# 40'~ RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 235 Promenade Street, Providence, R102908-5767 TDD401-222-4462

19 October 2009 David Conroy EPA - New

England, Region I 1 Congress Street, Suite 1100 Boston, MA 02114-2023 Dear Mr . Conroy: Enclosed is a revised Chapter 4 of the "Rhode Island Attainment Plan for the 8-Hour Ozone National Ambient Air Quality Standard" (Attainment Plan) . The Attainment Plan was originally submitted to you on 30 April 2008. The revisions to Chapter 4address VOC Emission Reduction Credits (ERCs) that were not included in the 2002 base year inventory or in the 2008 projection inventory that was compiled for the Reasonable Further Progress (RFP) analysis. The revisions to Chapter 4 demonstrate that inclusion of the Emission Reduction Credits will not change the results of the RFP analysis. Addition of the ERCs (700 tons ofVOC/year or 1 .9 tons per day) would increase the 2002 RFP VOC emissions from 111 .8 tons per day to 113 .7 tons per day and would increase 2008 RFP VOC emissions from 113 .5 tons per day to 115 .4 tons per day. Projected 2008 VOC emissions in the RFP are 1 .7 tons per day higher than 2002 VOC emissions. Since the ERC emissions would be added to both the 2002 and 2008 inventory, that difference would not change. The percent increase, 1 .5%of the 2002 VOC inventory, also would remain the same, since the ERCs only marginally increase the base year emissions The RFP targets assume that all of the required 15%emissions reductions are fromNOx, not VOC, and the analysis shows that NOx emissions would be reduced by 20.1 % between 2002 and 2008 . The reduction in NOx emissions is sufficient to account for the required 15%reduction, to compensate for the 1 .5%increase in VOC emissions, and to provide an additional 3.6% reduction which fulfills the 3%RFP contingency measure requirement in the Attainment SIP. To facilitate your reviewofthe revised Chapter 4, I am providing a copy showing the markups in addition to the "clean" copy. Feel free to call me or Barbara Morin if there are any questions concerning this submission. Sincerely, Douglas`'L. McVay Acting Chief Office of Air Resources

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.0 REASONABLE FURTHER PROGRESS ANALYSIS (October 6, 2009 amended version) 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 ofVOC, NOx, or a combination of VOCand NOx must be at least 15% lower than the 2002 baseline. As discussed in Section 2 .2, RI DEM

developed a 2008 projected emissions inventory for VOCand NOx that took into account anticipated 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 ofVOC, NOx or a combination of VOCand NOx will be reduced by at least 15% by 2008 fromthe 2002 baseline. The procedures and methodology for demonstrating compliance with the 1-hour ozone standard Rate of Progress requirements were established in a 1992 EPAguidance document ; these procedures are still applicable for purposes of the 8-hour ozone standard RFP .1 EPA's method for demonstrating that RFP requirements are met calls for : 1 . Developing a 2002 base year inventory for a nonattainment area; 2 . Adjusting that inventory to subtract emissions reductions determined to be non-creditable; 3. Establishing a target level of emissions for 2008 that reflects the required 15% reduction fromthe adjusted base year inventory; 4 . Developing a projected inventory of VOCand NOx emissions for 2008; and 5. Demonstrating that the projected 2008 emissions of NOx, VOCor a combination of NOx and VOCwill 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 oftypical summer day Rhode Island anthropogenic emissions of VOC and NOx for the 2002 base year were obtained fromthe 2002 Emissions Inventory discussed ' Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Targetfor the 15 Percent Rate ofProgress Plans, U.S. EPA, Office of Air Quality Planning and Standards, EPA452/R-92-005, October 1992.in Section 2 and attached as Appendix 2A . That inventory does not include organic compounds that are excluded fromthe EPAdefinition of "VOC ." Pursuant to EPA's RFP methodology, for the purpose ofthe RFP, RI DEM adjusted this inventory by subtracting from

