Identification and Evaluation of 

Candidate Control Measures 

Draft Final 

Technical Support Document

Prepared for: 

Ozone Transport Commission (OTC) 

444 North Capitol Street, NW, Suite 638 

Washington, DC 20001 

(202) 508-3840 

Prepared by: 

MACTEC Federal Programs, Inc. 

560 Herndon Parkway, Suite 200 

Herndon, VA 20170 

(703) 471-8383 

February 13, 2007 

______________________ ______________________ 

Edward Sabo Douglas A. Toothman 

Principal Scientist Principal Engineer 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Page i 

Table of Contents 

1.0 EXECUTIVE SUMMARY ................................................................................................. 1-1

2.0 INTRODUCTION................................................................................................................ 2-1

3.0 VOC ANALYSIS METHODS............................................................................................ 3-1

3.1 ADHESIVES, SEALANT, ADHESIVE PRIMER, AND SEALANT PRIMER

APPLICATION ....................................................................................................................... 3-1 

3.1.1 Existing Federal and State Rules............................................................................. 3-1

3.1.2 Description of the OTC 2006 Model Rule ............................................................... 3-2

3.1.3 Emission Benefit Analysis Methods......................................................................... 3-3

3.1.4 Cost Estimates.......................................................................................................... 3-4

3.2 CUTBACK AND EMULSIFIED ASPHALT PAVING.............................................. 3-4 

3.2.1 Existing Federal and State Rules............................................................................. 3-5

3.2.2 Description of the OTC 2006 Model Rule ............................................................... 3-5

3.2.3 Emission Benefit Analysis Methods......................................................................... 3-7

3.2.4 Cost Estimates.......................................................................................................... 3-7

3.3 CONSUMER PRODUCTS.......................................................................................... 3-7 

3.3.1 Existing Federal and State Rules............................................................................. 3-8

3.3.2 Description of the OTC 2006 Model Rule ............................................................... 3-8

3.3.3 Emission Benefit Analysis Methods....................................................................... 3-10

3.3.4 Cost Estimates........................................................................................................ 3-11

3.4 PORTABLE FUEL CONTAINERS.......................................................................... 3-11 

3.4.1 Existing Federal and State Rules........................................................................... 3-12

3.4.2 Description of the OTC 2006 Model Rule ............................................................. 3-13

3.4.3 Emission Benefit Analysis Methods....................................................................... 3-13

3.4.4 Cost Estimates........................................................................................................ 3-15

3.5 REGIONAL FUELS.................................................................................................. 3-15 

3.5.1 Existing Federal and State Rules........................................................................... 3-15

3.5.2 Description of the OTC 2006 Control Measure .................................................... 3-16

3.5.3 Emission Benefit Analysis Methods....................................................................... 3-16

3.5.4 Cost Estimates........................................................................................................ 3-16

3.6 VOC EMISSION REDUCTION SUMMARY.......................................................... 3-16 

4.0 NOX ANALYSIS METHODS............................................................................................ 4-1

4.1 HEAVY-DUTY TRUCK DIESEL ENGINE CHIP REFLASH..................................4-1 

4.1.1 Existing Federal and State Rules............................................................................. 4-1

4.1.2 Description of the OTC 2006 Control Measure ...................................................... 4-2

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4.1.3 Emission Benefit Analysis Methods......................................................................... 4-2

4.1.4 Cost Estimates.......................................................................................................... 4-2

4.2 REGIONAL FUELS.................................................................................................... 4-3 

4.2.1 Existing Federal and State Rules............................................................................. 4-3

4.2.2 Description of the OTC 2006 Control Measure ...................................................... 4-3

4.2.3 Emission Benefit Analysis Methods......................................................................... 4-3

4.2.4 Cost Estimates.......................................................................................................... 4-4

4.3 ASPHALT PAVEMENT PRODUCTION PLANTS .................................................. 4-4 

4.3.1 Existing Federal and State Rules............................................................................. 4-4

4.3.2 Description of the OTC 2006 Control Measure ...................................................... 4-4

4.3.3 Emission Benefit Analysis Methods......................................................................... 4-5

4.3.4 Cost Estimates.......................................................................................................... 4-6

4.4 CEMENT KILNS......................................................................................................... 4-6 

4.4.1 Existing Federal and State Rules............................................................................. 4-7

4.4.2 Description of the OTC 2006 Control Measure ...................................................... 4-7

4.4.3 Emission Benefit Analysis Methods......................................................................... 4-8

4.4.4 Cost Estimates.......................................................................................................... 4-9

4.5 GLASS/FIBERGLASS FURNACES.......................................................................... 4-9 

4.5.1 Existing Federal and State Rules............................................................................. 4-9

4.5.2 Description of the OTC 2006 Control Measure ...................................................... 4-9

4.5.3 Emission Benefit Analysis Methods....................................................................... 4-10

4.5.4 Cost Estimates........................................................................................................ 4-11

4.6 ICI BOILERS............................................................................................................. 4-11 

4.6.1 Existing Federal and State Rules........................................................................... 4-12

4.6.2 Description of the OTC 2006 Control Measure .................................................... 4-12

4.6.3 Emission Benefit Analysis Methods....................................................................... 4-14

4.6.4 Cost Estimates........................................................................................................ 4-21

4.7 NOX EMISSION REDUCTION SUMMARY .......................................................... 4-21 

5.0 REFERENCES..................................................................................................................... 5-1

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List of Appendices 

Appendix A – Process for Identifying and Evaluating Control Measures 

Appendix B – Initial List of Control Measures 

Appendix C – Control Measures Summary Sheets 

Appendix D – VOC Emissions by County for 2002 and 2009 

Appendix E – NOx Emissions by County for 2002 and 2009 

Appendix F – ICI Boiler Regulations by State 

List of Figures 

List of Tables Page

1-1 VOC Emission Reduction Benefits from OTC 2006 Control Measures ............. 1-7 

1-2 NOx Emission Reduction Benefits from OTC 2006 Control Measures.............. 1-8 

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List of Tables 

List of Tables Page

1-1 Summary of OTC 2006 Control Measures .......................................................... 1-3 

1-1 Estimated Emission Reduction Benefits in 2099 by State................................... 1-6 

3-1 Summary of OTC State Rules for Cutback and Emulsified Asphalt................... 3-8 

3-2 Status of OTC State’s Promulgation of the OTC 2001 Model Rule for 

Consumer Products ............................................................................................ 3-10 

3-3 Consumer Products Affected by CARB’s July 2005 Rule Amendments.......... 3-11 

3-4 Status of OTC State’s Promulgation of the OTC 2001 Model Rule for 

Portable Fuel Containers.................................................................................... 3-14 

3-5 OTC 2006 VOC Model Rule Benefits by State for 2009: 

 Adhesives and Sealants Application.................................................................. 3-20 

3-6 OTC 2006 VOC Model Rule Benefits by State for 2009: 

 Cutback and Emulsified Asphalt Paving ........................................................... 3-21 

3-7 OTC 2006 VOC Model Rule Benefits by State for 2009: 

 Consumer Products ............................................................................................ 3-22 

3-8 OTC 2006 VOC Model Rule Benefits by State for 2009: 

 Portable Fuel Containers.................................................................................... 3-23 

3-9 OTC 2006 VOC Model Rule Benefits by State for 2009: 

 Regional Fuels ................................................................................................... 3-24 

3-10 OTC 2006 VOC Model Rule Benefits by State for 2009: 

 All Five VOC Categories................................................................................... 3-25 

4-1 OTC Resolution 06-02 Emission Guidelines for Asphalt Plants......................... 4-5 

4-2 OTC Resolution 06-02 Emission Guidelines for Cement Kilns.......................... 4-8 

4-3 OTC Resolution 06-02 Emission Guidelines for Glass Furnaces...................... 4-10 

4-4 OTC Proposal for ICI Boilers............................................................................ 4-12 

4-5 Current State Emission Limits and Percent Reduction for OTC Proposal 

 Point Source Natural Gas-fired Boilers ............................................................. 4-14 

4-6 Current State Emission Limits and Percent Reduction for OTC Proposal 

 Point Source Distillate Oil-fired Boilers............................................................ 4-15 

4-7 Current State Emission Limits and Percent Reduction for OTC Proposal 

 Point Source Residual Oil-fired Boilers ............................................................ 4-16 

4-8 Current State Emission Limits and Percent Reduction for OTC Proposal 

 Point Source Coal Wall-fired Boilers ................................................................ 4-17 

4-9 Current State Emission Limits and Percent Reduction for OTC Proposal 

 Point Source Coal Tangential-fired Boilers....................................................... 4-18 

4-10 Current State Emission Limits and Percent Reduction for OTC Proposal 

 Point Source Coal-fired Stoker Boilers.............................................................. 4-19 

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List of Tables (continued) 

List of Tables Page

4-11 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 Heavy-Duty Truck Diesel Engine Chip Reflash................................................ 4-22 

4-12 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 Regional Fuels ................................................................................................... 4-23 

4-13 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 Asphalt Pavement Productio Plants................................................................... 4-24 

4-14 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 Cement Kilns ..................................................................................................... 4-25 

4-15 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 Glass/Fiberglass Furnaces.................................................................................. 4-26 

4-16 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 ICI Boilers – Area (minor) Sources................................................................... 4-27 

4-17 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 ICI Boilers – Point (major) Sources................................................................... 4-28 

4-18 OTC 2006 NOx Model Rule Benefits by State for 2009: 

 All Seven NOx Categories................................................................................. 4-29 

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Acronyms and Abbreviations 

Acronym Description 

BOTW Beyond-on-the-Way – refers to additional emission controls that are 

being considered 

CAIR Clean Air Interstate Rule 

EGAS 5.0 Economic Growth Analysis System Version 5.0 

EGU Electric Generating Unit 

EPA U.S. Environmental Protection Agency 

IPM Integrated Planning Model 

MANE-VU Mid-Atlantic/Northeast Visibility Union 

MARAMA Mid-Atlantic Regional Air Management Association 

MOBILE6 U.S. EPA’s emission model for onroad sources 

NESCAUM Northeast States for Coodinated Air Use Management 

NH3 Ammonia 

NIF3.0 National Emission Inventory Input Format Version 3.0 

NONROAD U.S. EPA’s emission model for certain types of nonroad equipment 

NOx Oxides of nitrogen 

OTB/W On-the-Books/On-the-Way – refers to emission control programs 

already adopted and proposed emission controls that will result in 

post-2002 emission reductions 

OTC Ozone Transport Commission 

OTC 2001 model rules Model rules developed by the OTC in 2001 

OTC 2006 model rules Model rules developed by the OTC in 2006 

PM10-PRI Particulate matter less than or equal to 10 microns in diameter that 

includes both the filterable and condensable components of 

particulate matter 

PM25-PRI Particulate matter less than or equal to 2.5 microns in diameter that 

includes both the filterable and condensable components of 

particulate matter 

SIC Standard Industrial Classification code 

SIP State Implementation Plan 

SCC Source Classification Code 

SO2 Sulfur dioxide 

VOC Volatile organic compounds 

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Section 1 – Executive Summary Page 1-1 

1.0 EXECUTIVE SUMMARY 

The States of the Ozone Transport Region (OTR) are faced with the requirement to submit 

attainment demonstration plans for the 8-hour ozone National Ambient Air Quality Standards 

(NAAQS). To accomplish this, most of the states will need to implement additional measures to 

reduce emissions that either directly impact their nonattainment status, or contribute to the 

nonattainment status in other states. As such, the Ozone Transport Commission (OTC) 

undertook an exercise to identify a suite of additional control measures that could be used by the 

OTR states in attaining their goals. 

The OTC staff and member states formed several workgroups to identify and evaluate candidate 

control measures. Initially, the Workgroups compiled and reviewed a list of approximately 

1,000 candidate control measures. These control measures were identified through published 

sources such as the U.S. Environmental Protection Agency’s (EPA’s) Control Technique 

Guidelines, STAPPA/ALAPCO “Menu of Options” documents, the AirControlNET database, 

emission control initiatives in member states as well as other states including California, 

state/regional consultations, and stakeholder input. The Workgroups developed a preliminary 

list of 30 candidate control measures to be considered for more detailed analysis. These 

measures were selected to focus on the pollutants and source categories that are thought to be the 

most effective in reducing ozone air quality levels in the Northeastern and Mid-Atlantic States. 

The Workgroups discussed the candidate control measures during a series of conference calls 

and workshops held periodically from the spring of 2004 through the autumn of 2006. The 

Workgroups collected and evaluated information regarding emission benefits, cost-effectiveness, 

and implementation issues. Each of the candidate control measures were summarized in a series 

of “Control Measure Summary Sheets”. Stakeholders were provided multiple opportunities to 

review and comment on the Control Measure Summary Sheets. 

Based on the analyses by the OTC Workgroups, the OTC Commissioners made several 

recommendations at the June 2006 Commissioners’ meeting in Boston (OTC 2006a-d) and at the 

November 2006 Commissioners’ meeting in Richmond (OTC 2006e-g). The Commissioners 

recommended that States consider emission 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 

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• Glass Furnaces 

• Industrial, Commercial, and Institutional (ICI) Boilers 

• Regional Fuels 

•

Additionally, the Commisioners directed the OTC to evaluate control measures for Electric 

Generating Units (EGUs) and high electric demand day units (these measures will be addressed 

in a separate OTC report) Finally, the Commissioners requested that EPA pursue federal 

regulations and programs designed to ensure national development and implementation of 

control measures for the following categories: architectural and maintenance coatings, consumer 

products, ICI boilers over 100 mmBtu/hour heat input, portable fuel containers, municipal waste 

combustors, regionally consistent and environmentally sound fuels, small offroad engine 

emission regulation, and gasoline vapor recovery (OTC 2006d). 

See Appendix A for a full description of the process used by the OTC to identify and evaluate 

candidate control measures. 

Table 1-1 summarizes information about the control measures identified by the OTC 

Commissioners at the June 2006 and November OTC meetings. Table 1-1 identifies the sector, 

the source category, and a brief description of the control measure. Next is a column that 

identifies the recommended approach for implementing the rule, such as an OTC model rule or 

updates to existing state-specific rules. The next two columns show the percent reduction from 

2009 emission levels. The final column provides the cost effectiveness estimate in units of 

dollars per ton of pollutant removed. 

Table 1-2 summarizes the expected emission reductions by pollutant, control measure and State. 

The emission reductions listed in Table 1-2 are for 2009, and take into account only the 

incremental reductions from the control measures listed in Table 1-1. Figures 1-1 and 1-2 show 

the anticipated emission reductions by state for VOC and NOx, respectively. 

 
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Table 1-1 Summary of OTC 2006 Control Measures

Sector Source Category Control Measure 

Implementation Method 

Percent Reducti

from 2009 OTB/

Emission Level

NOx VOC 

Area Adhesives, Sealants, 

Adhesive Primers, and Sealant Primers (Industrial) 

Enact VOC content limits similar to those contained in the CARB RACT/BARCT document for adhesives and sealants (Dec. 1998) 

Model Rule --- 64 

Area Cutback and 

Emulsified Asphalt Paving 

Prohibits the use of cutback asphalt furing the ozone season Limits the use of emulsified asphalt during the ozone season to that which contains not more than 0.5 mL of oil distillate from a 200 mL sample as determined using ASTM Method D244 

State Rule Update --- Stat

speci

depend

on cur

rule

Area Consumer Products Adopt the CARB 7/20/05 Amendments which sets 

new or revises existing VOC limits on 12 consumer product categories (does not include reductions for Tier2 shaving gels and antistatic aerosols since they have a later compliance date). 

Model Rule --- 2 

Area Portable Fuel 

Containers 

Adopt the CARB 2006 Amendments broadening the definition of PFCs to include kerosene and diesel containers and utility jugs used for fuel, and other changes to make OTC Model Rule consistent with CARB requirements. 

Model Rule --- Stat

speci

Area and Point 

Asphalt Production Plants 

Area/Point Sources (>25 MMBtu/hr)  Batch Natural Gas 0.02 lb/ton  Batch Distillate 0.09 lb/ton  Drum Natural Gas 0.02 lb/ton  Drum Distillate 0.04 lb/ton Area/Point Sources (<25 MMBtu/hr):  Low NOx Burner technology, or  Best Management Practices, and annual tune-up 

State Rule Update 10 - 35 --- 

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Sector Source Category Control Measure 

Implementation Method 

Percent Reducti

from 2009 OTB/

Emission Level

NOx VOC 

Area and Point 

Industrial/ Commercial/ Institutional (ICI) Boilers >250 mmBtu/hour 

Option 1 – Purchase current year NOx allowances equal to reductions needed to achieve the required emission rates Option 2 – Phase I 2009 emission rate equal to EGUs of similar size; Phase II 2013 emission rate equal to EGUs of similar size 

Model Rule Boiler 

and 

State 

specific 

--- 

Area and Point 

ICI Boilers 100-250 mmBtu/hour 

NOx Strategy #1:  Nat gas: 0.10 lb/mmBtu  #2, #4, $6 Oil: 0.20 lb/mmBtu  Coal: 0.08 to 0.22 lb/mmBtu, depending on  boiler type NOx Strategy #2:  Reductions achievable through  LNB/SNCR, LNB/FGR, SCR or some  combination of these controls NOx Strategy #3:  60% reduction from uncontrolled NOx Strategy #4:  Purchase current year CAIR allowances 

State Rule Update Boiler 

and 

State 

specific 

--- 

Area and Point 

ICI Boilers 25-100 mmBtu/hour 

NOx Strategy #1:  Nat gas: 0.05 lb/mmBtu  #2 Oil: 0.08 lb/mmBtu  #4, #6 Oil: 0.20 lbs/mmBtu  Coal: 0.30 lb/mmBtu NOx Strategy #2:  50% reduction from uncontrolled NOx Strategy #3:  Purchase current year CAIR allowances

State Rule Update Boiler 

and 

State 

specific 

--- 

Area and Point 

ICI Boilers <25 mmBtu/hour 

Annual boiler tune-up State Rule Update State 

specific 

--- 

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Sector Source Category Control Measure 

Implementation Method 

Percent Reducti

from 2009 OTB/

Emission Level

NOx VOC 

Point Glass Furnaces Require furnace operators to meet the emission 

limits in the San Joaquin Valley rule by 2009. These limits are achievable through implementation of “oxyfiring” technology for each furnace at furnace rebuild. If the operator does not rebuild the furnace by 2009 or implement measures to meet the limits in the San Joaquin Valley rule, the operator would be required to purchase NOx allowances equal to the difference between actual emissions and the limits in the San Joaquin Valley rule. Compliance with Rule 4354 will allow manufactures to use a mix of control options to meet the suggested limits. Manufacturers may propose alternative compliance methods to meet the specified limits, including emissions averaging. 

State Rule or Permit 

Source 

specific 

--- 

Point Cement Plants Require existing kilns to meet a NOx emission rate 

of 

3.88 lbs/ton clinker for wet kiln 3.44 lbs/ton clinker for long dry kiln 2.36 lbs/ton clinker for pre-heater kiln 1.52 lbs/ton clinker for pre-calciner kiln 

State Rule Update Source 

specific 

--- 

Onroad Mobile 

Diesel Truck Chip Reflash 

Mandatory program to upgrade the version of software in engine electronic control module (ECM), (also known as “chip reflash) to reduce offcycle NOx emissions. 

Model Rule 10 --- 

Onroad Mobile 

Regional Fuel based on Reformulated Gasoline Options 

Extend RFG requirements to counties in OTC that currently do not have RFG. 

Memorandum of Understanding - OTC 

State 

specific 

Stat

speci
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Table 1-2 Estimated Emission Benefits in 2009 by State 

Resulting from the OTC 2006 Control Measures State

VOC Emission Reduction Benefit 

(summer tpd)

NOx Emission Reduction Benefit 

(summer tpd)

State 

Adhesives & Sealants Cutback\Emulsified Asphalt Paving Consumer Products Portable Fuel Conatiners (PFCs) aRegional Fuels Total VOC Reduction Diesel Engine Chip Reflash Regional Fuels Asphalt Production Cement Kilns Glass/FiberglassbICI Boilers Area Sources ICI Boilers Point Sources Total NOx Reduction 

CT 4.2 4.3 0.7 0.4 0.0 9.6 3.5 0.0 0.0 0.0 0.0 2.8 2.1 8.4

DE 1.0 0.0 0.1 0.1 0.0 1.3 0.6 0.0 0.2 0.0 0.0 1.2 0.1 2.1

DC 0.1 0.0 0.1 0.1 0.0 0.4 0.8 0.0 0.0 0.0 0.0 0.4 0.4 1.6

ME 2.5 10.6 0.2 0.1 9.1 22.6 1.4 0.2 0.7 0.0 0.0 1.1 2.8 6.2

MD 5.8 0.0 1.0 1.4 3.2 11.4 5.6 0.0 0.1 13.1 0.3 1.2 2.4 22.7

MAd 8.9 8.1 10.2 1.7 0.0 28.8 6.7 0.0 0.6 0.0 1.5 6.6 6.8 22.2

NH 2.3 4.4 0.3 0.2 4.3 11.4 2.0 0.2 0.0 0.0 0.0 3.4 1.9 7.5

NJ 9.2 4.7 1.4 1.0 0.0 16.4 9.7 0.0 1.0 0.0 4.9 0.0 3.4 19.0

NY 21.5 16.4 3.7 2.6 56.9 101.1 16.1 2.1 0.0 15.3 5.8 33.8 7.0 80.1

PA 21.9 8.4 2.1 1.6 58.0 91.9 12.4 2.0 0.2 13.0 24.3 12.2 9.8 73.9

RI 1.5 1.1 0.2 0.2 0.0 3.0 0.8 0.0 0.0 0.0 0.5 2.1 0.5 3.9

VT 2.2 1.8 0.1 0.1 7.9 12.1 0.9 0.3 0.0 0.0 0.0 0.9 0.4 2.5

No. 

VAc 1.0 <0.1 0.5 0.4 0.0 1.8 2.5 0.0 0.1 0.0 0.0 3.9 0.1 6.6

OTR 82.3 59.8 20.5 9.9 139.4 311.8 63.0 4.8 3.0 41.4 37.3 69.5 37.7 256.7

a) The table shows the estimated emission reduction that will occur in 2009; additional reductions will occur in 

later years as new, less-emitting PFCs that comply with the OTC 2006 control measure penetrate the market. 

b) The table show the maximum emission reduction from glass/fiberglass furnaces when the OTC 2206 control 

measure is fully implemented. No all of the reduction shown will be achieved by 2009. 

c) The following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, Fairfax County, 

Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County. 

d) MA proposed rule has a January 1, 2009 effective date and includes the VOC limits from the OTC 2001 model 

rule and those in the OTC 2006 model rule. The 2009 benefit MA shows the benefit from both sets of limits. 

For all other States, the 2009 benefit shows the change in emissions from the OTC 2006 model rule only. 
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Section 1 – Executive Summary Page 1-7 

Figure 1-1 VOC Emission Reduction Benefits from OTC 2006 Control Measures in 200

0

102030405060708090

100110

CT DE DC ME MD MA NH NJ NY PA R

VOC Reduction (tpsd)

Regional FuelPortable Fuel ContainersConsumer ProductsAsphalt PavingAdhesives

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Figure 1-2 NOx Emission Reduction Benefits from OTC 2006 Control Measures in 200

Draft TSD for 2Section 1

0

102030405060708090

CT DE DC ME MD MA NH NJ NY PA R

NOx Reduction (tpsd)

ICI Boiler (Point)ICI Boiler (Area)Glass FurnacesCement KilnsAsphalt PlantsChip ReflashRegional Fuel
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Section 2 – Introduction Page 2-1 

2.0 INTRODUCTION 

The Ozone Transport Commission (OTC) is a multi-state organization created under the Clean Air Act 

(CAA). The OTC is responsible for advising EPA on transport issues and for developing and 

implementing regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic 

regions. To supplement local and state-level efforts to reduce ozone precursor emissions, which may 

not alone be sufficient to attain federal standards, the OTC member states are considering control 

measures appropriate for adoption by all states in the region as part of their planning to attain and 

maintain the 8-hour ozone National Ambient Air Quality Standards (NAAQS). 

The development of the control measures described in this document parallels a prior effort. The OTC 

developed a series of model rules in 2001 for the States to consider in adopting control measures to 

reduce volatile organic compound (VOC) emissions and oxide of nitrogen (NOx), which are ozone 

precursors, to (1) assist in the attainment of the one-hour ozone health standard, (2) address the VOC 

and NOx emission reduction shortfalls identified by EPA, and (3) implement the State Implementation 

Plans (SIP) commitments to EPA. These model rules, which have been adopted in many OTC states, 

will be referred to as the “OTC 2001 model rules” in this document. 

The analysis in this report provides a description of the control measures identified by the OTC to help 

states attain the 8-hour ozone NAAQS. It also describes the associated incremental emission 

reductions and costs associated with each measure. The control measures analyzed in this report are 

those that were identified by the OTC Commissioners at the June 2006 OTC annual meeting in Boston 

(OTC 2006a, OTC 2006b, OTC 2006c) and at the November 2006 OTC fall meeting in Richmond 

(OTC 2006d, OTC 2006e, OTC 2006f). These control measures will be referred to as the “OTC 2006 

control measures” in this document. For some source categories, the OTC has amended the OTC 2001 

model rules or developed new model rules. These model rules will be referred to as the “OTC 2006 

model rules” in this document. 

The OTC 2006 model rules for volatile organic compounds (VOC) will reduce emissions from 

adhesives, sealants, adhesive primer, and sealant primer application; cutback and emulsified asphalt 

paving; consumer products; regional fuels; and portable fuel containers. The OTC 2006 control 

measures for oxides of nitrogen (NOx) will reduce emissions from asphalt production plants, cement 

kilns, diesel engine chip reflash, regional fuels, electric generating units (EGUs), glass and fiberglass 

furnaces, and industrial, commercial, institutional (ICI) boilers. 

Section 3 describes the methods used to estimate the emission benefits of the VOC control measures. 

For each source category, there are subsections that describe the existing Federal and OTC State 

regulations that affect the VOC emissions, summarize the major elements of the control measures, 

discuss how the emission benefits were quantified, and present information on anticipated costs and 

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Section 2 – Introduction Page 2-2 

cost-effectiveness. VOC emissions and reductions by State and source category in 2002 and 2009 are 

presented at the end of Section 3. Section 4 presents similar information for the NOx source 

categories. Section 5 presents similar information for the SO2 source categories. Section 6 provides a 

list of references used in developing this report. 

Appendix A presents a brief decscription of the process that the OTC followed in identifying and 

evaluating candidate control measures. Appendix B lists the approximately 1,000 control measures 

that were initially analyzed. Appendix C contains the control measure summary sheets that were 

developed during this analysis. Appendices D, E, and F present the emission benefits by county for 

VOC, NOx, and SO2 respectively. Each appendix contains a tabulation of the 2002 base emissions, 

the projected 2009/2012/2018 emissions and expected emission reduction benefit from the additional 

control measures in 2009/2012/2018). Appendix G contains a listing of State ICI boiler regulations. 

 

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Section 3 – VOC Analysis Methods Page 3-1 

3.0 VOC ANALYSIS METHODS 

This Section describes the analysis of the 2006 OTC control measures to reduce VOC emissions 

from four source categories: adhesives, sealants, adhesive primer, and sealant primer 

application; cutback and emulsified asphalt paving; consumer products; regional fuels; and 

portable fuel containers. For each of the five categories, there are separate subsections that 

discuss existing Federal/state rules, summarize the requirements of the 2006 OTC control 

measure, describe the methods used to quantify the emission benefit, and provide an estimate of 

the anticipated costs and cost-effectiveness of the control measure. At the end of Section 3, we 

provide the estimated emissions for 2002 and 2009 by source category and State. Appendix D 

provides county-by-county summaries of the emission reductions for each of the categories and 

projection years. 

3.1 ADHESIVES, SEALANT, ADHESIVE PRIMER, AND SEALANT PRIMER 

APPLICATION 

Adhesives, sealants, adhesive primer, and sealant primer are used in product manufacturing, 

packaging, construction, and installation of metal, wood, rubber, plastic, ceramics, or fiberglass 

materials. In general, an adhesive is any material used to bond two surfaces together. In general, 

a sealant is a material with adhesive properties that is used primarily to fill, seal, waterproof or 

weatherproof gaps or joints between two surfaces. 

VOC emissions from this category result from evaporation of solvents during transfer, drying, 

surface preparation and cleanup operations. These solvents are the media used to solubilize the 

adhesive, sealant, or primer material so that it can be applied. The solvent is also used to 

completely wet the surface to provide a stronger bond. In plastic pipe bonding, the solvent 

dissolves the polyvinyl chloride pipe and reacts with the pipe to form a bond. Solvents used to 

clean the surface before bonding and to clean the application equipment after bonding also 

contribute to VOC emissions. 

VOC emissions in this category are primarily from industrial and commercial operations such as 

wood product manufacturers, upholstery shops, adhesives retailers and architectural trades, such 

as building construction, floor covering installation and roof repair.

3.1.1 Existing Federal and State Rules 

EPA published the consumer and commercial products rule on September 11, 1998 (40 CFR Part 

59 Subpart D) under authority of Section 183(e) of the Clean Air Act. The Federal Part 59 

Subpart C requirements for consumer products regulate five types of “household” adhesives 

(aerosols, contact, construction and panel, general purpose and structural waterproof). The VOC 

content limits for these products apply only to “household products”, defined as “any consumer 

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product that is primarily designed to be used inside or outside of living quarters or residences, 

including the immediate surroundings, that are occupied or intended for occupation by 

individuals.” Thus, the Part 59 rule applies only to adhesives used in household settings and not 

to adhesives used in industrial or commercial applications. 

The OTC developed a model rule for consumer and commercial products in 2001 (referred to as 

the “OTC 2001 model rule for consumer products” in this document) to regulate additional 

consumer product categories by requiring more stringent VOC content limits than the Federal 

rule. The OTC 2001 model rule for consumer products contains VOC limits for adhesives and 

sealants. However, with the exception of aerosol adhesives, the definitions of these products 

generally exempt products sold in larger containers. Specifically, the OTC 2001 model rule 

includes the following definitions (italics added for emphasis): 

• Section 2(8) Adhesive. "Adhesive" means any product that is used to bond one surface 

to another by attachment. “Adhesive” does not include products used on humans and 

animals, adhesive tape, contact paper, wallpaper, shelf liners, or any other product with 

an adhesive incorporated onto or in an inert substrate. For “Contact Adhesive,” adhesive 

does not include units of product, less packaging, which consist of more than one gallon. 

For “Construction, Panel, and Floor Covering Adhesive,” and “General Purpose 

Adhesive”, adhesive does not include units of product, less packaging, which weigh more 

than one pound and consist of more than 16 fluid ounces. This limitation does not apply 

to aerosol adhesives.

• Section 2(148) Sealant and Caulking Compound. "Sealant and Caulking Compound" 

means any product with adhesive properties that is designed to fill, seal, waterproof, or 

weatherproof gaps or joints between two surfaces. “Sealant and Caulking Compound” 

does not include roof cements and roof sealants; insulating foams; removable caulking 

compounds; clear/paintable/water resistant caulking compounds; floor seam sealers; 

products designed exclusively for automotive uses; or sealers that are applied as 

continuous coatings. “Sealant and Caulking Compound” also does not include units of 

product, less packaging, which weigh more than one pound and consist of more than 16 

fluid ounces. For the purposes of this definition only, “removable caulking compounds” 

means a compound which temporarily seals windows or doors for three to six month time 

intervals, and “clear/paintable/water resistant caulking compounds” means a compound 

which contains no appreciable level of opaque fillers or pigments; transmits most or all 

visible light through the caulk when cured; is paintable; and is immediately resistant to 

precipitation upon application. 

