# 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 EngineerDraft 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 NO X 

### 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 fr om OTC 2006 Control Measures ............. 1-7 1-2 NOx Emission Reduction Benefits fr om 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 Promulga tion 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 Promulgati on 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 Guid elines for Cement Kilns.......................... 4-8 4-3 OTC Resolution 06-02 Emission Guid elines for Glass Furnaces...................... 4-10 4-4 OTC Proposal for ICI Boilers............................................................................ 4-12 4-5 Current State Emission Limits a nd Percent Reduction for OTC Proposal Point Source Natural Gas-fired Boilers ............................................................. 4-14 4-6 Current State Emission Limits a nd Percent Reduction for OTC Proposal Point Source Distillate Oil-fired Boilers............................................................ 4-15 4-7 Current State Emission Limits a nd Percent Reduction for OTC Proposal Point Source Residual Oil-fired Boilers ............................................................ 4-16 4-8 Current State Emission Limits a nd Percent Reduction for OTC Proposal Point Source Coal Wall-fired Boilers ................................................................ 4-17 4-9 Current State Emission Limits a nd Percent Reduction for OTC Proposal Point Source Coal Tangential-fired Boilers....................................................... 4-18 4-10 Current State Emission Limits a nd 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 Be nefits by State for 2009: Heavy-Duty Truck Diesel Engine Chip Reflash................................................ 4-22 4-12 OTC 2006 NOx Model Rule Be nefits by State for 2009: Regional Fuels ................................................................................................... 4-23 4-13 OTC 2006 NOx Model Rule Be nefits by State for 2009: Asphalt Pavement Productio Plants................................................................... 4-24 4-14 OTC 2006 NOx Model Rule Be nefits by State for 2009: Cement Kilns ..................................................................................................... 4-25 4-15 OTC 2006 NOx Model Rule Be nefits by State for 2009: Glass/Fiberglass Furnaces.................................................................................. 4-26 4-16 OTC 2006 NOx Model Rule Be nefits by State for 2009: ICI Boilers – Area (minor) Sources................................................................... 4-27 4-17 OTC 2006 NOx Model Rule Be nefits by State for 2009: ICI Boilers – Point (major) Sources................................................................... 4-28 4-18 OTC 2006 NOx Model Rule Be nefits 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 – refe rs 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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## 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 th eir 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 additi onal control measures that could be used by the OTR states in attaining their goals.

The OTC staff and member states formed severa l workgroups to identify and evaluate candidate control measures. Initially, the Workgroups compiled and reviewed a list of approximately 1,000 candidate control measures. These contro l measures were iden tified through published
sources such as the U.S. Environmental Pr otection Agency’s (EPA ’s) Control Technique Guidelines, STAPPA/ALAPCO “Menu of Opti ons” documents, the AirControlNET database,
emission control initiatives in member states as well as other states including California, state/regional consultations, a nd stakeholder input. The Work groups developed a preliminary
list of 30 candidate control meas ures to be considered for mo re 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 ai r quality levels in the Northeaste rn and Mid-Atlantic States.

The Workgroups discussed the candidate control measures during a series of conference calls and workshops held periodically from the sp ring of 2004 through the autumn of 2006. The Workgroups collected and evaluated information re garding emission benefits, cost-effectiveness, and implementation issues. Each of the candidate control measures were summarized in a series of “Control Measure Summary Sheets”. Stakehol ders were provided multiple opportunities to review and comment on the Control Measure Summary Sheets.

Based on the analyses by the OTC Workgr oups, the OTC Commissioners made several
recommendations at the June 2006 Commissioners’ meeting in Bo ston (OTC 2006a-d) and at the November 2006 Commissioners’ meeting in Ri chmond (OTC 2006e-g). The Commissioners
recommended that States consider emission reduc tions 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 el ectric demand day units (these measures will be addressed in a separate OTC report) Finally, the Comm issioners requested that EPA pursue federal regulations and programs designed to ensure national development a nd implementation of control measures for the following categories: ar chitectural and maintena nce 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 proc ess 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 a nd November OTC meetings. Tabl e 1-1 identifies the sector, the source category, and a brief de scription of the cont rol measure. Next is a column that identifies the recommended approach for implemen ting the rule, such as an OTC model rule or updates to existing state-specific rules. The ne xt 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 reducti ons 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.Draft TSD for 2006 OTC Control Measure EvaluationFebruary 13, 2007Section 1 – Executive SummaryPage 1-3Table 1-1 Summary of OTC 2006 Control MeasuresSectorSource CategoryControl MeasureImplementationMethodPercent Reductionfrom 2009 OTB/WEmission LevelsCostEffectivenessNOxVOC($/ton)AreaAdhesives, Sealants,Adhesive Primers, andSealant Primers(Industrial)Enact VOC content limits similar to thosecontained in the CARB RACT/BARCT documentfor adhesives and sealants (Dec. 1998)Model Rule---64VOC: 2,500AreaCutback andEmulsified AsphaltPavingProhibits the use of cutback asphalt furing theozone seasonLimits the use of emulsified asphalt during theozone season to that which contains not more than0.5 mL of oil distillate from a 200 mL sample asdetermined using ASTM Method D244State Rule Update---Statespecificdependingon currentrulesVOC: minimalAreaConsumer ProductsAdopt the CARB 7/20/05 Amendments which setsnew or revises existing VOC limits on 12 consumerproduct categories (does not include reductions forTier2 shaving gels and antistatic aerosols since theyhave a later compliance date).Model Rule---2VOC: 4,800AreaPortable FuelContainersAdopt the CARB 2006 Amendments broadeningthe definition of PFCs to include kerosene anddiesel containers and utility jugs used for fuel, andother changes to make OTC Model Rule consistentwith CARB requirements.Model Rule---StatespecificVOC: 800to 1,400AreaandPointAsphalt ProductionPlantsArea/Point Sources (>25 MMBtu/hr)Batch Natural Gas 0.02 lb/tonBatch Distillate 0.09 lb/tonDrum Natural Gas 0.02 lb/tonDrum Distillate 0.04 lb/tonArea/Point Sources (<25 MMBtu/hr):Low NOx Burner technology, orBest Management Practices, and annual tune-upState Rule Update10 - 35---NOx: <500 to1,250MACTEC Federal Programs, Inc.Draft TSD for 2006 OTC Control Measure EvaluationFebruary 13, 2007Section 1 – Executive SummaryPage 1-4Sector Source Category Control MeasureImplementationMethodPercent Reductionfrom 2009 OTB/WEmission LevelsCostEffectivenessNOx VOC($/ton)AreaandPointIndustrial/Commercial/Institutional (ICI)Boilers>250 mmBtu/hourOption 1 – Purchase current year NOx allowancesequal to reductions needed to achieve the requiredemission ratesOption 2 – Phase I 2009 emission rate equal toEGUs of similar size; Phase II 2013 emission rateequal to EGUs of similar sizeModel RuleBoilerandStatespecific---NOx: 600 to18,000AreaandPointICI Boilers100-250 mmBtu/hourNOx Strategy #1:Nat gas: 0.10 lb/mmBtu#2, #4, $6 Oil: 0.20 lb/mmBtuCoal: 0.08 to 0.22 lb/mmBtu, depending onboiler typeNOx Strategy #2:Reductions achievable throughLNB/SNCR, LNB/FGR, SCR or somecombination of these controlsNOx Strategy #3:60% reduction from uncontrolledNOx Strategy #4:Purchase current year CAIR allowancesState Rule UpdateBoilerandStatespecific---NOx: 600 to18,000AreaandPointICI Boilers25-100 mmBtu/hourNOx Strategy #1:Nat gas: 0.05 lb/mmBtu#2 Oil: 0.08 lb/mmBtu#4, #6 Oil: 0.20 lbs/mmBtuCoal: 0.30 lb/mmBtuNOx Strategy #2:50% reduction from uncontrolledNOx Strategy #3:Purchase current year CAIR allowancesState Rule UpdateBoilerandStatespecific---NOx: 600 to18,000AreaandPointICI Boilers<25 mmBtu/hourAnnual boiler tune-upState Rule UpdateStatespecific---MACTEC Federal Programs, Inc.Draft TSD for 2Section 1006 OTC Control Measure EvaluationFebruary 13, 2007– Executive SummaryPage 1-5MACTEC Federal Programs, Inc.Sector Source Category Control MeasureImplementationMethodPercent Reductionfrom 2009 OTB/WEmission LevelsCostEffectivenessNOx VOC($/ton)PointGlass FurnacesRequire furnace operators to meet the emissionlimits in the San Joaquin Valley rule by 2009.These limits are achievable through implementationof “oxyfiring” technology for each furnace atfurnace rebuild. If the operator does not rebuild thefurnace by 2009 or implement measures to meet thelimits in the San Joaquin Valley rule, the operatorwould be required to purchase NOx allowancesequal to the difference between actual emissionsand the limits in the San Joaquin Valley rule.Compliance with Rule 4354 will allowmanufactures to use a mix of control options tomeet the suggested limits. Manufacturers maypropose alternative compliance methods to meet thespecified limits, including emissions averaging.State Rule orPermitSourcespecific---NOx: 1,254to 2,500PointCement PlantsRequire existing kilns to meet a NOx emission rateof3.88 lbs/ton clinker for wet kiln3.44 lbs/ton clinker for long dry kiln2.36 lbs/ton clinker for pre-heater kiln1.52 lbs/ton clinker for pre-calciner kilnState Rule UpdateSourcespecific---NOx: <2,500OnroadMobileDiesel Truck ChipReflashMandatory program to upgrade the version ofsoftware in engine electronic control module(ECM), (also known as “chip reflash) to reduce offcycle NOx emissions.Model Rule10---NOx: 20-30OnroadMobileRegional Fuel based onReformulated GasolineOptionsExtend RFG requirements to counties in OTC thatcurrently do not have RFG.Memorandum ofUnderstanding -OTCStatespecificStatespecificVOC: $2,500 to$29,000Draft TSD for 2 Section 1 006 OTC Control Measure Evaluation February 13, 2007 – Executive Summary Page 1-6