the VOCand NOx base year emissions non-creditable emissions reductions, which are those realized fromthe pre-1990 federal limits on the Reid Vapor Pressure (RVP) of gasoline (RVP of 9 .0) and the Federal Motor Vehicle Control Program (FMVCP) .2 Consistent with EPAguidance, non-creditable emissions reductions of VOC and NOx were calculated 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 actual 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 for 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 were calculated by subtracting the 2008 emissions factors calculated in Step 2 fromthe 2002 factors calculated in Step 1 and multiplying the difference by 2002 VMT. Non-creditable emissions calculated by this method are 5.51 tpsd VOCand 3.19 tpsd NOx. Non-creditable emissions calculations are shown in Appendix 4A . In addition, the 2002 Base Year Inventory was modified to account for 700 tons per year (1 .9 tpsd) of VOC Emissions Reduction Credits (ERCs) which were generated when Quebecor Printing Providence ceased operations on December 31, 1998 and which were subsequently sold/transferred to the Rhode Island Resource Recovery Corporation (RIItRC), the owner/operator ofthe Central Landfill . DEM approved this transfer in January of 2002. Table 4-1 shows the 2002 Base Year and Adjusted Base Year Inventories of NOx and VOC, in tons per summer day

2 The CAA (Section 182(b)(1)(D)) provides that reductions fromthe following measures are not creditable toward the required reductions: (1) Federal 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 nonattainment areas issued by June 15, 1990 ; (3) State regulations correcting deficiencies in reasonably available control technology (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.SOURCE TYPE 2002 Base Year VOC 2002

Adjusted VOC 2002 Base

Year NOx 2002 Adjusted

NOx Stationary Point 10.3 12.2 7.0 7 .0 Stationary Nonp oint 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 117.3 113.7 72.5 69.3

4.4 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 Table 4-2. The reductions can be VOCs, NOx or any combination of both. RI DEM is establishing its target levels based on a 15%

reduction in NOx emissions. The 2008 Target Levels and resultant required emissions reductions were calculated as follows : NOx: Required Emissions Reductions = 2002 Adjusted Emissions (69.3 tpsd) X 0 .15 = 10.4 tpsd 2008 Target = 2002 Adjusted Emissions (69.3 tpsd) - Required Reductions (10 .4 tpsd) _ 58.9 tpsd 

### VOC Required Emissions Reductions = 2002 Adjusted Emissions (113 .7 tpsd) X 0 .00 = 0 .0 tpsd 2008 Target = 2002 Adjusted Emissions (113 .7 tpsd) - Required Reductions (0.0 tpsd) _ 113.7 tpsd 4.5 2008 Projected Emissions Inventory Table 4-1 Rhode Island Base Year and Adjusted Base Year Emissions ( sd

Projected emissions in 2008 were calculated by estimating anticipated growth in emissions between 2002 and 2008 and then adjusting for any controls that will reduce emissions during that time period. Calculations of the projected 2008 inventory arediscussed in Section 2 .2 ofthis document . As with the 2002 Base Year Inventory, the 2008 projected inventory was adjusted to account for the 1 .9 tpsd of VOC ERCs which were generated when Quebecor Printing Providence closed and which were subsequently sold/transferred to the RIRRC . Those emissions were not accounted for in RIRRC's 2008 emissions projections. 4 .6 Results of RFPAnalysis The 2008 projections are shown in Table 4-2 below . Reductions anticipated by 2008 are compared to the reductions required to meet RFP . As shown, projected 2008 VOC emissions in Rhode Island are 1 .5%(1 .7 tons per day) higher than the target level . 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; therefore 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 the non-road and on-road mobile sectors. Note that the 2008 on-road mobile emissions of VOCand 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."Table 4-2 RFPCalculations VOC ( sd NOx sd 2002 RFP 2008 2002 REP 2008 Emissions Inventory Inventory Inventory Inventory Stationa ry Point 12.2 12 .9 7.0 7.3 Stationary Nonp

oint 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 113.7 115.4 69.3 55.3 

### 2008 RFP Tar get Emissions 113.7 58.9 Predicted 2002-2008 (1 .7) tpsd 13.9 tpsd Emissions Reductions (1 .5%) of 2002 RFP (20 .1% of 2002 RFP inventory) Increases invento ry) Required 2002-2008 0 .0 tpsd 10.4 tpsd Emissions Reductions (0.0%of 2002 RFP inventory) (15.0%of 2002 RFP inventory) Excess Emissions (1 .7) tpsd 3.5 tpsd Reductions (1 .5%) of 2002 RFP (5.1% of 2002 RFP inventory) inventory) 

