4A-1

APPENDIX 4: CONTROL STRATEGIES AND EMISSIONS REDUCTIONS

Overview

Chapter 4 describes the approach that EPA used in applying control measures to 

demonstrate attainment of alternative ozone standard levels of 70, 65, and 60 ppb and estimating 

the resulting emissions reductions. This Appendix contains more detailed information about the 

control strategy analyses, including the control measures that were applied and the geographic 

areas in which they were applied.

4A.1 Types of Control Measures

Several types of control measures were applied in the analyses for the baseline and 

alternative standard levels. These can be grouped into the following classes:

 Max NOx Reductions – NOx control measures for nonEGU point, nonpoint, and nonroad 

sources. For each of these sources, we identified the most effective control (i.e., control 

with the highest percent reduction) that could be applied to the source, given the 

following constraints:

 the source must emit at least 50 tons/yr of NOx (see description of controls on smaller 

sources below);

 any control for nonEGU point sources must result in a reduction of NOx emissions of 

at least 5 tons/yr; and

 any replacement control (i.e., a more effective control replacing an existing control) 

must achieve at least 10% more reduction than the existing control (e.g., we would 

not replace a 60% control with a 65% control).

 NOx Reductions from EGU SCRs – SCRs applied to coal-fired EGUs where no SCR is 

currently in place.

 NOx 25-50 TPY Source Reductions – Similar to the Max NOx Reductions above, except 

for smaller sources in the 25-50 ton/year NOx emissions range.

 Max VOC Reductions – Similar to Max NOx Reductions described above, except this 

includes only VOC controls.

4A.2 Application of Control Measures in Geographic Areas

Control measures were applied to geographic areas including or adjacent to areas that 

were projected to exceed the baseline and alternative standards. See Tables 4A-1 to 4A-4 for a 

listing of the NOx and VOC control groups and geographic areas to which they were applied.
4A-2

Table 4A-1. Geographic Areas for Application of NOx Controls in the Baseline and 

Alternative Standard Analyses - U.S., except Californiaa

Geographic Areas and Control Groups Baseline 70 ppb 65 ppb 60 ppb

EAST

Central Region

Max NOx Reductions within TX buffer x x x x 

NOx EGU SCR within TX buffer x x x 

NOx 25-50 tpy Source controls within TX buffer x x x 

Unknown control NOx Reductions within TX buffer U U U 

Max NOx Reductions outside of TX buffer x x x 

NOx EGU SCR outside of TX buffer x x 

NOx 25-50 tpy Source controls outside of TX buffer x x 

Unknown control NOx Reductions outside of TX buffer U U 

Northeast Region

Max NOx Reductions within Northeast buffer x x x 

NOx EGU SCR within Northeast buffer x x x 

NOx 25-50 tpy Source controls within Northeast buffer x x x 

Unknown control NOx Reductions within Northeast buffer U U U 

Max NOx Reductions outside of Northeast buffer x x x 

NOx EGU SCR outside of Northeast buffer x x 

NOx 25-50 tpy Source controls outside of Northeast buffer x x 

Unknown control NOx Reductions outside NE buffer U U 

Midwest Region

Max NOx Reductions in Midwest Region x x 

NOx EGU SCR in Midwest Region x x 

NOx 25-50 tpy Source controls in Midwest Region x x 

Unknown control NOx Reductions in MW Region U U 

WEST

Southwest Region

Max NOx Reductions in Southwest Region x x 

NOx EGU SCR in Southwest Region x x 

NOx 25-50 tpy Source controls in Southwest Region x 

Unknown control NOx Reductions in SW Region U 

a

“x” indicates known controls were applied; “U” indicates unknown control reductions.
4A-3

Table 4A-2. Geographic Areas for Application of VOC Controls in the Baseline and 

Alternative Standard Analyses - U.S., except Californiaa

Geographic Areas and Control Groups Baseline 70 ppb 65 ppb 60 ppb

EAST

Central Region

Max VOC Reductions within Houston buffer x x x 

Max VOC Reductions within Dallas buffer x x 

Northeast Region

Max VOC Reductions within CT-NJ-NY buffer x x x 

Max VOC Reductions within Baltimore buffer x 

Midwest Region

Max VOC Reductions in Chicago buffer x x 

Unknown control VOC Reductions in Chicago U 

WEST

Southwest Region

Max VOC Reductions in Denver buffer x x 

a

“x” indicates known controls were applied; “U” indicates unknown control reductions.