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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)

StateAdhesives & SealantsCutback\EmulsifiedAsphalt PavingConsumer ProductsPortable FuelConatiners (PFCs)aRegional FuelsTotal VOC ReductionDiesel EngineChip ReflashRegional FuelsAsphalt ProductionCement KilnsGlass/FiberglassbICI BoilersArea SourcesICI BoilersPoint SourcesTotal 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

MA d 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. VA c 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 w ill occur in 2009; additional reductions will occur in later years as new, less-emitting PFCs that comply w ith the OTC 2006 control m easure 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 th e OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassa s 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.Draft TSD for 2006 OTC Control Measure EvaluationFebruary 13, 2007Section 1 – Executive SummaryPage 1-7Figure 1-1 VOC Emission Reduction Benefits from OTC2006 Control Measures in 20090102030405060708090100110CT DE DC ME MD MA NH NJ NY PA RI VT NOVA

VOC Reduction (tpsd)Regional FuelPortable Fuel ContainersConsumer ProductsAsphalt PavingAdhesivesMACTEC Federal Programs, Inc.006 OTC Control Measure EvaluationFebruary 13, 2007– Executive SummaryPage 1-8MACTEC Federal Programs, Inc.Figure 1-2 NOx Emission Reduction Benefits from OTC 2006 Control Measures in 2009Draft TSD for 2Section 10102030405060708090CT DE DC ME MD MA NH NJ NY PA RI VT NOVA

NOx Reduction (tpsd)ICI Boiler (Point)ICI Boiler (Area)Glass FurnacesCement KilnsAsphalt PlantsChip ReflashRegional FuelDraft TSD for 2006 OTC Control Meaure Evaluation February 13, 2007 Section 2 – Introduction Page 2-1



## 2.0 INTRODUCTION

The Ozone Transport Commission (OTC) is a multi-s tate organization created under the Clean Air Act (CAA). The OTC is responsible for advising EP A on transport issues and for developing and implementing regional solutions to the ground-level oz one 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 standard s, the OTC member states are considering control measures appropriate for adoption by all states in the region as part of thei r planning to attain and
maintain the 8-hour ozone National Ambi ent 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 Stat es to consider in adopting control measures to reduce volatile organic compound (V OC) emissions and oxide of nitrogen (NOx), which are ozone precursors, to (1) assist in the attainment of th e one-hour ozone health sta ndard, (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 rule s, 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 provide s a description of the control measures identified by the OTC to help states attain the 8-hour ozone NAAQS. It also describes the associat ed incremental emission
reductions and costs associated with each measure. The control measures anal yzed in this report are those that were identified by the OTC Commissione rs at the June 2006 OTC annual meeting in Boston (OTC 2006a, OTC 2006b, OTC 2006c) and at the N ovember 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 organi c compounds (VOC) will reduce emissions from adhesives, sealants, adhesive prim er, and sealant primer application; cutback and emulsified asphalt paving; consumer products; regiona l fuels; and portable fuel c ontainers. The OTC 2006 control measures for oxides of nitrogen (NOx) will reduc e emissions from asphalt production plants, cement kilns, diesel engine chip reflas h, regional fuels, electric generating units (EGUs), glass and fiberglass furnaces, and industrial, commercial, institutional (ICI) boilers.

Section 3 describes the methods used to estimate th e emission benefits of the VOC control measures. For each source category, there are subsections th at describe the existing Federal and OTC State regulations that affect the VOC emissions, summari ze the major elements of the control measures,
discuss how the emission benefits were quantified, and present in formation on anticipated costs and

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### cost-effectiveness. VOC emissions and reduction s by State and source category in 2002 and 2009 are presented at the end of Section 3. Section 4 pr esents 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 contai ns 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. E ach appendix contains a tabulation of the 2002 base emissions, the projected 2009/2012/2018 emissions and expected em ission reduction benefit from the additional control measures in 2009/2012/2018). Appendix G cont ains a listing of State ICI boiler regulations.

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## 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, s ealants, adhesive primer, and sealant primer application; cutback and emulsified asphalt pa ving; 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 emi ssion reductions for each of the categories and projection years.

3.1 ADHESIVES, SEALANT, ADHESIVE PRIMER, AND SEALANT PRIMER
APPLICATION

Adhesives, sealants, adhesive primer, and seal ant primer are used in product manufacturing, packaging, construction, and instal lation of metal, wood, rubber, pl astic, ceramics, or fiberglass materials. In general, an adhesive is any materi al used to bond two surfaces together. In general,
a sealant is a material with adhesi ve properties that is used primar ily to fill, seal, waterproof or weatherproof gaps or joints between two surfaces.