Thus, the same products sold in containers larger than the above thresholds are not covered by 

the OTC 2001 model rule for consumer products. 

3.1.2 Description of the OTC 2006 Model Rule 

The OTC 2006 model rule for adhesives and sealants is based on the reasonably available control 

technology (RACT) and best available retrofit control technology (BARCT) determination by 

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the California Air Resources Board (CARB) developed in 1998. The OTC 2006 model rule has 

the following requirements: 

A. Regulates the application of adhesives, sealants, adhesive primers and sealant primers by 

providing options for appliers to either to use a product with a VOC content equal to or 

less than a specified limit or to use add-on controls; 

B. Limits the VOC content of aerosol adhesives to 25 percent by weight; 

C. Requirements for cleanup solvents; 

D. A VOC limit for surface preparation solvents; 

E. An alternative add-on control system requirement of at least 85 percent overall control 

efficiency (capture and destruction efficiency), by weight; 

F. VOC containing materials must be stored or disposed of in closed containers; 

G. Prohibits the sale of any adhesive, sealant, adhesive primer or sealant primer which 

exceeds the VOC content limits listed in the model rule; 

H. Manufacturers must label containers with the maximum VOC content as supplied, as well 

as the maximum VOC content on an as-applied basis when used in accordance with the 

manufacturer’s recommendations regarding thinning, reducing, or mixing with any other 

VOC containing material; and 

I. Prohibits the specification of any adhesive, primer, or sealant that violates the provisions 

of the model rule. 

Several adhesive and sealant applications and products are exempt from this model rule: tire 

repair, assembly and manufacturing of undersea-based weapon systems, testing and evaluation 

associated with research and development, solvent welding operations for medical devices, 

plaque laminating operations, products or processes subject to other state rules, low-VOC 

products (less than 20 g/l), and adhesives subject to the state rules based on the OTC 2001 

consumer products model rule. Additionally, the model rule provides an exemption for adhesive 

application operations at stationary sources that use less than 55 gallons per calendar year of 

noncomplying adhesives and for stationary sources that emit not more than 200 pounds of VOCs 

per year from adhesives operations.

3.1.3 Emission Benefit Analysis Methods 

Emissios from this category are classified as both point sources and area sources. About 96 

percent of adhesive and sealant VOC emissions in the OTC states fall into the area source 

category. The remaining four percent of the VOC emissions are included in the point source 

inventory. 

The emission reduction benefit estimation methodology for area sources is based on information 

developed and used by CARB for their RACT/BARCT determination in 1998. CARB estimates 

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that the total industrial adhesive and sealant emissions in California to be about 45 tons per day 

(tpd). Solvent-based emissions are estimated to be about 35 tpd of VOC and water-based 

adhesive and sealant emissions are about 10 tpd of VOC. CARB indicated that the emission 

reductions would be achieved mainly due to the switch from high-VOC to low-VOC products 

rather than from the use of add-on control devices. CARB estimated that emission reductions 

achieved by statewide compliance with the VOC limits in the RACT/BARCT determination will 

range from approximately 29 to 35 tpd (CARB 1998, pg. 18). These emission reductions 

correspond to a 64.4 to 77.8 percent reduction from uncontrolled levels. For OTC modeling 

purposes, we used the lower end of this range (i.e., 64.4 percent reduction) to estimate the 

emission benefit for area sources due to the OTC 2006 model rule. 

For point sources, we first identified those sources that were applying adhesives and sealants 

(using the source classification code of 4-02-007-xx, adhesives application). Next, we reviewed 

the MANEVU inventory to determine whether sources had existing capture and control systems. 

Several sources reported capture and destruction efficiencies in the 70 to 99 percent range. A 

few sources reported capture and destruction efficiencies of 99+ percent. Most of the controlled 

sources reported capture and destruction efficiencies in the 90-98 percent range. Sources with 

existing control systems that exceed an 85 percent overall capture and destruction efficiency 

would meet the OTC 2006 model rule provision for add-on air pollution control equipment; no 

additional reductions were calculated for these sources. For point sources without add-on control 

equipment, we used the 64.4 percent reduction discussed in the previous paragraph based on the 

CARB determination. 

3.1.4 Cost Estimates 

The cost of complying with the new requirements includes the cost of using alternative 

formulations of low-VOC or water-based adhesives, sealants, adhesive primers, and sealant 

primers and cleanup products. Based on information provided by the Ventura County Air 

Pollutio Control District, CARB determined that the cost-effectiveness of their adhesives rule 

ranges from a savings of $1,060 per ton to a cost of $2,320 per ton of VOC reduced (CARB 

1998, pg. 17). These costs are likely to be less in the OTR, because some of the one-time 

research and reformulation costs incurred for products sold in California will not have to be 

incurred again for products sold in the OTR. CARB also reports a cost-effectiveness of $9,000 

to $110,000 per ton of VOC reduced for the use of add-on control equipment to comply with the 

requirements.

3.2 CUTBACK AND EMULSIFIED ASPHALT PAVING 

Asphalt paving is used to pave, seal and repair surfaces such as roads, parking lots, drives, 

walkways and airport runways. Asphalt paving is grouped into three general categories: hotMACTEC Federal Programs, Inc. 
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mix, cutback, and emulsified. Hot-mix asphalt is the most commonly used paving asphalt. Hotmix asphalt produces minimal VOC emissions because its organic components have high 

molecular weights and low vapor pressures. Cutback asphalt is used in tack and seal operations, 

in priming roadbeds for hot-mix application and for paving operations for pavements up to 

several inches thick. In preparing cutback asphalt, asphalt cement is blended or “cut back” with 

a diluent, typically from 25 to 45 percent by volume of petroleum distillates, depending on the 

desired viscosity. Emulsified asphalt is used in most of the same applications as cutback asphalt 

but is a lower emitting alternative to cutback asphalt. Instead of blending asphalt cement with 

petroleum distillates, emulsified asphalts use a blend of asphalt cement, water and an 

emulsifying agent, such as soap. Some emulsified asphalts contain virtually no VOC diluents; 

however, some emulsified asphalts may contain up to 12 percent VOC by volume. 

3.2.1 Existing Federal and State Rules 

The EPA published a Control Technique Guideline (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. 

Table 3-1 summarizes the current asphalt paving rules for the 13 OTR states. Most of the states 

in the OTR have adopted the CTG banning cutback asphalt in the ozone season. Some states 

have exemptions to this rule, allowing the use of cutback asphalt with up to 5 percent VOC. For 

emulsified asphalt, the requirements vary greatly. The VOC content of emulsified asphalt is 

limited to 0-12 percent, depending on the State and the type of emulsified asphalt. Delaware 

completely bans the use of emulsified asphalt that contains any VOC. 

3.2.2 Description of the OTC 2006 Model Rule 

The OTC 2006 model rule for the asphalt paving control measure prohibits the use of cutback 

asphalt furing 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 {ASTM} Method D244 - Test Methods for Emulsified 

Asphalts) regardless of application. This is equivalent to a VOC content of 0.25 percent. 

Exemptions may be granted under certain circumstances upon the approval of the State 

commissioner. 

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Table 3-1 Summary of OTC State Rules for Cutback and Emulsified Asphalt 

State Cutback Asphalt Emulsified Asphalt 

CT 22a-174-20 (k): VOC content limited to 5% 

during June, July, August, and September 

Nothing specified 

DE Reg. No. 24, Section 34: Ban during ozone 

season 

Reg. No. 24, Section 34: Ban on use of 

emulsified asphalt that contains any VOC 

DC Chapter 7 Section 8-2:707(k): Ban during the 

months of April, May, June, July, August, and 

September 

Nothing specified 

ME Chapter 131: Ban during the period May 1 

through September 15, with some exceptions 

Chapter 131: VOC content limited to 3-12%, 

depending on the type of use 

MD COMAR 26.11.11.02: Ban during the period 

April 16 through October 14 

COMAR 26.11.11.02: Allowed upon approval 

of the Department; no VOC content limit 

specified 

MA 310 CMR 7.18(9): Ozone season ban on 

cutback asphalt with VOC content greater than 

5% by weight with exemptions including use as 

prime coat 

Nothing Specified 

NH Env-A 1204.42: Ban during the months of June 

through September; cutback with up to 5% 

VOC allowed upon approval of Department 

Env-A 1204.42: VOC content limited to 3-

12%, depending on the type of use 

NJ 7:27-16.19: Ban from April 16 through October 

14, with some exemptions 

7:27-16.19: VOC content limited to 8% by 

volume 

NY Part 211: Ban from May 2 through October 15 Part 211: VOC content limited to 2-12%, 

depending on the type of ASTM grade 

PA 25 Pa. Code Section 129.64: Ban from May 1 

to October 30 

25 Pa. Code Section 129.64: VOC content 

limited to 0-12%, depending on type 

RI Reg. No. 25: Ban from April 1 to September 

30, with some exemptions 

Reg No. 25: VOC content limited to 3-12%, 

depending on application/use 

VT 5-253.15: Ban on cutback asphalt with VOC 

content greater than 5% by weight, with some 

exemptions 

5-253.15: Ban on emulsified asphalt with VOC 

content greater than 5% by weight 

VA Chapter 40, Article 39: Ban during April 

through October 

Chapter 40, Article 39: VOC content limited to 

6% by volume 

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3.2.3 Emission Benefit Analysis Methods 

The OTC 2006 control measure for asphalt paving calls for a complete ban on the use of cutback 

asphalt during the ozone season. As shown in Table 3-1, current state regulations generally ban 

the use of cutback asphalt during the ozone season. However, there are exemptions from the ban 

and as a result there are VOC emissions from the use of cutback asphalt during the ozone season. 

The OTC 2006 control measure eliminates any exemptions and totally eliminate any VOC 

emissions from the use of cutback asphalt during the ozone season. 

The emission reductions resulting from OTC 2006 control measure for emulsified asphalt vary 

by State. the two percent VOC content limit on emulsified asphalt depend on the baseline VOC 

content of emulsified asphalt. The control measure limits emulsified asphalt to not more than 0.5 

mL of oil distillate from a 200 mL sample as determined using ASTM Method D244. This is 

equivalent to a VOC content of 0.25 percent. The baseline VOC content may range from 0 to 12 

percent. New Jersey used a VOC content of 8 percent in their baseline emission calculations 

(based on the 8 percent limit in their current rule). Reducing the VOC content to 0.25 percent in 

New Jersey will result in a 96.9 percent reduction. Delaware already bans the use of emulsified 

asphalt that contains any VOC, so there is no reduction in Delaware. Several other states used an 

average VOC content of 2.5 percent when developing their emission inventory. Thus, reducing 

the average VOC content from 2.5 percent to 0.25 percent results in a 90 percent reduction in 

VOC emissions. For States that did not supply a baseline VOC content for asphalt paving, we 

used the 90 percent reduction in VOC emissions from emulsified asphalt paving during the 

ozone season. 

3.2.4 Cost Estimates 

Low-VOC alternatives are currently available and no additional costs are expected from their 

use. 

3.3 CONSUMER PRODUCTS 

Consumer and commercial products are those items sold to retail customers for personal, 

household, or automotive use, along with the products marketed by wholesale distributors for use 

in commercial or institutional settings such as beauty shops, schools and hospitals. VOC 

emissions from these products are the result of the evaporation of propellant and organic solvents 

during use. Consumer and commercial products include hundreds of individual products, 

including personal care products, household products, automotive aftermarket products, 

adhesives and sealants, FIFRA-related insecticides, and other miscellaneous products. 

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3.3.1 Existing Federal and State Rules 

EPA published the Federal consumer and commercial products rule on September 11, 1998 (40 

CFR Part 59 Subpart D) under authority of Section 183(e) of the Clean Air Act. This rule limits 

the VOC content of 24 product categories representing 48 percent of the consumer and 

commercial products inventory nationwide. According to EPA, VOC emissions from those 24 

product categories were reduced by 20 percent. But since over half of the inventory is 

unaffected by the rule, the Federal rule is estimated to yield VOC reductions of 9.95 percent of 

the total consumer products inventory (Pechan 2001, pg 7). 

Since over half of the inventory is unregulated by the Federal Part 59 rule, the OTC developed a 

model rule for consumer and commercial products in 2001 (referred to as the “OTC 2001 model 

rule for consumer products” in this document) to be used by the OTC jurisdictions to develop 

regulations for additional consumer product categories and to specify more stringent VOC 

content limits than the Federal rule. The VOC content limits and products covered in the OTC 

2001 model rule are similar to the rules developed by CARB in the late 1990s. The OTC 2001 

model rule for consumer products provides background for OTC jurisdictions to develop 

programs to regulate approximately 80 consumer product categories and includes technologically 

feasible VOC content limits. The emission reductions for state programs based on the OTC 2001 

model rule are estimated to be 14.2 percent of the total consumer product inventory beyond the 

national rule reduction (Pechan 2001, pg. 8). 

Most, but not all, states in the OTR have adopted regulatory programs based on the OTC 2001 

model rule for consumer products. Table 3-2 summarizes the adoption status for the 13 OTR 

jurisdictions. 

3.3.2 Description of the OTC 2006 Model Rule 

The OTC 2001 model rule for consumer products closely mirrored a series of five CARB 

consumer products rules. CARB recently amended their consumer products rules in July 2005. 

As shown in Table 3-3, these amendments to the CARB rule affected 18 categories of consumer 

products (14 new categories, including subcategories, with new product category definitions and 

VOC limits; one previously regulated category with a more restrictive VOC limit; and two 

previously regulated categories with additional requirements). 

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Table 3-2 Status of OTC State’s Promulgation 

of the OTC 2001 Model Rule for Consumer Products. 

State Effective Date of VOC Limits Regulatory Citation 

CT a Initiated process to adopt in 2006 R.C.S.A. section 22a-174-40 

DE Effective January 1, 2005 Regulation Number 41 

DC Effective June 30, 2004 Regulation 719 

ME Effective May 1, 2005 Chapter 152 

MD Effective January 1, 2005 COMAR 26.11.32 

MA b In progress – proposed effective date is 

January, 2009 

310 CMR 7.25(12) 

NH Effective January 1, 2007 Chapter Env-A 4100 

NJ Effective June 6, 2004 Chapter 27, Subchapter 24 

NY Effective January 1, 2005 Chapter 3, Part 235 

PA Effective January 1, 2005 25 Pa. Code Chapter 130, Subchapter B 

RI Intend to develop in 2006 n/a 

VT Under Consideration n/a 

VA c Effective July 1, 2005 Chapter 40, Article 50 

a) Connecticut’s proposed rule includes both the VOC limits from the OTC 2001 model rule and the new and 

revised VOC emissions limits and related provisions that were adopted by the California Air Resources Board on 

July 20, 2005. These new and revised VOC limits are identical to those in the OTC 2006 model rule. 

b) Massachusett’s proposed rule includes the VOC limits from the OTC 2001 model rule and those in the OTC 2006 

model rule. 

c) Virginia’s rule applies only in Northern Virginia VOC Emission Control Area (10 northern Virginia jurisdictions 

in the OTR) 

 

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Table 3-3 Consumer Products Affected by CARB’s July 2005 Rule Amendments 

New Categories with VOC Limits for Regulation

Adhesive Remover 

– 4 subcategories 

Anti-Static Product 

Electrical Cleaner 

Electronic Cleaner 

Fabric Refresher 

Footwear or Leather Care Product 

Hair Styling Producta

Graffiti Remover 

Shaving Gel 

Toilet/Urinal Care Product 

Wood Cleaner 

Previously Regulated Category with More Restrictive Limit

Contact Adhesiveb

Previously Regulated Categories with Additional Requirements

Air Fresheners General Purpose Degreasers 

a) This product category will incorporate Hair Styling Gel and include additional forms of hair styling products (i.e., 

liquid, semi-solid, and pump spray) but does not include Hair Spray Product or Hair Mousse. 

b) This product category has been separated into 2 subcategories: General Purpose and Special Purpose 

Most of these new CARB limits become effective in California by December 31, 2006. Two of 

the limits, anti-static products (aerosol) and shaving gels, have effective dates in either 2008 or 

2009. For shaving gels, there is a VOC limit that becomes effective on December 31, 2006, with 

a more stringent second tier limit that becomes effective on December 31, 2009. The anti-static 

product (aerosol) limit becomes effective on December 31, 2008. 

The OTC 2006 model rule will modify the OTC 2001 model rule based on the CARB July 20, 

2005 amendments. The OTC is not including the anti-static aerosol products and the second tier 

shaving gel limit in its revisions to the OTC 2001 model rule because of industry concerns that 

meeting these limits may not be feasible. CARB acknowledged these concerns by requiring a 

technology review of these product categories in 2008 to determine whether the limits are 

achievable. 

3.3.3 Emission Benefit Analysis Methods 

The emission reduction benefit estimation methodology is based on information developed by 

CARB. CARB estimates 6.05 tons per day of VOC reduced in California from their July 2005 

amendments (CARB 2004a, pg. 8), excluding the benefits from the two products (anti-static 

products and shaving gels) with compliance dates in 2008 or 2009. This equates to about 2,208 

tons per year in California. The population of California as of July 1, 2005 is 36,132,147 

(Census 2006). On a per capita basis, the emission reduction from the CARB July 2005 

amendments equals 0.122 lbs/capita. 

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Since the OTC’s 2006 control measure is very similar to the CARB July 2005 amendments (with 

the exclusion of the anti-static products and shaving gel 2008/2009 limits), the per capita 

emission reductions are expected to be the same in the OTR. The per capita factor after the 

implementation of the OTC 2001 model rule is 6.06 lbs/capita (Pechan 2001, pg. 8). The 

percentage reduction from the OTC’s 2006 control measure was computed as shown below: 

Current OTC Emission Factor = 6.06 lbs/capita 

Benefit from CARB 2005 amendments = 0.122 lbs/capita 

Percent Reduction = 

= 

100%*(1 - (6.06 – 0.122)/6.06) 

2.0% 

3.3.4 Cost Estimates 

CARB estimates that the cost effectiveness of VOC limits with an effective date of December 

31, 2006, to be about $4000 per ton of VOC reduced (CARB 2004, pg. 21). CARB further 

estimates that the average increase in cost per unit to the manufacturer to be about $0.16 per unit. 

Assuming CARB’s estimates for the OTR provides a conservative estimate, because some of the 

one-time research and reformulation costs incurred for products sold in California will not have 

to be incurred again for products sold in the OTR. 

3.4 PORTABLE FUEL CONTAINERS 

Portable fuel containers (PFCs) are designed for transporting and storing fuel from a retail 

distribution point to a point of use and the eventual dispensing of the fuel into equipment. 

Commonly referred to as “gas cans,” these products come in a variety of shapes and sizes with 

nominal capacities ranging in size from less than one gallon to over six gallons. Available in 

metal or plastic, these products are widely used to refuel residential and commercial equipment 

and vehicles when the situation or circumstances prohibits direct refueling at a service station. 

PFCs are used to refuel a broad range of small off-road engines and other equipment (e.g., 

lawnmowers, chainsaws, personal watercraft, motorcycles, etc.). VOC emissions from PFCs are 

classified by five different activities: 

• Transport-spillage emissions from PFCs occur when fuel escapes from PFCs that are in 

transit. 

• Diurnal emissions result when stored fuel vapors escape to the air through any possible 

openings while the container is subjected to the daily cycle of increasing and decreasing 

ambient temperatures. Diurnal emissions depend on the closed- or open- storage 

condition of the PFC. 

• Permeation emissions are produced after fuel has been stored long enough in a container 

for fuel molecules to infiltrate and saturate the container material, allowing vapors to 

escape through the walls of containers made from plastic. 

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• Equipment refueling vapor displacement and spillage emissions result when fuel vapor 

is displaced from nonroad equipment (e.g., lawnmowers, chainsaws, personal watercraft, 

motorcycles, etc.) and from gasoline spillage during refueling of the equipment with 

PFCs. These VOC emissions are already taken into account in the nonroad equipment 

emission inventory by the NONROAD model. 

Diurnal evaporative emissions are the largest category. 

3.4.1 Existing Federal and State Rules 

The OTC developed a model rule for PFCs in 2001. The OTC 2001 model rule was very similar 

to a rule adopted by CARB in 2000. The OTC 2001 model rule provides background for OTC 

jursdictions to develop regulatory programs that require spill-proof containers to meet 

performance standards that reduce VOC emissions. The performance standards include a 

requirement that all PFCs to have an automatic shut-off feature preventing overfilling and an 

automatic closing feature so the can will be sealed when it is not being used. The performance 

standards also eliminate secondary venting holes and require new plastics to reduce vapor 

permeation through container walls. There is no requirement for owners of conventional PFCs 

to modify their PFCs or to scrap them and buy new ones. Compliance will be accomplished 

primarily through attrition. As containers wear out, are lost, damaged, or destroyed, consumers 

will purchase new spill-proof containers to replace the conventional containers. CARB 

determined that the average useful life of a PFC is five years. The OTC chose to assume a more 

conservative ten-year turnover rate, with 100 percent rule penetration occurring 10 years after 

adoption of the rule. 

CARB determined that the performance standards would reduce VOC emissions by 75 percent. 

CARB’s 2004 analysis (CARB 2004b) suggests the overall effectiveness is 65 percent. 

CARB has also adopted a second set of amendments expected to be adopted in the last quarter of 

2006 (CARB 2006). These amendments will: 

• Establish a mandatory certification program and accompanying test procedures; 

• Amend the existing performance standards to eliminate the automatic shutoff 

performance standard effective July 1, 2007; 

• Amend the existin performance standards to eliminate the fill height and flow rate 

performance standards; 

• Amend the existing PFC pressure standard; 

• Amend the current test methods; 

• Change the permeability standard from 0.4 to 0.3 grams/gallon-day; 

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• Establish a voluntary consumer acceptance-labeling program that allows participating 

manufacturers to label their PFCs with an ARB “Star Rating” indicating how consumers 

rate their products’ ease of use; and 

• Combine the currently separate evaporation requirement and permeation standard and test 

method into a single diurnal standard and test method. 

In February 2007, EPA finalized a national regulation to reduce hazardous air pollutant 

emissions from mobile sources. Included in the final rule are standards that would reduce PFC 

emissions from evaporation, permeation, and spillage. EPA included a performance-based 

standard of 0.3 grams per gallon per day of hydrocarbons, determined based on the emissions 

from the can over a diurnal test cycle specified in the rule. The standard applies to containers 

manufactured on or after January 1, 2009. The standards are based on the performance of best 

available control technologies, such as durable permeation barriers, automatically closing spouts, 

and cans that are well-sealed. 

3.4.2 Description of the OTC 2006 Model Rule 

As shown in Table 3-4, most states in the OTR have already adopted PFC regulations based on 

the OTC 2001 model rule. The OTC 2001 model rule for PFCs closely mirrors the 2000 version 

of CARB’s PFC rule. CARB recently amended their gas can regulation to address the use of 

utility jugs and kerosene containers that are sometimes offered for sale in place of gasoline cans 

(CARB 2005b). The 2005 and 2006 amendments are estimated to reduce VOC emissions by 

18.4 tons per day in California at full implementation in the year 2015 compared to the existing 

regulation. These amendments took effect on February 12, 2006. The OTC 2006 model rule 

will modify the OTC 2001 model rule based on the recent CARB amendments. 

3.4.3 Emission Benefit Analysis Methods 

Emissions from PFCs are accounted for in both the area and nonroad source inventories. The 

NONROAD model accounts for equipment refueling vapor displacement and spillage emissions 

result when fuel vapor is displaced from nonroad equipment (e.g., lawnmowers, chainsaws, 

personal watercraft, motorcycles, etc.) and from gasoline spillage during refueling of the 

equipment with PFCs. The area source inventory accounts for diurnal and permeation emissions 

associated with the fuel present in stored PFCs and transport-spillage emissions associated with 

refueling of a gas can at the gasoline pump. According to CARB (CARB 1999, pg 25) roughly 

90 percent of the VOC emissions are accounted for in the area source inventory, while the 

remaining 10 percent is from equipment refueling vapor displacement and spillage that is 

accounted for in the nonroad inventory. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-14 

Table 3-4 Status of OTC State’s Promulgation 

of the OTC 2001 Model Rule for Portable Fuel Containers 

State Date When New Containers are Required Regulatory Citation 

CT Effective May 1, 2004 Section 22a-174-43 

DE Effective January 1, 2004 Reg. No. 41, Section 3 

DC Effective November 15, 2003 Rule 720 

ME Effective January 1, 2004 Chapter 155 

MD Effective January 1, 2003 COMAR 26.11.13.07 

MAa In progress (effective date will be January 1, 

2009) 

n/a 

NH Effective March 1, 2006 Env-A 4000 

NJ Effective January 1, 2005 Subchapter 24 (7:27-24.8) 

NY Effective January 1, 2003 Part 239 

PA Effective January 1, 2003 25 Pa. Code Chapter 130, Subchapter A 

RI In progress (late 2006 target date for final rule) n/a 

VT Under Consideration n/a 

VAb Effective January 1, 2005 Chapter 40, Article 42 

a) Massachusetts’ proposed rule will be based only on the OTC 2006 model rule; Massachessetts will not adopt the 

OTC 2001 model rule. 

b) Virginia’s rule applies only in Northern Virginia VOC Emission Control Area (10 northern Virginia jurisdictions 

in the OTR) 

The emission benefits have only been calculated for the emissions accounted for in the area 

source inventory. Additional benefits (not estimated for this report) would be expected from 

equipment refueling vapor displacement and spillage that is accounted for in the nonroad 

inventory. 

Also note that the OTC baseline emissions (i.e., 2002 emissions) do not include changes to the 

emission estimation methodology made by CARB in 2004. CARB conducted a new survey of 

PFCs in 2004, which included kerosene containers and utility jugs. Using this survey data, 

CARB adjusted their baseline emissions; a similar adjustment to the OTC baseline inventory has 

not been made. 

Estimated emission reductions were based on information compiled by CARB to support their 

recent amendments. CARB estimated that PFC emissions in 2015 will be 31.9 tpd in California 

with no additional controls or amendments to the 2000 PFC rules (CARB 2005a, pg. 10). CARB 

further estimates that the 2006 amendment will reduce emission from PFCs by 18.4 tpd in 2015 

in California compared to the 2000 PFC regulations (CARB 2005a, pg. 23). Thus, at full 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-15 

implementation, the expected incremental reduction is approximately 58 percent, after an 

estimated 65 percent reduction from the original 2000 rule. 

The OTC calculations assume that States will adopt the rule by July 2007 (except in 

Massachusetts) and provide manufacturers one year from the date of the rule to comply. Thus, 

new compliant PFCs will not be on the market until July 2008. Assuming a 10-year turnover to 

compliant cans, only 10 percent of the existing inventory of PFCs will comply with the new 

requirements in the summer of 2009. Therefore, only 10 percent of the full emission benefit 

estimated by CARB will occur by 2009 – the incremental reduction will be 5.8 percent in 2009. 

3.4.4 Cost Estimates 

CARB estimates that the cost-effectiveness of the 2005/2006 amendments will range from $0.40 

to $0.70 per pound of VOC reduced, or $800 to $1,400 per ton of VOC reduced (CARB 2005a, 

pg. 27). Assuming CARBs costs for the OTR provides a conservative estimate, because some of 

the one-time research and reformulation costs incurred for products sold in California will not 

have to be incurred again for products sold in the OTR. 

3.5 REGIONAL FUELS 

The Clean Air Act Amendments of 1990 required significant changes to conventional fuels used 

by motor vehicles. Beginning in 1995, “reformulated” gasoline must be sold in certain nonattainment areas and other states with non-attainment areas are permitted to opt-in. 

Reformulated gasoline results in lower VOC emissions than would occur from the use of normal 

“baseline” gasoline. 

3.5.1 Existing Federal and State Rules 

All but two states in the OTR are participating, in whole or in part, with the federal reformulated 

gasoline program. However, nearly one-third of the gasoline sold in the OTR is not reformulated 

gasoline. NESCAUM has estimated the following fraction of gasoline that is reformulated by 

State: 

State Current RFG Fraction State Current RFG Fraction 

CT 100% NJ 100% 

DC 100% NY 54% 

DE 100% PA 24% 

MA 100% RI 100% 

MD 86% NoVA 100% 

ME 0% VT 0% 

NH 64% 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-16 

3.5.2 Description of the OTC 2006 Control Measure 

The Energy Policy Act of 2005 provides the opportunity for the OTR to achieve a single cleanburning gasoline and is consistent with what OTR states have promoted through the long debate 

over MTBE/ethanol/RFG. Approximately one-third of the gasoline currently sold in the OTR is 

not reformulated. The new authority plus the potential for emission reductions from the amount 

of non-reformulated gasoline sold in the OTR provides an opportunity for additional emission 

reductions in the region as well as for a reduced number of fuels, and possibly a single fuel, to be 

utilized throughout the region. The OTC Commissioners recommended that the OTC member 

states pursue a region fuel program consistent with the Energy Act of 2005 (OTC 2006b). 

3.5.3 Emission Benefit Analysis Methods 

Emission benefits resulting from extending reformulated gasoline to all areas of the OTR have 

been calculated for 2006 by NESCAUM (NESCAUM 2006a). 

3.5.4 Cost Estimates 

EPA’s AirControlNET document (Pechan 2005, pg III-1392) indicates that the annual costs for 

RFG is estimated to be $0.043 per gallon. The cost effectiveness of RFG varies greatly by 

county. Cost effectiveness for VOC ranged from $28,905,773 to $2,498 per ton. The average 

vost-effectiveness is $25,093 per ton of VOC reduced (median is $16,656 per ton). 

3.6 VOC EMISSION REDUCTION SUMMARY 

The results of the emission benefit calculations for the OTC states are described in this 

subsection. The starting point for the quantification of the emission reduction benefits is the 

MANEVU emission inventory, Version 3 (Pechan 2006, MACTEC 2006a) and the VISTAS 

emission inventory, BaseG (MACTEC 2006b), for the northern Virginia counties that are part of 

the OTR. The MANEVU and VISTAS inventories include a 2002 base year inventory as well as 

projection inventories for 2009 and 2018 (MANEVU also has projections for 2012, but VISTAS 

does not). The projection inventories account for growth in emissions based on growth 

indicators such as population and economic activity. The projection inventories also account for 

“on-the-books/on-the-way” (OTB/W) emission control regulations that have (or will) become 

effective between 2003 and 2008 that will achieve post-2002 emission reductions. For example, 

many States have already adopted the 2001 OTC model rules for consumer products and portable 

fuel containers. The emission reduction benefit from the 2001 OTC model rules are already 

accounted for in the MANEVU and VISTAS projection inventories. Emission reductions from 

existing regulations are already accounted for to ensure no double counting of emission benefits 

occurs. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-17 

Note that the emission reductions contained in this Section are presented in terms of tons per 

summer day. The MANEVU base and projection emission inventories do not contain summer 

day emissions for all States and source categories; the VISTAS inventory only contains annual 

values. When States provided summer day emissions in the MANEVU inventory, these values 

were used directly to quantify the emission benefit from the 2006 OTC control measure. When 

summer day emissions were missing from the MANEVU or VISTAS inventories, the summer 

day emissions were calculated using the annual emissions and the seasonal throughput data from 

the NIF Emission Process table. If the seasonal throughput data was missing, the summer day 

emissions were calculated using the annual emissions and a summer season adjustment factor 

derived from the monthly activity profiles contained in the SMOKE emissions modeling system. 