Table 4A-3. Geographic Areas for Application of NOx Controls in the Baseline and 

Alternative Standard Analyses - Californiaa

Geographic Areas and Control Groups Baseline 70 ppb 65 ppb 60 ppb

California

Max NOx Reductions within California (CA) buffer x 

NOx 25-50 tpy Source controls within N. CA buffer x 

Unknown Control NOx Reductions within N. CA buffer U U U U 

NOx 25-50 tpy Source controls within S. CA buffer x 

Unknown Control NOx Reductions within S. CA buffer U U U U 

a

“x” indicates known controls were applied; “U” indicates unknown control reductions.
4A-4

Table 4A-4. Geographic Areas for Application of VOC Controls in the Baseline and 

Alternative Standard Analyses - Californiaa

Geographic Areas and Control Groups Baseline 70 ppb 65 ppb 60 ppb

California

Max VOC Reductions within N. California buffer x 

Max VOC Reductions within S. California buffer x 

a

“x” indicates known controls were applied.

4A.3 NOx Control Measures for NonEGU Point Sources

Several types of NOx control technologies exist for non-EGU point sources: selective 

catalytic reduction (SCR), selective noncatalytic reduction (SNCR), natural gas reburn (NGR), 

coal reburn, and low-NOx burners (LNB). In some cases, LNB accompanied by flue gas 

recirculation (FGR) is applicable, such as when fuel-borne NOx emissions are expected to be of 

greater importance than thermal NOx emissions. When circumstances suggest that combustion 

controls do not make sense as a control technology (e.g., sintering processes, coke oven batteries, 

sulfur recovery plants), SNCR or SCR may be an appropriate choice. Finally, SCR can be 

applied along with a combustion control such as LNB with overfire air (OFA) to further reduce 

NOx emissions. All of these control measures are available for application on industrial boilers.

Besides industrial boilers, other non-EGU point source categories covered in this RIA 

include petroleum refineries, kraft pulp mills, cement kilns, stationary internal combustion 

engines, glass manufacturing, combustion turbines, and incinerators. NOx control measures 

available for petroleum refineries, particularly process heaters at these plants, include LNB, 

SNCR, FGR, and SCR along with combinations of these technologies. NOx control measures 

available for kraft pulp mills include those available to industrial boilers, namely LNB, SCR, 

SNCR, along with water injection. NOx control measures available for cement kilns include 

those available to industrial boilers, namely LNB, SCR, and SNCR. Non-selective catalytic 

reduction (NSCR) can be used on stationary internal combustion engines. OXY-firing, a 

technique to modify combustion at glass manufacturing plants, can be used to reduce NOx at 

such plants. LNB, SCR, and SCR plus steam injection (SI) are available measures for 

combustion turbines. Finally, SNCR is an available control technology at incinerators. 

Tables 4A-5 through 4A-12 contain lists of the NOx and VOC control measures applied in 

these analyses for non-EGU point sources,EGUs, nonpoint sources, and nonroad sources. The 
4A-5

table also presents the associated emission reductions for the baseline and alternative standard 

analyses. The number of geographic areas in which they were applied expanded as the level of 

the alternative standard analyzed became more stringent.