VOC emissions from this category result from ev aporation of solvents during transfer, drying, surface preparation and cleanup operations. These solv ents 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 pi pe and reacts with the pipe to form a bond. Solvents used to clean the surface before bonding and to clean th e application equipment after bonding also
contribute to VOC emissions.

VOC emissions in this category are primarily fro m industrial and commercial operations such as wood product manufacturers, upholstery shops, adhesi ves retailers and architectural trades, such as building construction, floor cove ring installation and roof repair.

3.1.1 Existing Federal and State Rules
EPA published the consumer and commercial pr oducts rule on September 11, 1998 (40 CFR Part 59 Subpart D) under authority of Section 183(e) of th e Clean Air Act. The Federal Part 59 Subpart C requirements for consumer products re gulate five types of “household” adhesives (aerosols, contact, construction a nd panel, general purpose and stru ctural 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 surr oundings, that are occupied or intended for occupation by individuals.” Thus, the Part 59 rule applies only to adhesives us ed 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 st ringent VOC content limits than the Federal rule. The OTC 2001 model rule for consumer pr oducts 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 c ontainers. 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, wallp aper, shelf liners, or any other product with an adhesive incorporated ont o or in an inert substrat e. For “Contact Adhesive,” adhesive does not include units of product, less pack aging, which consist of more than one gallon

. For “Construction, Panel, and Floor Cove ring Adhesive,” and “General Purpose Adhesive”, adhesive does not include units of pr oduct, 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. "S ealant 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 seal ants; insulating foams; removable caulking compounds; clear/paintable/water resistant caulking compou nds; floor seam sealers; products designed exclusively for automotive uses; or sealers that are applied as continuous coatings. “Sealant and Caulking Compound” al so 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/painta ble/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 wh en cured; is paintable; and is immediately resistant to precipitation upon application.
Thus, the same products sold in containers larg er than the above thresh olds 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 (BAR CT) determination by

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### the California Air Resources Board (CARB) de veloped in 1998. The OTC 2006 model rule has the following requirements:

A. Regulates the applicatio n of adhesives, sealants, adhesi ve 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 requireme nt of at least 85 percent overall control efficiency (capture and destruc tion efficiency), by weight;

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

G. Prohibits the sale of any adhe sive, sealant, adhesive prim er or sealant primer which exceeds the VOC content limits listed in the model rule;

H. Manufacturers must label containers with th e maximum VOC content as supplied, as well as the maximum VOC content on an as-applie d 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, prim er, or sealant that vi olates the provisions of the model rule.

Several adhesive and sealant a pplications and products are exem pt from this model rule: tire repair, assembly and manufacturing of undersea-b ased weapon systems, testing and evaluation associated with research and development, so lvent welding operations for medical devices, plaque laminating operations, products or proces ses subject to other state rules, low-VOC products (less than 20 g/l), and adhesives subj ect 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 stationa ry 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 sealan t VOC emissions in the OTC states fall into the area source category. The remaining four percent of the VOC emissions are include d in the point source inventory.

The emission reduction benefit estimation methodol ogy 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 Cali fornia 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. CA RB 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 devi ces. 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 (C ARB 1998, pg. 18). These emission reductions correspond to a 64.4 to 77.8 percent reduction fr om uncontrolled levels. For OTC modeling purposes, we used the lower end of this range (i.e., 64.4 percent reduc tion) to estimate the
emission benefit for area sources due to the OTC 2006 model rule.

For point sources, we first identified those sour ces that were applying adhesives and sealants (using the source classification c ode of 4-02-007-xx, adhesives appli cation). 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 efficien cies of 99+ percent. Most of the controlled sources reported capture and dest ruction efficiencies in the 90- 98 percent range. Sources with existing control systems that exceed an 85 per cent overall capture and destruction efficiency would meet the OTC 2006 model rule provision for add-on air pollution control equipment; no
additional reductions were calculat ed for these sources. For poin t sources without add-on control equipment, we used the 64.4 percent reduction disc ussed in the previous paragraph based on the
CARB determination.

3.1.4 Cost Estimates
The cost of complying with the new requireme nts includes the cost of using alternative
formulations of low-VOC or water-based adhesi ves, sealants, adhesive primers, and sealant primers and cleanup products. Based on info rmation 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 ge neral categories: hotMACTEC Federal Programs, Inc.Draft TSD for 2006 OTC Control Measure Evaluation February 13, 2007 Section 3 – VOC Analys is Methods Page 3-5



### 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 asphal t, asphalt cement is ble nded or “cut back” with a diluent, typically from 25 to 45 percent by volume of petroleum distillates, depending on the desired viscosity. Emulsified aspha lt is used in most of the same applications as cutback asphalt but is a lower emitting alternative to cutback aspha lt. 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 emulsi fied asphalts contain virtually no VOC diluents; however, some emulsified asphalts may c ontain up to 12 percent VOC by volume.

3.2.1 Existing Federal and State Rules
The EPA published a Control Technique Guidelin e (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 adde d a specification for emulsified asphalt to
the CTG recommendations to limit the content of o il distillate in emulsifi ed asphalt to no higher than 7 percent oil distillate.

Table 3-1 summarizes the current asphalt paving rule s 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 a nd 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 di stillate from a 200 mL sample (as determined using American Society for Testing and Mate rials {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 circ umstances 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 cal ls for a complete ban on the use of cutback asphalt during the ozone season. As shown in Ta ble 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 cutb ack asphalt during the ozone season.

The emission reductions resulti ng 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 measur e limits emulsified aspha lt 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 th e 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 Delawa re. Several other states used an average VOC content of 2.5 percent when develo ping 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 suppl y a baseline VOC content for asphalt paving, we used the 90 percent reduction in VOC emissions from emulsi fied asphalt paving during the

ozone season.

3.2.4 Cost Estimates

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

use.

3.3 CONSUMER PRODUCTS

Consumer and commercial products are those item s sold to retail customers for personal, household, or automotive use, along with the produc ts 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 th e evaporation of propellant and organic solvents during use. Consumer and commercial products include hundreds of individual products, including personal care products, household pr oducts, automotive af termarket products, adhesives and sealants, FIFRA -related insecticides, and othe r 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 re presenting 48 percent of the consumer and commercial products inventory na tionwide. 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 Federa l 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 th is document) to be used by the OTC jurisdictions to develop regulations for additional consumer product cate gories and to specify more stringent VOC
content limits than the Federal rule. The VOC content limits a nd products covered in the OTC
2001 model rule are similar to the rules develo ped 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 amende d 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 subcategor ies, 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 OT C 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 fro m 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 Product a
Graffiti Remover Shaving Gel
Toilet/Urinal Care Product
Wood Cleaner Previously Regulated Category with More Restrictive Limit

Contact Adhesive b
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 shav ing 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 become s 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 OT C 2001 model rule based on the CARB July 20, 2005 amendments. The OTC is not including the an ti-static aerosol product s 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. CA RB acknowledged these co ncerns 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 met hodology 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 be nefits 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 populat ion 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 si milar 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 contro l 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 reformulati on costs incurred for products so ld in California will not have to be incurred again for produc ts sold in the OTR.