Tables 3-5 to 3-9 show State summaries of the emission benefits from the OTC 2006 VOC 

control measures described previously in this Section. For each of the five source categories, the 

Tables show four columns: (1) the actual 2002 summer daily emissions; (2) the summer daily 

emissions for the 2009 OTB/W scenario that accounts for growth and for the emission control 

regulations that have (or will) become effective between 2003 and 2008 that will achieve post2002 emission reductions; (3) the summer daily emissions for 2009 with the implementation of 

the OTC 2006 control measures identified in this Section, and (4) the emission benefit in 2009 

resulting from the OTC 2006 control measure. Table 3-10 shows the same information for the 

total of all five source categories. 

The largest estimated VOC emission reductions are in the most populous States – New York and 

Pennsylania. The emission benefits listed for Virginia just include the Virginia counties in the 

northern Virginia area that are part of the OTR. Benefit estimates for all other States include the 

entire state. The emission benefits also assume that all OTC members will adopt the rules as 

described in the previous sections. 

The requirement for a regional fuel throughout the OTR provides the largest emission benefit, 

about 139.4 tons per day across the OTR. The adhesives and sealants application model rule 

provides the second largest emission benefit in 2009 – 82.3 tons per day across the OTR. The 

incremental benefits accrued from the amendments to State’s existing consumer products and 

portable fuel container model rules are not as large, since the States already have accrued 

substantial benefits from the adoption of these rules. 

Appendix D provides county-by-county summaries of the VOC emission benefits from the OTC 

2006 VOC model rules described previously in this Section. Appendix D also provides 

additional documentation regarding the data sources and emission benefit calculations that were 

performed. These tables can be used by the States to create additional summaries, for example, 

by nonattainment area. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-18 

Table 3-5 OTC 2006 VOC Model Rule Benefits by State for 2009 

Adhesives and Sealants Application 

Adhesives/Sealants Application 

Summer VOC Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 4.8 6.6 2.4 4.2 

DE 1.4 1.6 0.6 1.0 

DC 0.2 0.2 0.1 0.1 

ME 3.1 3.9 1.4 2.5 

MD 6.9 9.1 3.3 5.8 

MA 10.6 14.7 5.8 8.9 

NH 2.5 3.6 1.3 2.3 

NJ 14.9 15.2 6.0 9.2 

NY 24.7 33.4 11.9 21.5 

PA 25.5 34.0 12.2 21.8 

RI 1.8 2.4 0.9 1.5 

VT 2.4 3.4 1.2 2.2 

NOVA 1.2 1.6 0.6 1.0 

OTR 99.8 129.8 47.5 82.3 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G inventory 

(for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 inventory 

and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions associated with onthe-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-the-way 

control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this 

section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-19 

Table 3-6 OTC 2006 VOC Model Rule Benefits by State for 2009 

Cutback and Emulsified Asphalt Paving 

Cutback and Emulsified Asphalt Paving 

Summer VOC Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT* 4.5 4.5 0.3 4.3 

DE 0.1 0.1 0.1 0.0 

DC 0.0 0.0 0.0 0.0 

ME 8.6 10.6 0.0 10.6 

MD 0.0 0.0 0.0 0.0 

MA* 8.4 8.6 0.5 8.1 

NH 3.8 4.8 0.5 4.4 

NJ 4.9 4.8 0.1 4.7 

NY 15.4 18.3 1.8 16.4 

PA 7.7 9.3 0.9 8.4 

RI 1.0 1.2 0.1 1.1 

VT 1.4 1.8 0.0 1.8 

NOVA <0.1 <0.1 <0.1 <0.1 

OTR 55.9 64.0 4.3 59.8 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G inventory 

(for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 inventory 

and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions associated with onthe-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-the-way 

control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this 

section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). 

* CT and MA provided revised emission estimates that differ from those in the MANEVU Version 3 inventories. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-20 

Table 3-7 OTC 2006 VOC Model Rule Benefits by State for 2009 

Consumer Products 

Consumer Products 

Summer VOC Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 40.1 35.4 34.7 0.7 

DE 7.3 6.7 6.5 0.1 

DC 5.7 5.1 5.0 0.1 

ME 10.9 9.7 9.5 0.2 

MD 52.8 48.4 47.4 1.0 

MA* 62.2 64.1 53.9 10.2 

NH 13.7 12.6 12.4 0.3 

NJ 82.9 71.9 70.5 1.4 

NY 209.6 183.3 179.6 3.7 

PA 119.6 104.4 102.4 2.1 

RI 10.6 9.3 9.1 0.2 

VT 6.1 5.6 5.5 0.1 

NOVA 21.5 23.0 22.5 0.5 

OTR 642.9 579.5 559.0 20.5 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G inventory 

(for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 inventory 

and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions associated with onthe-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-the-way 

control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this 

section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). 

* MA proposed rule has a January 1, 2009 effective date and includes the VOC limits from the OTC 2001 model 

rule and those in the OTC 2006 model rule. The 2009 benefit for MA shows the benefit from both sets of limits. 

For all other States, the 2009 benefit shows the change in emissions from the OTC 2006 model rule only. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-21 

Table 3-8 OTC 2006 VOC Model Rule Benefits by State for 2009 

Portable Fuel Containers 

Portable Fuel Containers 

Summer VOC Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 9.7 6.5 6.1 0.4 

DE 3.0 2.1 1.9 0.1 

DC 3.6 2.5 2.4 0.1 

ME 3.6 2.4 2.3 0.1 

MD 39.6 24.5 23.1 1.4 

MA* 18.1 18.6 16.9 1.7 

NH 3.6 3.0 2.8 0.2 

NJ 24.4 17.7 16.7 1.0 

NY 76.6 45.0 42.4 2.6 

PA 47.0 27.6 26.0 1.6 

RI 3.0 2.7 2.5 0.2 

VT 1.7 1.5 1.5 0.1 

NOVA 8.6 6.1 5.7 0.4

OTR 242.5 160.1 150.3 9.9 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G inventory 

(for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 inventory 

and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions associated with onthe-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-the-way 

control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this 

section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). 

Note: The table shows the estimated emission reduction that will occur in 2009; additional reductions will occur in 

later years as new, less-emitting PFCs that comply with the OTC 2006 control measure penetrate the market. 

* MA PFC regulation will be based on only the OTC 2006 model rule (which updates the provisions of the OTC 

2001 model rule) and will have an effective date of January 1, 2009. The 2009 base emissions in MA are 

uncontrolled emissions. The 2009 emission benefits represents the total emission reductions from the MA rule. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-22 

Table 3-9 OTC 2006 VOC Model Rule Benefits by State for 2009 

Regional Fuels 

Regional Fuels 

Summer VOC Emissions (tpd) 

State 2006 

Actual 

2006 

Base 

2006

Control 

2006 

Benefit 

CT 87.9 87.9 87.9 0.0 

DE 26.6 26.6 26.6 0.0 

DC 9.1 9.1 9.1 0.0 

ME 56.2 56.2 47.1 9.1 

MD 158.7 158.7 155.6 3.2 

MA 148.6 148.6 148.6 0.0 

NH 45.3 45.3 41.0 4.3 

NJ 219.6 219.6 219.6 0.0 

NY 465.0 465.0 408.1 56.9 

PA 363.0 363.0 305.0 58.0 

RI 22.2 22.2 22.2 0.0 

VT 35.9 35.9 27.9 7.9 

NOVA 54.9 54.9 54.9 0.0 

OTR 1693.1 1693.1 1553.7 139.4 

Note: NESCAUM analysis was only completed for 2006. Data for 2002 and 2009 are not currently available 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Section 3 – VOC Analysis Methods Page 3-23 

Table 3-10 OTC 2006 VOC Model Rule Benefits by State for 2009 

All Five VOC Categories 

All Five Categories 

Summer VOC Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 147.0 140.9 131.3 9.6 

DE 38.4 37.1 35.7 1.3 

DC 18.5 16.9 16.5 0.4 

ME 82.4 82.9 60.3 22.6 

MD 258.1 240.8 229.4 11.4 

MA 247.9 254.5 225.7 28.8 

NH 68.9 69.4 58.0 11.4 

NJ 346.8 329.3 312.9 16.4 

NY 791.3 744.9 643.8 101.1 

PA 562.7 538.4 446.5 91.9 

RI 38.6 37.8 34.8 3.0 

VT 47.5 48.2 36.1 12.1 

NOVA 31.3 30.6 28.8 1.8 

OTR 2,679.3 2,571.6 2,259.7 311.8 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G inventory 

(for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 inventory 

and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions associated with onthe-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-the-way 

control measures described in this Section. Assumes that 2009 reductions from RFG are the same as those 

calculated for 2006. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this 

section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). Assumes that 2009 

reductions from RFG are the same as those calculated for 2006. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-1 

4.0 NOx ANALYSIS METHODS 

This Secton describes the analysis of the 2006 OTC control measures to reduce NOx 

emissions from six source categories: diesel engine chip reflash, regional fuels, asphalt 

production plants, cement kilns, glass/fiberglass furnaces, ICI boilers. For each of the 

categories, there are separate subsections that discuss existing Federal/state rules, 

summarize the requirements of the 2006 OTC control measure, describe the methods used 

to quantify the emission benefit, and provide an estimate of the anticipated costs and costeffectiveness of the control measure. At the end of Section 4, we provide the estimated 

emissions for 2002 and 2009 by source category and State. Appendix E provides countyby-county summaries of the emission reductions for each of the categories. 

4.1 HEAVY-DUTY TRUCK DIESEL ENGINE CHIP REFLASH 

In the mid-1990s, the U.S. Department of Justice (DOJ), EPA, and CARB determined that 

seven major engine manufacturers had designed their 1993 through 1998 model heavyduty diesel engines to operate with advanced electronic engine controls that resulted in 

excessive NOx emissions. When these engines were operated in the vehicle under “real 

world” conditions, the electronic calibration would change, altering the fuel delivery 

characteristics and resulting in elevated NOx levels. DOJ, EPA and ARB developed 

Consent Decrees that required the manufacturers to provide software (the “Low-NOx 

Rebuild Kit” or “chip reflash”) that modifies the injection timing adjustment that caused 

the excess NOx emissions. The kits are to be installed at the time the vehicle is brought in 

for a major engine rebuild/overhaul. The rate of rebuild has been considerably lower than 

what was envisioned under the Consent Decrees; the primary reasons being that engine 

rebuilds occur at considerably higher elapsed vehicle mileage than what was contemplated 

when the Consent Decrees were negotiated, and there is no federal oversight program to 

ensure that individual rebuilds are occurring at the time of rebuild. In response to this low 

rebuild rate, CARB has adopted a mandatory program, not tied to the time of rebuild, but 

rather to a prescribed period of time, within which owners must bring their vehicles into 

the dealer to have the reflash operation performed, with all costs borne by the engine 

manufacturers. (NESCAUM 2006b). 

4.1.1 Existing Federal and State Rules 

California entered into Settlement Agreements, separate from the federal Consent Decrees, 

but with analogous requirements for low-NOx rebuilds. The slow rate of progress in 

California mirrored the progress nationally. Accordingly, California embarked upon its 

own program, by rule, to accelerate and ultimately complete the rebuilds for trucks 

registered in California and for out-of-state registered trucks traveling on roadways within 

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Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-2 

the state. The ARB rule, effective March 21, 2005, mandates that rebuilds occur over a 

prescribed time period, with a final rebuild compliance date of December 31, 2006. The 

CARB mandatory program, faced two separate legal challenges, alleging that CARB has 

breached its settlement agreement and alleging that CARB is illegally establishing 

different emissions standards on “new engines”. The Sacramento County Superior Court 

ruled that the Low NOx Software Upgrade Regulation is invalid. CARB indicates that it 

will not appeal that ruling and is suspending further enforcement of this regulation. 

4.1.2 Description of the OTC 2006 Control Measure 

NESCAUM developed a model rule for consideration by its member states to implement a 

low-NOx rebuild program, similar to the program in California. The regulation applies to 

the engine manufacturers and to owners, lessees, and operators of heavy-duty vehicles 

powered by the engines that are required to have the low-NOx rebuild. Consistent with the 

Consent Decrees, the engine manufacturers are required to provide the rebuild kits at no 

cost to dealers, distributors, repair facilities, rebuild facilities, owners, lessees, and 

operators, upon their request and to reimburse their authorized dealers, authorized 

distributors, authorized repair facilities and authorized rebuild facilities for their labor 

costs. 

4.1.3 Emission Benefit Analysis Methods 

NESCUAM estimated potential NOx emissions reductions (tons per day) if the Northeast 

States were to adopt a rebuild program similar to the California program. These estimates 

are based on the ratio of Northeast to California in-state heavy-duty vehicle registrations, 

and ARB-estimated California NOx reductions of 35 TPD (NESCAUM 2006b, pg. 5). 

NESCAUM also estimated potential NOx emissions reductions for the Mid-Atlantic States 

by scaling the NESCAUM projections based on population. For the Mid-Atlantic States, 

the NOx benefit was calculated based on the per capita factors of a one ton per day 

reduction for each one million people (NESCAUM 2005). 

4.1.4 Cost Estimates 

The cost associated with the reflash has been estimated at $20-$30 per vehicle, which is 

borne by the engine manufacturer. There may be costs associated with potential downtime 

to the trucking firms, and record-keeping requirements on the dealer performing the reflash 

and the vehicle owner. The MRPO estimated cost effectiveness to be $1,800 to $2,500 

(depending on vehicle size) due to incremental “fuel penalty” of 2 percent increase in fuel 

consumption (ENVIRON 2006). 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-3 

4.2 REGIONAL FUELS 

The Clean Air Act Amendments of 1990 required significant changes to conventional fuels 

used by motor vehicles. Beginning in 1995, “reformulated” gasoline must be sold in 

certain non-attainment areas and other states with non-attainment areas are permitted to 

opt-in. Reformulated gasoline results in lower VOC emissions than would occur from the 

use of normal “baseline” gasoline. 

4.2.1 Existing Federal and State Rules 

All but two states in the OTR are participating, in whole or in part, with the federal 

reformulated gasoline program. However, nearly one-third of the gasoline sold in the OTR 

is not reformulated gasoline. NESCAUM has estimated the following fraction of gasoline 

that is reformulated by State: 

State Current RFG Fraction State Current RFG Fraction 

CT 100% NJ 100% 

DC 100% NY 54% 

DE 100% PA 24% 

MA 100% RI 100% 

MD 86% NoVA 100% 

ME 0% VT 0% 

NH 64% 

4.2.2 Description of the OTC 2006 Control Measure 

The Energy Policy Act of 2005 provides the opportunity for the OTR to achieve a single 

clean-burning gasoline and is consistent with what OTR states have promoted through the 

long debate over MTBE/ethanol/RFG. Approximately one-third of the gasoline currently 

sold in the OTR is not reformulated. The new authority plus the potential for emission 

reductions from the amount of non-reformulated gasoline sold in the OTR provides an 

opportunity for additional emission reductions in the region as well as for a reduced 

number of fuels, and possibly a single fuel, to be utilized throughout the region. The OTC 

Commissioners recommended that the OTC member states pursue a region fuel program 

consistent with the Energy Act of 2005 (OTC 2006b). 

4.2.3 Emission Benefit Analysis Methods 

Emission benefits resulting from extending reformulated gasoline to all areas of the OTR 

have been calculated for 2006 by NESCAUM (NESCAUM 2006a). 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-4 

4.2.4 Cost Estimates 

EPA’s AirControlNET document (Pechan 2005, pg III-1392) indicates that the annual 

costs for RFG is estimated to be $0.043 per gallon. 

4.3 ASPHALT PAVEMENT PRODUCTION PLANTS 

Hot mix asphalt (HMA) is created by mixing and heating size-graded, high quality 

aggregate (which can include reclaimed asphalt pavement) with liquid asphalt cement. 

HMA can be manufactured by batch mix, continuous mix, parallel flow drum mix, or 

counterflow drum mix plants. The dryer operation is the main source of pollution at hot 

mix asphalt manufacturing plants. Dryer burner capacities are usually less than 100 

mmBtu/hr, but may be as large as 200 mmBtu/hr. Natural gas is the preferred source of 

heat used by the industry, although oil, electricity and combinations of fuel and electricity 

are used. The reaction of nitrogen and oxygen in the dryer creates nitrogen oxide (NOx) 

emissions in the combustion zone, 

4.3.1 Existing Federal and State Rules 

Only two of the OTR states have regulations that specifically address NOx emissions from 

asphalt pavement manufacturing plants. New Hampshire limits NOx emissions to 0.12 

pound per ton of asphalt produced, or 0.429 lb per mmBtu {Chapter Env-A 1211.08 (c )} for units 

greater than 26 mmBTU/hour in size. New Jersey limits NOx emissions to 200 ppmvd at seven 

percent oxygen {7:27-19.9(a)}. Asphalt plants in other OTR states are subject to more general fuel 

combustion requirements or case-by-case RACT determinations.

4.3.2 Description of the OTC 2006 Control Measure 

NOx emissions from asphalt plants can be reduced through installation of low-NOx 

burners and flue gas recirculation (FGR). The OTC Commissioners recommended that 

OTC member states pursue as necessary and appropriate state-specific rulemakings or 

other implementation methods to establish emission reduction percentages, emission rates 

or technologies that are consistent with the guidelines shown in Table 4.1 (OTC 2006b). 

Industry leaders have identified a number of Best Management Practices that allow for 

substantial reduction in plant fuel consumption and the corresponding products of 

combustion including NOx. Best management practices include: 

• Burner tune-ups: A burner tune-up may reduce NOx emissions by up to 10 percent 

and may also help reduce fuel consumption. In other words, there can be a direct payback to the business from regular burner tune-ups. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-5 

Table 4.1 Addendum to OTC Resolution 06-02 Emission Guidelines 

for Asphalt Plants 

Plant Type 

Emission Rate 

(lbs NOx/ton asphalt 

produced) 

% Reduction 

Area/Point Sources (>25 MMBtu/hr) 

 Batch Mix Plant – Natural Gas 0.02 35 

 Batch Mix Plant – Distillate/Waste Oil 0.09 35 

 Drum Mix Plant – Natural Gas 0.02 35 

 Drum Mix Plant – Distillate/Waste Oil 0.04 35 

Area/Point Sources (<25 MMBtu/hr) 

 Batch/Drum Mix Plant – Natural Gas Low-NOx Burner Technology or Best 

Management Practices 

 Batch/Drum Mix Plant – Distillate/Waste Oil Low-NOx Burner Technology or Best 

Management Practices 

• Effective stockpile management to reduce aggregate moisture content: Current 

information indicates that effective stockpile management can reduce aggregate 

moisture content by about 25 percent, corresponding to a reduction in fuel consumption 

by approximately 10 - 15 percent. There are a number of ways to reduce aggregate 

moisture: covering stockpiles, paving under stockpiles, and sloping stockpiles are all 

ways that prevent aggregate from retaining moisture. Best Practices are plant- and 

geographic locale-specific. 

• Lowering mix temperature: A Technical Working Group of FHWA is currently 

investigating a number of newer formulation technologies, to understand the 

practicality and performance of lowering mix temperatures. Substantial reductions in 

mix temperatures, on the order of 20 percent or more, appear to be plausible. Lowering 

mix temperatures, by this amount, may reduce fuel consumption, as less heat is needed 

to produce the mix. 

• Other maintenance and operational best practices: Additional practices can be 

employed throughout the plant to help optimize production and operations. For 

example, regular inspection of drum mixing flites and other measures can be taken – all 

in the effort to make a plant operate more efficiently, thereby using less fuel.

4.3.3 Emission Benefit Analysis Methods 

The emission rates and percent reductions estimates shown above for major sources were 

developed the the state of New York based on the use of low-NOx burners and FGR. For 

minor sources, the requirement is the use of low-NOx burner technology. NOx emissions 

can be reduced by 35 to 50 percent with low-NOx burners and FGR, and by 25 to 40 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-6 

percent with low-NOx burners alone. For modeling purposes, a 35 percent reduction was 

assumed to apply all types of asphalt plants. 

The reductions estimated for this category only include emissions included in the 

MANEVU point source emission inventory. Only emissions from major point sources are 

typically included in the MANEVU point source database. Emissions from non-major 

sources are not explicitly contained in the area source inventory. The emissions from nonmajor asphalt plants are likely lumped together in the general area source industrial and 

commercial fuel use category. Reductions from area source emissions at asphalt 

production plants are included in the ICI boiler source category. Therefore, there is some 

uncertainty regarding the actual reductions that will occur as no accurate baseline exists for 

both major and minor facilities. 

4.3.4 Cost Estimates 

The anticipate costs for control are similar to those of small to midsize boilers or process heaters. 

Low NOx burners range from $500 to $1,250 per ton and low-NOx burners in combination with 

FGR range from $1,000 to $2,000 per ton. These cost-effectiveness data were provided by 

NYSDEC. These control efficiencies and cost-effectiveness estimates for low-NOx 

burners plus FGR are generally consistent EPA’s published data for small natural gas-fired 

and oil-fired process heaters and boilers (Pechan 2005). 

4.4 CEMENT KILNS 

Portland cement manufacturing is an energy intensive process in which cement is made by 

grinding and heating a mixture of raw materials such as limestone, clay, sand and iron ore 

in a rotary kiln. Nationwide, about 82 percent of the industry’s energy requirement is 

provided by coal. Waste-derived fuels (such as scrap tires, used motor oils, surplus 

printing inks, etc.) provide about 14 percent of the energy. NOx emissions are generated 

during fuel combustion by oxidation of chemically-bound nitrogen in the fuel and by 

thermal fixation of nitrogen in the combustion air. 

There are four main types of kilns used to manufacture portlant cement: long wet kilns, 

long dry kilns, dry kilns with preheaters, dry kilns with precalciners. Wet kilns tend to be 

older units and are often located where the moisture content of feed materials from quarries 

tends to be high. 

Cement kilns are located in Maine, Maryland, New York, and Pennsylvania. There are no 

cement kilns in the other OTR states. According to the MANEVU 2002 inventory (Pechan 

2006), the number of cement kilns operating in 2002 by size and type was: 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-7 

State 

Number of 

Facilities 

Number of Wet 

Kilns 

Number of Dry 

Kilns 

Maine 1 1 0 

Maryland 3 2 2 

New York 3 2 1 

Pennsylvania 10 5 16 

4.4.1 Existing Federal and State Rules 

The NOx SIP Call required states to submit revisions to their SIPs to reduce the 

contribution of NOx from cement kilns. All kilns in the OTR, except for the one kiln in 

Maine, are subject to the NOx SIP Call. Based on its SIP Call analysis, EPA determined 

30 percent reduction of baseline uncontrolled emission levels was highly cost-effective for 

cement kilns emitting greater than 1 ton/day of NOx. Some states elected to include 

cement kilns in their NOx Budget Trading Programs. For example, requirements in 

Pennsylvania’s regulations in 25 Pa. Code Chapter 145 set a kiln allowable limit of 6 

pounds per ton of clinker produced, and require sources to purchase NOx allowances for 

each ton of NOx actual emissions that exceed the allowable limits. Maryland did not 

include kilns in the trading program but instead provided two options for reducing NOx 

emissions: 

• Option 1 – for long wet kilns, meet NOx emission limit of 6.0 pounds per ton of 

clinker produced; for long dry kilns, meet limit of 5.1 pounds per ton of clinker 

produced; and for pre-heater/pre-calciner or pre-calciner kilns, meet limit of 2.8 

pounds per ton of clinker produced; 

• Option 2 – install low NOx burners on each kiln or modify each kiln to implement 

mid-kiln firing. 

The one kiln in Maine is a wet process cement kiln and has been licensed to modernize by 

converting to the more efficient dry cement manufacturing process. The new kiln is 

subject to BACT requirements. 

4.4.2 Description of the OTC 2006 Control Measure 

There is a wide variety of proven control technologies for reducing NOx emissions from 

cement kilns. Automated process control has been shown to lower NOx emissions by 

moderate amounts. Low-NOx burners have been successfully used, especially in the 

precalciner kilns. CemStarSM is a process that involves adding steel slag to the kiln, 

offering moderate levels of NOx reduction by reducing the required burn zone heat input. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-8 

Mid-kiln firing of tires provides moderate reductions of NOx emissions while reducing 

fuel costs and providing an additional revenue stream from receipt of tire tipping fees. 

SNCR technology has the potential to offer significant reductions on some precalciner 

kilns. SNCR is being used in numerous cement kilns in Europe. A recent study (EC 

2001a) indicates that there are 18 full-scale SNCR installations in Europe. Most SNCR 

installations are designed and/or operated for NOx reduction rates of 10-50% which is 

sufficient to comply with current legislation in some countries. Two Swedish plants 

installed SNCR in 1996/97 and have achieved a reduction of 80-85%. A second recent 

study (ERG 2005) of cement kilns in Texas has identified a variety of NOx controls for 

both wet and dry cement kilns, with reductions in the 40 to 85% range. 

The OTC Commissioners recommended that OTC member states pursue, as necessary and 

appropriate, state-specific rulemakings or other implementation methods to establish 

emission reduction percentages, emission rates or technologies that are consistent with the 

guidelines shown in Table 4.2 (OTC 2006b). The guidelines were presented in terms of 

both an emission rate (lbs/ton of clinker by kiln type) as well as a percent reduction from 

uncontrolled levels. 

Table 4.2 OTC Resolution 06-02 Emission Guidelines for Cement Kilns

Kiln Type 

Emission Rate 

(lbs NOx/ton of 

clinker produced) 

% Reduction 

from 

Uncontrolled 

Wet Kiln 3.88 60 

Long Dry Kiln 3.44 60 

Pre-heater Kiln 2.36 60 

Pre-calciner Kiln 1.52 60 

4.4.3 Emission Benefit Analysis Methods 

To calculate the additional reductions from the OTC 2006 Control Measure, MACTEC 

calculated the 2002 emission rate (lbs NOx per ton of clinker produced) for each kiln. The 

2002 emission rate was compared to the OTC 2006 control measure emission rate list 

above to calculate a kiln-specific percent reduction. The kiln-specific percent reduction 

was then applied to the 2002 actual emissions to calculate the emissions remaining after 

implementation of the control measure. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-9 

4.4.4 Cost Estimates 

The TCEQ study (ERG 2005) estimated a cost-effectiveness of $1,400-1,600 per ton of 

NOx removed for an SNCR system achieving a 50 percent reduction on modern dry 

preheat precalcination kilns. The study also estimate a cost-effectiveness of $2,200 per ton 

of NOx removed for SNCR systems achieving a 35 percent reduction on wet kilns. The 

most recent EPA report (EC/R 2000) shows data for two SNCR technologies, biosolids 

injection and NOXOUT®. These technologies showed average emission reductions of 50 

and 40 percent, respectively. The cost effectiveness was estimated to be $1,000-2,500/ton 

depending on the size of the kiln. Costs and the cost effectiveness for a specific unit will 

vary depending on the kiln type, characteristics of the raw material and fuel, uncontrolled 

emission rate, and other source-specific factors. 

4.5 GLASS/FIBERGLASS FURNACES 

The manufacturing process requires raw materials, such as sand, limestone, soda ash, and 

cullet (scrap and recycled glass), be fed into a furnace where a temperature is maintained in 

the 2,700°F to 3,100°F range. The raw materials then chemically react creating a molten 

material, glass. The reaction of nitrogen and oxygen in the furnace creates NOx emissions. 

The main product types are flat glass, container glass, pressed and blown glass, and 

fiberglass. In the OTR, the preponderance of glass manufacturing plants is in Pennsylania. 

New York and New Jersey also have several plants. Massachussetts, Maryland, and 

Rhode Island each have one glass manufacturing plant. 

4.5.1 Existing Federal and State Rules 

Only Massachussetts and New Jersey have specific regulatory limits for NOx emissions 

from glass melting furnaces. Massachusetts has a 5.3 pound per ton of glass removed limit 

for container glass melting furnaces having a maximum production of of 15 tons of glass 

per day or greater. New Jersey has a 5.5 pound per ton of glass limit for commercial 

container glass manufacturing furnaces and a 11 pound per ton of glass for specialty 

container glass manufacturing furnaces. New Jersey also required borosilicate recipe glass 

manufacturing furnaces to achieve at least a 30 percent reduction from 1990 baseline levels 

by 1994. The regulations for other states with glass furnaces (Maryland, New York, 

Pennsylvania, and Rhode Island) do not contain specific emission limitation requirements, 

but rather require RACT emission controls as determined on a case-by-case basis. 

4.5.2 Description of the OTC 2006 Control Measure 

Several alternative control technologies are available to glass manufacturing facilities to 

limit NOx emissions (MACTEC 2005). These options include combustion modifications 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-10 

(low NOx burners, oxy-fuel firing, oxygen-enriched air staging), process modifications 

(fuel switching, batch preheat, electric boost), and post combustion modifications (fuel 

reburn, SNCR, SCR). Oxyfiring is the most effective NOx emission reduction technique 

and is best implemented with a complete furnace rebuild. This strategy not only reduces 

NOx emissions by as much as 85 percent, but reduces energy consumption, increases 

production rates by 10-15 percent, and improves glass quality by reducing defects. Oxyfiring is 

demonstrated technology and has penetrated into all segments of the glass industry.

The OTC Commissioners recommended that OTC member states pursue, as necessary and 

appropriate, state-specific rulemakings or other implementation methods to establish 

emission reduction percentages, emission rates or technologies that are consistent with the 

guidelines shown in Table 4.3 (OTC 2006g). The guidelines were presented in terms of 

both an emission rate (lbs/ton of glass produced) as well as a percent reduction from 

uncontrolled levels for the different types of glass manufactured. 

Table 4.3 Addendum to OTC Resolution 06-02 Guidelines for Glass Furnaces 

Type of Glass 

Emission Rate 

(lbs NOx/ton of glass 

pulled) 

Block 24-hr Ave. 

Emission Rate 

(lbs NOx/ton of glass 

pulled) 

Rolling 30-day Ave. 

Container Glass 4.0 n/a 

Flat Glass 9.2 7.0 

Pressed/blown Glass 4.0 n/a 

Fiberglass 4.0 n/a 

Note: Compliance date is 2009. NOx allowances may be surrendered in lieu of meeting the emission rate 

based on a percentage of the excess emissions at the facility, at the discretion of the State.

4.5.3 Emission Benefit Analysis Methods 

The NOx emission reduction benefit calculation varied by State depending upon the 

availability of data: 

• New Jersey DEP evaluated the existing controls at each facility. NJDEP identified 

furnaces that have closed, indicated whether the facility requested banking of 

emissions, and specified whether the emissions from the closed furnace should remain 

in the projection year inventory. NJDEP also identified furnace-specific projected 

emission rates based on the use of oxyfuel technology. 

• Pennsylvania DEP provided 2002 throughput (tons of glass pulled) and emission rate 

data (lbs NOx/ton of glass pulled). The 2002 emission rate was compared to the OTC 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-11 

2006 control measure emission rate list above to calculate a furnace-specific percent 

reduction. The furnace-specific percent reduction was then applied to the 2002 actual 

emissions to calculate the emissions remaining after implementation of the control 

measure. If a furnace had an emission rate below the OTCC 2006 control measure 

emission rate, then no incremental reduction was calculated. PADEP also identified 

several furnaces that have shut down – emissions from these furnace were set to zero in 

the projection year inventory. 

• For all other States with glass furnaces (MA, MD, NY, and RI), furnace specific data 

were not available. The NOx emission reduction benefit was calculated by applying an 

85 percent reduction for oxyfiring technology to the projected 2009 base inventory. 

This approach does not take into account existing controls at the facilities. 