Table 4A-5. NOx Control Measures Applied in the Baseline Analysis

NOx Control Measure

Reductions 

(tons/yr) 

Adjust Air to Fuel Ratio and Ignition Retard - Gas Fired IC Engines 694

Biosolid Injection Technology - Cement Kilns 1,021

Episodic Ban - Open Burning 570

Ignition Retard - IC Engines 30

Low Emission Combustion - Gas Fired Lean Burn IC Engines 1,552

Low NOx Burner - Commercial/Institutional Boilers & IC Engines 6,699

Low NOx Burner - Industr/Commercial/Institutional (ICI) Boilers 165

Low NOx Burner - Industrial Combustion 270

Low NOx Burner - Lime Kilns 309

Low NOx Burner - Natural Gas-Fired Turbines 4,735

Low NOx Burner - Residential Furnaces 5,381

Low NOx Burner - Residential Water Heaters & Space Heaters 6,605

Low NOx Burner and Flue Gas Recirculation - Coke Oven/Blast Furnace 36

Low NOx Burner and Flue Gas Recirculation - Iron & Steel Mills - Reheating 42

Low NOx Burner and SCR - Coal-Fired ICI Boilers 1,174

Low NOx Burner and SCR - Industr/Commercial/Institutional Boilers 5,286

Natural Gas Reburn - Natural Gas-Fired EGU Boilers 79

Nonroad Diesel Retrofits & Engine Rebuilds - e.g., Construction Equipment 4,998

Non-Selective Catalytic Reduction (NSCR) - 4 Cycle Rich Burn IC Engines 20,008

OXY-Firing - Glass Manufacturing 5,429

Selective Catalytic Reduction (SCR) - Cement Kilns 2,982

Selective Catalytic Reduction (SCR) - Coal Fired EGU Boilers 76

Selective Catalytic Reduction (SCR) - Fluid Catalytic Cracking Units 945

Selective Catalytic Reduction (SCR) - IC Engines, Diesel 2,041

Selective Catalytic Reduction (SCR) - ICI Boilers 3,218

Selective Catalytic Reduction (SCR) - Industrial Incinerators 1,062

Selective Catalytic Reduction (SCR) - Petroleum Refinery Gas-Fired Process Heaters 456

Selective Catalytic Reduction (SCR) - Sludge Incineration 366

Selective Catalytic Reduction (SCR) - Utility Boilers 55

Selective Non-Catalytic Reduction (SNCR) - Comm./Inst. Incinerators 16

Selective Non-Catalytic Reduction (SNCR) - Industrial Incinerators 130

Selective Non-Catalytic Reduction (SNCR) - Utility Boilers 158
4A-6

Table 4A-6. VOC Control Measures Applied in the Baseline Analysis

VOC Control Measure

Reductions 

(tons/yr) 

Control of Fugitive Releases - Oil & Natural Gas Production 39

Control Technology Guidelines - Wood Furniture Surface Coating 777

Gas Recovery - Municipal Solid Waste Landfill 2,064

Improved Work Practices, Material Substitution, Add-On Controls - Cleaning Solvents 155

Improved Work Practices, Material Substitution, Add-On Controls - Printing 77

Incineration - Other 181

Incineration - Surface Coating 6,362

Low-VOC Coatings and Add-On Controls - Surface Coating 945

LPV Relief Valve - Underground Tanks 353

Permanent Total Enclosure (PTE) - Surface Coating 100

Process Modification - Oil and Natural Gas Production 4,311

RACT - Graphic Arts 3,423

Reduced Solvent Utilization - Surface Coating 342

Reformulation - Aerosol Paints 12

Reformulation - Architectural Coatings 1,912

Reformulation - Industrial Adhesives 5,076

Reformulation-Process Modification - Automobile Refinishing 4,665

Reformulation-Process Modification - Cold Cleaning 5,877

Reformulation-Process Modification - Cutback Asphalt 6,478

Reformulation-Process Modification - Open Top Degreasing 47

Reformulation-Process Modification - Surface Coating 4,225

Wastewater Treatment Controls- POTWs 237

Table 4A-7. NOx Control Measures Applied in the 70 ppb Alternative Standard Analysis