3.4 PORTABLE FUEL CONTAINERS

Portable fuel containers (PFCs) are designed for transporting a nd 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 refuelin g at a service station. PFCs are used to refuel a broad range of sm all off-road engines and other equipment (e.g., lawnmowers, chainsaws, personal watercraft, moto rcycles, etc.). VOC emissions from PFCs are classified by five different activities:

• 

### Transport-spillage emissions from PFCs occur when fu el escapes from PFCs that are in transit.

• 

### Diurnal emissions result when stored fuel vapor s 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 cont ainers 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., la wnmowers, chainsaws, personal watercraft, motorcycles, etc.) and from gasoline spilla ge during refueling of the equipment with PFCs. These VOC emissions are already ta ken 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 2 001 model rule provides background for OTC jursdictions to develop regulat ory programs that require spil l-proof containers to meet performance standards that re duce VOC emissions. The performance standards include a requirement that all PFCs to have an automatic shut-off feature preven ting overfilling and an automatic closing feature so the can will be seal ed when it is not being used. The performance standards also eliminate secondary venting ho les and require new plas tics 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 c ontainers 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 ra te, with 100 percent rule pene tration occurring 10 years after adoption of the rule.

CARB determined that the performance standa rds would reduce VOC emissions by 75 percent. CARB’s 2004 analysis (CARB 2004b) suggests th e 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 progr am 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-la beling program that a llows 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 re gulation 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 sp illage. 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 st andards are based on the performance of best available control technologies, su ch 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 OT R have already adopted PFC regulations based on
the OTC 2001 model rule. The OTC 2001 model ru le for PFCs closely mirrors the 2000 version of CARB’s PFC rule. CARB recently amended thei r gas can regulation to address the use of utility jugs and kerosene containe rs that are sometimes offered fo r sale in place of gasoline cans (CARB 2005b). The 2005 and 2006 amendments ar e estimated to reduce VOC emissions by 18.4 tons per day in California at full implemen tation in the year 2015 co mpared 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 th e 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 fr om gasoline spillage during refueling of the equipment with PFCs. The area source inventor y 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 th e 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.

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### Table 3-4 Status of OT C State’s Promulgation
of the OTC 2001 Model Rule for Portable Fuel Containers

State Date When New Containers a re 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

MA a 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

VA b Effective January 1, 2005 Chapter 40, Article 42
a) Massachusetts’ proposed rule will be based only on th e 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 calculate d for the emissions accounted for in the area source inventory. Additional benefits (not estimat ed for this report) would be expected from equipment refueling vapor displacement and sp illage 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. Usi ng 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 in formation 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

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### implementation, the expected incremental reduc tion is approximately 58 percent, after an estimated 65 percent reduction from the original 2000 rule.

The OTC calculations assume that States wi ll 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 un til 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 provide s a conservative estimate, because some of
the one-time research and reformulation costs in curred 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 si gnificant changes to c onventional fuels used by motor vehicles. Beginning in 1995, “reformula ted” 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 emis sions 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%

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### 3.5.2 Description of the OTC 2006 Control Measure
The Energy Policy Act of 2005 provides the opportuni ty for the OTR to achieve a single cleanburning gasoline and is consistent with what OT R 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 re ductions 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, a nd possibly a single fuel, to be utilized throughout the region. The OTC Commissioners recommended that the OTC member states pursue a region fuel program consiste nt with the Energy Act of 2005 (OTC 2006b).

3.5.3 Emission Benefit Analysis Methods
Emission benefits resulting from extending reform ulated 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 ra nged 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 fo r the quantification of the emi ssion reduction benefits is the MANEVU emission inventory, Version 3 (P echan 2006, MACTEC 2006a) and the VISTAS emission inventory, BaseG (MACTE C 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 projecti on inventories also account for “on-the-books/on-the-way” (OTB/W) emission cont rol regulations that ha ve (or will) become effective between 2003 and 2008 that will achieve post-2002 emission reductions. For example, many States have already adopt ed the 2001 OTC model rules for consumer products and portable
fuel containers. The emission reduction bene fit from the 2001 OTC model rules are already accounted for in the MANEVU and VISTAS projec tion inventories. Emission reductions from existing regulations are already accounted for to ensure no double counting of emission benefits

occurs.

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### Note that the emission reductions contained in th is 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 emi ssions in the MANEVU inventory, these values were used directly to quantify the emission be nefit from the 2006 OTC control measure. When summer day emissions were missing from the M ANEVU 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 s easonal throughput data was missing, the summer day emissions were calculated using the annual em issions and a summer season adjustment factor derived from the monthly activity profiles contai ned 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 Sec tion. 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 acco unts for growth and for the emission control regulations that have (or will) become effec tive between 2003 and 2008 that will achieve post2002 emission reductions; (3) the summer daily em issions for 2009 with the implementation of
the OTC 2006 control measures id entified 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 ar e in the most populous States – New York and Pennsylania. The emission benefits listed for Virg inia 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 th e OTR provides the largest emission benefit, about 139.4 tons per day across the OTR. The a dhesives and sealants ap plication model rule provides the second largest emissi on benefit in 2009 – 82.3 tons per day across the OTR. The
incremental benefits accrued fr om 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 sour ces and emission benefit calculations that were performed. These tables can be used by the States to create additional summaries, for example, by nonattainment area.

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### 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 emissi on 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 fro m the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions).

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### 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 emissi on 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 fro m 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.

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### 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 emissi on 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 fro m 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.

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### 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 emissi on 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 fro m 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 w ith the OTC 2006 control m easure 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 Ja nuary 1, 2009. The 2009 base emissions in MA are uncontrolled emissions. The 2009 emission benefits represents the total emission reductions from the MA rule.

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### 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

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### 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 emissi on 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 fro m 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.

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## 4.0 NOx ANALYSIS METHODS

This Secton describes the analysis of th e 2006 OTC control measures to reduce NOx emissions from six source categories: diesel engine chip reflash, regional fuels, asphalt production plants, cement kilns, glass/fiberg lass 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 cont rol measure, describe the methods usedto quantify the emission benefit, and provide an estimate of the anticipated costs and costeffectiveness of the control measure. At th e 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 Jus tice (DOJ), EPA, and CARB determined that seven major engine manufacturers had designed their 1993 th rough 1998 model heavyduty diesel engines to operate w ith advanced electronic engine controls that resulted in
excessive NOx emissions. W 

### hen these engines were operated in the vehicle under “real world” conditions, the electroni c calibration would change, altering the fuel delivery characteristics and resulting in elevated NOx levels. DOJ, EPA and ARB developed Consent Decrees that require d 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 in stalled 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, a nd 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 pr ogram, 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 refl ash 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 fe deral 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 ultima tely complete the rebuilds for trucks registered in California and for out-of-state re gistered trucks trave ling on roadways within

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### the state. The ARB rule, effective March 21, 2005, mandates that re builds occur over a prescribed time period, with a final rebuild compliance da te of December 31, 2006. The CARB mandatory program, faced two separate legal challenges, alleging that CARB has breached its settlement agreement and alle ging that CARB is illegally establishing
different emissions standards on “new engines”. The Sacram ento County Superior Court ruled that the Low NOx Software Upgrade Re gulation 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 consider ation 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, le ssees, and operators of heavy-duty vehicles powered by the engines that are required to ha ve the low-NOx rebuild. Consistent with the Consent Decrees, the engine ma nufacturers are required to pr ovide the rebuild kits at no cost to dealers, distributors , repair facilities, rebuild f acilities, owners, lessees, and operators, upon their request and to reimburse their authorized dealers, authorized distributors, authorized repair facilities and authorized re build facilities for their labor

costs.

