40'~ 

RHODE ISLAND 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

235 Promenade Street, Providence, R102908-5767 TDD 401-222-4462 

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 4 address 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 of VOC/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 from NOx, 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 review of the 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 

IL 4% 0 30% post-consumer fiber 
4.0 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 VOC and 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 VOC and 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 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 the 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.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 from the adjusted base year inventory; 

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

5 . Demonstrating that the projected 2008 emissions 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 Island anthropogenic emissions of VOC and 

NOx for the 2002 base year were obtained from the 2002 Emissions Inventory discussed 

' 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 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 from the EPA definition of "VOC." Pursuant to EPA's 

RFP methodology, for the purpose of the RFP, RI DEM adjusted this inventory by 

subtracting from the VOC and NOx base year emissions non-creditable emissions 

reductions, which are those realized 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).2 Consistent with EPA guidance, 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 from 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 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 of the 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 from the 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 

Non point 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 are 
discussed 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 RFP Analysis 

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 

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." 
Table 4-2 RFP Calculations 

VOC ( sd NOx sd 

2002 RFP 2008 2002 REP 2008 

Emissions Inventory Inventory Inventory Inventory 

Stationary Point 12.2 12 .9 7.0 7.3 

Stationary Non point 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 Target 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 inventory) 

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 from 2002 

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 Emissions 
4.0 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 VOC and 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 VOC and 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 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 the 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.' 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 from the adjusted base year inventory; 

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

5. Demonstrating that the projected 2008 emissions 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 Island anthropogenic emissions of VOC and 

NOx for the 2002 base year were obtained from the 2002 Emissions Inventory discussed 

' 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 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 from the EPA definition of "VOC." Pursuant to EPA's 

RFP methodology, for the purpose of the RFP, RI DEM adjusted this inventory by 

subtracting from the VOC and NOx base year emissions non-creditable emissions 

reductions, which are those realized 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).2 Consistent with EPA guidance, 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 from 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 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 

(RIRRC) the owner/operator of the 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 from the 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 48:312 .2 7.0 7.0 

Stationary 

Non point 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-.8 113 .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 are 
discussed 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 RFP Analysis 

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 

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." 
Table 4-2 RFP Calculations 

VOC (t sd NOx t sd 

2002 RFP 2008 2002 RFP 2008 

Emissions Inventory Inventory Inventory Inventory 

Stationary Point 40:312 .2 a-1:-A12.9 7.0 7.3 

Stationary Non point 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 RFP Target 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 inventory) 

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 from 2002 

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 Emissions