NOx Control Measure

Reductions 

(tons/yr) 

Adjust Air to Fuel Ratio and Ignition Retard - Gas Fired IC Engines 8,091

Biosolid Injection Technology - Cement Kilns 1,315

Episodic Ban - Open Burning 2,086

Ignition Retard - IC Engines 486

Low Emission Combustion - Gas Fired Lean Burn IC Engines 83,046

Low NOx Burner - Coal Cleaning 255

Low NOx Burner - Commercial/Institutional Boilers & IC Engines 20,004

Low NOx Burner - Industr/Commercial/Institutional (ICI) Boilers 2,290

Low NOx Burner - Industrial Combustion 495

Low NOx Burner - Lime Kilns 1,870

Low NOx Burner - Natural Gas-Fired Turbines 14,408

Low NOx Burner - Residential Furnaces 12,056

Low NOx Burner - Residential Water Heaters & Space Heaters 18,843

Low NOx Burner and Flue Gas Recirculation - Coke Oven/Blast Furnace 350
4A-7

NOx Control Measure

Reductions 

(tons/yr) 

Low NOx Burner and Flue Gas Recirculation - Iron & Steel Mills - Reheating 388

Low NOx Burner and Over Fire Air - Utility Boilers 178

Low NOx Burner and SCR - Coal-Fired ICI Boilers 7,197

Low NOx Burner and SCR - Industr/Commercial/Institutional Boilers 22,632

Low NOx Burner and SNCR - Industr/Commercial/Institutional Boilers 153

Low Sulfur Fuel - Miscellaneous 2,892

Natural Gas Reburn - Natural Gas-Fired EGU Boilers 262

Nonroad Diesel Retrofits & Engine Rebuilds - e.g., Construction Equipment 4,984

Non-Selective Catalytic Reduction (NSCR) - 4 Cycle Rich Burn IC Engines 189,563

Non-Selective Catalytic Reduction (NSCR) - Nitric Acid Mfg 659

OXY-Firing - Glass Manufacturing 17,155

SCR and Flue Gas Recirculation - Fluid Catalytic Cracking Units 163

SCR and Flue Gas Recirculation - ICI Boilers 307

Selective Catalytic Reduction (SCR) - Ammonia Mfg 4,476

Selective Catalytic Reduction (SCR) - Cement Kilns 18,260

Selective Catalytic Reduction (SCR) - Fluid Catalytic Cracking Units 2,995

Selective Catalytic Reduction (SCR) - IC Engines, Diesel 1,675

Selective Catalytic Reduction (SCR) - ICI Boilers 6,049

Selective Catalytic Reduction (SCR) - Industrial Combustion 1,111

Selective Catalytic Reduction (SCR) - Industrial Incinerators 717

Selective Catalytic Reduction (SCR) - Petroleum Refinery Gas-Fired Process Heaters 4,757

Selective Catalytic Reduction (SCR) - Process Heaters 19

Selective Catalytic Reduction (SCR) - Sludge Incineration 7,991

Selective Catalytic Reduction (SCR) - Utility Boilers 30,482

Selective Non-Catalytic Reduction (SNCR) - Coke Mfg 1,543

Selective Non-Catalytic Reduction (SNCR) - Comm./Inst. Incinerators 1,082

Selective Non-Catalytic Reduction (SNCR) - ICI Boilers 154

Selective Non-Catalytic Reduction (SNCR) - Industrial Incinerators 482

Selective Non-Catalytic Reduction (SNCR) - Miscellaneous 31

Selective Non-Catalytic Reduction (SNCR) - Municipal Waste Combustors 304

Ultra-Low NOx Burner - Process Heaters 229
4A-8

Table 4A-8. VOC Control Measures Applied in the 70 ppb Alternative Standard Analysis

VOC Control Measure

Reductions 

(tons/yr) 