4.1.3 Emission Benefit Analysis Methods
NESCUAM estimated potential NOx emissions re ductions (tons per day) if the Northeast States were to adopt a rebuild program simila r to the California program. These estimates
are based on the ratio of Nort heast to California in-state h eavy-duty vehicle registrations,
and ARB-estimated California NOx reduc tions of 35 TPD (NESCAUM 2006b, pg. 5). NESCAUM also estimated potential NOx emissi ons reductions for the Mid-Atlantic States by scaling the NESCAUM projec tions 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 b een 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 requ irements on the dealer performing the reflash
and the vehicle owner. The MRPO estimat ed 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).

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### 4.2 REGIONAL FUELS

The Clean Air Act Amendments of 1990 require d significant changes to conventional fuels used by motor vehicles. Beginning in 1995, “r eformulated” 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 ha s 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 oppo rtunity 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. Approxima tely 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-reformulat ed 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 refo rmulated gasoline to all areas of the OTR have been calculated for 2006 by NESCAUM (NESCAUM 2006a).

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### 4.2.4 Cost Estimates
EPA’s AirControlNET document (Pechan 2005, pg III-1392) indicate s 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 crea ted by mixing and heating size-graded, high quality aggregate (which can include reclaimed as phalt pavement) with liquid asphalt cement. HMA can be manufactured by batch mix, con tinuous mix, parallel flow drum mix, or counterflow drum mix plants. The dryer opera tion 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, electric ity 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 manufactur ing 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 Jer sey 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 Commissione rs recommended that OTC member states pursue as necessary and appropriate st ate-specific rulemakings or other implementation methods to establish em ission reduction percenta ges, emission rates or technologies that are consistent with the guidelines shown in Table 4.1 (OTC 2006b).

Industry leaders have identifie d a number of Best Manageme nt Practices that allow for substantial reduction in plant fuel cons umption 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.

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### 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/Wast e Oil Low-NOx Burner Technology or Best Management Practices



### • Effective stockpile management to reduce aggregate moisture content : Current information indicates that effective st ockpile management can reduce aggregate moisture content by about 25 percent, corres ponding to a reduction in fuel consumption by approximately 10 - 15 percent. There ar e 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 mi x 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 fu el 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 f lites and other measures can be taken – all in the effort to make a plant operate mo re efficiently, thereby using less fuel.

4.3.3 Emission Benefit Analysis Methods
The emission rates and percent reductions estim ates shown above for major sources were developed the the state of Ne w 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 pe rcent with low-NOx burners and FGR, and by 25 to 40

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### 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. On ly emissions from major point sources are typically included in the MANEVU point s ource database. Emissions from non-major sources are not explicitly c ontained in the area source inve ntory. The emissions from nonmajor asphalt plants are likely lumped togeth er in the general ar ea source industrial and commercial fuel use category. Reductions from area source emissions at asphalt production plants are included in the ICI boiler source category. Theref ore, 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 simila r to those of small to midsize boilers 

### or process heaters

. Low NOx burners range from $500 to $1,250 per to n 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 EP A’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 lime stone, clay, sand and iron ore in a rotary kiln. Nationwide, about 82 per cent 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 oxi dation 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 ki lns 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. Acco rding to the MANEVU 2002 inventory (Pechan 2006), the number of cement kilns opera ting 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 subm it 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 ki ln or modify each kiln to implement mid-kiln firing.

The one kiln in Maine is a wet process cemen t 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 fo r reducing NOx emissions from cement kilns. Automated process control has been shown to lower NOx emissions by
moderate amounts. Low-NOx burners have be en successfully used, especially in the precalciner kilns. CemStarSM is a process that involves adding stee l slag to the kiln, offering moderate levels of NOx reduction by reducing the required burn zone heat input.

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### Mid-kiln firing of tires provides moderate reductions of NOx emi ssions 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 a nd/or operated for NOx reduction rates of 10-50% which is sufficient to comply with current legislati on in some countries. Two Swedish plants
installed SNCR in 1996/97 and have achieve d 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). Th e guidelines were presented in terms of both an emission rate (lbs/ton of clinker by ki ln type) as well as a percent reduction from
uncontrolled levels.

Table 4.2 OTC Resolution 06-02 Emissi on 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 fr om 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 OT C 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 cal culate the emissions remaining after implementation of the control measure.

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### 4.4.4 Cost Estimates
The TCEQ study (ERG 2005) estimated a co st-effectiveness of $1,400-1,600 per ton of NOx removed for an SNCR system achievi ng 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 e ffectiveness 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 sour ce-specific factors.

4.5 GLASS/FIBERGLASS FURNACES

The manufacturing process requires raw materi als, 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 a nd oxygen in the furnace creates NOx emissions.

The main product types are flat glass, cont ainer glass, pressed and blown glass, and fiberglass. In the OTR, the preponderance of gl ass manufacturing plants is in Pennsylania. New York and New Jersey also have seve ral plants. Massachu ssetts, Maryland, and Rhode Island each have one glass manufacturing plant.

4.5.1 Existing Federal and State Rules
Only Massachussetts and New Jersey have sp ecific 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 Je rsey 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 cont ain 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

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### (low NOx burners, oxy-fuel firing, oxygen-enri ched 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 fu rnace rebuild. This strategy not only reduces NOx emissions by as much as 85 percent, but reduces energy consumption, in creases 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). Th e guidelines were presented in terms of both an emission rate (lbs/ton of glass produ ced) 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 calcul ation varied by State depending upon the availability of data:

• New Jersey DEP evaluated the existing cont rols at each facility. NJDEP identified furnaces that have closed, indicated whet her the facility requested banking of emissions, and specified whether the emissi ons 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 (ton s of glass pulled) and emission rate data (lbs NOx/ton of glass pulled). The 2002 emission rate was compared to the OTC

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### 2006 control measure emission rate list above to calculate a furnace-specific percent reduction. The furnace-specific percent re duction was then app lied to the 2002 actual
emissions to calculate the emissions rema ining 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 – emissi ons 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 reduc tion 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 fu rnace. EPA’s Alternative Control Techniques Document (USEPA 1994) estimated an 85 percen t reduction in NOx emissions for oxyfiring with a cost-effectiveness of $2,150 to $5,300.

Other technologies may be used to meet the lim its 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-spe cific factors greatly influence the actual achievable performance level and control costs at a particul ar facility.

4.6 ICI BOILERS

Industrial/commercial/institutional (ICI) boilers combust fuel to produce heat and process steam for a variety of applications. Industria l boilers are routinely found in applications the chemical, metals, paper, petroleum, food production and other indus tries. 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/h r 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 boile rs generally have a heat in put less than 100 mmBtu/hour. It is estimated that 80 percent of the comm ercial/institutional population is smaller than 15 mmBtu/hour. The ICI boiler population is highly diverse – encompassing a variety of fuel

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### types, boiler designs, capacity utilizations a nd pollution control systems – that result in variability in emission rate s and control options.

For emission inventory purposes, emissions from ICI boilers are included in both the point
and area source emission invent ories. Generally, the point source emission inventory includes all ICI boilers at majo r facilities. The point sour ce inventory lists individual boilers, along with their si ze and associated emissions. The area source inventory generally includes emissions fo r ICI boilers located at non-ma jor facilities. It does not provide emissions by the size of boiler, as is done in the point s ource inventory. Area
sources emissions are calculated based on the fu el use not accounted for in the point source inventory. This is done by taki ng the total fuel consumption fo r the state (by fuel type and category), as published by the U.S. Departme nt of Energy, and subtracting out the fuel usage reported in the point s ource 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, boile r design, and geographic location.