4.5.4 Cost Estimates 

A recent study by the European Commission (EC 2001b) reports a 75 to 85 percent 

reduction in NOx based on oxyfiring technology, resulting in emission rates of 1.25 to 4.1 

pounds of NOx per ton of glass produced. The cost effectiveness was determined to be 

$1,254 to $2,542 depending on the size of the furnace. EPA’s Alternative Control 

Techniques Document (USEPA 1994) estimated an 85 percent reduction in NOx emissions 

for oxyfiring with a cost-effectiveness of $2,150 to $5,300. 

Other technologies may be used to meet the limits in Table 4.3. The costs associated with 

meeting those limits are source-specific and depend on the existing controls in place and 

the emission rates being achieved. Site-specific factors greatly influence the actual 

achievable performance level and control costs at a particular facility. 

4.6 ICI BOILERS 

Industrial/commercial/institutional (ICI) boilers combust fuel to produce heat and process 

steam for a variety of applications. Industrial boilers are routinely found in applications 

the chemical, metals, paper, petroleum, food production and other industries. Commercial 

and institutional boilers are normally used to produce steam and heat water for space 

heating in office buildings, hotels, apartment buildings, hospitals, universities, and similar 

facilities. Industrial boilers are generally smaller than boilers in the electric power 

industry, and typically have a heat input in the 10-250 mmBtu/hr range; however, 

industrial boilers can be as large as 1,000 mmBtu/hr or as small as 0.5 mmBtu/hour. Most 

commercial and institutional boilers generally have a heat input less than 100 mmBtu/hour. 

It is estimated that 80 percent of the commercial/institutional population is smaller than 15 

mmBtu/hour. The ICI boiler population is highly diverse – encompassing a variety of fuel 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-12 

types, boiler designs, capacity utilizations and pollution control systems – that result in 

variability in emission rates and control options. 

For emission inventory purposes, emissions from ICI boilers are included in both the point 

and area source emission inventories. Generally, the point source emission inventory 

includes all ICI boilers at major facilities. The point source inventory lists individual 

boilers, along with their size and associated emissions. The area source inventory 

generally includes emissions for ICI boilers located at non-major facilities. It does not 

provide emissions by the size of boiler, as is done in the point source inventory. Area 

sources emissions are calculated based on the fuel use not accounted for in the point source 

inventory. This is done by taking the total fuel consumption for the state (by fuel type and 

category), as published by the U.S. Department of Energy, and subtracting out the fuel 

usage reported in the point source inventory. Emissions are then calculated on a countyby-county basis using the amount of fuel not accounted for in the point source inventory 

and average emission factors for each fuel type. 

4.6.1 Existing Federal and State Rules 

ICI boilers are subject to a variety of Clean Air Act programs. Emission limits for a 

specific source may have been derived from NSPS, NSR, NOx SIP Call, State RACT 

rules, case-by-case RACT determinations, or MACT requirements. Thus, the specific 

emission limits and control requirements for a given ICI boiler vary and depend on fuel 

type, boiler age, boiler size, boiler design, and geographic location. 

State regulations affecting ICI boilers were researched and are summarized in Appendix G. 

The specific requirements for each state were organized into a common format to 

efficiently include the State-by-State differences by fuel type and boiler size. This 

organization oversimplifies the source categories and size limitations that differ from 

State-to-State. This simplification was necessary to match the rules to the organization of 

the emission data bases (i.e., Source Classification Codes) being used in the analysis. 

4.6.2 Description of the OTC 2006 Control Measure 

The OTC Commissioners recommended that OTC member states pursue as necessary and 

appropriate state-specific rulemakings or other implementation methods to establish 

emission reduction percentages, emission rates or technologies for ICI boilers (OTC 

2006b). These guidelines have undergone revision based on a more refined analyses. 

Table 4.4 provides the current OTC proposal for ICI boilers. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-13 

Table 4.4 OTC Proposal for ICI Boilers

ICI Boiler Size 

(mmBtu/hr) 

Control Strategy/ 

Compliance Option 

NOx 

Control Measure 

Notes 

Less than 25 OTC Proposal Annual 

Boiler Tune-Up 

(OTC-10% Reduction from 

2009) 

For 5-25 

mm Btu/hr 

Annual Boiler 

Tune-Up 

Natural Gas 

0.05 lb NOx/mmBtu 

#2 Fuel Oil 

0.08 lb NOx/mmBtu 

#4 or #6 Fuel Oil 

0.20 lb NOx/mmBtu 

OTC Proposal 

Strategy #1 

(Choice of strategy is at 

the discretion of the 

source) Coal 

0.30 lb NOx/mmBtu** 

OTC Proposal 

Strategy #2 

(Choice of strategy is at 

the discretion of the 

source)

50% Reduction from 

uncontrolled 

(OTC: for 25-50 mm Btu/hr 50% 

Reduction from 2009, for 50-

100 mm Btu/hr 

10% Reduction from 2009) 

25-100 

OTC Proposal 

Strategy #3 

(Choice of strategy is at 

the discretion of the 

source)

Purchase Current year CAIR 

NOx Allowances 

For 25-50 

mmBtu/hr 

Initial stack test 

then Annual 

Boiler Tune-Up 

For 50-100 

mmBtu/hr 

Initial NOx 

stack test then 

once every 5 

years and 

Annual Boiler 

Tune-Up 

#2 fuel oil same as 

On-road low 

sulfur diesel oil

Natural Gas 

0.10 lb NOx/mmBtu

#2, #4, or #6 Fuel Oil 

0.20 lb NOx/mmBtu

Natural Gas & Fuel Oil 

Combined 

0.20 lb NOx/mmBtu 

OTC Proposal 

Strategy #1 

(Choice of strategy is at 

the discretion of the 

source) Coal 

Wall-fired 0.14 lb NOx/mm Btu 

Tangential 0.12 lb NOx/mm Btu 

Stoker 0.22 lb NOx/mm Btu 

FBC 0.08 lb NOx/mm Btu 

Strategy #2 LNB/SNCR*, LNB/FGR*, 

SNCR, SCR, or some 

combination of these controls 

Strategy #3

60% Reduction from 

uncontrolled 

(OTC-Nat gas 75%, Oil 40%, 

Coal 25% Reduction from 2009)

Strategy #4

Purchase Current year CAIR 

NOx Allowances 

Initial NOx 

stack test then 

once every 5 

years and 

Annual Boiler 

Tune-Up 

#2 fuel oil same as 

On-road low 

sulfur diesel oil

100-250 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-14 

*LNB/SNCR and LNB/FGR are examples of NOx control technologies for achieving NOx reductions. 

**Emission rate from March 6, 2001 OTC Model Rule, not discussed with LADCO. 

4.6.3 Emission Benefit Analysis Methods 

The emission reduction benefits resulting from the OTC ICI boiler control measure were 

calculated differently for point and area sources. For point sources, the emission 

reductions were estimated by comparing the emission limits in the existing (2006) state 

regulations with the limits contained in the OTC ICI boiler proposal. Tables 4-5 through 

4-10 shows the current state emission limits by size range and fuel type, and the percentage 

reduction from the OTC proposed limits to the current state requirement. In cases where a 

state did not have a specific limit for a given size range, then the more general percent 

reduction from uncontrolled values in Table 4-4 was used. The fuel types/boiler types 

shown in Tables 4-5 through 4-10 were matched to SCCs in the point source inventory. 

MACTEC used the SCC and design capacity (mmBtu/hour) from the MANEVU and 

VISTAS emission inventories to apply the appropriate state specific reduction factor to 

estimate the emission reduction benefit. 

ICI Boiler Size 

(mmBtu/hr) 

Control Strategy/ 

Compliance Option

NOx Notes

Control Measure

OTC Proposal 

Strategy #1 

(Choice of strategy is at 

the discretion of the 

source)

Include in NOx SIP Call or 

purchase 

Current year CAIR NOx 

allowances

NY- currently 

includes these 

in the NOx SIP 

Call trading 

program 

NOx CEMs 

Phase I – 2009 

0.12 NOx lb/mmBtu 

(OTC-20% Reduction from 2009 

if NOx SIP call and 30% 

Reduction if not NOx SIP call) 

Greater than 

250 

OTC Proposal 

Strategy #2 

(Choice of strategy is at 

the discretion of the 

source) Phase II – 2013 

0.08 NOx lb/mmBtu 

Equivalent to 

proposed 

EGU Control 

Measures 

NOx CEMS 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-15 

Table 4.5 Current State Emission Limits and Percent Reduction Estimated from 

Adoption of OTC ICI Boiler Proposal 

Point Source Natural Gas-Fired Boilers

 

Current 2006 NOx RACT Limit 

(lbs/mmBtu) OTC 2006 Percent Reduction 

 (from State regulations) (Current State reg compared to OTC Limit) 

 

Applicability Threshold 

mmBtu/hour Heat Input 

Applicability Threshold 

mmBtu/hour Heat Input 

State 

> 

250* 

100 to 

250 

50 to 

100 

25 to 

50 

5 to 

25 > 250* 

100 to 

250 

50 to 

100 

25 to 

50 <25 

 

OTC Limits 

(lbs/mmBtu): 0.12 0.10 0.05 0.05 NL 

CT 0.20 0.20 0.20 0.20 0.20 40.0 50.0 75.0 75.0 10.0 

DE 0.10 0.10 LNB NL NL 0.0 0.0 0.0 50.0 10.0 

DC 0.20 0.20 NL NL NL 40.0 50.0 50.0 50.0 10.0 

ME 0.20 NL NL NL NL 40.0 60.0 50.0 50.0 10.0 

MD 0.20 0.20 0.20 0.20 0.20 40.0 50.0 75.0 75.0 10.0 

MA 0.20 0.20 0.10 NL NL 40.0 50.0 50.0 50.0 10.0 

NH 0.10 0.10 0.10 NL NL 0.0 0.0 50.0 50.0 10.0 

NJ 0.10 0.10 0.10 NL NL 0.0 0.0 50.0 50.0 10.0 

NY 0.20 0.20 0.10 NL NL 40.0 50.0 50.0 50.0 10.0 

PA Source Specific NOx RACT 29.4 50.0 50.0 50.0 10.0 

SE PA 0.17 0.10 Source Specific RACT 29.4 0.0 50.0 50.0 10.0 

RI 0.10 0.10 0.10 NL NL 0.0 0.0 50.0 50.0 10.0 

VT 0.20 NL NL NL NL 40.0 60.0 50.0 50.0 10.0 

NOVA 0.2 0.2 0.2 0.2 0.2 40.0 50.0 75.0 75.0 10.0 

NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 

4-4 was used. 

Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were 

determined on a case-by-case basis); in those cases, the more general percent reduction from Table 4-4 was 

used. 

SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and 

Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) 

NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, 

Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince 

William County. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-16 

Table 4.6 Current State Emission Limits and Percent Reduction Estimated from 

Adoption of OTC ICI Boiler Proposal 

Point Source Distillate Oil-Fired Boilers 

 

Current 2006 NOx RACT Limit 

(lbs/mmBtu) OTC 2006 Percent Reduction 

 (from State regulations) (Current State reg compared to OTC Limit) 

 

Applicability Threshold 

mmBtu/hour Heat Input 

Applicability Threshold 

mmBtu/hour Heat Input 

State 

> 

250* 

100 to 

250 

50 to 

100 

25 to 

50 

5 to 

25 > 250* 

100 to 

250 

50 to 

100 

25 to 

50 <25 

 

OTC Limits 

(lbs/mmBtu): 0.12 0.20 0.08 0.08 NL 

CT 0.20 0.20 0.20 0.20 0.20 40.0 0.0 60.0 60.0 10.0 

DE 0.10 0.10 LNB NL NL 0.0 0.0 0.0 50.0 10.0 

DC 0.30 0.30 0.30 NL NL 60.0 33.3 73.3 50.0 10.0 

ME 0.20 0.30 0.30 NL NL 40.0 33.3 73.3 50.0 10.0 

MD 0.25 0.25 0.25 0.25 0.25 52.0 20.0 68.0 68.0 10.0 

MA 0.25 0.30 0.12 NL NL 52.0 33.3 33.3 50.0 10.0 

NH 0.30 0.30 0.12 NL NL 60.0 33.3 33.3 50.0 10.0 

NJ 0.20 0.20 0.12 NL NL 40.0 0.0 33.3 50.0 10.0 

NY 0.25 0.30 0.12 NL NL 52.0 33.3 33.3 50.0 10.0 

PA Source Specific NOx RACT 29.4 33.3 33.3 50.0 10.0 

SE PA 0.17 0.20 Source Specific RACT 29.4 0.0 33.3 50.0 10.0 

RI 0.12 0.12 0.12 NL NL 0.0 0.0 33.3 50.0 10.0 

VT 0.30 NL NL NL NL 60.0 60.0 50.0 50.0 10.0 

NOVA 0.25 0.25 0.25 0.25 0.25 52.0 20.0 68.0 68.0 10.0 

NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 

4-4 was used. 

Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were 

determined on a case-by-case basis); in those cases, the more general percent reduction from Table 4-4 was 

used. 

SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and 

Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) 

NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, 

Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince 

William County. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-17 

Table 4.7 Current State Emission Limits and Percent Reduction Estimated from 

Adoption of OTC ICI Boiler Proposal 

Point Source Residual Oil-Fired Boilers 

 Current 2006 NOx RACT Limit (lbs/mmBtu) OTC 2006 Percent Reduction 

 (from State regulations) (Current State reg compared to OTC Limit) 

 

Applicability Threshold 

mmBtu/hour Heat Input 

Applicability Threshold 

mmBtu/hour Heat Input 

State > 250* 

100 to 

250 

50 to 

100 

25 to 

50 

5 to 

25 > 250* 

100 to 

250 

50 to 

100 

25 to 

50 <25 

 

OTC Limits 

(lbs/mmBtu): 0.12 0.20 0.20 0.20 NL 

CT 0.25 0.25 0.25 0.25 0.25 52.0 20.0 20.0 20.0 10.0 

DE 0.10 0.10 LNB NL NL 0.0 0.0 0.0 50.0 10.0 

DC 0.30 0.30 0.30 NL NL 60.0 33.3 33.3 50.0 10.0 

ME 0.20 0.30 0.30 NL NL 40.0 33.3 33.3 50.0 10.0 

MD 0.25 0.25 0.25 0.25 0.25 52.0 20.0 20.0 20.0 10.0 

MA 0.25 0.30 0.30 NL NL 52.0 33.3 33.3 50.0 10.0 

NH 0.30 0.30 0.30 NL NL 60.0 33.3 33.3 50.0 10.0 

NJ 0.20 0.20 0.30 NL NL 40.0 0.0 33.3 50.0 10.0 

NY 0.25 0.30 0.30 NL NL 52.0 33.3 33.3 50.0 10.0 

PA Source Specific NOx RACT 29.4 33.3 33.3 50.0 10.0 

SE PA 0.17 0.20 Source Specific RACT 29.4 0.0 50.0 50.0 10.0 

RI LNB/FGR LNB/FGR LNB/FGR NL NL 0.0 0.0 0.0 50.0 10.0 

VT 0.30 NL NL NL NL 60.0 60.0 50.0 50.0 10.0 

NOVA 0.25 0.25 0.25 0.25 0.25 52.0 20.0 20.0 20.0 10.0 

NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 

4-4 was used. 

Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were 

determined on a case-by-case basis); in those cases, the more general percent reduction from Table 4-4 was 

used. 

SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and 

Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) 

NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, 

Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince 

William County. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-18 

Table 4.8 Current State Emission Limits and Percent Reduction Estimated from 

Adoption of OTC ICI Boiler Proposal 

Point Source Coal Wall-Fired Boilers 

 

Current 2006 NOx RACT Limit 

(lbs/mmBtu) OTC 2006 Percent Reduction 

 (from State regulations) (Current State reg compared to OTC Limit) 

 

Applicability Threshold 

mmBtu/hour Heat Input 

Applicability Threshold 

mmBtu/hour Heat Input 

State 

> 

250* 

100 to 

250 

50 to 

100 

25 to 

50 

5 to 

25 > 250* 

100 to 

250 

50 to 

100 

25 to 

50 <25 

 

OTC Limits 

(lbs/mmBtu): 0.12 0.14 0.30 0.30 NL 

CT 0.38 0.38 0.38 0.38 0.38 68.4 63.2 21.1 21.1 10.0 

DE n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

DC 0.43 0.43 NL NL NL 72.1 67.4 50.0 50.0 10.0 

ME n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

MD 0.38 0.65 0.38 0.38 0.38 68.4 78.5 21.1 21.1 10.0 

MA 0.45 0.45 NL NL NL 73.3 68.9 50.0 50.0 10.0 

NH 0.50 0.50 0.50 NL NL 76.0 56.0 40.0 50.0 10.0 

NJ n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

NY 0.45 0.5 NL NL NL 73.3 72.0 50.0 50.0 10.0 

PA Source Specific NOx RACT 29.4 72.0 50.0 50.0 10.0 

SE PA 0.17 0.20 Source Specific RACT 29.4 30.0 50.0 50.0 10.0 

RI n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

VT n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

NOVA 0.38 0.38 0.38 0.38 0.38 68.4 63.2 21.1 21.1 10.0 

n/a indicates that there are no coal-fired boilers in the state. 

NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 

4-4 was used. 

Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were 

determined on a case-by-case basis); in those cases, the more general percent reduction from Table 4-4 was 

used. 

SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and 

Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) 

NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, 

Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince 

William County. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-19 

Table 4.9 Current State Emission Limits and Percent Reduction Estimated from 

Adoption of OTC ICI Boiler Proposal 

Point Source Coal Tangential-Fired Boilers 

 

Current 2006 NOx RACT Limit 

(lbs/mmBtu) OTC 2006 Percent Reduction 

 (from State regulations) (Current State reg compared to OTC Limit) 

 

Applicability Threshold 

mmBtu/hour Heat Input 

Applicability Threshold 

mmBtu/hour Heat Input 

State 

> 

250* 

100 to 

250 

50 to 

100 

25 to 

50 

5 to 

25 > 250* 

100 to 

250 

50 to 

100 

25 to 

50 <25 

 

OTC Limits 

(lbs/mmBtu): 0.12 0.12 0.30 0.30 NL 

CT 0.20 0.20 0.20 0.20 0.20 40.0 40.0 0.0 0.0 10.0 

DE n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

DC 0.43 0.43 NL NL NL 72.1 72.1 50.0 50.0 10.0 

ME n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

MD 0.38 0.65 0.38 0.38 0.38 68.4 81.5 21.1 21.1 10.0 

MA 0.38 0.38 NL NL NL 68.4 68.4 50.0 50.0 10.0 

NH 0.38 0.38 0.38 NL NL 68.4 42.1 21.1 50.0 10.0 

NJ n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

NY 0.42 0.5 NL NL NL 71.4 76.0 50.0 50.0 10.0 

PA Source Specific NOx RACT 29.4 76.0 50.0 50.0 10.0 

SE PA 0.17 0.20 Source Specific RACT 29.4 40.0 50.0 50.0 10.0 

RI n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

VT n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

NOVA 0.38 0.38 0.38 0.38 0.38 68.4 68.4 21.1 21.1 10.0 

n/a indicates that there are no coal-fired boilers in the state. 

NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 

4-4 was used. 

Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were 

determined on a case-by-case basis); in those cases, the more general percent reduction from Table 4-4 was 

used. 

SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and 

Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) 

NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, 

Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince 

William County. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-20 

Table 4.10 Current State Emission Limits and Percent Reduction Estimated from 

Adoption of OTC ICI Boiler Proposal 

Point Source Coal-Fired Stoker Boilers 

 

Current 2006 NOx RACT Limit 

(lbs/mmBtu) OTC 2006 Percent Reduction 

 (from State regulations) (Current State reg compared to OTC Limit) 

 

Applicability Threshold 

mmBtu/hour Heat Input 

Applicability Threshold 

mmBtu/hour Heat Input 

State 

> 

250* 

100 to 

250 

50 to 

100 

25 to 

50 

5 to 

25 > 250* 

100 to 

250 

50 to 

100 

25 to 

50 <25 

 

OTC Limits 

(lbs/mmBtu): 0.12 0.22 0.30 0.30 NL 

CT 0.20 0.20 0.20 0.20 0.20 40.0 0.0 0.0 0.0 10.0 

DE n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

DC 0.43 0.43 NL NL NL 72.1 48.8 50.0 50.0 10.0 

ME n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

MD 0.38 0.65 0.38 0.38 0.38 68.4 66.2 21.1 21.1 10.0 

MA 0.33 0.33 NL NL NL 63.6 33.3 50.0 50.0 10.0 

NH 0.30 0.30 0.30 NL NL 60.0 26.7 0.0 50.0 10.0 

NJ n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

NY 0.3 0.3 NL NL NL 60.0 26.7 50.0 50.0 10.0 

PA Source Specific NOx RACT 29.4 26.7 50.0 50.0 10.0 

SE PA 0.17 0.20 Source Specific RACT 29.4 0.0 50.0 50.0 10.0 

RI n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

VT n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 

NOVA 0.4 0.4 0.4 0.4 0.4 70.0 45.0 25.0 25.0 10.0 

n/a indicates that there are no coal-fired boilers in the state. 

NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 

4-4 was used. 

Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were 

determined on a case-by-case basis); in those cases, the more general percent reduction from Table 4-4 was 

used. 

SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and 

Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) 

NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, 

Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince 

William County. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-21 

The emission limits shown in Tables 4-5 through 4-10 generally apply only to ICI boilers 

located at major sources (i.e. point sources). ICI boilers located at minor sources (i.e., area 

sources) are generally not subject to the emissions limits. In general, emissions from area 

source ICI boilers are uncontrolled (except possibly for an annual tune-up requirement). 

MACTEC applied the general percent reduction from uncontrolled values in Table 4-4 to 

the area source inventory. 

4.6.4 Cost Estimates 

The OTC recently completed an analysis of ICI boiler NOx control cost estimates 

(Bodnarik 2006) using detailed information on direct capital equipment costs, direct 

installation costs, indirect capital costs, and direct and indirect operating costs. The 

analysis examined five types of NOx control technologies – low-NOx burners (LNB), ultra 

low-NOx burners (ULNB), LNB plus flue gas recirculation (LNB+FGR), LNB pluse 

selective non-catalytic reduction (LNB+SNCR), and selective catalytic reduction (SCR). 

The analysis also considered various fuel types – coal, residual oil, distillate oil, and 

natural gas. The cost effectiveness varies by fuel type, boiler size, current regulatory 

requirements, current control technology, and boiler firing type. The annual costeffectiveness was found as low as $600 per ton and as high as $18,000 per ton. In general, 

for most scenarios the cost effectiveness was estimated to be less than $5,000 per ton of 

NOx removed. 

4.7 NOx EMISSION REDUCTION SUMMARY 

The results of the emission benefit calculations for the OTC states are described in this 

subsection. The starting point for the quantification of the emission reduction benefits is 

the MANEVU emission inventory, Version 3 (Pechan 2006, MACTEC 2006a) and the 

VISTAS emission inventory, BaseG (MACTEC 2006b), for the northern Virginia counties 

that are part of the OTR. The MANEVU and VISTAS inventories include a 2002 base 

year inventory as well as projection inventories for 2009 and 2018 (MANEVU also has 

projections for 2012, but VISTAS does not). The projection inventories account for 

growth in emissions based on growth indicators such as population and economic activity. 

The projection inventories also account for “on-the-books/on-the-way” (OTB/W) emission 

control regulations that have (or will) become effective between 2003 and 2008 that will 

achieve post-2002 emission reductions. Emission reductions from existing regulations are 

already accounted for to ensure no double counting of emission benefits occurs. 

Note that the emission reductions contained in this Section are presented in terms of tons 

per summer day. The MANEVU base and projection emission inventories do not contain 

summer day emissions for all States and source categories; the VISTAS inventory only 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-22 

contains annual values. When States provided summer day emissions in the MANEVU 

inventory, these values were used directly to quantify the emission benefit from the 2006 

OTC control measure. When summer day emissions were missing from the MANEVU or 

VISTAS inventories, the summer day emissions were calculated using the annual 

emissions and the seasonal throughput data from the NIF Emission Process table. If the 

seasonal throughput data was missing, the summer day emissions were calculated using the 

annual emissions and a summer season adjustment factor derived from the monthly 

activity profiles contained in the SMOKE emissions modeling system. 

Tables 4-11 to 4-17 show State summaries of the emission benefits from the OTC 2006 

NOx control measures described previously in this Section. For each of the seven source 

categories, the Tables show four emission numbers: (1) the actual 2002 summer daily 

emissions; (2) the summer daily emissions for the 2009 OTB/W scenario that accounts for 

growth and for the emission control regulations that have (or will) become effective 

between 2003 and 2008 that will achieve post-2002 emission reductions; (3) the summer 

daily emissions for 2009 with the implementation of the OTC 2006 control measures 

identified in this Section, and (4) the emission benefit in 2009 resulting from the OTC 

2006 control measure. Table 4-18 shows the same information for the total of all seven 

source categories. 

The largest estimated NOx emission reductions are in the more industrialized States – New 

York and Pennsylania – which have most of the cement kilns and glass furnaces in the 

OTR. These two states also have a large population of ICI boilers. The emission benefits 

listed for Virginia just include the Virginia counties in the northern Virginia area that are 

part of the OTR. Benefit estimates for all other States include the entire state. The 

emission benefits also assume that all OTC members will adopt the rules as described in 

the previous sections. 

Appendix E provides county-by-county summaries of the NOx emission benefits from the 

OTC 2006 NOx control measures described previously in this Section. Appendix E also 

provides additional documentation regarding the data sources and emission benefit 

calculations that were performed. These tables can be used by the States to create 

additional summaries, for example, by nonattainment area. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-23 

Table 4-11 OTC 2006 NOx Model Rule Benefits by State for 2009 

Heavy-Duty Truck Diesel Engine Chip Reflash 

Heavy-Duty Truck Diesel Engine Chip Reflash 

Summer NOx Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 66.7 n/a n/a 3.5 

DE 21.8 n/a n/a 0.6 

DC 8.1 n/a n/a 0.8 

ME 82.8 n/a n/a 1.4 

MD 105.0 n/a n/a 5.6 

MA 152.7 n/a n/a 6.7 

NH 30.5 n/a n/a 2.0 

NJ 133.5 n/a n/a 9.7 

NY 177.6 n/a n/a 16.1 

PA 437.1 n/a n/a 12.4 

RI 8.3 n/a n/a 0.8 

VT 13.7 n/a n/a 0.9 

NOVA 16.6 n/a n/a 2.5

OTR 1254.5 0.0 0.0 63.0 

n/a – not available due to lack of 2009 emissions data for on-road vehicles in NIF format. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-24 

Table 4-12 OTC 2006 NOx Model Rule Benefits by State for 2009 

Regional Fuels 

Regional Fuels 

Summer NOx Emissions (tpd) 

State 2006 

Actual 

2006 

Base 

2006

Control 

2006 

Benefit 

CT 81.3 81.3 81.3 0.0 

DE 24.8 24.8 24.8 0.0 

DC 8.4 8.4 8.4 0.0 

ME 44.1 44.1 43.8 0.2 

MD 144.0 144.0 144.0 0.0 

MA 137.4 137.4 137.4 0.0 

NH 38.4 38.4 38.2 0.2 

NJ 204.2 204.2 204.2 0.0 

NY 381.3 381.3 379.1 2.1 

PA 284.8 284.8 282.9 2.0 

RI 20.5 20.5 20.5 0.0 

VT 26.3 26.3 26.0 0.3 

NOVA 50.8 50.8 50.8 0.0

OTR 1446.2 1446.2 1441.4 4.8 

NESCAUM analysis was only completed for 2006. Data for 2002 and 2009 are not currently available 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-25 

Table 4-13 OTC 2006 NOx Model Rule Benefits by State for 2009 

Asphalt Pavement Production Plants 

Asphalt Pavement Production Plants 

Summer NOx Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 0.0 0.0 0.0 0.0 

DE 0.6 0.6 0.4 0.2 

DC 0.0 0.0 0.0 0.0 

ME 1.7 2.0 1.3 0.7 

MD 0.2 0.2 0.1 0.1 

MA 1.1 1.8 1.2 0.6 

NH 0.0 0.0 0.0 0.0 

NJ 1.3 2.8 1.8 1.0 

NY 0.0 0.1 0.0 0.0 

PA 0.6 0.7 0.5 0.2 

RI 0.1 0.1 0.1 0.0 

VT 0.0 0.0 0.0 0.0 

NOVA 0.3 0.3 0.2 0.1

OTR 5.9 8.6 5.6 3.0 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G 

inventory (for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 

inventory and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions 

associated with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-theway control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures 

described in this section (i.e., the difference between the 2009 base emissions and the 2009 control 

emissions). 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-26 

Table 4-14 OTC 2006 NOx Model Rule Benefits by State for 2009 

Cement Kilns 

Cement Kilns 

Summer NOx Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 0.0 0.0 0.0 0.0 

DE 0.0 0.0 0.0 0.0 

DC 0.0 0.0 0.0 0.0 

ME 4.7 4.7 4.7 0.0 

MD 17.2 17.2 4.1 13.1 

MA 0.0 0.0 0.0 0.0 

NH 0.0 0.0 0.0 0.0 

NJ 0.0 0.0 0.0 0.0 

NY 35.1 35.1 19.8 15.3 

PA 44.0 44.0 31.0 13.0 

RI 0.0 0.0 0.0 0.0 

VT 0.0 0.0 0.0 0.0 

NOVA 0.0 0.0 0.0 0.0

OTR 101.1 101.1 59.6 41.4 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G 

inventory (for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 

inventory and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions 

associated with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-theway control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures 

described in this section (i.e., the difference between the 2009 base emissions and the 2009 control 

emissions). 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-27 

Table 4-15 OTC 2006 NOx Model Rule Benefits by State for 2009 

Glass/Fiberglass Furnaces 

Glass/Fiberglass Furnace 

Summer NOx Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

Maximum

Control 

Maximum

Benefit 

CT 0.0 0.0 0.0 0.0 

DE 0.0 0.0 0.0 0.0 

DC 0.0 0.0 0.0 0.0 

ME 0.0 0.0 0.0 0.0 

MD 0.3 0.3 0.1 0.3 

MA 1.4 1.8 0.3 1.5 

NH 0.0 0.0 0.0 0.0 

NJ 7.7 7.1 2.2 4.9 

NY 6.1 6.8 1.0 5.8 

PA 36.3 44.3 20.0 24.3 

RI 0.7 0.5 0.1 0.5 

VT 0.0 0.0 0.0 0.0 

NOVA 0.0 0.0 0.0 0.0

OTR 52.5 60.9 23.6 37.3 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G 

inventory (for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 

inventory and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions 

associated with on-the-books/on-the-way controls measures. 

Maximum Control Inventory emissions are the emissions remaining after full implementation of the 

beyond-on-the-way control measures described in this Section. Not all of the anticipated reductions from the 

glass/fiberglass OTC 2006 control measure will be achieved by 2009. This columns shows the emissions 

remaining after full implementation of the measure, which may not occur until 2012. 

Maximum Emission Reduction Benefit is the incremental emission reduction from the control measures 

described in this section (i.e., the difference between the base emissions and the maximum control 

emissions). 