Control of Fugitive Releases - Oil & Natural Gas Production 16

Control Technology Guidelines - Wood Furniture Surface Coating 1,184

Flare - Petroleum Flare 110

Gas Recovery - Municipal Solid Waste Landfill 242

Improved Work Practices, Material Substitution, Add-On Controls - Cleaning Solvents 10

Improved Work Practices, Material Substitution, Add-On Controls - Printing 148

Incineration - Other 350

Incineration - Surface Coating 14,071

Low-VOC Coatings and Add-On Controls - Surface Coating 209

LPV Relief Valve - Underground Tanks 4,011

Permanent Total Enclosure (PTE) - Surface Coating 446

RACT - Graphic Arts 3,054

Reduced Solvent Utilization - Surface Coating 2,541

Reformulation - Architectural Coatings 17,678

Reformulation - Industrial Adhesives 1,793

Reformulation-Process Modification - Automobile Refinishing 3,209

Reformulation-Process Modification - Cold Cleaning 1,600

Reformulation-Process Modification - Cutback Asphalt 817

Reformulation-Process Modification - Surface Coating 3,571

Solvent Recovery System - Printing/Publishing 31

Wastewater Treatment Controls- POTWs 217

Table 4A-9. NOx Control Measures Applied in the 65 ppb Alternative Standard Analysis

NOx Control Measure

Reductions 

(tons/yr) 

Adjust Air to Fuel Ratio and Ignition Retard - Gas Fired IC Engines 27,057

Biosolid Injection Technology - Cement Kilns 6,423

Episodic Ban - Open Burning 4,423

Ignition Retard - IC Engines 761

Low Emission Combustion - Gas Fired Lean Burn IC Engines 174,033

Low NOx Burner - Coal Cleaning 518

Low NOx Burner - Commercial/Institutional Boilers & IC Engines 40,691

Low NOx Burner - Industr/Commercial/Institutional (ICI) Boilers 4,226

Low NOx Burner - Industrial Combustion 1,578

Low NOx Burner - Lime Kilns 5,273

Low NOx Burner - Miscellaneous Sources 21

Low NOx Burner - Natural Gas-Fired Turbines 26,982

Low NOx Burner - Residential Furnaces 16,660

Low NOx Burner - Residential Water Heaters & Space Heaters 57,314

Low NOx Burner - Steel Foundry Furnaces 294

Low NOx Burner - Surface Coating Ovens 26

Low NOx Burner and Flue Gas Recirculation - Coke Oven/Blast Furnace 420
4A-9

NOx Control Measure

Reductions 

(tons/yr) 

Low NOx Burner and Flue Gas Recirculation - Iron & Steel Mills - Reheating 892

Low NOx Burner and Over Fire Air - Utility Boilers 333

Low NOx Burner and SCR - Coal-Fired ICI Boilers 30,790

Low NOx Burner and SCR - Industr/Commercial/Institutional Boilers 37,948

Low NOx Burner and SNCR - Industr/Commercial/Institutional Boilers 263

Low Sulfur Fuel - Miscellaneous 3,194

Natural Gas Reburn - Natural Gas-Fired EGU Boilers 480

Nonroad Diesel Retrofits & Engine Rebuilds - e.g., Construction Equipment 12,863

Non-Selective Catalytic Reduction (NSCR) - 4 Cycle Rich Burn IC Engines 323,763

Non-Selective Catalytic Reduction (NSCR) - Nitric Acid Mfg 927

OXY-Firing - Glass Manufacturing 29,546

SCR and Flue Gas Recirculation - Fluid Catalytic Cracking Units 185

SCR and Flue Gas Recirculation - ICI Boilers 318

SCR and Flue Gas Recirculation - Process Heaters 548

Selective Catalytic Reduction (SCR) - Ammonia Mfg 5,151

Selective Catalytic Reduction (SCR) - Cement Kilns 36,013

Selective Catalytic Reduction (SCR) - Fluid Catalytic Cracking Units 4,108

Selective Catalytic Reduction (SCR) - IC Engines, Diesel 8,905

Selective Catalytic Reduction (SCR) - ICI Boilers 18,284

Selective Catalytic Reduction (SCR) - Industrial Combustion 4,428

Selective Catalytic Reduction (SCR) - Industrial Incinerators 1,006

Selective Catalytic Reduction (SCR) - Iron Ore Processing 1,195

Selective Catalytic Reduction (SCR) - Petroleum Refinery Gas-Fired Process Heaters 7,691