State regulations affecting ICI boilers were researched and are summarized in Appendix G. The specific requirements for each state we re organized into a common format to efficiently include the State- by-State differences by fuel t ype and boiler size. This organization oversimplifies the source categ ories and size limitations that differ from State-to-State. This simplification was necessa ry to match the rules to the organization of the emission data bases (i.e., Source Classifi cation Codes) being used in the analysis.

4.6.2 Description of the OTC 2006 Control Measure

The OTC Commissioners recommended that OT C member states pursue as necessary and appropriate state-specific rulemakings or other implementation methods to establish emission reduction percentages, emission ra tes or technologies fo r 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.

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### 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 contro l 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 s ources. For point sources, the emission reductions were estimated by comparing the em ission limits in the existing (2006) state regulations with the limits c ontained 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 cu rrent state requirement. In cases where a state did not have a specific limit for a give n 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 capacit y (mmBtu/hour) from the MANEVU and VISTAS emission inventories to apply the a ppropriate 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

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### 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 th ose cases, the more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates th at 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 C ounty, Manassas City, Manassas Park, and Prince William County.

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### 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 th ose cases, the more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates th at 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 C ounty, Manassas City, Manassas Park, and Prince William County.

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### 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 th ose cases, the more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates th at 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 C ounty, Manassas City, Manassas Park, and Prince William County.

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### 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 th ose cases, the more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates th at 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 C ounty, 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 th ose cases, the more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates th at 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 C ounty, 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 th ose cases, the more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates th at 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 C ounty, 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 subjec t to the emissions limits. In general, emissions from area
source ICI boilers are uncontro lled (except possibly for an an nual 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 equipm ent costs, direct installation costs, indirect capital costs, a nd direct and indirect operating costs. The analysis examined five types of NOx contro l technologies – low-NOx burners (LNB), ultra low-NOx burners (ULNB), LNB plus flue gas recirculation (LNB+FGR), LNB pluse selective non-catalytic reduc tion (LNB+SNCR), and selectiv e catalytic reduction (SCR). The analysis also considered va rious fuel types – coal, residu al oil, distillate oil, and natural gas. The cost effectiveness varies by fuel type, boiler size, current regulatory requirements, current control technology, a nd 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 e ffectiveness 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 ar e described in this subsection. The starting point for the quantific ation of the emission reduction benefits is the MANEVU emission inventory, Version 3 (Pechan 2006, MACTEC 2006a) and the VISTAS emission inventory, BaseG (MACTEC 2 006b), 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 i nventories for 2009 and 2018 (MANEVU also has projections for 2012, but VISTAS does not). The projecti on inventories account for growth in emissions based on growth indicato rs such as population and economic activity. The projection inventories also account fo r “on-the-books/on-the-way” (OTB/W) emission control regulations that have (or will) b ecome 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 c ounting of emission benefits occurs.

Note that the emission reductions contained in this Section are presen ted in terms of tons per summer day. The MANEVU base and proj ection emission inventories do not contain summer day emissions for all States and sour ce categories; the VIST AS 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 pr ovided 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 em issions were missing from the MANEVU or VISTAS inventories, the summer day emi ssions were calculated using the annual emissions and the seasonal throughput data fr om 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 adjust ment factor derived from the monthly activity profiles contained in the SM OKE 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 emissi on numbers: (1) the ac tual 2002 summer daily emissions; (2) the summer daily emissions for the 2009 OTB/W scenario that accounts for growth and for the emission control regulati ons that have (or will) become effective between 2003 and 2008 that will achieve pos t-2002 emission reductions; (3) the summer daily emissions for 2009 with the implemen tation 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 sa me information for the total of all seven source categories.

The largest estimated NOx emission reductions ar e 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 popul ation 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 me mbers will adopt the rules as described in the previous sections.

Appendix E provides county-by-county summarie s of the NOx emission benefits from the
OTC 2006 NOx control measures de scribed previously in this Section. Appendix E also provides additional documentation regarding the data sources and emission benefit calculations that were performe d. 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 emissi ons 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).

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### 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 Sec tion. 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 redu ction from the control measures described in this section (i.e., the difference be tween the base emissions and the maximum control emissions).

Note: The table show the maximum em ission reduction from glass/fiberg lass 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 emissi ons 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 Ha mpshire 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 Re trofit Control Technology for Adhesives and Sealants”, December, 1998.

CARB 1999: California Air Resources Board, “I nitial 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 Res ourses Board, “Initial Statement of Reasons for Proposed Amendments to the California Aerosol Coating Products, Antiperspirants and Deodorants, and Consumer Products Regula tions, Test Method 310, and Airborne Toxic Control Measure for Para-dichl orobenzene Solid Air Fresheners and Toilet/Urinal Care Products Volume I: Executive Summary”, June 24, 2004.

CARB 2004b: California Air Resourses Boar d, Letter from William V. Loscutoff to Stakeholders, June 7, 2004.

CARB 2005a: California Air Res ourses Board, “Staff Report: In itial Statement of Reasons for Proposed Amendments to the Portable Fuel Container Regulations”, July 29, 2005.

CARB 2005b: California Air Resourses Boar d, “Final Statement of Reasons: Public Hearing to Consider Amendments to the Re gulations for Portable Fuel Containers”, October 2005.

CARB 2006: California Air Resourses Boar d, “Final Statement of Reasons: Public Hearing to Consider Amendments to the Re gulations 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, “Integrate d Pollution Prevention and Control (IPPC) Reference Document on Best Available Techniques in the Cement and Lime Manufacturing Industries”, December 2001.

EC 2001b. European Commission, “Integrate d Pollution Prevention and Control (IPPC) Bureau Reference Document on Best Availa ble Techniques in th e 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 Contro l Technologies for the Cement Industry – Final Report”, prepared for the U.S. Envi ronmental Protection Agency, September 19, 2000.

ENVIRON 2006: ENVIRON Intern ational Corporation, “Evaluat ion of Candidate Mobile Source Control Measures”, prepared for La ke Michigan Air Directors Consortium, January 5, 2006.

ERG 2005. Eastern Research Group, Inc., “Assessment of NOx Emissions Reduction Strategies for Cement Kilns – Ellis Count y’, 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 Manage ment 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 th e 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: Draf t Model Rule Staff Report, February 20, 2006.

OTC 2006a: Ozone Transport Commission, “Mem orandum of Understanding Among the States of the Ozone Transport Commissi on on a Regional Strategy Concerning the Integrated Control of Ozone Precursor s from Various Sources”, June 7, 2006.

OTC 2006b: Ozone Transport Commission, “Resolution 06-02 of the Ozone Transport Commission Concerning Coordi nation and Implementation of Regional Ozone Control Strategies for Certain Sour ce Categories”, June 7, 2006.

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### OTC 2006c: Ozone Transport Commission, “S tatement of the Ozone Transport Commission Concerning Multi-Pollutant Em ission 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, “Modif ied Charge of the Ozone Transport Commission to the Stationary Area Source Committee Regarding Electric Generating Units”, November 15, 2006.

OTC 2006f: Ozone Transport Commission, “S tatement 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 Coordina tion and Implementation of Regiona Ozone Control Strategies for Va rious Sources”, November 15, 2006.

Pechan 2001: E.H. Pechan & Associates, Inc., “Control Measure Development Support Analyis of Ozone Transport Commission Mode l Rules”, prepared for Ozone Transport Commission, March 31, 2001.