Note: The table show the maximum emission reduction from glass/fiberglass furnaces when the OTC 2206 

control measure is fully implemented. Not all of the reduction shown will be achieved by 2009. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-28 

Table 4-16 OTC 2006 NOx Model Rule Benefits by State for 2009 

ICI Boilers – Area (Minor) Source 

ICI Boilers – Area (Minor) Sources 

Summer NOx Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 8.9 9.4 6.5 2.8 

DE 3.4 3.5 2.3 1.2 

DC 1.3 1.6 1.1 0.4 

ME 5.0 5.3 4.2 1.1 

MD 3.5 4.0 2.9 1.2 

MA 24.4 25.8 19.1 6.6 

NH 21.3 24.2 20.8 3.4 

NJ 20.5 15.6 15.6 0.0 

NY 105.2 112.2 78.4 33.8 

PA 38.0 39.8 27.6 12.2 

RI 6.6 7.3 5.3 2.1 

VT 2.3 2.9 1.9 0.9 

NOVA 11.8 11.9 8.1 3.9

OTR 252.0 263.4 193.9 69.5 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G 

inventory (for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 

inventory and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions 

associated with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-theway control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures 

described in this section (i.e., the difference between the 2009 base emissions and the 2009 control 

emissions). 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-29 

Table 4-17 OTC 2006 NOx Model Rule Benefits by State for 2009 

ICI Boilers – Point (Major) Source 

ICI Boilers – Point (Major) Sources 

Summer NOx Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 5.8 5.6 3.5 2.1 

DE 7.7 7.3 7.2 0.1 

DC 1.0 1.1 0.8 0.4 

ME 10.2 12.8 10.1 2.8 

MD 14.2 11.2 8.8 2.4 

MA 13.8 15.4 8.7 6.8 

NH 3.9 4.8 2.9 1.9 

NJ 12.9 10.8 7.4 3.4 

NY 31.4 30.8 23.8 7.0 

PA 33.4 36.5 26.7 9.8 

RI 4.2 4.9 4.3 0.5 

VT 0.7 0.9 0.5 0.4 

NOVA 0.2 0.2 0.0 0.1 

OTR 139.3 142.3 104.6 37.7 

2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G 

inventory (for the 10 northern Virginia jurisdictions that are part of the OTR). 

2009 Base Inventory emissions are the emissions forecasted in the MANEVU 2009 OTB/W Version 3.1 

inventory and the VISTAS 2009 Base G inventory, and account for growth and any emission reductions 

associated with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after implementation of the beyond-on-theway control measures described in this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction from the control measures 

described in this section (i.e., the difference between the 2009 base emissions and the 2009 control 

emissions). 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 4 – NOx Analysis Methods Page 4-30 

Table 4-18 OTC 2006 NOx Model Rule Benefits by State for 2009 

All Seven NOx Categories 

All Seven NOx Categories 

Summer NOx Emissions (tpd) 

State 2002 

Actual 

2009 

Base 

2009

Control 

2009 

Benefit 

CT 162.7 n/a n/a 8.4 

DE 58.2 n/a n/a 2.1 

DC 18.8 n/a n/a 1.6 

ME 148.5 n/a n/a 6.2 

MD 284.4 n/a n/a 22.7 

MA 330.8 n/a n/a 22.2 

NH 94.1 n/a n/a 7.5 

NJ 380.0 n/a n/a 19.0 

NY 736.8 n/a n/a 80.1 

PA 874.1 n/a n/a 73.9 

RI 40.5 n/a n/a 3.9 

VT 42.9 n/a n/a 2.5 

NOVA 79.6 n/a n/a 6.6 

OTR 3251.5 n/a n/a 256.7 

n/a – not available due to lack of 2009 emissions data for on-road vehicles in NIF format. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 5 – References Page 5-1 

5.0 REFERENCES 

Bodnarik 2006: Bodnarik, Andrew M., New Hampshire Department of Environmental 

Services, “ICI Boiler NOx Control Cost Estimates from OTC Methodology”, presented 

at the OTC Control Strategy/SAS Committee Meeting, November 2, 2006. 

CARB 1998: California Air Resources Board, “Determination of Reasonably Available 

Control Technology and Best Available Retrofit Control Technology for Adhesives 

and Sealants”, December, 1998. 

CARB 1999: California Air Resources Board, “Initial Statement of Reasons for Proposed 

Rule Making Public Hearing to Consider the Adoption of Portable Fuel Container 

Spillage Control Regulations”, August 6, 1999. 

CARB 2004a: California Air Resourses Board, “Initial Statement of Reasons for Proposed 

Amendments to the California Aerosol Coating Products, Antiperspirants and 

Deodorants, and Consumer Products Regulations, Test Method 310, and Airborne 

Toxic Control Measure for Para-dichlorobenzene Solid Air Fresheners and 

Toilet/Urinal Care Products Volume I: Executive Summary”, June 24, 2004. 

CARB 2004b: California Air Resourses Board, Letter from William V. Loscutoff to 

Stakeholders, June 7, 2004. 

CARB 2005a: California Air Resourses Board, “Staff Report: Initial Statement of Reasons 

for Proposed Amendments to the Portable Fuel Container Regulations”, July 29, 2005.

CARB 2005b: California Air Resourses Board, “Final Statement of Reasons: Public 

Hearing to Consider Amendments to the Regulations for Portable Fuel Containers”, 

October 2005.

CARB 2006: California Air Resourses Board, “Final Statement of Reasons: Public 

Hearing to Consider Amendments to the Regulations for Portable Fuel Containers”, 

July 2006.

Census 2006: U.S. Census Bureau, web site www.census.gov/popest/counties/tables/

containing county population files for 2005. 

EC 2001a. European Commission, “Integrated Pollution Prevention and Control (IPPC) 

Reference Document on Best Available Techniques in the Cement and Lime 

Manufacturing Industries”, December 2001. 

EC 2001b. European Commission, “Integrated Pollution Prevention and Control (IPPC) 

Bureau Reference Document on Best Available Techniques in the Glass Manufacturing 

Industry”, December 2001. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 5 – References Page 5-2 

EC/R 2000. EC/R Incorporated, “NOx Control Technologies for the Cement Industry – 

Final Report”, prepared for the U.S. Environmental Protection Agency, September 19, 

2000. 

ENVIRON 2006: ENVIRON International Corporation, “Evaluation of Candidate Mobile 

Source Control Measures”, prepared for Lake Michigan Air Directors Consortium, 

January 5, 2006. 

ERG 2005. Eastern Research Group, Inc., “Assessment of NOx Emissions Reduction 

Strategies for Cement Kilns – Ellis County’, prepared for the Texas Commission on 

Environmental Quality, December 19, 2005. 

MACTEC 2005: MACTEC Federal Programs, Inc., “Interim White Paper - Midwest RPO 

Candidate Control Measures: Glass Manufacturing”, prepared for Lake Michigan air 

Directors Consortium, December 2005. 

MACTEC 2006a: MACTEC Federal Programs, Inc., “Draft Final Technical Support 

Document: Development of Emission Projections for 2009, 2012, and 2018 for 

NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region”, prepared for 

Mid-Atlantic Regional Air Management Association, December 7, 2006. 

MACTEC 2006b: MACTEC Federal Programs, Inc., “Draft Documentation for the 2002, 

2009, and 2018 Emission Inventories for VISTAS”, prepared for Vibility Improvement 

State and Tribal Association of the Southeast, under development. 

NESCAUM 2005a: The Clean Air Association of the Northeast States, email from Arthur 

Marin NESCAUM to Chris Recchia OTC, December 7, 2005. 

NESCAUM 2005b: The Clean Air Association of the Northeast States, “Low Sulfur 

Heating Oil in the Northeast States: An Overview of Benefits, Costs and 

Implementation Issues,” December 2005. 

NESCAUM 2006a: The Clean Air Association of the Northeast States, email from Arthur 

Marin NESCAUM to Seth Barna OTC, February 2006. 

NESCAUM 2006b: The Clean Air Association of the Northeast States, “Low NOx 

Sofware Upgrade for Heavy-Duty Trucks: Draft Model Rule Staff Report, February 20, 

2006. 

OTC 2006a: Ozone Transport Commission, “Memorandum of Understanding Among the 

States of the Ozone Transport Commission on a Regional Strategy Concerning the 

Integrated Control of Ozone Precursors from Various Sources”, June 7, 2006. 

OTC 2006b: Ozone Transport Commission, “Resolution 06-02 of the Ozone Transport 

Commission Concerning Coordination and Implementation of Regional Ozone Control 

Strategies for Certain Source Categories”, June 7, 2006. 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measures February 13, 2007 

Section 5 – References Page 5-3 

OTC 2006c: Ozone Transport Commission, “Statement of the Ozone Transport 

Commission Concerning Multi-Pollutant Emission Control of Electric Generating 

Units”, June 7, 2006. 

OTC 2006d: Ozone Transport Commission, “Resolution 06-03 of the Ozone Transport 

Commission Concerning Federal Guidance and Rulemaking for Nationally-Relevant 

Ozone Control Measures”, June 7, 2006. 

OTC 2006e: Ozone Transport Commission, “Modified Charge of the Ozone Transport 

Commission to the Stationary Area Source Committee Regarding Electric Generating 

Units”, November 15, 2006. 

OTC 2006f: Ozone Transport Commission, “Statement of the Ozone Transport 

Commission Concerning Regional and State Measures to Address Emissions from 

Mobile Sources”, November 15, 2006. 

OTC 2006g: Ozone Transport Commission, “Addendum to Resolution 06-02 of the Ozone 

Transport Commission Concerning Coordination and Implementation of Regiona 

Ozone Control Strategies for Various Sources”, November 15, 2006. 

Pechan 2001: E.H. Pechan & Associates, Inc., “Control Measure Development Support 

Analyis of Ozone Transport Commission Model Rules”, prepared for Ozone Transport 

Commission, March 31, 2001. 

Pechan 2005: E.H. Pechan & Associates, Inc., “AirControlNET Version 4.1 

Documentation Report”, prepared for the U.S. Environmental Protection Agency, 

September, 2005. 

Pechan 2006: E.H. Pechan & Associates, Inc., “Documentation for 2002 Emission 

Inventory, Version 3”, prepared for Mid-Atlantic Regional Air Management 

Association, April x, 2006. 

USEPA 1994. U.S. Environmental Protection Agency, “Alternative Control Techniques 

Document – NOx Emissions from Glass Manufacturing”, EPA-453/R-94-037, June 

1994. 

MACTEC Federal Programs, Inc. 
Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-1 

Appendix A – Process for Identifying and Evaluating Control Measures 

Background 

The States of the Ozone Transport Region (OTR) are faced with the requirement to 

demonstrate attainment with the 8-hour ozone NAAQS 8-hour ozone National Ambient 

Air Quality Standards (NAAQS) by June 15, 2008. To accomplish this, most of the states 

will need to implement additional measures to reduce emissions that either directly impact 

their nonattainment status, or contribute to the nonattainment status in other states. In 

addition, the States are conducting attainment planning work to support development of 

PM2.5 and regional haze State Implementation Plans (SIPs). As such, the Ozone 

Transport Commission (OTC) undertook an exercise to identify a suite of additional 

control measures that could be used by the OTR states in attaining their goals. 

In March 2005, the Ozone Transport Commission (OTC) established the Control Strategies 

Committee as an ad-hoc committee to assist with coordination of the attainment planning 

work. The Control Strategies Committee works with three other OTC committees. The 

Stationary and Area Source (SAS) Commmittee evaluates control measures for specific 

stationary source sectors or issues. The Mobile Source Committee examines control 

measures for on-road and non-road mobile sources. And the Modeling Committee 

develops and implements a strategic plan for SIP-quality modeling runs to support 

attainments demonstrations. 

The SAS Commmittee is comprised of various workgroups that evaluate control measures 

for specific sectors or issues. These workgroups included: 

• Control Measures Workgroup focuses on stationary area sources; 

• Reasonably Available Control Technology (RACT) workgroup focuses on major 

point sources; 

• Multi-Pollutant Workgroup focuses on electric generating units (EGUs); 

• High Electric Demand Day (HEDD) examines EGU peaking units; and 

• Industrial, Commercial, and Institutional (ICI) Boiler Workgroup focuses on 

control technologies for different fuels and boiler size ranges. 

The OTC also issued a contract to MACTEC to help the SAS Committee identify and 

evaluate candidate control measures as well as to quantify expected emission reductions 

for each control measure. 

Workgroup Activities 

Initially, the Workgroups compiled and reviewed a list of approximately 1,000 candidate 

control measures. These control measures were identified through published sources such 

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Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-2 

as the U.S. Environmental Protection Agency’s (EPA’s) Control Technique Guidelines, 

STAPPA/ALAPCO “Menu of Options” documents, the AirControlNET database, 

emission control initiatives in member states as well as other states including California, 

state/regional consultations, and stakeholder input. Appendix B provides the initial list of 

control measures that were evaluated. 

Based on the review of the 1,000 candidate control measures, the Workgroups developed a 

short list of measures to be considered for more detailed analysis. These measures were 

selected to focus on the pollutants and source categories that are thought to be the most 

effective in reducing ozone air quality levels in the Northeastern and Mid-Atlantic States. 

The Workgroups reviewed information on current emission levels, controls already in 

place, expected emission reductions from the control measures, when the emission 

reductions would occur, preliminary cost and cost-effectiveness data, and other 

implementation issues. Each of the candidate control measures on the short list were 

summarized in a series of “Control Measure Summary Sheets”. The Control Measure 

Summary Sheets are contained in Appendix C. The Workgroups discussed the candidate 

control measures during a series of conference calls and workshops to further refine the 

emission reduction estimates, the cost data, and any implementation issues. The 

Workgroups also discussed coments from stakeholders. The Workgroups prioritized the 

control measures and made preliminary recommendations regarding which measures to 

move forward on. 

OTC Commissioners’ Recommendations 

Based on the analyses by the OTC Workgroups, the OTC Commissioners made several 

recommendations at the Commissioner’s meeting in Boston June 2006 and November 

2006. The Commissioners recommended that States consider emission 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 

• Glass Furnaces 

• Industrial, Commercial, and Institutional (ICI) Boilers 

• Regional Fuels 

• Electric Generating Units (EGUs) 

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Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-3 

Additionally, the Commisioners requested that EPA pursue federal regulations and 

programs designed to ensure national development and implementation of control 

measures for the following categories: architectural and maintenance coatings, consumer 

products, ICI boilers over 100 mmBtu/hour heat input, portable fuel containers, municipal 

waste combustors, regionally consistent and environmentally sound fuels, small offroad 

engine emission regulation, and gasoline vapor recovery. The various recommendations 

by the OTC Commissioners made from 2004 to 2006 are summarized in Table A-1. 

Stakeholder Input 

Stakeholders were provided multiple opportunities to review and comment on the Control 

Measure Summary Sheets. Table A-2 lists the public meetings that were held as an 

opportunity for stakeholders to review and respind to the Control Measure Summary 

Sheets and Commissioner’s recommendations. Stakeholders provided written comments, 

as listed in Table A-3. In addition to submitting written comments, the Workgroups 

conducted teleconferences with specific stakeholder groups to allow stakeholders to 

vocalize their concerns directly to state staff and to discuss the control options. These 

stakeholder conference calls and meeting are listed in Table A-4. The OTC staff and state 

Workgroups carefully considered the verbal and written comments received during this 

process. 

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Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-4 

Table A-1: OTC Formal Actions, 2004-2006 

Date Action/Synopsis 

Charge to Stationary and Area Sources Committee Directs SAS Committee to 

continue to seek out innovative programs to address emissions from all 

stationary and area sources.

Nov. 10, 2004 

Charge to Stationary and Area Sources Committee Regarding Multi-Pollutant 

Emission Control for Electrical Generating Units and Large Industrial Sources 

Directs the SAS Committee to develop an implementation strategy for to 

implement the OTC’s multi—pollutant position, recommend methods for 

allocating NOx and SO2 caps, assess methods to advance the OTC’s 

Multi0Pollutant position beyond the OTR, develop a program implementation 

structure, and present a Memorandum of Understanding for consideration by 

the Commission.

Nov. 10, 2004 

Charge to the Mobile Source Committee Directs the Mobile Source Committee 

to identify selected scenarios to be modeled and evaluate strategies including 

anti-idling programs, voluntary and regulatory retrofit programs, VMT growth 

strategies, port and marine engine programs, national mobile source programs, 

California Low Emission Vehicle programs, and model incentive programs.

Nov. 10, 2004 

Statement on OTC Modeling Directs the Modeling Committee to coordinate 

inventories and modeling needed for ozone, regional haze, and PM; seek input 

for air directors and OTC committees on regional strategies for modeling; 

continue to use CALGRID as a screening tool; and continue to explore 

application of emerging tools.

Nov. 10, 2004 

Resolution of the States of the Ozone Transport Commission Regarding 

Development of a Regional Strategy for the Integrated Control of Ozone 

Precursors and Other Pollutants of Concern from Electrical Generating Units 

(EGUs) and Other Large Sources Resolves that member States: develop a 

regional Multi-Pollutant prgarm to assist in attaining and maintaining the 8-

hour ozone NAAQS; seek to gain support from other states for a broader interregional strategy; develop an emissions budget and region-wide trading 

program; explore all feasible options to utilize the CAIR framework; and 

develop implementation mechanisms including a Memorandum of 

Understanding among the states.

June 8, 2005 

Statement of the Ozone Transport Commission With Regard to Advancement of 

Potential Regional Control Measures for Emission Reduction from Appropriate 

Sources and State Attain Planning Purposes Directs the staff of the OTC to 

continue investigation and modeling work associated with all potential regional 

control measures.

Nov. 3, 2005 

Feb. 23, 2006 Action Items Directs OTC staff to continue efforts on the following issues: 

Letter to EPA on Small Engines, Consumer Products, Architectural/Industrial 

Maintenance Coatings (AIM), Chip Reflash, Diesel Emissions Reductions, 

Modeling Efforts.

June 7, 2006 Memorandum of Understanding Among the States of the Ozone Transport 

Commission on a Regional Strategy Concerning the Integrated Control of 

Ozone Precursors from Various Sources Commits OTC States to continue to 

MACTEC Federal Programs, Inc. 
Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-5 

Date Action/Synopsis 

work with interested stakeholders and pursue state-specific rulemakings as 

needed and appropriate regarding the following sectors to reduce emission of 

ozone precursors: Consumer Products, Portable Fuel Containers, Adhesives and 

Sealants, and Diesel Engine Chip Reflash.

June 7, 2006 Statement of the Ozone Transport Commission Concerning Multi-Pollutant 

Emission Control of Electric Generating Units Directs OTC staff and its 

workgroups to continue to formulate a program beyond CAIR to addess 

emissions from this sector and to evaluate and recommend options to address 

emissions associated with high electrical demand days during the ozone season.

June 7 2006 Resolution 06-02 of the Ozone Transport Commission Concerning 

Coordination and Implementation of Regional Ozone Control Strategies for 

Certain Source Categories Resolves that OTC States continue to work with 

interested stakeholders and pursue state-specific rulemakings as needed to 

establish emission reduction percentages, emission rates or technologies as 

appropriate for the following source categories: asphalt paving (cutback and 

emulsified), asphalt plants, cement kilns, regional fuels, glass furnaces, and ICI 

boilers. 

June 7, 2006 Resolution 06-03 of the Ozone Transport Commission Concerning Federal 

Guidance and Rulemaking for Nationally-Relevant Ozone Control Measures 

Resolves that OTC States request that EPA pursue federal regulations and 

programs for national implementation of control measures comparable to the 

levels the OTC has adopted; these areas include AIM Coatings, Consumer 

Products, ICI Boilers over 100 MMBTU, Portable Fuel Containers, Municipal 

Waste Combustors, Regiona Fuels, Small Engine Emission Regulation, and 

Gasoline Vapor Recovery.

Nov. 15, 2006 Modified Charge of the Ozone Transport Commission to the Stationary Area 

Source Committee Regarding Electric Generating Units Directs the SAS 

Committee and workgroups to continue work on EGU emission reduction 

strategies to incorporate “CAIR Plus” and High Energy Demand Day (HEDD) 

emission reduction strategies.

Nov. 15, 2006 Statement of the Ozone Transport Commission Concerning Regional and State 

Measures to Address Emissions from Mobile Sources Supports the aggressive 

implementation of a suite of controls through the OTC Clean Corridor Initiative 

including: diesel retrofits, the Smartways program, California Low Emission 

Vehicle programs, anti-idling programs, low-NOx diesel alternatives, 

transportation demand management to reduce the growth in VMT, and 

voluntary action and outreach programs. 

Nov. 15, 2006 Addendum to Resolution 06-02 of the Ozone Transport Commission 

Concerning Coordination and Implementation of Regiona Ozone Control 

Strategies for Various Sources Resolves that OTC States continue to pursue 

state-specific rulemakings as needed to establish emission reduction 

percentages, emission rates or technologies as appropriate for the following 

source categories: asphalt plants, glass furnaces, and ICI boilers.

OTC formal actions can be found on the OTC website at the following address: 

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

MACTEC Federal Programs, Inc. 
Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-6 

Table A-2: OTC Control Measures Public Meetings, 2004-2006 

Date Meeting Locaton 

June 8-9, 2004 OTC/MANE-VU Annual Meeting Red Bank, NJ 

Nov. 9-10, 2004 OTC Fall Meeting Annapolis, MD 

Apr. 21-22, 2005 OTC Stationary and Area Source/Mobile Source 

Committee Meeting 

Linthicum, MD 

June 7-8, 2005 OTC Annual Meeting Burlington, VT 

Oct. 5, 2005 OTC Strategy Committee Meeting Linthicum, MD 

Nov. 2-3, 2005 OTC Fall Meeting Newark, DE 

Jan. 24, 2006 OTC Control Strategy Committee Meeting Linthicum, MD 

Feb. 22-23, 2006 OTC Special Meeting Washington, DC 

Apr. 5-6, 2006 OTC Control Strategy Meeting Linthicum, MD 

June 6-7, 2006 OTC Annual Meeting Boston, MA 

July 28, 2006 OTC/RTO/ISO Meeting Herndon, VA 

Sep. 18, 2006 OTC High Energy Demand Day Workgroup 

Meeting 

Herndon, VA 

Sep. 19, 2006 OTC Stationary and Area Source Committee 

Meeting 

Herndon, VA 

Nov. 2, 2006 OTC Control Strategies and Stationary and Area 

Source Committee Meeting 

Linthicum, MD 

Nov. 15, 2006 OTC Fall Meeting Richmond, VA 

Dec. 5-6, 2006 OTC High Energy Demand Day Workgroup 

Meeting 

Hartford, CT 

Meeting agendas and presentations can be found on the OTC website at the following 

address: 

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

MACTEC Federal Programs, Inc. 
Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-7 

Table A-4: Stakeholder Comments on OTC Control Strategies 

Stakeholder Source Cateogory 

Adhesive and Sealant Council Adhesives and Sealants 

National Paint & Coatings Association (NPCA) Adhesives and Sealants 

Ameron International AIM Coatings 

McCormick Paints AIM Coatings 

National Paint and Coatings Association (NPCA) AIM Coatings 

Painting and Decorating Contractors of America (PDCA) AIM Coatings 

PROSOCO, Inc. AIM Coatings 

RUDD Company Inc. AIM Coatings 

TEX COTE AIM Coatings 

The Master Painters Institute (MPI) AIM Coatings 

The Society for Protective Coatings (SSPC) AIM Coatings 

Wank Adams Slavin and Associates, LLC (WASA) AIM Coatings 

NAPA Asphalt Production Asphalt Production 

MATRIX Systems Auto Refinishing Auto Refinishing 

Portland Cement Association (PCA) Cement Kilns 

St Lawrence Cement Cement Kilns 

Consumer Specialty Products Association (CSPA) Consumer Products 

Cosmetic, Toiletry and Fragrance Association (CTFA) Consumer Products 

National Paint & Coatings Association (NPCA) Consumer Products 

Clean Air Task Force Diesel Retrofits 

Center for Energy and Economic Development, Inc. (CEED) EGUs 

Chesapeake Bay Foundation EGUs 

Clean Air Task Force EGUs 

Conectiv Energy EGUs 

Dominion EGUs 

Exelon EGUs 

International Brotherhood of Electrical Workers , United Mine Workers 

of America, Center for Energy & Economic Development, Inc., 

Pennsylvania Coal Association 

EGUs 

NRG EGUs 

PPL Services EGUs 

The Clean Energy Group EGUs 

National Lime Association (NLA) Lime Kilns 

Debra Jacobson, Prof. Lecturer in Energy Law NOx Sources 

Flexible Packaging Association (FPA)s Printing/Graphic Arts 

Graphic Arts Coalition Flexography Air Regulations Printing – Flexography 

Graphic Arts Coalition Printing & Graphic Arts Printing/Graphic Arts 

Graphic Arts Coalition Screen Litho Air Regulations Printing – Lithography 

Stakeholder comments can be found on the OTC website at the following address: 

http://www.otcair.org/projects_details.asp?FID=95&fview=stationary 

MACTEC Federal Programs, Inc. 
Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix A –Process for Identifying and Evaluating Control Measures Page A-8 

Table A-4: OTC Conference Calls and Meetings with Stakeholders, 2006 

Source Category Date(s) Industry Lead 

Adhesives and Sealants Aug. 30, 2006 Adhesives Council 

Asphalt Paving Mar. 30, 2006 

Sep. 21, 2006 

Sep. 28, 2006 

Oct. 13, 2006 

National Asphalt Paving Association (meeting) 

National Asphalt Paving Association 

Asphalt Emulation Manufacturers Association 

Asphalt Emulation Manufacturers Association 

Asphalt Production Oct. 25, 2006 National Asphalt Paving Association (meeting) 

Consumer Products Mar. 24, 2006 Consumer Specialty Products Association 

June 22, 2006 American Solvents Council (meeting) 

June 22, 2006 Consumer Specialty Products Association 

Aug. 29, 2006 Consumer Specialty Products Association 

Glass Manufacturers July 5, 2006 North American Insulation Manufacturers Assoc. 

Aug. 16, 2006 North American Insulation Manufacturers Assoc. 

Sep. 14, 2006 Glass Association of North America 

Oct. 19, 2006 Glass Association of North America 

ICI Boilers Mar. 14, 2006 Council of Industrial Boiler Owners 

Mar. 24, 2006 Institute of Clean Air Companies 

July 18, 2006 Council of Industrial Boiler Owners (meeting) 

Aug. 1, 2006 Council of Industrial Boiler Owners (conference) 

MACTEC Federal Programs, Inc. 
Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix B – Initial List of Control Measures Page B-1 

MACTEC Federal Programs, Inc. 

Appendix B – Initial List of Control Measures 

The comprehensive list of control measures can be found at: 

http://www.otcair.org 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-1 

MACTEC Federal Programs, Inc. 

Appendix C – Control Measure Worksheets 

This Appendix contains the Control Measure Summary Worksheets for the following source 

categories: 

Manufacture and Use of Adhesives and Sealants 

Architectural and Industrial Maintenance Coatings 

Asphalt Paving (Emulsified and Cutback) 

Asphalt Production Plants 

Automotive Refinish Coatings 

Cement Kilns 

Chip Reflash (Heavy Duty Diesel Engines) 

Consumer Products 

Glass and Fiberglass Furnaces 

Industrial, Commercial, Institutional Boilers 

Industrial Surface Coatings – Fabric Printing, Coating, and Dyeing 

Industrial Surface Coatings – Large Appliances 

Industrial Surface Coatings – Metal Cans 

Industrial Surface Coatings – Metal Coils 

Industrial Surface Coatings – Metal Furniture 

Industrial Surface Coatings – Miscellaneous Metal Parts 

Industrial Surface Coatings – Paper and Web Coating 

Industrial Surface Coatings – Plastics Parts 

Industrial Surface Coatings – Wood Building Products 

Industrial Surface Coatings – All Categories 

Lime Kilns 

Municipal Waste Combustors 

Printing and Graphic Arts 

Portable Fuel Containers 

Reformulated Gasoline 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-2 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY 

Manufacture and Use of Adhesives and Sealants 

(SCC- 2440020000)

Control Measure Summary

The provisions of this model rule limit emissions of volatile organic compounds (VOCs) from adhesives, 

sealants and primers. The model rule achieves VOC reductions through two basic components: sale and 

manufacture restrictions that limit the VOC content of specified adhesives, sealants and primers sold in the 

state; and use restrictions that apply primarily to commercial/industrial applications. By reducing the 

availability of higher VOC content adhesives and sealants within the state, the sales prohibition is also 

intended to address adhesive and sealant usage at area sources. Emissions from residential use of regulated 

products are addressed through the sales restrictions and simple use provisions. 

A reasonably available control technology determination prepared by the California Air Resources Board 

(CARB) in 1998 forms the basis of this model rule. In the years 1998-2001, the provisions of the CARB 

determination were adopted in regulatory form in various air pollution control districts in California including 

the Bay Area, South Coast, Ventura County, Sacramento Metropolitan and San Joaquin Valley.

Costs and Emissions Reductions

2002 existing measure: No existing limitations for this category 

Candidate measure: Approximately 75% of VOC emissions originate 

from solvent-based adhesives and sealants, the remaining 25% of VOC in 

this category are due to water-based materials. VOC content limits have 

been enacted by various APCD in California from 1998 to 2001. 

Emissions reductions: VOC content limits for the solvent-based materials 

can result in 64.4% reduction in total emissions from this category. (CARB 

RACT/BARCT for Adhesives/ Sealants, Dec 1998) 

Control costs: Costs for control by reformulation are estimated by the 

CARB at less than $2500 / ton (1999$). Many manufacturers have either 

reformulated solvent-based products to reduce the VOC content or have 

developed low-VOC water-based latex and acrylic products, or 

polyurethane or silicone products in response to the adoption of similar 

regulations in California. Thus, the actual costs in the OTC region are 

anticipated to be lower. 

Estimated costs for add-on controls carbon and thermal oxidizers ranged 

from $10,000 to $100,000 per ton. 

Timing of implementation: 01/01/09 

Implementation area: Region-wide

Annual VOC 

2002 Emissions: 35,489 tpy 

2009 Emissions: 46,241 tpy 

2009 Reduction: 29,438 tpy 

2009 Remaining: 16,803 tpy 

Summer VOC 

2002 Emissions: 99.8 tpd 

2009 Emissions: 129.8 tpd 

2009 Reduction: 82.3 tpd 

2009 Remaining: 47.5 tpd 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-3 

MACTEC Federal Programs, Inc. 

Interaction with other OTC Model Rules 

The products regulated in this model rule do not overlap with the products regulated by either the architectural 

and industrial maintenance (AIM) or consumer product rules. A “coating,” as contemplated in the AIM rule, 

is a “material applied onto or impregnated into a substrate for protective, decorative or functional purposes.” 

Because the coating is applied only to one substrate, it is clearly distinguished from adhesives and sealants, 

which are defined in both the consumer product and adhesive rules by application to two surfaces; in the case 

of adhesives, the two surfaces are directly bonded while in the case of sealants, a gap between two surfaces is 

filled. 

The overlap between the consumer product and adhesive rules is addressed mainly by an exemption in the 

adhesive rule for adhesives and sealers subject to the state’s consumer products regulation.

Reference:

California Air Resources Board. Determination of Reasonably Available Control Technology and Best 

Available Retrofit Technology for Adhesives and Sealants. December 1998. Page 18 provides the 

emission reduction estimates for California: the ARB emission inventory estimates 45 tons per day prerule; reductions will range from approximately 29 to 35 tons per day. We used the low end of this range 

to calculate the percent reduction of 64.4% (i.e. 29 tpd/45 tpd). Page 17 provides the cost-effectiveness 

information: the cost of complying with the determination reflects the cost of using alternative 

formulations of low-VOC or water-based adhesives, sealants, and cleanup products. Ventura County 

APCD staff determined that the cost-effectiveness of their adhesives rule ranges from a savings of $0.53 

per pound to a cost of $1.16 per pound of VOC reduced ($1,060 to 2,320). The use of add-on control 

equipment to comply was $4.50 to $55.00 per pound ($9,000 to $110,000). 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-4 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

AIM Coatings

Control Measure Summary: VOC emission reductions can be obtained 

through modifying the current formulation of the coating to obtain a lower VOC 

content. The regulatory approach for reducing emissions is to establish VOC 

content limits for specific coatings that manufacturers are required to meet either 

through reformulating products or substituting products with compliant coatings.