Selective Catalytic Reduction (SCR) - Process Heaters 19

Selective Catalytic Reduction (SCR) - Sludge Incineration 9,007

Selective Catalytic Reduction (SCR) - Space Heaters 272

Selective Catalytic Reduction (SCR) - Utility Boilers 211,200

Selective Non-Catalytic Reduction (SNCR) - Coke Mfg 2,399

Selective Non-Catalytic Reduction (SNCR) - Comm./Inst. Incinerators 1,260

Selective Non-Catalytic Reduction (SNCR) - ICI Boilers 170

Selective Non-Catalytic Reduction (SNCR) - Industrial Combustion 69

Selective Non-Catalytic Reduction (SNCR) - Industrial Incinerators 1,502

Selective Non-Catalytic Reduction (SNCR) - Miscellaneous 132

Selective Non-Catalytic Reduction (SNCR) - Municipal Waste Combustors 1,351

Selective Non-Catalytic Reduction (SNCR) - Utility Boilers 329

Ultra-Low NOx Burner - Process Heaters 300
4A-10

Table 4A-10. VOC Control Measures Applied in the 65 ppb Alternative Standard Analysis

VOC Control Measure

Reductions 

(tons/yr) 

Control of Fugitive Releases - Oil & Natural Gas Production 31

Control Technology Guidelines - Wood Furniture Surface Coating 1,928

Flare - Petroleum Flare 110

Gas Recovery - Municipal Solid Waste Landfill 332

Improved Work Practices, Material Substitution, Add-On Controls - Cleaning Solvents 245

Improved Work Practices, Material Substitution, Add-On Controls - Printing 564

Incineration - Other 379

Incineration - Surface Coating 25,785

Low VOC Adhesives and Improved Application Methods - Industrial Adhesives 223

Low-VOC Coatings and Add-On Controls - Surface Coating 1,267

LPV Relief Valve - Underground Tanks 7,317

Permanent Total Enclosure (PTE) - Surface Coating 1,554

Petroleum and Solvent Evaporation - Surface Coating Operations 159

RACT - Graphic Arts 5,988

Reduced Solvent Utilization - Surface Coating 2,796

Reformulation - Architectural Coatings 39,057

Reformulation - Industrial Adhesives 1,698

Reformulation-Process Modification - Automobile Refinishing 5,264

Reformulation-Process Modification - Cutback Asphalt 3,058

Reformulation-Process Modification - Surface Coating 6,913

Solvent Recovery System - Printing/Publishing 842

Solvent Substitution and Improved Application Methods - Fiberglass Boat Mfg 14

Wastewater Treatment Controls- POTWs 242

Table 4A-11. NOx Control Measures Applied in the 60 ppb Alternative Standard Analysis

NOx Control Measure

Reductions 

(tons/yr) 

Adjust Air to Fuel Ratio and Ignition Retard - Gas Fired IC Engines 27,547

Biosolid Injection Technology - Cement Kilns 6,423

Episodic Ban - Open Burning 4,561

Ignition Retard - IC Engines 821

Low Emission Combustion - Gas Fired Lean Burn IC Engines 178,146

Low NOx Burner - Coal Cleaning 518

Low NOx Burner - Commercial/Institutional Boilers & IC Engines 40,876

Low NOx Burner - Industr/Commercial/Institutional (ICI) Boilers 4,319

Low NOx Burner - Industrial Combustion 1,578

Low NOx Burner - Lime Kilns 5,273

Low NOx Burner - Miscellaneous Sources 35

Low NOx Burner - Natural Gas-Fired Turbines 29,155

Low NOx Burner - Residential Furnaces 17,103

Low NOx Burner - Residential Water Heaters & Space Heaters 57,726

Low NOx Burner - Steel Foundry Furnaces 294
4A-11

NOx Control Measure

Reductions 

(tons/yr) 