### 2008 RFP Target NOx 57.8 tpsd Emissions Adjusted to (16.5% reduction from2002 Account for Increase in RFP inventory) VOC Emissions Required Emissions Reductions Adjusted to 11 .4 tpsd Account for Increase in (16.5%of 2002 RFP inventory) VOC Emissions Excess Emissions Reductions Adjusted to 2 .5 tpsd Account for Increase in (3.6%of 2002 RFP inventory) VOC Emissions4

.0 REASONABLE FURTHER PROGRESS ANALYSIS (October 6, 2009 amended version 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 VOCand NOx must be at least 15% lower than the 2002 baseline. As discussed in Section 2 .2, RI DEM

developed a 2008 projected emissions inventory for VOCand NOx that took into account anticipated 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 ofVOC, NOx or a combination of VOCand NOx will be reduced by at least 15% by 2008 fromthe 2002 baseline. The procedures and methodology for demonstrating compliance with the 1-hour ozone standard Rate of Progress requirements were established in a 1992 EPAguidance document ; these procedures are still applicable for purposes of the 8-hour ozone standard RFP .' EPA's method for demonstrating that RFP requirements are met calls for : 1 . Developing a 2002 base year inventory for a nonattainment area; 2 . Adjusting that inventory to subtract emissions reductions determined to be non-creditable; 3. Establishing a target level of emissions for 2008 that reflects the required 15% reduction fromthe adjusted base year inventory; 4 . Developing a projected inventory of VOCand NOx emissions for 2008; and 5 . Demonstrating that the projected 2008 emissions of NOx, VOCor a combination of NOx and VOCwill 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 oftypical summer day Rhode Island anthropogenic emissions of VOC and NOx for the 2002 base year were obtained fromthe 2002 Emissions Inventory discussed ' Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Targetfor the 15 Percent Rate ofProgress Plans, U.S. EPA, Office of Air Quality Planning and Standards, EPA452lR-92-005, October 1992.in Section 2 and attached as Appendix 2A . That inventory does not include organic compounds that are excluded fromthe EPAdefinition of "VOC ." Pursuant to EPA's RFP methodology, for the purpose ofthe RFP, RI DEM adjusted this inventory by subtracting fromthe VOCand NOx base year emissions non-creditable emissions reductions, which are those realized fromthe pre-1990 federal limits on the Reid Vapor Pressure (RVP) of gasoline (RVP of 9 .0) and the Federal Motor Vehicle Control Program (FMVCP) .2 Consistent with EPAguidance, non-creditable emissions reductions of VOC and NOx were calculated 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 actual 2002 emissions butwith 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 for 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 were calculated by subtracting the 2008 emissions factors calculated in Step 2 fromthe 2002 factors calculated in Step 1 and multiplying the difference by 2002 VMT. Non-creditable emissions calculated by this method are 5.51 tpsd VOCand 3.19 tpsd NOx. Non-creditable emissions calculations are shown in Appendix 4A . In addition the 2002 Base Year Inventory was modified to account for 700 tons per year (1 .9 tpsd) of VOCEmissions Reduction Credits (ERCs) which were generated when Quebecor Printing Providence ceased operations on December 31, 1998 and which were subsequently sold/transferred to the Rhode Island Resource Recovery Corporation (RIRRC) the owner/operator ofthe Central Landfill . DEM approved this transfer in January of 2002. Table 4-1 shows the 2002 Base Year and Adjusted Base Year Inventories of NOx and VOC, in tons per summer day

z The CAA (Section 182(b)(1)(D)) provides that reductions fromthe following measures are not creditable toward the required reductions: (1) Federal 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 nonattainment areas issued by June 15, 1990 ; (3) State regulations correcting deficiencies in reasonably available control technology (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.SOURCE TYPE 2002 Base Year VOC 2002