Emissions (tons/year) 

2001 existing measure: Federal AIM rules 40CFR Part 59 

Emission Reductions: 20% reduction from uncontrolled levels 

Control Cost: $228 per ton 

Timing of Implementation: Compliance required by September 1999 

Implementation Area: Nationwide 

VOC (with Part 59 limits) 

2002 OTR total: 124,173 

2009 On-the-Way Measure: OTC Model Rule based on a model rule adopted 

by the California Air Resources Board (CARB) in June, 2000 for 33 air 

control districts. 

Emission Reductions: 31% beyond Federal AIM rule 

Control Cost: $6,400 per ton 

VOC (After OTC Model 

Rule) 

2009 Reduction: -25,150

2009 Remaining: 99,023

Candidate measure: Follow CARB 2007 Rulemaking. Modify rule as 

appropriate when complete (in time for 2009) Participate actively in CARB 

process. Conduct survey in 2006 for 2005 sales data. 

Emission Reductions : 6% emissions reduction 

For modeling purposes we split the difference between SCAQMD and OTC 

model rule. But we go 75% of the way toward SCAQMD on the top four sales 

products, and set a 250 g/l VOC limit for Industrial Maintenance coatings. 

The reductions are calculated using the “reg neg” spreadsheet. 

Control Cost: Cost of OTC Survey (revise with cost data from the future 

CARB SCM when available in 2007) SCAQMD estimated the overall costeffectiveness for their 1999 Amendments to $13,317 per ton. For Dec. 5 2003 

amendments to Rule 1113, SCAQMD estimated the cost-effectiveness to be 

in the range of $4,229 to $11,405 per ton

Timing of Implementation: 01/01/09 

Implementation Area: Throughout OTR and MRPO 

VOC (After CARB 2007 

Rule) 

2009 Reduction: -5,941

2009 Remaining: 93,082 

Policy Recommendation: Final recommendation not made as of June, 2006. 

REFERENCES: 

2002 Existing Measure (Federal Part 59 Rules): 

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation Report, September 2005. 

Pages III-1347 and III-1348 shows the 20% reduction for the Federal Part 59 rule at a cost of $228 per ton 

(1990$). 

2009 On-the-Books Measure (OTC Model Rule): 

E.H. Pechan & Associates, Inc., Control Measure Development Support Analysis of Ozone Transport 

Commission Model Rules, March 31, 2001. Table II-6 shows 31% reduction (OTC Model Rule beyond 

Federal rule). Page 15 presents cost of $6,400 per ton based on CARB’s 2000 Staff Report for the 

Suggested Control Measure for Architectural Coatings. 

Candidate Measure (CARB 2007 Suggested Control Measure): 

CARB is in the process of updating the 2000 Suggested Control Measure (SCM) for Architectural 

Coatings this year. They will be using 2004 survey data as an important resource to update the SCM, but 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-5 

MACTEC Federal Programs, Inc. 

will not begin the formal SCM update process until the survey is completed. They anticipate bringing the 

SCM update to our Board in mid to late 2007. 

CARB is developing an analysis of costs for implementing an updated it’s Suggested Control Measure. Results of 

the analysis will not be available until 2007. 

Cost information for the South Coast Phase rules were obtained from: 

South Coast Air Quality Management District. Final Staff Report for Proposed Amended Rule 1113 – 

Architectural Coatings. December 5, 2003. “estimated the cost-effectiveness to be in the range of $4,229 to 

$11,405 per ton of VOC reduced. The low end of the range was determined based on the retail cost of 

compliant coatings reported by coating manufacturers surveyed by staff. The upper end of the range was 

derived by estimating the increased cost at the retail level due to the increase in cost of raw materials, 

reformulation, testing and packaging a new product prior to commercialization.” The Dec. 2003 amendments 

lowered the VOC limit for the following specialty coating categories: clear wood finishes including varnishes 

and sanding sealers, roof coatings, stains, and waterproofing sealers including concrete and masonry sealers. 

South Coast Air Quality Management District. Appendix F Addendum to Staff Report, Final Socioeconomic 

Impact Assessment, Proposed Amendments to Rule 1113. May 1999. The May 1999 amendments to Rule 

1113 lower VOC limits for the coating categories of industrial maintenance; non-flats; primers, sealers, and 

undercoaters; quick-dry enamels; quick-dry primers, sealers, and undercoaters; roof coatings; floor coatings, 

rust preventative coatings, stains, and waterproofing wood sealers. The overall cost-effectiveness of the 

proposed amendments, (total costs/total emission reductions) over the years 2002-2015, is estimated to be 

$13,317 per ton. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-6 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR EMULSIFIED AND CUTBACK ASPHALT PAVING 

Control Measure Summary: OTC Regional Ban on Cutback Asphalt in 

Ozone Season, with lower VOC/Solvent Contents for Emulsified 

Asphalt. 

VOC Emissions in 

Ozone Transport Region 

2002 existing measures: 

1. Cutback asphalt: The OTC states typically ban the use of cutback 

asphalt during the ozone season. States do provide various exemptions 

to the ban, most notably allowances may be made for cutbacks which 

contain less than 5% VOC. 

2. Emulsified asphalt: Ten of the OTC states regulate emulsified 

asphalt by providing allowable VOC content limits for the various 

applications. Three of the states do not address emulsified asphalts in 

their regulation. 

Control Cost: According to the 1977 CTG (EPA-450/2-77-037), which 

formed the basis for the existing regulations, the use of emulsified asphalts 

(no VOC) presented a cost savings. 

Timing of Implementation: All regulations implemented in 1990s or earlier 

under the 1-hour ozone standard. 

Implementation Area: OTC 1-hour ozone non-attainment areas. 

Annual VOC 

2002 cutback: ,154 tpy 

2002 emulsified: 10,379 tpy 

2002 total: 19,533 tpy 

Summer VOC 

2002 cutback: 17.5 tpd 

2002 emulsified: 38.5 tpd 

2002 total: 56.0 tpd 

Candidate measure: For cutback asphalt paving

Measure ID: BOTW09-AP-Cutback

Place a complete prohibition on the use of cutback asphalt during 

the ozone season.

Emission Reductions: to be achieved from using lower VOC content 

emulsified asphalt products or working outside the ozone season. 

Control Cost: Negligible.

Timing of Implementation: 01/01/09 

Implementation Area: All OTC 8-hour ozone non-attainment 

counties or individual state-wide. 

Summer VOC 

2009 OTB: 19.9 tpd 

2009 Reduction: 19.9 tpd 

2009 Remaining: 0.0 tpd 

Candidate measure: For emulsified asphalt paving 

Measure ID: BOTW09-AP-Emulsified

Proposes to limit ozone season use of emulsified asphalt to that 

which contains not more than 0.5 ml of oil distillate from the 200 

mL sample using the ASTM D244 test method regardless of 

application (which is 0.25% VOC by volume) 

Emission Reductions: to be achieved from using lower VOC content 

emulsified asphalt products or working outside the ozone season. 

Control Cost: Negligible 

Timing of Implementation: 01/01/09 

Implementation Area: All OTC 8-hour ozone non-attainment 

counties or individual state-wide.

Summer VOC 

2009 OTB: 44.2 tpd 

2009 Reduction: 4.3 tpd 

2009 Remaining: 39.9 tpd 

d

Control Measure Recommendation: 

States implement most stringent measure possible to achieve VOC reductions by 2009 from OTB projections 

in OTC states, with out disrupting state and county paving operations. 

Brief Rationale for Recommended Strategy: 

(1) Delaware already implements and complies with the most stringent proposed control strategy. 

(2) The control strategy is supported by the 1977 Control Techniques Document EPA-450/2-77-037. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-7 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-8 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Asphalt Production Plants 

Control Measure Summary: NOx emission reductions can be obtained 

through installation of low NOx burners and flue gas recirculation. 

SO2 can be reduced by reducing the sulfur in fuel limits for distillate 

oil to 500 ppm.

Emissions (tons/year) in Ozone 

Transport Region 

2002 existing measure: No existing limitations for this specific category 

have been identified. 2002 NOx Base: 

2002 SO2 Base:

827 

847

Candidate Measure: 

Emission Reductions: NOx can be reduced between 35% to 50% with 

low NOx burners and flue gas recirculation (FGR). SO2 can be 

reduced 25% to 75% by reducing the sulfur in fuel limits for distillate 

oil to 500 ppm. 

The MANEVU data for this category is incomplete. Only major point 

sources are typically included in the point source database. Non-major 

source emissions are likely lumped into the area source inventory with 

other industrial/commercial boilers/heaters. The point source data 

projects only 800+ tons per year (TPY) of both NOx and SO2 actual 

emissions in 2002 for the entire region. New York actual emissions 

are over 600 TPY of NOx and 400 TPY of SO2. Therefore, it is 

unknown what the actual reductions will produce as no accurate 

baseline exists for both major and minor facilities. 

Control Cost: Costs for control are similar to those of small to midsize 

boilers or process heaters. Low NOx burners range from $500 to 

$1250 per ton. While Low NOx burners in combination with FGR 

range from $1000 to $2000 per ton. 

Projected cost increase from lowing sulfur in distillate oil is 

approximately 2 to 3 cents per gallon. 

Timing of Implementation: Similar to the NOx RACT procedures of 

1994. Require a NOx compliance plan by the spring of 2008 with full 

implementation and compliance within one year (01/01/09). 

 

Unknown for sulfur-in-fuel reductions. 

 

Implementation Area: Region-wide 

NOx

2009 Base: 

2009 Reduction: 

2009 Remaining: 

SO2

2009 Base: 

2009 Reduction: 

2009 Remaining: 

1,276 

-549

727 

1,266 

-950

316 

Recommended Strategy: States should support model rules that encourage a combination of Best 

Management Practices, Low NOx Burners and FGR in asphalt production plants to achieve a 20-35% 

reduction in NOx emissions form a 2002 base, and encourage the use of low-sulfur oil. Area source emissions 

from asphalt plants are not included in this summary. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-9 

MACTEC Federal Programs, Inc. 

REFERENCES: 

Note: The reductions estimated for this category only include emissions from point sources. Area source 

emissions from fuel combustion at asphalt production plants are not explicitly contained in the area source 

emissions. These emissions are likely lumped together in the general area source industrial and 

commercial fuel use category. Reductions from area source emissions at asphalt production plants are 

included in the ICI boiler source category. 

Candidate Measure (Low NOx Burners plus FGR; low sulfur fuel oil): 

The emission reduction estimates and cost-effectiveness data were provided by NYSDEC. These 

control efficiencies and cost-effectiveness estimates for Low NOx Burners plus FGR are generally 

consisten with the data presented in E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: 

Documentation Report, September 2005. Information in this report for small oil-fired process heaters 

and ICI boilers provide similar levels of control and cost-effectiveness. 

Candidate Measure (Best Management Practices) 

Best Practices to Reduce Fuel Consumption and/or Lower Air Emissions: HMA industry leaders have 

identified a number of Best Practices that, if implemented, allow for substantial reduction in plant fuel 

consumption and the corresponding products of combustion including NOx. In today’s business environment, 

there is significant incentive to reduce fuel usage. For this reason, implementing best practices to reduce fuel 

consumption and NOx emissions, forms the basis of a sustainable strategy. 

Effective stockpile management to reduce aggregate moisture content: Current information indicates that 

effective stockpile management can reduce aggregate moisture content by about 25 percent, corresponding to a 

reduction in fuel consumption by approximately 10 - 15 percent. There are a number of ways to reduce 

aggregate moisture: covering stockpiles, paving under stockpiles, and sloping stockpiles are all ways that 

prevent aggregate from retaining moisture. Best Practices are plant- and geographic locale-specific. 

Burner tune-ups: As identified in OTC Resolution 06-02 and companion control measures summaries, a 

burner tune-up may reduce NOx emissions by up to 10 percent. From a contractor’s perspective, this also is 

helpful in reducing fuel consumption. In other words, there can be a direct pay-back to the business from 

regular burner tune-ups. 

Lowering mix temperature: A Technical Working Group of FHWA is currently investigating a number of 

newer formulation technologies, to understand the practicality and performance of lowering mix temperatures. 

Substantial reductions in mix temperatures, on the order of 20 percent or more, appear to be plausible. 

Lowering mix temperatures, by this amount, may reduce fuel consumption, as less heat is needed to produce 

the mix. 

Other maintenance and operational best practices: Additional practices can be employed throughout the 

plant to help optimize production and operations. For example, regular inspection of drum mixing flites and 

other measures can be taken – all in the effort to make a plant operate more efficiently, thereby using less fuel. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-10 

MACTEC Federal Programs, Inc. 

Plant Type 

Emission Rate 

(lbs NOx/ton asphalt 

produced) 

% Reduction 

Area/Point Sources (>25 MMBtu/hr) 

 Batch Mix Plant – Natural Gas 0.02 35 

 Batch Mix Plant – Distillate/Waste Oil 0.09 35 

 Drum Mix Plant – Natural Gas 0.02 35 

 Drum Mix Plant – Distillate/Waste Oil 0.04 35 

Area/Point Sources (<25 MMBtu/hr) 

 Batch/Drum Mix Plant – Natural Gas Low-NOx Burner Technology or Best 

Management Practices 

 Batch/Drum Mix Plant – Distillate/Waste Oil Low-NOx Burner Technology or Best 

Management Practices 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-11 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Auto Refinish Coatings – Area Source

Control Measure Summary: Limiting the concentration of solvents in 

Auto Refinishing Coatings in order to reduce VOC emissions. Encourage 

the use of high transfer-efficiency painting methods (e.g., high volume low 

pressure spray guns), and controls on emissions from equipment (e.g., 

spray gun) cleaning, housekeeping activities (e.g., use of sealed containers 

for clean-up rags), and operator training. 

Emissions (tons/year) in Ozone 

Transport Region 

2002 existing measure: Federal Auto Body Refinishing rules 40CFR 

Part 59 Subpart B 

Emission Reductions: 37% reduction from Part 59 (from Pechan OTC 

Model Rule Report) due to Part 59 VOC content limits 

Control Cost: $118 per ton for Part 59 rules 

Timing of Implementation: Part 59 compliance required by January 

1999 

Implementation Area: Part 59 – Nationwide; 

VOC 

Uncontrolled: 

2002 Reduction: 

2002 Base:

50,759 

-18,781

31,978

OTB Control Measure: OTC Model Rule for Mobile Equipment 

Repair and Refinishing

Emission Reductions: 38% reduction from 2002 Levels in those States 

that adopted OTC model Rule (per Pechan March 31, 2001 OTC 

Model Rule Report) 

Control Cost: $1,534 per ton of VOC 

Timing of Implementation: Assuming 2007 effective date of rule, 

emission reductions are achieved 01/01/09. 

Implementation Area: All counties in the OTR. 

VOC:

2009 Reduction: 

2009 Remaining:

-10,468

21,510

Candidate measure: CARB October 20, 2005 SCM Staff Report – 

Lowers VOC limits, combines coatings categories, simplifies 

recording.

Emission Reductions: CARB estimates a 65% reduction in VOC 

emissions from a 2002 baseline; the OTC model rule is very similar to 

the CARB 2002 baseline, so a similar reduction would be expected in 

the OTR. 

Control Cost: $2,860 per ton 

Timing of Implementation: Assuming 2007 effective date of rule, 

emission reductions are achieved in beginning 01/01/09. 

Implementation Area: All counties in the OTR. 

VOC:

2009 Reduction: 

2009 Remaining:

-13,981

7,529 

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: 

REFERENCES: 

2002 Existing Measure (Federal Part 59 Rules): 

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation Report, September 2005. 

Pages III-1364 shows the Federal Part 59 rule at a cost of $118 per ton (1990$) and a reduction of 37 

percent from uncontrolled levels. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-12 

2009 On-the-Books Measure (OTC Model Rule): 

E.H. Pechan & Associates, Inc., Control Measure Development Support Analysis of Ozone Transport 

Commission Model Rules, March 31, 2001. Table II-6 shows 37% reduction for Federal Part 59 rule 

and 38% (OTC Model Rule beyond Federal rule). Page 17 presents cost of $1,534 per ton based on 

estimates used for PA Rule 129.75. 

Candidate Measure (CARB 2005 Suggested Control Measure): 

California Air Resources Board. Staff Report for the Proposed Suggested Control Measure for 

Automotive Coatings. October 2005. Table V-3 shows the estimated 65% reduction from 2002 

baseline emissions for new automotive coatings limits. A similar reduction is expected for the OTR. 

Page VII-6 indicates that the cost-effectiveness of the SCM is estimated to be $1.43 per pound of VOC 

reduced ($2,860 per ton). The CARB SCM coating categories and VOC limits are: 

The OTC Model Rule coating categories and VOC limits are: 

OTC Model Rule Limit

Coating Type Grams per 

Liter 

Pounds per 

gallon

Automotive pretreatment primer 780 6.5 

Automotive primer-surfacer 575 4.8 

Automotive primer-sealer 550 4.6 

Automotive topcoat: 

single stage-topcoat 600 5.0 

2 stage basecoat/clearcoat 600 5.0 

3 or 4-stage basecoat/clearcoat 625 5.2 

Automotive Multi-colored Topcoat 680 5.7 

Automotive specialty 840 7.0 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-13 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Cement Kilns

Control Measure Summary: 

Emissions (tons/year) in Ozone 

Transport Region 

2002 existing measure: NSR; PSD; State RACT. 

Emission Reductions: 

Control Cost: 

Timing of Implementation: 

Implementation Area: OTR 

NOx 

2002 Base: 31,822

On the Books: NOx SIP Call

Measure ID: NOx SIP Call 

Emission Reductions: The SIP Call requirements were estimated 

by EPA to result in NOx reductions of approximately 25 percent 

from the cement industry. 

Control Cost: $2,000 per ton 

Timing of Implementation: 2004 

Implementation Area: OTR 

NOx 

2009 Uncontrolled: 

with growth: 

2009 Reduction: 

2009 Remaining: 

33,588 

-8,397

25,191

Candidate measure: Selective Non-catalytic Reduction (SNCR) 

Measure ID: SNCR 

Emission Reductions: 10-80 percent from 2002 base. Rates need 

to be expresses in BTU or clinker per unit time 

Control Cost: less than 2,500 per ton 

Timing of Implementation: 01/01/09 

Implementation Area: OTR

 NOx 

2009 Uncontrolled: 

NOx SIP Reduction: 

Candidate Reduction: 

2009 Remaining: 

33,588 

-8,392 

*-11,761

13,435 

* reduction 

of 60% from 

uncontrolled 

minus 

reduction due 

to NOx SIP 

Call 

Policy Recommendation: It is recommended that a program be developed reduces NOx emissions from 

existing cement kilns to an emission rate of 2.0 pounds per ton of clinker by 2009. Trading between 

facilities would not be permitted, but averaging at a facility would be permissible. 

Brief Rationale for Recommended Strategy: This limit is consistent with the emission reduction 

capabilities of SNCR. There are 18 full-scale SNCR installations in Europe. The use of SCR has been 

tested on a kiln in Missouri and a kiln in Europe and should be examined further. 

REFERENCES 

EC/R Incorporated. NOx Control Technologies for the Cement Industry – Final Report. September 19, 

2000. This report for EPA shows data for two SNCR technologies, biosolids injection and NOXOUT®. 

These technologies showed average emission reductions of 50 and 40 percent, respectively. For biosolids 

injection, “Cost effectiveness for this kiln is based on the annualized costs of ($320,000/year), the 

emission reduction achieved at that facility (emissions decreased from 2.4 lb/ton of clinker to 1.2 lb/ton of 

clinker), a kiln capacity of 215 tons/hr, and an annual operation of 8,000 hr/yr. Cost effectiveness is a 

credit of ($310/ton) for installing biosolids injection on this kiln” due to tipping fee for using biosolids 

(dewatered sewage sludge) For NOXOUT®, “40 percent NOX reduction based on the available test data. 

Cost effectiveness for the two kilns, using urea as the reagent, is based on an uncontrolled emission rate of 

3.8 lb NOX/ton of clinker, kiln capacities of 92 and 130 tons/hr respectively, annual operation of 8,000 

hr/yr, and a NOX control efficiency of 40%. Cost effectiveness is $1,000/ton for the smaller kiln and 

$2,500/ton for the larger kiln.” 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-14 

MACTEC Federal Programs, Inc. 

European Commission. Integrated Pollution Prevention and Control (IPPC) Reference Document on Best 

Available Techniques in the Cement and Lime Manufacturing Industries. December 2001. These report 

indicates that there are 18 full-scale SNCR installation in Europe. Most SNCR installations are designed 

and/or operated for NOx reduction rates of 10-50% which is sufficient to comply with current legislation 

in some countries. Two Swedish plants installed SNCR in 1996/97 and have achieved a reduction of 80-

85% at both kilns.

Emission Rates: 

Table 4-5 of the EPA’s NOx Control Technologies for the Cement Industry, September 19, 2000 provides 

the following uncontrolled emission rates for the four types of cement kilns: 

Kiln Type 

Heat Input 

Requirement 

(mmBtu/ton 

of clinker) 

Average 

NOx 

Uncontrolled 

Emission 

Rate 

(lb/ton of 

clinker) 

Range of 

NOx 

Uncontrolled 

Emission 

Rate 

(lb/ton of 

clinker) 

Wet 6.0 9.7 3.6 to 19.5 

Long Dry 4.5 8.6 6.1 to 10.5 

Preheater 3.8 5.9 2.5 to 11.7 

Precalciner 3.8 3.8 0.9 to 7.0 

The OTC Control Measure Summary Sheet calls for a 60% reduction from uncontrolled 

emissions. Using this percent reduction figure and the uncontrolled emission rates above, the 

following controlled emission rates were calculated: 

Kiln Type 

Percent 

Reduction 

from 

Uncontrolled 

Low-End 

NOx 

Controlled 

Emission 

Rate 

(lb/ton of 

clinker) 

Average 

NOx 

Controlled 

Emission 

Rate 

(lb/ton of 

clinker) 

High-End 

NOx 

Controlled 

Emission 

Rate 

(lb/ton of 

clinker) 

Wet 60 1.44 3.88 7.80 

Long Dry 60 2.44 3.44 4.20 

Preheater 60 1.00 2.36 4.68 

Precalciner 60 0.36 1.52 2.80 

The State/workgroup lead (Terry Black) recommended a program be developed that reduces 

NOx emissions from existing cement kilns to an emission rate of 2.0 pounds per ton of clinker by 

2009. Trading between facilities would not be permitted, but averaging at a facility would be 

permissible. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-15 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Chip Reflash 

Control Measure Summary: Upgrade the version of software in engine electronic 

control module (ECM) aka “Chip Reflash”. Software reprograms the vehicle's 

computer and reduces off-cycle NOx emissions. The installation process 

typically takes between one-half to one hour.

Emissions Reductions 

(tons/day) 

2002 existing measure: 

No existing measure in the OTR other than the EPA program resulting from the 

consent decrees on 7 heavy duty engine manufacturers. The results of the EPA 

program thus far are significantly lower than the level originally projected by the 

Agency (less than 10% implementation). CARB implemented a voluntary program 

that did not achieve its expected results, so the Board’s backstop mandatory program 

was triggered. The CARB mandatory program is facing two separate legal 

challenges, alleging that CARB has breached its settlement agreement and alleging 

that CARB is illegally establishing different emissions standards on “new engines”. 

Candidate measure: 

Measure ID: Model rule for Mandatory Chip Reflash Program in the OTR 

Emission Reductions: NOx reduction (TPD) from in-state registered vehicles 

Control Cost: Moderate – manufacturers must provide the rebuild kits free to any 

truck operator who requests it. The cost associated with the reflash has been 

estimated at $20-$30 per vehicle, which is borne by the engine manufacturer. There 

may be costs associated with potential downtime to the trucking firms, and recordkeeping requirements on the dealer performing the reflash and the vehicle owner. For 

the MRPO, ENVIRON estimated cost effectiveness to be “$1,800 to $2,500 

(depending on vehicle size) due to incremental “fuel penalty” of 2% increase in fuel 

consumption). However, in reality, no fuel penalty has been documented on vehicles 

that have already been reflashed. 

Timing of Implementation: The kits are currently available, so once the states adopt 

the rule, retrofits can begin according to the schedule. 

Implementation Area: All OTR and MRPO states (NOx reductions 109 TPD) 

LADCO 

Northeast 

states 

MidAtlantic 

States 

Total OTR 

46 TPD 

41 TPD 

22 TPD 

63 TPD 

Policy Recommendation of State/Workgroup Lead: Expand scope of the model 

rule for the Northeast states to the entire OTR and MWRPO

Brief Rationale for Recommended Strategy: While the EPA program provides a 

good platform for chip reflash retrofits, the federal program is not even achieving 

10% of its estimated emission reductions. The kits are available and must be given 

to the truckers for free; yet without additional motivation, it is unlikely that the 

implementation rate will improve due to fuel consumption and/or performance 

perceptions and the ability to extend the time to next major rebuild/overhaul. The 

states in the OTR do not face the prospect of breach-of-settlement allegations that 

CARB did in adopting a mandatory program, since they did not participate in the 

negotiation of the CD settlements. And there are significant emission reductions that 

can be achieved through a mandatory program, even though installing the kits will 

not result in the engines operating at the same emission levels required for the EPA 

engine certification test. Nevertheless, this is a relatively simple fix for a problem 

that our states will face if they rely on the federal program alone to produce emission 

reductions from these sources.
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-16 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Consumer Products

Control Measure Summary: Consumer Products 

This control measure establishes limits on the VOC content of consumer 

products. It is based on the California Air Resources Board (CARB) 

consumer products rules, with some region specific modifications. It 

regulates categories such as hairspray, air fresheners, glass and general 

purpose cleaners, adhesives, anti-perspirants and deodorants, insecticides 

and automotive aftermarket products. 

VOC Emissions in Ozone 

Transport Region 

2002 Existing Measure: The Federal Consumer Products Rule Part 59 

Emission Reductions: 20 % reduction of the categories being regulated 

or 9.95 % reduction of the entire consumer products inventory (about 

40 % of products were included in rule). 

Control Cost: $237 per ton of VOC reduced 

Timing of Implementation: 12/98 

Implementation Area: Nationwide 

2002 Annual 

Uncontrolled: 

Reduction: 

Remaining: 

2002 Summer 

Uncontrolled: 

Reduction: 

Remaining: 

258,537 tpy 

25,724 tpy 

232,813 tpy 

713.9 tpd 

71.0 tpd 

642.9 tpd

2009 On-the-Books Measure: Adopt the 2001 OTC Model Rule for 

Consumer Products in all OTC states (this model rule was based 

on a series of five CARB consumer products rules).

Emission Reductions: 14.2 % beyond federal rule or a total of 21 % 

from the uncontrolled state. 

Control Cost: $800 per ton VOC reduced 

Timing of Implementation: 1/1/05 effective date of VOC limits 

(though some states were later and some have yet to adopt) 

Implementation Area: OTR 

2009 Annual 

Reduction: 

Remaining: 

2009 Summer 

Reduction: 

Remaining: 

22,916 tpy 

209,897 tpy 

63.4 tpd 

579.5 tpd

Candidate Measure #1: Adopt the CARB amendments to their 

consumer products rule, adopted 7/20/05, with the exception of the 

12/31/09 shaving gel, and 12/31/08 anti-static aerosol VOC limits. 

This rule sets new VOC limits for 11 categories, revises the existing 

VOC limit for 1 category and includes some additional requirements. 

See more detailed limits below. 

Emission Reductions: CARB estimates their rule will achieve a 6.3 

ton/day reduction of VOC in California, which is equivalent to about 

11.3 tons per day in the OTR or a 2% reduction beyond the on-thebooks measure. 

Control Cost: $4,800 per ton of VOC reduced 

Timing of Implementation: 01/01/09 

Implementation Area OTR

2009 Annual 

Reduction: 

Remaining: 

2009 Summer 

Reduction: 

Remaining: 

7,453 tpy 

202,444 tpy 

20.6 tpd 

558.9 tpd 

Candidate Measure #2: Follow and adopt as appropriate CARB ‘s 

next round of amendments to their consumer products rule, to be 

developed and proposed by approximately late 2006/early 2007 

with limits effective in 2010. 

Emission Reductions: The CONS-2 amendments are estimated by 

CARB to achieve VOC reductions of about 20-35 tpd in California by 

2010 which is equivalent to about 36-63 tpd in the OTR (The midpoint of this range was used in the calculations, 49.5 tpd). 

Control Cost: Unknown at present; 

Timing of Implementation: 01/01/10 

Implementation Area OTR

VOC not 

modeled: 

2009 Annual 

Reduction: 

Remaining: 

2009 Summer 

Reduction: 

Remaining:

Not 

Available
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-17 

MACTEC Federal Programs, Inc. 

Summary of Candidate Measure #1: The proposed VOC limits based on CARB’s 7/20/05 amendments are 

as follows: 

PRODUCT CATEGORY 

CARB VOC 

CONTENT 

LIMIT % 

OTC 

PROPOSED 

CONTENT 

LIMIT% 

CARB 

EFFECTIVE 

DATE 

OTC 

PROPOSED 

EFFECTIVE 

DATE 

Adhesive, Contact – General purpose * 55 55 12/31/2006 1/1/2009 

 Special Purpose* 80 80 12/31/2006 1/1/2009 

Adhesive Remover - Floor or Wall covering 5 5 12/31/2006 1/1/2009 

 Gasket or Thread Locking 50 50 12/31/2006 1/1/2009 

 General Purpose 20 20 12/31/2006 1/1/2009 

 Specialty 70 70 12/31/2006 1/1/2009 

Anti-static - non-aerosol 11 11 12/31/2006 1/1/2009 

Electrical Cleaner 45 45 12/31/2006 1/1/2009 

Electronic Cleaner 75 75 12/31/2006 1/1/2009 

Fabric refresher – aerosol 15 15 12/31/2006 1/1/2009 

 non-aerosol 6 6 12/31/2006 1/1/2009 

Footware or Leather Care - aerosol 75 75 12/31/2006 1/1/2009 

 Solid 55 55 12/31/2006 1/1/2009 

 all other forms 15 15 12/31/2006 1/1/2009 

Graffiti Remover –aerosol 50 50 12/31/2006 1/1/2009 

 non-aerosol 30 30 12/31/2006 1/1/2009 

Hair Styling Products – aerosol & pump sprays 6 6 12/31/2006 1/1/2009 

 all other forms 2 2 12/31/2006 1/1/2009 

Shaving Gel 7 7 12/31/2006 1/1/2009 

Toilet/Urinal Care – aerosol 10 10 12/31/2006 1/1/2009 

 non-aerosol 3 3 12/31/2006 1/1/2009 

Wood Cleaner – aerosol 17 17 12/31/2006 1/1/2009 

 non-aerosol 4 4 12/31/2006 1/1/2009 

* Change to an existing category 

Brief Rationale for Recommended Strategy: CARB, through their comprehensive history of research and 

multiple product surveys, have the best technical data available to create rules to regulate consumer 

products. Most consumer products manufacturers market their products nationally, therefore many will be 

selling the new products nationally after they have reformulated for the CARB rules. 

References: 

2002 Existing Measure (Federal Part 59 Rules): 

E.H. Pechan & Associates, Inc., Control Measure Development Support Analysis of Ozone Transport 

Commission Model Rules, March 31, 2001. 