Low NOx Burner - Surface Coating Ovens 26

Low NOx Burner and Flue Gas Recirculation - Coke Oven/Blast Furnace 420

Low NOx Burner and Flue Gas Recirculation - Iron & Steel Mills - Reheating 892

Low NOx Burner and Over Fire Air - Utility Boilers 333

Low NOx Burner and SCR - Coal-Fired ICI Boilers 30,817

Low NOx Burner and SCR - Industr/Commercial/Institutional Boilers 38,350

Low NOx Burner and SNCR - Industr/Commercial/Institutional Boilers 263

Low Sulfur Fuel - Miscellaneous 3,194

Natural Gas Reburn - Natural Gas-Fired EGU Boilers 502

Nonroad Diesel Retrofits & Engine Rebuilds - e.g., Construction Equipment 12,863

Non-Selective Catalytic Reduction (NSCR) - 4 Cycle Rich Burn IC Engines 325,380

Non-Selective Catalytic Reduction (NSCR) - Nitric Acid Mfg 958

OXY-Firing - Glass Manufacturing 29,546

SCR and Flue Gas Recirculation - Fluid Catalytic Cracking Units 185

SCR and Flue Gas Recirculation - ICI Boilers 318

SCR and Flue Gas Recirculation - Process Heaters 548

Selective Catalytic Reduction (SCR) - Ammonia Mfg 5,151

Selective Catalytic Reduction (SCR) - Cement Kilns 36,013

Selective Catalytic Reduction (SCR) - Fluid Catalytic Cracking Units 4,135

Selective Catalytic Reduction (SCR) - IC Engines, Diesel 9,288

Selective Catalytic Reduction (SCR) - ICI Boilers 18,284

Selective Catalytic Reduction (SCR) - Industrial Combustion 4,428

Selective Catalytic Reduction (SCR) - Industrial Incinerators 1,006

Selective Catalytic Reduction (SCR) - Iron Ore Processing 1,195

Selective Catalytic Reduction (SCR) - Petroleum Refinery Gas-Fired Process Heaters 7,691

Selective Catalytic Reduction (SCR) - Process Heaters 19

Selective Catalytic Reduction (SCR) - Sludge Incineration 9,007

Selective Catalytic Reduction (SCR) - Space Heaters 335

Selective Catalytic Reduction (SCR) - Utility Boilers 236,736

Selective Non-Catalytic Reduction (SNCR) - Coke Mfg 2,399

Selective Non-Catalytic Reduction (SNCR) - Comm./Inst. Incinerators 1,260

Selective Non-Catalytic Reduction (SNCR) - ICI Boilers 170

Selective Non-Catalytic Reduction (SNCR) - Industrial Combustion 92

Selective Non-Catalytic Reduction (SNCR) - Industrial Incinerators 1,502

Selective Non-Catalytic Reduction (SNCR) - Miscellaneous 132

Selective Non-Catalytic Reduction (SNCR) - Municipal Waste Combustors 1,351

Selective Non-Catalytic Reduction (SNCR) - Utility Boilers 329

Ultra-Low NOx Burner - Process Heaters 300
4A-12

Table 4A-12. VOC Control Measures Applied in the 60 ppb Alternative Standard Analysis

VOC Control Measure

Reductions 

(tons/yr) 

Control of Fugitive Releases - Oil & Natural Gas Production 33

Control Technology Guidelines - Wood Furniture Surface Coating 2,063

Flare - Petroleum Flare 110

Gas Recovery - Municipal Solid Waste Landfill 372

Improved Work Practices, Material Substitution, Add-On Controls - Cleaning Solvents 265