Pechan 2005: E.H. Pechan & Associ ates, 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 Mi d-Atlantic Regional Air Management Association, April x , 2006.

USEPA 1994. U.S. Environmental Protection Agency, “Alternative Control Techniques Document – NOx Emissions from Gla ss Manufacturing”, EPA-453/R-94-037, June 1994.

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## 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 additiona l measures to reduce emissions that either directly impact their nonattainment status, or contribute to th e nonattainment status in other states. In addition, the States are conduc ting attainment planning work to support development of PM2.5 and regional haze State Implementati on Plans (SIPs). As such, the Ozone Transport Commission (OTC) undertook an exerci se 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 w ith coordination of th e attainment planning work. The Control Strategies Committee wo rks 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 mob ile 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 focuse s on stationary area sources;

• Reasonably Available Cont rol 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 MACT EC to help the SAS Committee identify and
evaluate candidate control measures as well as to quantify expect ed emission reductions
for each control measure.

Workgroup Activities

Initially, the Workgroups compiled and review ed a list of approxima tely 1,000 candidate
control measures. These control measures we re identified through published sources such

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### 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, a nd 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 t hought to be the most effective in reducing ozone air quality levels in the Northeastern and Mid-Atlantic States. The Workgroups reviewed information on curre nt 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 work shops to further refine the emission reduction estimates, the cost da ta, and any implementation issues. The Workgroups also discussed coments from stak eholders. The Workgroups prioritized the control measures and made preliminary reco mmendations regarding which measures to
move forward on.

OTC Commissioners’ Recommendations

Based on the analyses by the OTC Workgr oups, the OTC Commissioners made several
recommendations at the Commissioner’s m eeting in Boston June 2006 and November
2006. The Commissioners recommended that St ates consider emi ssion 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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### Additionally, the Commisioners requested that EPA pursue federal regulations and programs designed to ensure national deve lopment and implementation of control measures for the following categories: archit ectural and maintenance coatings, consumer products, ICI boilers over 100 mmBtu/hour heat input, portable fuel containers, municipal waste combustors, regionally consistent a nd environmentally sound fuels, small offroad engine emission regulation, and gasoline vapo r recovery. The vari ous recommendations by the OTC Commissioners made from 2004 to 2006 are summarized in Table A-1.

Stakeholder Input

Stakeholders were provided multiple opportuniti es 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 a nd respind to the Control Measure Summary
Sheets and Commissioner’s reco mmendations. 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 sta ff and to discuss the control options. These stakeholder conference calls and meeting are li sted 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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### Table A-1: OTC Formal Actions, 2004-2006

Date Action/Synopsis Charge to Stationary an d 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 an d 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, asses s 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 m odeled and evaluate strategies including anti-idling programs, voluntary and regulatory retrofit programs, VMT growth strategies, port and marine engine progr ams, 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 oz one, 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 fo r 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 fo r 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, Cons umer 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 Con cerning the Integrated Control of Ozone Precursors from Various Sources Commits OTC States to continue to

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Date Action/Synopsis
work with interested stakeholders a nd pursue state-specific rulemakings as needed and appropriate regarding the following sectors to reduce emission of ozone precursors: Consumer Products, Port able 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 cat egories: asphalt paving (cutback and emulsified), asphalt plants, cement kiln s, 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, Port able Fuel Containers, Municipal Waste Combustors, Regiona Fuels, Sm all Engine Emission Regulation, and Gasoline Vapor Recovery.
Nov. 15, 2006 Modified Charge of the Ozone Transpor t 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 Co mmission 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 Implemen tation 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

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### Table A-2: OTC Control Measu res 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

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### 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 Asso ciation (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 Asso ciation (CSPA) Consumer Products Cosmetic, Toiletry and Fragrance A ssociation (CTFA) Consumer Products National Paint & Coatings Associ ation (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 Ai r Regulations Printing – Lithography



### Stakeholder comments can be found on the OTC website at the following address: http://www.otcair.org/projects_deta ils.asp?FID=95&fview=stationary

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### Table A-4: OTC Conference Calls a nd 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 Nationa l 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

North American Insulation Manufacturers Assoc. Glass Manufacturers July 5, 2006
North American Insulation Manufacturers Assoc. Aug. 16, 2006
Glass Association of North America Sep. 14, 2006
Glass Association of North America Oct. 19, 2006

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)

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MACTEC Federal Programs, Inc. 

## Appendix B – Initial List of Control Measures

The comprehensive list of cont rol measures can be found at:
http://www.otcair.orgDraft 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 A dhesives 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 – Fabr ic Printing, Coating, and Dyeing Industrial Surface Coatings – Large Appliances Industrial Surface Coat ings – Metal Cans Industrial Surface Coat ings – Metal Coils Industrial Surface Coati ngs – 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 Coati ngs – All Categories Lime Kilns Municipal Waste Combustors Printing and Graphic Arts Portable Fuel Containers Reformulated GasolineDraft 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 VO C reductions through two basic components: sale and manufacture restrictions that limit the VOC content of sp ecified 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 sealan ts 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 rest rictions 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 regulat ory form in various air pollution control districts in California including the Bay Area, South Coast, Ventura County, Sacr amento 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 sealan ts, 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 th e solvent-based materials can result in 64.4% reduction in total emissions from this category. (CARB RACT/BARCT for Adhesiv es/ 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 la tex 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 tpdDraft 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 impre gnated 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 adh esive rules by application to two surfaces; in the case of adhesives, the two surfaces are directly bonded whil e 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 A RB emission inventory estimates 45 tons per day prerule; reductions will range fro m 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 de termination 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 produc ts 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 futureCARB 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 es timated 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 Suggest ed Control Measure (SCM) for Architectural Coatings this year. They will be using 2004 survey data as an important resource to update the SCM, butDraft 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 implementi ng 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-eff ectiveness 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 su rveyed 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 pr ior to commercialization.” The Dec. 2003 amendments lowered the VOC limit for the following specialty coa ting categories: clear wood finishes including varnishes and sanding sealers, roof coatings, stains, and waterpr oofing 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 i ndustrial maintenance; non-flats; primers, sealers, and undercoaters; quick-dry enamels; quick-dry primers, seal ers, and undercoaters; roof coatings; floor coatings, rust preventative coatings, stains, and waterproofi ng wood sealers. The overall cost-effectiveness of the proposed amendments, (total costs/total emission reduc tions) 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. St ates do provide various exemptions to the ban, most notably allow ances 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 regulat ions, the use of emulsified asphalts (no VOC) presented a cost savings. Timing of Implementation : All regulations implemen ted 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 wo rking 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 em ulsified 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 wo rking 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

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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 su lfur 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 regi on. 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 bur ners 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 encourag e 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 onl y include emissions from point sources. Area source emissions from fuel combustion at asphalt production pl ants are not explicitly contained in the area source emissions. These emissions are likely lumped toge ther 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 si milar 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 substantia l reduction in plant fuel consumption and the corresponding pr oducts of combustion including NOx . In today’s business environment, there is significant incentive to reduce fu el 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 mois ture 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 st ockpiles, 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 an d companion control measures summaries, a burner tune-up may reduce NOx emissions by up to 10 per cent. 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 u nderstand the practicality and performance of lowering mix temperatures. Substantial reductions in mix temperatures, on the orde r 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 ex ample, 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/Wast e Oil Low-NOx Burner Technology or Best Management PracticesDraft 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 activ ities (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 co st 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 Fe deral 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 S uggested 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 th e 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/c learcoat 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 pou nds 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 w ith the emission reduction capabilities of SNCR. There are 18 full-scale SNCR insta llations 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 annu al 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 percen t 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 a nd 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 Cont rol (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% whic h 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 ca lls for a 60% reduction from uncontrolled emissions. Using this percent reduction figure and the uncontrolled emission rates above, the following controlled emissi on 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) recomm ended a program be developed that reduces NOx emissions from existing cement kilns to an emission rate of 2.0 pound s per ton of clinker by 2009. Trading between facilities would not be pe rmitted, 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 ma nufacturers. 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 breach ed 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 th e reflash has been estimated at $20-$30 per vehicle, which is borne by the engine manufacturer. There may be costs associated with potential down time 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 incremen tal “fuel penalty” of 2% increase in fuel consumption). However, in reality, no fu el penalty has been documented on vehicles that have already been reflashed.