Adjusted VOC 2002 Base

Year NOx 2002 Adjusted

NOx Stationa ry Point 10.3 48 :312 .2 7.0 7.0 Stationary Nonp oint 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 4-1-1:,8113.7 72.5 69.3

4.4 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 Table 4-2. The reductions can be VOCs, NOx or any combination of both. RI DEM is establishing its target levels based on a 15%

reduction in NOx emissions. The 2008 Target Levels and resultant required emissions reductions were calculated as follows: 

### NOx : Required Emissions Reductions = 2002 Adjusted Emissions (69 .3 tpsd) X 0

.15 = 10

.4 tpsd 2008 Target = 2002 Adjusted Emissions (69.3 tpsd) - Required Reductions (10 .4 tpsd) _ 58.9 tpsd 

### VOC

~ Required Emissions Reductions = 2002 Adjusted Emissions (444-.8113.7 tpsd) X 0 .00 = 0 .0 tpsd 2008 Target = 2002 Adjusted Emissions (11-1-8113.7 tpsd) - Required Reductions (0.0 ( tpsd) = 111 :8 113.7 tpsd 4 .5 2008 Projected Emissions Inventory Table 4-1 Rhode Island Base Year and Ad'usted Base Year Emissions ( sd)

Projected emissions in 2008 were calculated by estimating anticipated growth in emissions between 2002 and 2008 and then adjusting for any controls that will reduce emissions during that time period. Calculations of the projected 2008 inventory arediscussed in Section 2.2 of this document . As with the 2002 Base Year Inventory, the

2008 projected inventory was adjusted to account for the 1 .9 tpsd of VOC ERCs which were generated when Quebecor Printing Providence closed and which were subsequently sold/transferred to the RIRRC . Those emissions were not accounted for in RIRRC's 2008 emissions projections. 4.6 Results of RFPAnalysis The 2008 projections are shown in Table 4-2 below . Reductions anticipated by 2008 are compared to the reductions required to meet RFP . As shown, projected 2008 VOC emissions in Rhode Island are 1 .5%(1 .7 tons per day) higher than the target level . 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; therefore 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 the non-road and on-road mobile sectors. Note that the 2008 on-road mobile emissions of VOCand 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."Table 4-2 RFPCalculations VOC (t sd NOx t sd 2002 RFP 2008 2002 RFP 2008 Emissions Invento ry Invento

ry Invento

ry Inventory Stationa ry Point 40 :312 .2 a-1 :-A12.9 7.0 7.3 Stationa ry 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 44-1 :9113.7 11-3-5 115.4 69.3 55.3 2008 RFPTarg

et Emissions 444- :8113.7 58.9 Predicted 2002-2008 (1 .67) tpsd 13 .9 tpsd Emissions Reductions (1 .45%) of 2002 RFP (20.1% of 2002 RFP inventory) Increases invento ry) Required 2002-2008 0 .0 tpsd 10.4 tpsd Emissions Reductions (0.0% of 2002 RFP inventory) (15 .0%of 2002 RFP inventory) Excess Emissions (1 .7) tpsd 3.5 tpsd 

### Reductions (1 .5%) of 2002 RFP (5.1 % of 2002 RFP inventory) inventory) 2008 RFPTarget NOx 57.8 tpsd Emissions Adjusted to (16.5% reduction from2002 Account for Increase in RFP inventory) VOCEmissions Required Emissions Reductions Adjusted to 11 .4 tpsd Account for Increase in (16.5% of 2002 RFP inventory) VOC Emissions 

### Excess Emissions Reductions Adjusted to 2.5 tpsd Account for Increase in (3 .6% of 2002 RFP inventory) VOC Emissions