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation Report, September 2005. 

Pages III-1377 shows the Federal Part 59 rule at a cost of $237 per ton (1990$). 

2009 On-the-Books Measure (OTC Model Rule): 

E.H. Pechan & Associates, Inc., Control Measure Development Support Analysis of Ozone Transport 

Commission Model Rules, March 31, 2001. Table II-6 shows 14.2% reduction (OTC Model Rule 

beyond Federal rule). Page 8 presents cost of $800 per ton based on CARB’s Sept. 1999 Initial 

Statement of Reasons for Proposed Amendments to the California Consumer Products Regulation. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-18 

MACTEC Federal Programs, Inc. 

Candidate Measure #1 (CARB 2005 and 2006/2007 Amendments): 

California Air Resources Board. Initial Statement of Reasons for Proposed Amendments, Volume 1: 

Executive Summary. June 24, 2004. Table 2 of the Executive Summary shows that the CONS-1 

amendments will achieve reductions of about 6.8 tons per day state wide (6.3 tons per day without the 

12/31/09 Shaving gel, and 12/31/08 anti-static aerosol regs.. Page 21 states the cost of CONS-1 will 

be $2.40 per pound ($4,800 per ton). Since OTC’s model rule is very similar to the CARB’s rule, and 

emissions are proportional to population, CARB’s 6.3 ton per day reduction was prorated to the OTC 

region based on the ratio of OTR 2002 population (63 million) to CA 2002 population (35 million) 

yielding approximately 11.3 tons per day in the OTR (4,139 tons per year). 

Page 4 states that the estimated reductions from CONS-2 (not yet proposed) will achieve 20-35 tons 

per day statewide by 2010. Since OTC’s model rule is very similar to the CARB’s rule, and emissions 

are proportional to population, the mid-point of CARB’s 20-35 ton per day reduction (i.e., 27.5 tons 

per day) was prorated to the OTC region based on the ratio of OTR 2002 population (63 million) to 

CA 2002 population (35 million) yielding approximately 49.5 tons per day in the OTR (18,068 tons 

per year). 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-19 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Glass/Fiberglass Furnaces 

Control Measure Summary: Emissions (tons/year) in Ozone 

Transport Region 

2002 existing measure: NSR; PSD; State RACT. 

Emission Reductions: 

Control Cost: 

Timing of Implementation: 

Implementation Area: OTR 

NOx

2002 Uncontrolled 

(Includes state RACT): 

2002 Reduction: 

2002 Base:

19,017 

0

19,017

Candidate measure: Low NOx Burners

Measure ID: LNBl 

Emission Reductions: 40 percent from 2009 projection 

Control Cost: $ 924 to 2,232 per ton 

Timing of Implementation: 01/01/09 

Implementation Area: OTR 

NOx

2009 projected: 

2009 Reduction: 

2009 Remaining: 

22,990 

- 9,196

13,794 

Candidate measure: Selective Non-catalytic Reduction (SNCR) 

Measure ID: SNCR 

Emission Reductions: 40 percent from 2009 projection 

Control Cost: $ 977 to 2,337 per ton 

Timing of Implementation: 01/01/09 

Implementation Area: OTR

NOx

2009 projected: 

2009 Reduction: 

2009 Remaining: 

22,990 

- 9,196

13,794 

Candidate measure: Oxyfiring 

Measure ID: Oxy 

Emission Reductions: 85 percent from 2009 projection 

Control Cost: $ 1,254 to 2,500 per ton 

Timing of Implementation: 01/01/09 and later 

Implementation Area: OTR

 NOx 

2009 projected: 

2009 Reduction: 

2009 Remaining

22,990 

- 18,392

 4,598 

Control Measure Recommendation: Develop a control strategy that requires implementation of an 

“oxyfiring” program for each furnace at the next furnace rebuild. From 2009 to the completion of the furnace 

rebuild, the owner/operator would be required to purchase NOx allowances equal to 85% of the actual furnace 

emissions for the ozone season. Continuous emission monitoring systems would be used to determine 

emissions. This Measure should be modeled at 85% reduction. 

States may instead choose to implement emission limits based on California’s San Jacquie Valley Rule 4354. 

Compliance with Rule 4354 will allow manufactures to use a mix of control options to meet the suggested 

limits. Manufacturers may propose alternative compliance methods to meet the specified limits. 

Brief Rationale for Recommended Strategy: Oxyfiring is best implemented, and provides the most 

effective NOx emission reductions, with a complete furnace rebuild. This strategy not only reduces NOx 

emissions by as much as 85 percent, but reduces energy consumption, increases production rates by 10-15%, 

and improves glass quality by reducing defects. Oxyfiring is demonstrated technology and has penetrated into 

all segments of the glass industry. 

REFERENCES 

European Commission, Integrated Pollution Prevention and Control (IPPC) Bureau. Reference Document 

on Best Available Techniques in the Glass Manufacturing Industry. December 2001. This document 

reports 75 to 85% reduction in NOx and emission rates of 1.25 to 4.1 lbs NOx/ton. The cost effectiveness 

was determined to be $1,254 to $2,542 depending on the size of the furnace. 

U.S. EPA Alternative Control Techniques Document – NOx Emissions from Glass Manufacturing, EPA453/R-94-037, June 1994. Oxyfiring reduction of 85%, cost-effectiveness of $2,150 to $5,300.
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-20 

MACTEC Federal Programs, Inc. 

Emission rates based on San Jacquin Valley Rule 4354 

Type of Furnace Block 24-hour Average Rolling 30-day average 

 Container Glass 4.0 pounds of NOx per ton 

of glass pulled 

4.0 pounds of NOx per ton 

of glass pulled 

 Fiberglass 4.0 pounds of NOx per ton 

of glass pulled 

4.0 pounds of NOx per ton 

of glass pulled 

 Flat Glass 9.2 pounds of NOx per ton 

of glass pulled 

7.0 pounds of NOx per ton 

of glass pulled 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-21 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial, Commercial, Institutional (ICI) Boilers – Jointly processed with MANE-VU 

ICI Boiler Size 

(mmBtu/hr) 

Control Strategy/ 

Compliance Option 

NOx 

Control Measure 

SO2

Control Measure 

Notes 

Less than 25 OTC Proposal Annual 

Boiler Tune-Up 

(OTC-10% Reduction from 

2009) 

#2 fuel oil - 0.05% S by wt. 

by 2012 

#4 fuel oil - 0.25% S by wt. 

by 2012 

For 5-25 

mm Btu/hr 

Annual Boiler 

Tune-Up 

#2 fuel oil same as 

On-road low 

sulfur diesel oil 

Natural Gas 

0.05 lb NOx/mmBtu 

#2 Fuel Oil 

0.08 lb NOx/mmBtu 

#4 or #6 Fuel Oil 

0.20 lb NOx/mmBtu 

OTC Proposal 

Strategy #1 

(Choice of strategy is at 

the discretion of the 

source) Coal 

0.30 lb NOx/mmBtu** 

OTC Proposal 

Strategy #2 

(Choice of strategy is at 

the discretion of the 

source)

50% Reduction from 

uncontrolled 

(OTC: for 25-50 mm Btu/hr 50% 

Reduction from 2009, for 50-

100 mm Btu/hr 

10% Reduction from 2009) 

25-100 

OTC Proposal 

Strategy #3 

(Choice of strategy is at 

the discretion of the 

source)

Purchase Current year CAIR 

NOx Allowances 

#2 fuel oil - 0.05% S by wt. 

by 2012 

#4 fuel oil - 0.25% S by wt. 

by 2012 

#6 fuel oil - 0.50% S by wt. 

by 2012

For 25-50 

mmBtu/hr 

Initial stack test 

then Annual 

Boiler Tune-Up 

For 50-100 

mmBtu/hr 

Initial NOx 

stack test then 

once every 5 

years and 

Annual Boiler 

Tune-Up 

#2 fuel oil same as 

On-road low 

sulfur diesel oil

Natural Gas 

0.10 lb NOx/mmBtu

#2, #4, or #6 Fuel Oil 

0.20 lb NOx/mmBtu

Natural Gas & Fuel Oil 

Combined 

0.20 lb NOx/mmBtu 

OTC Proposal 

Strategy #1 

(Choice of strategy is at 

the discretion of the 

source) Coal 

Wall-fired 0.14 lb NOx/mm Btu 

Tangential 0.12 lb NOx/mm Btu 

Stoker 0.22 lb NOx/mm Btu 

FBC 0.08 lb NOx/mm Btu 

Strategy #2 LNB/SNCR*, LNB/FGR*, 

SNCR, SCR, or some 

combination of these controls 

Strategy #3

60% Reduction from 

uncontrolled 

(OTC-Nat gas 75%, Oil 40%, 

Coal 25% Reduction from 2009)

100-250 

Strategy #4

Purchase Current year CAIR 

NOx Allowances 

#2 fuel oil - 0.05% S by wt. 

by 2012 

#4 fuel oil - 0.25% S by wt. 

by 2012 

#6 fuel oil - 0.50% S by wt. 

by 2012

Initial NOx 

stack test then 

once every 5 

years and 

Annual Boiler 

Tune-Up 

#2 fuel oil same as 

On-road low 

sulfur diesel oil
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-22 

ICI Boiler Size 

(mmBtu/hr) 

Control Strategy/ 

Compliance Option

NOx 

Control Measure

SO2

Control Measure

Notes

MACTEC Federal Programs, Inc. 

 *LNB/SNCR and LNB/FGR are examples of NOx control technologies for achieving 

NOx reductions. 

 **Emission rate from March 6, 2001 OTC Model Rule. 

OTC Proposal 

Strategy #1 

(Choice of strategy is at 

the discretion of the 

source)

Include in NOx SIP Call or 

purchase 

Current year CAIR NOx 

allowances

Purchase 

Current year CAIR SO2

allowances

NOx CEMs 

Phase I – 2009 

0.12 NOx lb/mmBtu 

(OTC-20% Reduction from 2009 

if NOx SIP call and 30% 

Reduction if not NOx SIP call) 

Phase I – 2009 

0.35 lb SO2/mmBtu

Greater than 

250 Equivalent to 

proposed 

EGU Control 

Measures 

OTC Proposal 

Strategy #2 

(Choice of strategy is at 

the discretion of the 

source) Phase II – 2013 

0.08 NOx lb/mmBtu 

Phase II – 2013 

0.25 lb SO2/mmBtu 

NOx CEMS 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-23 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Fabric Printing

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in 

Ozone Transport Region 

Fabric Printing, Coating and Dyeing - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties 

 EPA CTG RACT limit: 2.9 lbs VOC/gal coating [0.35 kg/liter] (minus 

H2O & exempt solvents) 

 Applicability: Sources 3 lbs/hour, 15 lb/day or 10 tons/year 

uncontrolled emissions 

 OTC state RACT limits: MD, NJ, NH = 2.9 lbs/gal coating 

 MA = 4.8 lbs VOC/gal of solids applied (equivalent to 2.9 lbs/gal 

coating) 

VOC 

Actual 2002:

(not 

available)

Fabric Printing, Coating and Dyeing - 2009 On-the-Books measures: 

 MACT Std. - Subpart OOOO (68 FR 32172, 5/29/03) 

 EPA MACT limits existing sources: 

 Coating and printing operations - 0.12 kg HAP/liter solids 

 Dyeing and finishing operations - 0.016 kg HAP/liter solids 

 Dyeing operations only - 0.016 kg HAP/liter solids 

 Finishing operations only - 0.0003 kg HAP/liter solids 

Emission Reductions: 

 Nationwide – 60% HAP reduction from 1997 baseline 

 MACT Organic HAP control efficiency option: 97% for existing 

sources 

 MACT Estimated VOC reduction 60% (Pechan Table) 

Control Cost: 

 Nationwide –$14.5 million/yr for 4,100 tons/yr = $3,537/ton 

Timing of Implementation: Compliance Date (existing) May 29, 2006 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Fabric Printing, Coating and Dyeing 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: Permanent Total Enclosure 

 Emission Reductions: Estimated VOC reduction 95-97% 

 (Air Control Net 3.0 Table) 

Control Cost: $1,459-$1,565/ton 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr 

ozone nonattainment areas plus adjacent counties, or (3) all counties 

 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-24 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Large Appliances

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in Ozone 

Transport Region 

Large Appliances - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties; 

 EPA CTG RACT limit: 2.8 lbs VOC/gal coating [0.34 kg/liter] 

 (minus H2O & exempt solvents) 

VOC 

Actual 2002: (not 

available)

Large Appliances - 2009 On-the-Books measures: 

 MACT Std. – Subpart NNNN (67 FR 48254, 7/23/02) 

 EPA MACT limits existing sources: 0.13 kg HAP/liter solids 

Emission Reductions: 

 Nationwide – 45% HAP reduction from 1995 baseline 

 MACT Organic HAP control efficiency option: xx% for existing 

sources 

 Estimated VOC reduction: 0% (Pechan Table) - 60%?? 

Control Cost: 

 Nationwide – $1.63 million/yr for 1,190 tons/yr = $1,370/ton

Timing of Implementation: Compliance Date (existing) July 23, 2005 

 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Large Appliances 

Candidate measure 1: Adopt More Stringent RACT regulations (e.g., 

ICAC letter 2/16/2001); lower applicability thresholds, extend 

geographic coverage 

Measure ID: 

 ICAC Option 1 - Nationwide – 80% HAP reduction from 1995 

baseline ( Additional 250 tons/per HAP) 

 ICAC Option 2 - Nationwide – 98% HAP reduction from 1995 

baseline ( Additional 1,190 tons/per HAP) 

Emission Reductions: 

Control Cost: 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr 

ozone nonattainment areas plus adjacent counties, or (3) all counties 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation of: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-25 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Metal Cans

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in 

Ozone Transport Region 

Metal Can - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties; 

 EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt 

solvents)

 Sheet basecoat & over varnish 2.8 [0.34 kg/l] 

 2 and 3-piece can interior & 2-piece can 4.2 [0.50 kg/l] 

 3-piece can side-seam spray 5.5 [0.66 kg/l] 

 End sealing compound 3.7 [0.44 kg/l] 

 Applicability: 10 tons/year uncontrolled emissions 

 OTC state RACT limits: MD, NJ, NH same limits as CTG; 

 MA (4.5, 9.8, 21.8, 7.7 lbs/gallon of solids applied) 

VOC 

Actual 2002: (not 

available)

Metal Can - 2009 On-the-Books measures: 

 MACT Std. – Subpart KKKK (68 FR 64432 , 11/13/03) 

 EPA MACT limits existing sources: 

 Sheet coating 0.03 kg HAP/l solids 

 Body Coating 

 2-piece beverage cans 0.07 kg HAP/l solids 

 2-piece food cans 0.06 kg HAP/l solids 

 1-piece aerosol cans 0.12 kg HAP/l solids 

 3-piece can assembly 

 Inside Spray 0.29 kg HAP/l solids 

 Aseptic side seam strips on food cans 1.94 kg HAP/l solids 

 Nonaseptic side seam strips on food cans 0.79 kg HAP/l solids 

 Side seam strips on non-food cans 1.18 kg HAP/l solids 

 Side seam strips on aerosol cans 1.46 kg HAP/l solids 

 End sealing compound 

 Aseptic end seal compounds 1.94 kg HAP/l solids 

 Nonaseptic end seal compounds 0.00 kg HAP/l solids 

 Repair spray coatings 2.06 kg HAP/l solids 

 Emission Reductions: 

 Nationwide – 70% HAP reduction from 1997 baseline 

 MACT Organic HAP control efficiency option: xx% for existing 

sources 

 Estimated VOC reduction 70% (Pechan Table) 

Control Cost: 

 Nationwide – $58.7 million/yr for 6,800 tons/yr = $8,632/ton

Timing of Implementation: Compliance Date (existing) Nov. 13, 2006 

 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-26 

MACTEC Federal Programs, Inc. 

Metal Can (Continued) 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: Permanent Total Enclosure 

 Emission Reductions: Estimated VOC reduction 95% 

 (Air Control Net 3.0 Table) 

Control Cost: $7,947/ton 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr 

ozone nonattainment areas plus adjacent counties, or (3) all counties. 

 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-27 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Metal Coils

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in 

Ozone Transport Region 

Metal Coil - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties; 

 EPA CTG RACT limit: 2.6 lbs VOC/gal coating [0.31 kg/liter] 

 (minus H2O & exempt solvents) 

 Applicability: Sources 10 tons/year uncontrolled emissions 

 OTC state RACT limits: NH - same limits as CTG 

VOC 

Actual 2002:

(not 

available)

Metal Coil – 2009 On-the-Books measures: 

 MACT Std. – Subpart SSSS (67 FR 39794 , 6/10/02) 

 EPA MACT limits existing sources: 0.046 kg HAP/liter solids 

Emission Reductions: 

 Nationwide – 53% HAP reduction from current levels? 

 MACT Organic HAP control efficiency option: xx% for existing 

sources 

 Estimated VOC reduction 53% (Pechan Table) 

Control Cost: 

 Nationwide – $7.6 million/yr for 1,316 tons/yr = $5,775/ton

Timing of Implementation: Compliance Date (existing) June 10, 2005 

 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Metal Coil 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: 

Emission Reductions: 

Control Cost: 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr 

ozone nonattainment areas plus adjacent counties, or (3) all counties. 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-28 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Metal Furniture

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in Ozone 

Transport Region 

Metal Furniture - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment 

counties 

 EPA CTG RACT limit: 3.0 lbs VOC/gal coating [0.36 kg/liter] 

 (minus H2O & exempt solvents) 

 Applicability: Sources 10 tons/year uncontrolled emissions 

 OTC state RACT limits: NH - same limits as CTG 

VOC 

Actual 2002:

(not 

available)

Metal Furniture – 2009 On-the-Books measures: 

 MACT Std. – Subpart RRRR (67 FR 28606 , 5/23/03) 

 EPA MACT limits existing sources: 0.10 kg HAP/liter solids 

Emission Reductions: 

 Nationwide – 73% HAP reduction from 1997/1998 baseline 

 MACT Organic HAP control efficiency option: xx% for existing 

sources 

 Estimated VOC reduction 0% (Pechan Table) 

Control Cost: 

 Nationwide – $14.8 million/yr for 16,300 tons/yr = $908/ton

Timing of Implementation: Compliance Date (existing) May 23, 2006 

 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Metal Furniture 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: Permanent Total Enclosure 

 Emission Reductions: Estimated VOC reduction 95% 

 (Air Control Net 3.0 Table) 

Control Cost: $20,115/ton 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr 

ozone nonattainment areas plus adjacent counties, or (3) all counties. 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-29 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Miscellaneous Metal Parts

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in Ozone 

Transport Region 

Miscellaneous Metal Parts - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties 

 EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt 

solvents)

 Clear or transparent top coat 4.3 [0.52 kg/l] 

 Air dries Coatings 3.5 [0.42 kg/l] 

 Coating used in extreme environmental conditions 3.5 [0.42 kg/l] 

 All other coatings 3.0 [0.35 kg/l] 

 Applicability: 10 tons/year uncontrolled emissions 

 OTC state RACT limits: NH same limits as CTG 

VOC 

 Actual 2002: (not 

available)

Miscellaneous Metal Parts – 2009 On-the Books measures: 

 MACT Std. – Subpart MMMM (69 FR 130 , 1/2/04) 

 EPA MACT limits existing sources:

 General use Coating 0.31 kg HAP/l solids 

 High Performance Coating 3.30 kg HAP/l solids 

 Rubber-to-Metal Coating 4.50 kg HAP/l solids 

 Extreme Performance Fluoropolymer 1.5 kg HAP/l solids 

Emission Reductions: 

 Nationwide – 48% HAP reduction from 1997 baseline 

 MACT Organic HAP control efficiency option: xx% for existing 

sources 

 Estimated VOC reduction 0% (Pechan Table)

Control Cost: 

 Nationwide – $57.3 million/yr for 26,000 tons/yr = $2204/ton

Timing of Implementation: Compliance Date (existing) Jan. 2, 2007 

 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Miscellaneous Metal Parts 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: 

Emission Reductions: 

Control Cost: 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

Implementation Area: 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-30 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Paper and Other Web

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in Ozone 

Transport Region 

Paper & Other Web - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties 

 EPA CTG RACT limit: 2.9 lbs VOC/gal coating [0.35 kg/liter] 

 (minus H2O & exempt solvents) 

 Applicability: Sources 3 lbs/hour, 15 lb/day or 10 tons/year 

 uncontrolled emissions 

 OTC state RACT limits: MD, NJ, NH = 2.9 lbs/gal coating 

 MA = 4.8 lbs VOC/gal of solids (equivalent to 2.9 lbs/gal coating) 

VOC 

Actual 2002:

Paper & Other Web – 2009 On-the-Books measures: 

 MACT Std. – Subpart JJJJ (67 FR 72330 , 12/4/02) 

 EPA MACT limits existing sources: 0.2 kg organic HAP/kg coating 

solids 

Emission Reductions: 

 Nationwide – 80% HAP reduction from current levels??

 MACT Organic HAP control efficiency option: 95% for existing 

sources 

 Estimated VOC reduction 80% (Pechan Table) 

Control Cost: 

 Nationwide – $64 million/yr for 34,500 tons/yr = $1,855/ton

Timing of Implementation: Compliance Date (existing) Dec. 5, 2005 

 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Paper & Other Web 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: 

Emission Reductions: 

Control Cost: 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

 

Implementation Area: 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-31 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Plastic Parts

Control Measure Summary: This category includes several source types: 

Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can 

coating, Metal Coil coating; Metal Furniture coating; Misc. Metal 

Parts coating; Paper and Other Web coating; Plastic Parts coating; & 

Wood Building Products coating 

Emissions (tons/year) in Ozone 

Transport Region 

Plastic Parts - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties 

 EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

 Auto Interior Auto Exterior

 High Bake Prime 3.8 [0.46 kg/l] -- 

 High Bake Prime - Flexible -- 5.0 [0.60 kg/l] 

 High Bake Prime – Nonflexible -- 4.5 [0.54 kg/l] 

 High Bake Color 4.1 [0.49 kg/l] 4.6 [0.55 kg/l] 

 Low Bake Prime 3.5 [0.42 kg/l] 5.5 [0.66 kg/l] 

 Low Bake Color 3.5 [0.42 kg/l] 5.6 red or black 

 Low Bake Color -- 4.5 all others 

 Applicability: NH - 50 tons/year uncontrolled emissions 

 OTC state RACT limits: NH - same limits as CTG 

VOC 

Actual 2002: (not 

available)

Plastic Parts - 2009 On-the Books measures: 

 MACT Std. – Subpart PPPP (69 FR 20968 , 4/19/04) 

 EPA MACT limits existing sources: 

 General Use Coating - 0.16 kg HAP/kg coating solids

 Automotive Lamp Coating - 0.45 kg HAP/kg coating solids

 Thermoplastic Olefins - 0.26 kg HAP/kg coating solids

 New Assembled On-Road Vehicles - 1.34 kg HAP/kg coating solids

Emission Reductions: 

 Nationwide – 80% HAP reduction from 1997 baseline

 Estimated VOC reduction 0% (Pechan Table) 

Control Cost: 

 Nationwide – $10.9 million/yr for 7,560 tons/yr = $1,442/ton

Timing of Implementation: Compliance Date (existing) April 19, 2007 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Plastic Parts 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: 

 Emission Reductions: 

Control Cost: 

Timing of Implementation: Assuming 2007 or 2008 effective date of rule, 

emission reductions in 2009 or 2010 

Implementation Area: 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-32 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Wood Building Products

Control Measure Summary: This category includes several source 

types: Fabric, Printing, Coating and Dyeing; Large Appliances; 

Metal Can coating, Metal Coil coating; Metal Furniture coating; 

Misc. Metal Parts coating; Paper and Other Web coating; Plastic 

Parts coating; & Wood Building Products coating 

Emissions (tons/year) in Ozone 

Transport Region 

Wood Building Products - 2002 existing measures: 

 NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties 

 EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt 

solvents)

VOC 

Actual 2002: (not 

available)

Wood Building Products - 2009 On-the-Books measures: 

 MACT Std. – Subpart QQQQ (68 FR 31746 , 5/28/03) 

 EPA MACT limits existing sources: 

 - kg HAP/liter of solids (lb HAP/gal 

solids)

 Doors, Windows & Misc. 0.231 (1.93) 

 Flooring 0.093 (0.78) 

 Interior Wall Paneling & Tileboard 0.183 (1.53) 

 Other Interior Panels 0.020 (0.17) 

 Exterior Siding & Primed Door Skins 0.007 (0.06) 

Emission Reductions: 

 Nationwide – 63% HAP reduction from 1997 baseline

 MACT Organic HAP control efficiency option: xx% for existing 

sources 

 Estimated VOC reduction 63% (Pechan Table) 

Control Cost: 

 Nationwide –$22.5 million/yr for 4,900 tons/yr = $4,592/ton

Timing of Implementation: Compliance Date (existing) May 28, 2006 

 

Implementation Area: Nationwide 

VOC 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB:

(not 

available)

Wood Building Products 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: 

Emission Reductions: 

Control Cost: 

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

Implementation Area: 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation of State/Workgroup Lead: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-33 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings All Categories

Control Measure Summary: This category includes several source types: 

Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can 

coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts 

coating; Paper and Other Web coating; Plastic Parts coating; & Wood 

Building Products coating 

Emissions (tons/year) in Ozone 

Transport Region 

Industrial Surface Coatings Category Total - 2002 existing measures: 

 NSPS: PSD/NSR; State RACT rules in 1-hour non-attainment counties 

Total VOC 

Point &Area 

Actual 2002: 

164,445 

Industrial Surface Coatings Category Total - 2009 On-the-Books measures: 

 MACT Stds. – Subpart OOOO (68 FR 32172, 5/29/03) 

 Subpart NNNN (67 FR 48254, 7/23/02) 

 Subpart KKKK (68 FR 64432 , 11/13/03) 

 Subpart SSSS (67 FR 39794 , 6/10/02) 

 Subpart RRRR (67 FR 28606 , 5/23/03) 

 Subpart MMMM (69 FR 130 , 1/2/04) 

 Subpart JJJJ (67 FR 72330 , 12/4/02) 

 Subpart PPPP (69 FR 20968 , 4/19/04) 

 Subpart QQQQ (68 FR 31746 , 5/28/03) 

Emission Reductions: 

 OTC Regional – x,xxx from 2002 baseline

Control Cost: 

 OTC Regional –$ xx.x million/yr for x,xxx tons/yr = $4,592/ton

Timing of Implementation: Compliance Dates (existing) 5/29/06; 

 (existing) 7/23/05; 

 (existing) 11/13/06; 

 (existing) 6/10/05; 

 (existing) 5/23/06; 

 (existing) 1/2/07; 

 (existing) 12/5/05; 

 (existing) 4/19/07; 

 (existing) 5/28/06 

Implementation Area: Ozone Transport Region 

Total VOC 

Point & Area 

Actual 2002: 

OTB 2009: 

Reduction from 

OTB: 

MANE-VU 

2002 Point* 

MANE-VU 

2002 Area* 

(Ed Sabo’s 

 e-mail 

 01/06/06)

164,445 

-175,983

 -11,448 

 24,931 

139,512 

From 

10/04/05 

draft 

emission 

inventory

Industrial Surface Coatings Category Total 

Candidate measure 1: Adopt More Stringent RACT regulations; lower 

applicability thresholds, extend geographic coverage 

Measure ID: 

 Emission Reductions: 

Control Cost: 

Timing of Implementation: Assuming 2007 or 2008 effective date of rule, 

emission reductions in 2009 or 2010 

Implementation Area: 

 VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

(not 

available)

Policy Recommendation: Final recommendation not made as of June, 2006. 

Brief Rationale for Recommended Strategy: See additional discussion in briefing paper 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-34 

MACTEC Federal Programs, Inc. 

Background Information 

Industrial surface coatings are used during the manufacture of a wide variety of products 

including: fabrics, paper, large appliances, metal cans, metal coils, metal furniture, metal parts, plastic 

parts, and wood building materials. Surface coating is the process by which paints, inks, varnishes, 

adhesives or other decorative or functional coatings are applied to a substrate (e.g., fabric, metal, wood, or 

plastic) to protect or decorate the substrate. Industrial surface coatings can be applied by brushing, 

rolling, spraying, dipping, flow coating, electro-coating, or combinations and variations of these methods. 

The process used to coat a particular product is dependent on the composition of the coating, the substrate 

to which the coating is applied and the intended end use of the final product. After a coating is applied, it 

is dried or cured either by conventional curing through the use of thermal drying ovens, or through the use 

of radiation. During conventional curing, heat from thermal ovens is used to evaporate the solvents 

and/or water trapped in the coating and release them into the atmosphere. Two types of radiation curing 

processes currently in use are ultraviolet (UV) curing and electron beam (EB) curing. 

Emissions are released by the evaporation of the solvents used in the coatings and the evaporation 

of any additional solvents used to dilute (thin) the coating prior to application and for cleaning the coating 

equipment after use. Emissions from surface preparation and coating applications are a function of the 

VOC content of product used. Emissions are also a function of the type of coating process used (rolling, 

dipping, spraying, etc.) and the transfer efficiency of the process. Transfer efficiency is the percentage of 

the coating solids that are applied (e.g., sprayed) which actually adhere to the surface being coated. 

Emissions from cleaning vary with the type of cleanup and the housekeeping practices used. 

Industrial surface coating is estimated to account for approximately 164,000 tons per year of 

VOC emissions in the Mid-Atlantic/Northeast Visibility Union (MANE-VU) region in 2002 from both 

point and area sources. It is important to consider two aspects regarding the accuracy of this emissions 

estimate when assessing this category for additional controls: 

1) The MANE-VU VOC emissions inventory for the industrial surface coating category 

includes emissions from both point and area sources. While the 2002 VOC emissions 

inventory for the MANE-VU region indicates that VOC emission from area sources in 

this category are substantial, the area source part of the emissions inventory is highly 

uncertain and may be substantially overestimated. The method used to estimate area 

source VOC emissions relies heavily on employee emission factors and employment 

data. These emission factors are based on data collected by EPA in the 1980s and 

may not accurately portray the types of coatings, the type of coating equipment, or the 

type of control technology currently in use. 

 

2) At least nine types of industrial surface coating point sources are already controlled 

due to state specific VOC RACT regulations or will soon be controlled prior to 2009 

as a result of the recently promulgated Maximum Achievable Control Technology 

(MACT) standards. Since the MACT standards were designed to control air toxic 

emissions and not necessarily VOC emissions the effectiveness of the MACT 

standards for controlling VOC emissions will vary with the industrial surface coating 

subcategory (e.g., metal cans, wood building products, etc.) and the type of coating 

equipment and the type of solvents used in that subcategory. 

Regulatory History 

 Industrial surface coating processes are currently subject to multiple state and federal regulations 

pursuant to Titles I and III of the Clean Air Act. Title I imposes Standards of Performance for New 

Stationary Sources (NSPS) on new and modified large stationary sources. In the early 1990s, EPA 

promulgated NSPSs for various types of industrial surface coating operations. These regulations applied 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-35 

MACTEC Federal Programs, Inc. 

to surface coating operations that were constructed or modified after effective dates specified in each 

NSPS. In general, surface coating operations constructed or modified after 1980 are subject to NSPS 

requirements. The NSPS generally established VOC emission rate limits that could be complied with 

using either compliant coatings or add-on capture and control equipment. For certain source categories 

the NSPS also set transfer efficiency requirements. 

