and a 157.91 tpd decrease in NO X from 2011 levels

. In general, growth in point and area source emissions are projected to be offset by the continued
introduction of cleaner on road and off road vehicles.

The EPA proposes to conclude that the TCEQ has demonstrated maintenance of the ozone standard during the 10

- plus year maintenance period for the HGB area through projections of
VOC and NO X emissions that show that the emissions will remain belo w the 2011 attainment
levels during the maintenance period.

Conclusion

The review of the Texas redesignation substitute repo rt found that Texas has demonstrated that:

(1) The HGB area has attained the revoked 1

- hour ozone NAAQS due to permanent and
enforceable emission reductions (2) The HGB area will maintain th e revoked 1

- hour ozone NAAQS for ten years from the date of the EPA’s app roval of this demonstration.

It is recommended that EPA approve the HGB redesignation substitute for the revoked 1

- hour ozone NAAQS.