Timing of Implementation : The kits are currently availa ble, 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. Th e 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 tim e 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 progr am, 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-pers pirants 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 st ates (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 Californi a, which is equivalent to about11.3 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 thei r 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 by2010 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 AvailableDraft 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 da ta 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 show s 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 m odel 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 CA RB’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 approximat ely 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 furna ce 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 u se a mix of control options to meet the suggested limits. Manufacturers may propose alternative compli ance 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 pulledDraft 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 SO 2 

### 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 oilDraft 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 SO 2 

### Control Measure Notes

MACTEC Federal Programs, Inc. 

### *LNB/SNCR and LNB/FGR are examples of NOx control technol ogies 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 SO 2 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 SO 2 /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 SO 2 /mmBtu NOx CEMSDraft 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 H 2 O & 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 paperDraft 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 H 2 O & 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 paperDraft 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 H 2 O&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 paperDraft 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 H 2 O & exempt solvents) Applicability: Sour ces 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 paperDraft 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 H 2 O & exempt solvents) Applicability: Sour ces 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 paperDraft 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 H 2 O&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 envir onmental 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 paperDraft 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 H 2 O & 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 paperDraft 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 Dyei ng; 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 H 2 O&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 paperDraft 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 H 2 O&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 paperDraft 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 Dyei ng; 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 Categor y 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 paperDraft 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. I ndustrial 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 so lvents 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 prepara tion and coating applications are a function of the VOC content of product used. Emissions are also a function of the type of co ating process used (rolling, dipping, spraying, etc.) and the transfer efficiency of th e 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 overest imated. The method used to estimate area source VOC emissions relies heavily on employee emission factors and employment data. These emission factors are based on da ta collected by EPA in the 1980s and may not accurately portray the types of coati ngs, 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 cont rolled prior to 2009 as a result of the recently promulgated Maximum Achievable Control Technology (MACT) standards. Since the MACT standa rds 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 pr oducts, etc.) and the type of coating equipment and the type of solven ts used in that subcategory.

Regulatory History

Industrial surface coating processes are currently su bject 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 larg e stationary sources. In the early 1990s, EPA promulgated NSPSs for various types of industrial surface coating operations. These regulations appliedDraft 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 cons tructed or modified after 1980 are subject to NSPS requirements. The NSPS generally established VOC em ission 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 T echnology (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 contro l equipment and are reviewed on a case-by-case basis during state permitting process.

Criteria pollutants, which include VOCs, nitrogen oxides (NOx), sulfur dioxide (SO 2 ), fine particulate matter (PM fine ), 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 locat ed 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 Contro l 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 th at a case-by-case RACT determination be made. Most of the EPA’s CTGs and ACT documents for th e industrial surface coating category were developed prior to 1990. While specific RACT requirements wi ll vary from state to state, some OTC states have already adopted RACT regulations that are mo re 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 po llutants 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 geogra phic 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 surf ace coatings category to be 164, 445 tons (24,931 tons of VOC from point sources and 139,512 tons from ar ea sources). Further investigation into the amount of VOC emissions from area sources will most likely reveal that these VOC emissions areDraft 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 emissi on 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 coati ng minus water and exempt solvents), but also in the size of source to which these limits apply.

Several complications arise when trying to cal culate 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 coa tings 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 OT C states RACT standards apply statewide. MACT standards are applicable nationwide and only to majo r 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 contro l requirements for specific industrial surface coating categories (e.g., permanent total en closures 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 be fore 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 ceme nt kilns to lime kilns is not straightforward. In cement kilns, flame temperatures are higher and low- NOx burners have been de veloped 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, Industr ial Boilers, Cement Plants, and Paper and Pulp Facilities . March 2005. “Due to the design of the li me 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 resulte d 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 r esponse to the federal emissions guidelines and whether SNCR is feasible. Timing of Implementation : Assuming timely adoption of state rule amendments, compliance with emissi ons 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 emi ssions reductions. At the regional le vel, this strategy should not be emphasized as it is state-specific in nature (depending on the MWC popul ation, 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 standa rds, including standards for NOx, under Section 129 of the Clean Air Act. To comply with these MACT st andards, 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 NO x emissions limits were reduced, in October 2000, the Department amended the state MWC rule to require th e MWC owners and operators to meet more stringent NOx emissions limits as of May 1, 2003. The resulti ng emissions reductions of 1.62 tons of NOx per summer day (248 tons per ozone season) were used for compliance with the "shor tfall" emission reduction obligationDraft 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 demonstr ation 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 m easure 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, reducti on 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. Ho wever, 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 perform ance of maximum achievable control technology (MACT). The emission guidelines required complian ce 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 achieve d due to the installation of control equipment (70 FR 75348). This proposal includes reduced NOx emi ssions 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 late r than May 1, 2003. The following NOx emissions reductions, relative to emissions levels under the Phas e 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 dur ing 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 ar e 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 reas onable 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 amm onia is injected within a boiler or in ducts in a region where the temperature is between 900 and 11 00 degrees Celsius. The reaction converts NOx to nitrogen gas and water vapor. SNCR performance depe nds 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 le vel and carbon monoxide and ox ygen concentrations.

Some disadvantages arise from the use of SNCR in cluding: the high operating temperatures required; ineffectiveness at high temperatur es 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), whic h EPA estimates as falling between 680 and 1,200 $/MMBtu (1993 dollars). Thus, SNCR is well suite d 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 repor ted reductions ranging from 35 - 75% from the operation of urea-based SNCR (A ppendix 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/wast e/facilities/algonquin-power.htm ) because the nature of municipal solid waste requires huge SCR reactor si zes and significant actions to prevent catalyst poisoning. These factors, combined with the relative ly 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/h r 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 Interna tional 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 captu re and control equipment, meet the capture and control efficiency requ irement 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 equipmen t (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 th e 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 am endments 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 tpdDraft 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 calcula ted 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 permeati on, 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 implementati on 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 re gulations are implemented. CARB also estimates the cost-effectiveness to be betw een $0.40 to $0.70 per pound.

Recommended Strategy: CARB, through their comprehensive hist ory of research and multiple product surveys, have the best technical data available to cr eate rules to regulate portable fuel containers. Most portable fuel container manufacturers market their pr oducts 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 analys is 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 th e 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 HEARI NG 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 allowi ng 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 of2005 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 pr ovided 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 Aspha lt 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 bei ng transmitted electronically in the spreadsheet
named VOC OTC 2009 Control Measures. There ar e 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 bei ng transmitted electronically in the spreadsheet
named NOx OTC 2009 Control Measures. There ar e 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 bei ng 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.