 New and modified large stationary sources that increase their emissions can also be subject to the 

New Source Review (NSR) requirements of Title I. NSR requires a control technology review for large 

new plants and for modifications at existing plants that result in a significant increase in emissions, 

subjecting these sources to Best Available Control Technology (BACT) in attainment areas and Lowest 

Achievable Emission Rate (LAER) in nonattainment areas. BACT and LAER control requirements are 

updated over time to reflect improvements in control equipment and are reviewed on a case-by-case basis 

during state permitting process. 

 Criteria pollutants, which include VOCs, nitrogen oxides (NOx), sulfur dioxide (SO2), fine 

particulate matter (PMfine), carbon monoxide (CO) and lead (Pb), are also regulated by the State 

Implementation Plans (SIPs) required by Title I. SIPs set forth the states’ strategies for achieving 

reductions of criteria pollutants for which the state is currently out of attainment. SIPs must include 

requirements that all major stationary sources located in nonattainment areas must install reasonably 

available control technology (RACT). RACT levels must be basedon the level of emissions reduction 

that can be reasonably achieved at a reasonable cost. The U.S. EPA has issued a series of Control 

Technology Guidelines (CTGs) and Alternative Control Technologies (ACT) documents to assist states in 

defining RACT for a number of industrial surface coating categories. For categories not covered by a 

CTG or ACT document, state regulations require that a case-by-case RACT determination be made. 

Most of the EPA’s CTGs and ACT documents for the industrial surface coating category were developed 

prior to 1990. While specific RACT requirements will vary from state to state, some OTC states have 

already adopted RACT regulations that are more stringent than the CTG/ACT requirements. 

Policy Recommendation 

 As can be noted from the background information, the regulatory history, and the information contained 

in summary tables, the industrial surface coatings category includes at least nine different major source 

types and multiple processes for each source type with regulations and emissions limits that vary not only 

by major source type, but also by individual process and individual product. In addition, the industrial 

surface coatings category is already subject to a variety of regulations (NSPS; PSD/NSR, state RACT, 

MACT, state specific rules on hazardous air pollutants) that were adopted to achieve different goals. 

Some regulations (e.g., RACT) were designed to reduce VOC emissions. Other regulations (e.g., MACT) 

were designed to reduce emissions of hazardous air pollutants but have the side benefit of reducing VOC 

emissions as well. 

 

 Analysis of the potential benefits and costs of adopting additional VOC control measures, Beyond OnThe-Way (BOTW) measures) is further complicated by the following: 

1) Uncertainty as to the accuracy of the current (2002) MANE-VU VOC emissions inventory 

for the industrial surface coatings category; 

2) Difference in current VOC RACT limits among the OTC states; 

3) Difference in the estimates of the potential VOC reductions from MACT standards; and 

4) Difference in the source size and geographic area covered by a specific regulation. 

 The most recent version of the (2002) MANE-VU VOC emissions inventory for the MANE-VU region 

estimates total VOC emissions from the industrial surface coatings category to be 164, 445 tons (24,931 

tons of VOC from point sources and 139,512 tons from area sources). Further investigation into the 

amount of VOC emissions from area sources will most likely reveal that these VOC emissions are 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-36 

MACTEC Federal Programs, Inc. 

substantially overestimated due in part to the emission factors and employment data used and in part to 

the cutpoints used by various states for distinguishing a point source from an area source. 

 

 A quick sampling of the current VOC RACT limits in the OTC states reveals differences not only in the 

limits for existing sources (lbs. VOC per gallon of coating minus water and exempt solvents), but also in 

the size of source to which these limits apply. 

 Several complications arise when trying to calculate the potential VOC reductions from a particular 

MACT standard including the following: 

 

1) Not all toxics regulated under the MACT are VOCs; 

2) MACT standards are expressed as kg HAP/liter of solids or lbs. HAP/gallon of solids not lbs. 

VOC/gallon of coating minus water and exempt solvent so the MACT limit applies to all 

HAPs not just VOCs; and 

3) The specific types of processes and coatings regulated under the MACT standards are 

different than the types of processes and coatings regulated under the RACT standards. 

These complications have lead to widely varying estimates of the potential additional VOC reductions 

from the application of a particular MACT requirement (from 0% to as much as 80% VOC reduction 

nationwide). 

 RACT standards and MACT standards apply to sources located in different geographic areas throughout 

the Ozone Transport Region. For some OTC states RACT standards apply only to sources located in 1-

hour ozone nonattainment counties while in other OTC states RACT standards apply statewide. MACT 

standards are applicable nationwide and only to major HAP sources (10 tons/year of individual HAP or 

25 tons/year of combined HAPs). 

Given all of these uncertainties the following options are available: 

1) OTC states that currently have higher VOC RACT limits than the EPA CTG/ACT VOC 

RACT limits can adopt more stringent RACT regulations; 

2) OTC states can extend the geographic coverage for RACT limits to statewide; 

3) OTC states can lower the RACT applicability thresholds 

4) OTC states can adopt more stringent control requirements for specific industrial surface 

coating categories (e.g., permanent total enclosures for metal can coating processes). 

Policy recommendations: 

1) Due to uncertainty in current MANE-VU VOC emissions inventory for this category, develop 

an improved, state specific VOC emissions inventory for point and area sources for each 

subcategory of industrial surface coatings before requiring additional controls beyond MACT. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-37 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Lime Kilns 

Control Measure Summary: Good combustion practices and kiln 

operation for Lime Kilns. These kilns are used for the calcination 

of limestone. Lime kilns are also often associated with paper 

mills. 

Emissions (tons/year) in Ozone 

Transport Region 

2002 existing measure: NSR; PSD; State RACT. 

Emission Reductions: 

Control Cost: 

Timing of Implementation: 

Implementation Area: OTR 

NOx 

 Uncontrolled: 

2002 Reduction: 

2002 Base: 

4,649 

 0

 4,649

Candidate measure: Good combustion practices and kiln 

operation 

Emission Reductions: Under Evaluation 

Control Cost: less than $2,000 per ton 

Timing of Implementation: 01/01/09 

Implementation Area: OTR

 NOx 

2009 Base 

including growth: 

2009 Reduction: 

2009 Remaining: 

5,228 

TBD

Policy Recommendation: Final recommendation not made as of June, 2006. 

Recommended Strategy: See additional discussion in briefing paper 

REFERENCES: 

European Commission, Integrated Pollution Prevention and Control (IPPC) Bureau. Reference Document 

on Best Available Techniques in the Cement and Lime Manufacturing Industries. December 2001. “The 

direct transfer of low-NOx burner technology from cement kilns to lime kilns is not straightforward. In 

cement kilns, flame temperatures are higher and low-NOx burners have been developed for reducing high 

initial levels of ‘thermal NOx’. In most lime kilns the levels of NOx are lower and the ‘thermal NOx’ is 

probably less important.” 

Northeast States for Coordinated Air Use Management. Assessment of Control Technology Options for 

BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants, and Paper and Pulp 

Facilities. March 2005. “Due to the design of the lime kiln, SNCRs and SCRs are not viable NOx 

reduction techniques. Installing low-NOx burners is also not a practical NOx reduction technique 

according to a BACT analysis conducted on a new lime kiln in 1997...combustion modification such as 

decreasing excess air is the best way to reduce NOx emissions”. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-38 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Municipal Waste Combustiors 

(Only NOx reductions are evaluated under this strategy) 

Control Measure Summary Emissions (tons/year) in Ozone 

Transport Region 

NOx

2002 Base: 26,139

SO2:

2002 Base 3,865

2002 existing measure: Federal performance standards and emissions 

guidelines for large MWCs (40 CFR 60 Subparts Cb and Eb). No 

control technology is mandated to meet the emissions limitations. 

EPA approved state trading programs for NOx compliance are allowed 

as is facility-wide averaging for NOx compliance. 

Emission Reductions: 19,000 Mg NOx/yr nationally (increment over 

1991 40 CFR 60 Subpart Ca standards).

Control Cost: $7.2 per Mg municipal solid waste combusted. 

Timing of Implementation: Compliance required December 19, 2000. 

Implementation Area: Nationwide. 

VOC:

2002 Base 473

NOx

2009 Reduction: 

2009 Remaining:

-3,610

22,529

SO2 *** 

Implement Federal Rules:

Measure ID: 

Emission Reductions: Varies per state depending on the number of 

MWC units, incinerator technology and chosen emissions limitations. 

In Connecticut, this measure resulted in NOx emissions reductions of 

1.6 tons/summer day and 592 tons/year. 

Control Cost: $0 to approximately $1,500/MMBtu/hr depending on 

whether SNCR was installed in response to the federal emissions 

guidelines and whether SNCR is feasible. 

Timing of Implementation: Assuming timely adoption of state rule 

amendments, compliance with emissions limitations could be required 

by May 1, 2009. 

Implementation Area: Maine, Maryland, Massachusetts, New 

Hampshire, New Jersey, New York and Pennsylvania report operating 

MWC units (assuming state NOx emissions limitations are at the level 

of the federal emissions guidelines). 

VOC *** 

Policy Recommendation of State/Workgroup Lead: 

Individual states with operating MWCs should evaluate the possible reduction of state NOx emissions 

limitations to produce creditable emissions reductions. At the regional level, this strategy should not be 

emphasized as it is state-specific in nature (depending on the MWC population, current control level and 

current state standards); does not require regional implementation to maximize its effectiveness; emissions 

from MWCs are a minor portion of the regional inventory given MACT-based standards required under 

Section 129 of the Clean Air Act; and EPA has proposed more stringent NOx emission limits for MWCs that 

states will be required to adopt and implement as of April 2009. 

Recommended Strategy: 

MWCs are subject to stringent MACT emissions standards, including standards for NOx, under Section 129 of 

the Clean Air Act. To comply with these MACT standards, many MWC owners and operators installed 

control technologies, including SNCR, to comply with the federal deadline of December 19, 2000. Many 

MWCs may be operated to reduce emissions to a level below the current federal standards. For example, 

Connecticut includes a state NOx emission reduction credit (ERC) trading program in its MWC rule. 

Recognizing that the "excess emissions" produced in Connecticut's MWC NOx ERC trading program could 

yield creditable emissions reductions if the required NOx emissions limits were reduced, in October 2000, the 

Department amended the state MWC rule to require the MWC owners and operators to meet more stringent 

NOx emissions limits as of May 1, 2003. The resulting emissions reductions of 1.62 tons of NOx per summer 

day (248 tons per ozone season) were used for compliance with the "shortfall" emission reduction obligation 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-39 

MACTEC Federal Programs, Inc. 

needed for EPA approval of the attainment demonstration for the 1-hour ozone national ambient air quality 

standard. 

Other states in the OTC region have operating MWC units that now comply with MACT-based state emissions 

limitations. Many MWC units now operate with SNCR to control NOx emissions. For MWC units that do not 

now have SNCR, SNCR is likely a feasible RACT measure capable of reducing NOx emissions below the 

state limits. Thus, the reduction of the state MWC NOx limits may produce creditable NOx emissions 

reductions. Furthermore, since MWCs are not subject to the Clean Air Interstate Rule (CAIR) and may not 

participate in a CAIR NOx trading program, reduction of state MWC NOx emissions limitations could be 

considered an equity measure that places MWC owners in a position similar to the owners of large electric 

generating units subject to CAIR. However, the amount of creditable emissions reductions a state may obtain 

from this strategy is limited given EPA's December 19, 2005 proposal of reduced emissions limitations for 

MWCs. 

BACKGROUND INFORMATION

In December 1995, EPA adopted new source performance standards (NSPS) (40 CFR 60 subpart Eb) and 

emission guidelines (subpart Cb) for MWC units with a combustion capacity greater than 250 tons per 

day. Both the NSPS and emission guidelines require compliance with emission limitations for nine 

pollutants including NOx that reflect the performance of maximum achievable control technology 

(MACT). The emission guidelines required compliance by December 2000 for all existing MWCs, while 

the NSPS apply to new MWCs. On December 19, 2005, EPA proposed revisions to the emissions 

guidelines to reflect the levels of performance achieved due to the installation of control equipment (70 

FR 75348). This proposal includes reduced NOx emissions limitations that states will be required to 

adopt and implement by April 2009, if the proposal is finalized. Selective non-catalytic reduction 

(SNCR) is considered MACT for NOx under both the 1995 guidelines and the 2005 proposal. 

Connecticut's MWC regulation, section 22a-174-38 of the Regulations of Connecticut State Agencies 

(R.C.S.A.) (Attachment A), was adopted in June 1999 with NOx emissions limits equivalent to the 

federal emissions guidelines (Phase I NOx limits). Owners and operators of the state's 15 MWC units 

were required to comply with the emissions limits no later than December 19, 2000. R.C.S.A. section 

22a-174-38 was amended in October 2000 to include more stringent NOx emissions limits (Phase II NOx 

limits), for which compliance was required no later than May 1, 2003. The following NOx emissions 

reductions, relative to emissions levels under the Phase I NOx limits, are attributed to the Phase II NOx 

limits in Connecticut: 

• 592 tons per year; 

• 248 tons per ozone season; and 

• 1.62 tons per day during the ozone season.1

 

EPA's December 19, 2005 proposal to update the 1995 emissions standards will substantially reduce the 

ability of other states to achieve the same level of emissions reductions that Connecticut achieved by 

implementing this measure in 2003. 

Add-on NOx Control

The number of NOx-reduction technologies for MWCs are limited as these units use a heterogeneous, wet 

fuel; are less thermally efficient than fossil fuel-fired boilers of comparable heat input; and require larger 

amounts of excess air and less densely-packed heat recovery systems. Low-NOx burners, fuel switching 

and load curtailment are not possible control options. 

 

1

 Assumes 100% rule effectiveness, which is reasonable given that the MWCs are operated with 

continuous emissions monitoring. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-40 

MACTEC Federal Programs, Inc. 

The only generally applicable and feasible add-on control technology for reducing NOx emissions from 

MWCs is SNCR.2

 SNCR is a chemical process for removing NOx from flue gas. In the SNCR process, a 

reagent, typically liquid urea or anhydrous gaseous ammonia is injected within a boiler or in ducts in a 

region where the temperature is between 900 and 1100 degrees Celsius. The reaction converts NOx to 

nitrogen gas and water vapor. SNCR performance depends on factors specific to each type of combustion 

equipment, including flue gas temperature, residence time for the reagent and flue gas, amount of reagent 

injected, reagent distribution, uncontrolled NOx level and carbon monoxide and oxygen concentrations. 

Some disadvantages arise from the use of SNCR including: the high operating temperatures required; 

ineffectiveness at high temperatures with low concentrations of NOx; the need to accommodate enough 

residence time to complete the chemical reaction at high temperatures; and undesirable excess ammonia 

and urea emissions ("ammonia slip") that arise from an incomplete chemical reaction (Thermal Energy 

International, 2000). 

All of Connecticut's large MWC units are equipped with SNCR, including nine mass burn/waterwall units 

and three refuse-derived fuel units. Two tire-fired units subject to the state MWC rule also operate with 

SNCR.3

 Similarly, all of New Jersey's large MWC units are equipped with SCR to meet NOx emissions 

limitations based on the federal emissions guidelines. 

Cost

The capital cost of installing SNCR on a MWC unit is approximately $1,500 MMBtu/hr (see, e.g., 

Institute of Clean Air Companies, 2000).4

 Most of the cost of using SNCR is in operating expenses 

(Institute of Clean Air Companies, 2000), which EPA estimates as falling between 680 and 1,200 

$/MMBtu (1993 dollars). Thus, SNCR is well suited for seasonal control in that it may provide 

significant reductions in NOx emissions but incurs little cost when the system is not in use. EPA has 

assigned an ozone season cost effectiveness to SNCR operated on MWC units of $2,140 per ton of NOx 

reduced (1990 dollars)(EPA, 1999, Table 16). 

Emissions reductions

In Connecticut, MWC facility owners report emissions reductions of 25 to 50% from the operation of 

SNCR; a typical reduction of 35-40% could be assumed from the installation and operation of 

SNCR/ammonia injection to MWC units of similar size and type. Other combustors of varying 

technologies and capacities but with similar baseline NOx emissions have reported reductions ranging 

from 35 - 75% from the operation of urea-based SNCR (Appendix 1, Institute of Clean Air Companies, 

2000). EPA assigns a typical 45% emission reduction to the effectiveness of SNCR at MWCs (EPA, 

1999, Table 16). 

 

2

 The use of SCR to control NOx emissions from MWCs in North American is limited to very few 

units (see, e.g., http://www.region.peel.on.ca/pw/waste/facilities/algonquin-power.htm) because the nature of 

municipal solid waste requires huge SCR reactor sizes and significant actions to prevent catalyst 

poisoning. These factors, combined with the relatively small size of most MWCs, makes the use of SCR 

prohibitively expensive (EPA 2005, comment by IWSA). 

3

 Connecticut also has three mass burn refractory units that are classified as small MWCs and do 

not use SNCR. 

4

 For comparison, EPA places the capital cost of SNCR between 1,600 and 3,300 $/MMBtu (1993 

dollars). In 2002, the 3-unit facility (140 MMBTU/hr per unit) owned by the Connecticut Resources 

Recovery Authority in Bridgeport, Connecticut installed SNCR on all three units at a capital cost of $2.1 

million. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-41 

MACTEC Federal Programs, Inc. 

REFERENCES

Institute of Clean Air Companies. May 2000. Selective Non-Catalytic Reduction (SNCR) for Controlling 

NOx Emissions. http://www.fueltechnv.com/pdf/TPP-534.pdf

Thermal Energy International Inc. 2000. Thermal THERMALONOx Competitive Advantages. 

http://www.thermalenergy.com/solutions/solutions.html

U.S. Environmental Protection Agency. November 1999. Nitrogen Oxides (NOx), Why and How They 

are Controlled. Clean Air Technology Center: EPA 456/F-99-006R. 

U.S. Environmental Protection Agency. April 2005. Corrected Response to Significant Public 

Comments on the Proposed Clean Air Interstate Rule. Comment of IWSA. 

U.S. Environmental Protection Agency. December 19, 2005. Standards of Performance for New 

Stationary Sources and Emission Guidelines for Existing Sources: Large Municipal Waste Combustors; 

Proposed Rule. 70 FR 75348. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-42 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Printing and Graphic Arts 

Control Measure Summary: This category includes categories of both 

heat set and non-heat set operations. It includes lithographic, gravure, 

flexographic and screen printing. It includes both point sources and 

area sources. 

Emissions (tons/year) in 

Ozone Transport Region 

2002 existing measures: RACT, BACT, NSPS 

 

VOC Point 

Actual 2002 

VOC Area 

Actual 2002: 

5,501 

31,738 

2009 On-the-Books measures: MACT Std. - Subpart KK 

 Publication rotogravure – limit organic HAP emissions to no more 

than 8% of volatile matter used each month. Either reformulation or 

92% capture and control efficiency. Product and packaging rotogravure 

and wide-web flexo – limit organic HAP emissions to no more than 5% 

of volatile matter used each month. Either reformulation or 95% 

capture and control efficiency.

 Emission Reductions: 

 Control Cost: 

Timing of Implementation: Compliance Date (existing) December 5, 

2005 

Implementation Area: Nationwide 

VOC Point 

Actual 2002: 

2009 Reduction: 

2009 Remaining: 

VOC Point 

Actual 2002: 

2009 Reduction: 

2009 Remaining:

5,501 

-121

5,380 

31,738 

-0

31,738

Candidate measure: Adopt the requirements of SCAQMD rule 1130 

and 1130.1 

 Emission Reductions: Under evaluation

Control Cost: Under evaluation

Timing of Implementation: Assuming 2007 or 2008 effective date of 

rule, emission reductions in 2009 or 2010 

Implementation Area: OTR 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

Under 

review

Candidate measure: Same option as CM1, except potentially require that 

publication, packaging and product rotogravure and wide web flexo 

printers that are equipped with capture and control equipment, meet the 

capture and control efficiency requirement in the MACT standard for 

VOC reductions (this would apply to facilities not major for HAPs). 

Implementation Area: OTR 

VOC 

OTB 2009: 

BOTW 2009: 

Reduction from 

BOTW: 

Under 

review

Candidate measure: Adopt September 2006 CTGs. In September 

2006, EPA determined that control technique 

guideline (CTG) documents will be 

substantially as effective as national 

regulations in reducing VOC emissions in 

ozone nonattainment areas from the following 

Group II product categories: lithographic 

printing materials, letterpress printing 

materials, and flexible packaging printing 

materials 

Implementation Area: OTR

Under 

Review

Policy Recommendation: Final recommendation not made as of June, 2006. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-43 

MACTEC Federal Programs, Inc. 

Brief Rationale for Recommended Strategy: 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-44 

MACTEC Federal Programs, Inc. 

CONTROL MEASURE SUMMARY FOR 

Portable Fuel Containers

Control Measure Summary: Portable Fuel Containers 

This control measure establishes design and manufacturing specifications 

for portable fuel containers (PFCs) based on the California Air Resources 

Board (CARB) rules. PFCs are used to refuel residential and commercial 

equipment and vehicles. PFCs are used to refuel a broad range of small 

off-road engines and other equipment (e.g., lawnmowers, chainsaws, 

personal watercraft, motorcycles, etc.). 

VOC Emissions 

in Ozone Transport Region 

2002 Existing Measure: None 2002 Annual: 

2002 Summer:

76,861 tpy 

242.5 tpd

2009 On-the-Books Measure: Adopt the OTC Model Rule for PFCs, 

which is based on the 2000 CARB rule for PFCs. 

Emission Reductions: Based on a CE=65%, RE=100%, RP=based on 

the number of years the rule has been in place based on the assumed 

10-yr turnover of the sale of the cans, and Total control = 65% when 

fully implemented after 10 years. 

Control Cost: $581 per ton 

Timing of Implementation: State specific with a 10% per year turnover, 

full reductions are achieved after 10 years. CARB, and the EPA, have 

estimated a 5 year turnover for the cans, but the OTC used a more 

conservative 10 year turnover in calculating emission reductions. 

Implementation Area: OTR 

Annual:

2009 Reduction: 

2009 Remaining: 

Summer:

2009 Reduction: 

2009 Remaining:

25,427 tpy 

51,434 tpy 

82.4 tpd 

160.1 tpd

2009 On-the-Way Measure: Proposed Federal HAP Mobile Source 

Reg (Feb 28, 2006) Rule – This rule proposes to regulate PFCs 

similar to CARBs 2006 rule amendments and will regulate 

permeability to 0.3 grams of HC per gallon per day (2001 OTC Model 

Rule has 0.4 grams per gallon per day). It does not contain CARBs 

amendments regarding kerosene containers and utility jugs. 

Emission Reductions: EPA estimates about a 9% reduction nationwide 

in 2009 and a 61% reduction when fully implemented after 5 years. 

Control Cost: $180 per ton without fuel savings; over the long term, 

fuel savings outweigh costs. 

Timing of Implementation: Jan.1, 2009 effective date of rule and 20% 

per year turnover, full reductions are achieved after 5 years, in 2014. 

Implementation Area: Nationwide

Annual:

2009 Reduction: 

2009 Remaining: 

Summer:

2009 Reduction: 

2009 Remaining:

negligible

51,434 tpy 

negligible

160.1 tpd 

Candidate measure: Adopt the CARB 2006 amendments broadening 

PFC definition to include kerosene containers and utility jugs, 

increasing the permeability requirement from 0.3 grams of 

hydrocarbons per gallon per day to 0.4 grams of hydrocarbons per 

gallon per day, and other changes needed to make the OTC Model 

Rule consistent with CARB 

Emission Reductions: CARB estimates their amendments are expected 

to reduce ROG emissions by 58% after full penetration into the 

marketplace, assumed to be 5 years. 

Control Cost: CARB estimate is $800 to $1,400 per ton reduced 

Timing of Implementation: State specific with a 10% per year turnover, 

full reductions are achieved after 10 years 

Implementation Area: OTR 

Annual:

2009 Base: 

2009 Reduction: 

2009 Remaining: 

Summer:

2009 Base: 

2009 Reduction: 

2009 Remaining:

51,434 tpy 

3,194 tpy

48,240 tpy 

160.1 tpd 

9.8 tpd

150.3 tpd 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-45 

MACTEC Federal Programs, Inc. 

Summary of Candidate Measure: 

The California Air Resources Board (CARB) 2000 PFC regulation establishes design and manufacturing 

specifications for PFCs. PFC emissions are calculated by accounting for emissions from five different 

components related to gas container use: permeation, diurnal, transport-spillage, refueling spillage and 

refueling vapor displacement emissions. The permeation, diurnal emissions (associated with storage) and 

transport-spillage emissions are included in the area source inventory. The equipment refueling spillage and 

refueling vapor displacement emissions are calculated from the non-road model and are included in the nonroad inventory. After four years of implementation and a comprehensive assessment of the program, CARB 

staff identified some problems with the rule related to consumer acceptance and reducing anticipated emission 

reductions. Their 2006 amendments address these issues, as well as expanding on the regulation to increase 

emission reductions. The amendments include the following: 

1. Eliminate the requirement for an auto shutoff. 

2. Eliminate fuel flow rate and fill level standards. 

3. Eliminate one opening standard. 

4. Reduce pressure standard from 10 psig to 5 psig. 

5. Establish a certification program for PFCs. 

6. Expand the definition of a PFC to include utility jugs and kerosene containers. CARB staff determined 

that consumers were using these containers for gasoline. 

7. Change permeability standard from 0.4 grams ROG /gallon-day to 0.3 grams/gallon-day. 

8. Combine the evaporation and permeation standards into a new diurnal standard to simplify certification 

and compliance testing. 

9. Adopt new PFC test procedures. 

10. Include a voluntary Consumer Acceptance Program to support and encourage user-friendly PFC designs 

(i.e., allowing the use of the ARB Star Rating system to clearly identify superior designs as determined by 

users). 

While ARB staff does not expect these changes to affect the cost of gasoline cans, the price of kerosene cans 

could rise to as much as $8.50 per container once the regulations are implemented. CARB also estimates the 

cost-effectiveness to be between $0.40 to $0.70 per pound. 

Recommended Strategy: CARB, through their comprehensive history of research and multiple product 

surveys, have the best technical data available to create rules to regulate portable fuel containers. Most 

portable fuel container manufacturers market their products nationally, therefore many will be selling the 

new products nationally after they have produced cans than conform with the CARB rules. The CARB 

rule contains some revisions to their original rule to ease consumer acceptance of the cans, for states that 

have adopted the original OTC model rule. In addition the CARB rule amendments regulate kerosene 

cans and utility jugs, which the Federal rule proposal does not. 

References: 

2009 On-the-Books Measure (OTC Model Rule): 

E.H. Pechan & Associates, Inc., Control Measure Development Support Analysis of Ozone Transport 

Commission Model Rules, March 31, 2001. Much of the analysis in this report was based on CARB’s 

analysis for CARB’s original 1999 PFC rule , which estimated a 75% reduction that would be fully 

achieved after 5 years (CARB’s assumed life cycle for PFCs). The OTC used a more conservative 10-

year turnover rate in its analysis. Table II-5 of the Pechan report shows the cost of compliance to be 

$581/ton. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-46 

MACTEC Federal Programs, Inc. 

2009 On-the-Way Measure (Proposed 2/28/06 Federal Rule): 

U.S. EPA Office of Transportation and Air Quality. Estimating Emissions Associated with Portable 

Fuel Containers (PFCs), Draft Report, EPA420-D-06-003, February 2006. 

U.S. EPA Office of Transportation and Air Quality. Draft Regulatory Impact Analysis: Control of 

Hazardous Air Pollutants from Mobile Sources, EPA420-D-06-004, February 2006. 

Candidate Measure (CARB 2006 Amendments): 

California Air Resources Board. Final Statement of Reasons for Rulemaking, Including Summary of 

Comments and Agency Response: PUBLIC HEARING TO CONSIDER AMENDMENTS TO THE 

PORTABLE FUEL CONTAINER REGULATIONS. September 15, 2005. 

California Air Resources Board. Initial Statement of Reasons for Proposed Amendments to the 

Portable Fuel Container Regulations. July 29, 2005. Table 5.1 shows the cost-effectiveness of the 

proposed amendments to be $0.40 to $0.70 per pound ($800 to $1,400 per ton) 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix C – Control Measure Worksheets Page C-47 

CONTROL MEASURE SUMMARY FOR 

Regional Fuel 

Control Measure Summary: The OTR proposes a common fuel standard 

for the OTR states that does not require MTBE or Ethanol, but exhibits 

Environmentally Beneficial Combustion Properties.

NOx Emissions 

(tons/summer day) in 

OTR 

2002 existing measure: Federal program in the CAA requiring RFG in 

certain non-attainment areas and allowing other states with non-attainment 

areas to opt-in. All but two states in the OTR are participating, in whole or 

in part, with the federal program, however nearly 1/3 of the gasoline sold 

in the OTR is not RFG. 

Candidate measure: 

Measure ID: OTR-wide Regional Fuel NOx ~ 4.8 tpsd 

Emission Reductions: VOC ~ 139.4 tpsd 

Control Cost: unknown at this time 

Timing of Implementation: 

Implementation Area: All states in the OTR 

Policy Recommendation: Continue to examine the potential for a 

regional fuel, keeping in mind that some states like PA may have 

statutory/legislative constraints. 

Brief Rationale for Recommended Strategy: The Energy Policy Act of 

2005 provides the opportunity for the OTR to achieve a single cleanburning gasoline without MTBE, as it also eliminates the oxygen content 

requirement for RFG. The authority provided in Energy Act is consistent 

with what states promoted through the long debate over 

MTBE/ethanol/RFG. Approximately one-third of the gasoline currently 

sold in the OTR is not RFG; most is conventional gasoline. The new 

authority plus the potential for emission reductions from the amount of 

non-RFG sold in the OTR provides an opportunity for additional emission 

reductions in the region as well as for a reduced number of fuels, and 

possibly a single fuel, to be utilized throughout the region.

 

MACTEC Federal Programs, Inc. 
Draft TSD for OTC Control Measure Evaluation February 13, 2007 

Appendix D –VOC Emissions by County for 2002 and 2009 Page D-1 

Appendix D – VOC Emissions by County for 2002 and 2009 

Table D-1 Adhesives and Sealants VOC Area Source Emission Summary for 2002 and 

2009 by County 

Table D-2 Adhesives and Sealants VOC Point Source Emission Summary for 2002 and 

2009 by County 

Table D-3 Cutback and Emulsified Asphalt Paving VOC Area Source Emission Summary 

for 2002 and 2009 by County 

Table D-4 Consumer Products VOC Area Source Emission Summary for 2002 and 2009 

by County 

Table D-5 Portable Fuel Containers VOC Area Source Emission Summary for 2002 and 

2009 by County 

Due to their large size, these tables are being transmitted electronically in the spreadsheet 

named VOC OTC 2009 Control Measures. There are separate tabs for each of the five 

tables listed above. In the final report, these tables will be provided in electronic format 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix E – NOx Emissions by County for 2002 and 2009 Page E-1 

Appendix E – NOx Emissions by County for 2002 and 2009 

Due to their large size, these tables are being transmitted electronically in the spreadsheet 

named NOx OTC 2009 Control Measures. There are separate tabs for each of the seven 

source categories listed in Section 4. In the final report, these tables will be provided in 

electronic format 

MACTEC Federal Programs, Inc. 
Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 

Appendix F – State ICI Boiler Regulations Page G-1 

Appendix F – State ICI Boiler Regulations 

Due to their large size, these tables are being transmitted electronically in the spreadsheet 

named Appendix F State ICI Regs.xls. There are separate tabs for each state. In the final 

report, these tables will be provided in electronic format 

MACTEC Federal Programs, Inc.