Improved Work Practices, Material Substitution, Add-On Controls - Printing 564

Incineration - Other 379

Incineration - Surface Coating 26,109

Low VOC Adhesives and Improved Application Methods - Industrial Adhesives 237

Low-VOC Coatings and Add-On Controls - Surface Coating 1,523

LPV Relief Valve - Underground Tanks 7,610

Permanent Total Enclosure (PTE) - Surface Coating 1,857

Petroleum and Solvent Evaporation - Surface Coating Operations 237

RACT - Graphic Arts 6,273

Reduced Solvent Utilization - Surface Coating 2,886

Reformulation - Architectural Coatings 40,866

Reformulation - Industrial Adhesives 1,698

Reformulation-Process Modification - Automobile Refinishing 5,633

Reformulation-Process Modification - Cutback Asphalt 3,571

Reformulation-Process Modification - Surface Coating 7,072

Solvent Recovery System - Printing/Publishing 888

Solvent Substitution and Improved Application Methods - Fiberglass Boat Mfg 14

Wastewater Treatment Controls- POTWs 242

4A.4 VOC Control Measures for Non-EGU Point Sources

VOC controls were applied to a number of non-EGU point sources. Some examples are 

permanent total enclosures (PTE) applied to paper and web coating operations and fabric 

operations, and incinerators or thermal oxidizers applied to wood products and marine surface 

coating operations. A PTE confines VOC emissions to a particular area where they can be 

destroyed or used in a way that limits emissions to the outside atmosphere, and an incinerator or 

thermal oxidizer destroys VOC emissions through exposure to high temperatures (2,000 degrees 

Fahrenheit or higher). Another control is petroleum and solvent evaporation applied to printing 

and publishing sources as well as to surface coating operations.

4A.5 NOx Control Measures for Nonpoint (Area) and Nonroad Sources

The nonpoint source sector of the emissions inventory is composed of sources that are 

generally too small and/or numerous to estimate emissions on an individual source basis (e.g., 
4A-13

dry cleaners, residential furnaces, woodstoves, fireplaces, backyard waste burning, etc). Instead, 

we estimate their emissions for each county as a whole, often using an emissions factor that is 

applied to a surrogate of activity such as population or number of houses. 

Control measures for nonpoint sources are also applied at the county level, i.e., to the 

county level emissions as a whole. Several control measures were applied to NOx emissions from 

nonpoint sources. One is low NOx burner technology to reduce NOx emissions. This control is 

applied to industrial oil, natural gas, and coal combustion sources. Other nonpoint source 

controls include the installation of low-NOx space heaters and water heaters in commercial and 

institutional sources, and episodic bans on open burning. The open burning control measure 

applied to yard waste and land clearing debris. It consists of periodic daily bans on burning such 

waste, as the predicted ozone levels indicate that such burning activities should be postponed. 

This control measure is not applied to any prescribed burning activities.

Retrofitting diesel nonroad equipment can provide NOx and HC benefits. The retrofit 

strategies included in the RIA nonroad retrofit measure are:

• Installation of emissions after-treatment devices called selective catalytic reduction 

(“SCRs”)

• Rebuilding engines (“rebuild/upgrade kit”)

We chose to focus on these strategies due to their high NOx emissions reduction potential 

and widespread application.

4A.6 VOC Control Measures for Nonpoint (Area) Sources

Some VOC controls for nonpoint sources are for the use of low or no VOC materials for 

graphic art sources. Other controls involve the application of limits for adhesive and sealant 

VOC content in wood furniture and solvent source categories. The OTC solvent cleaning rule 

establishes hardware and operating requirements for specified vapor cleaning machines, as well 

as solvent volatility limits and operating practices for cold cleaners. The Low Pressure/Vacuum 

Relief Valve control measure is the addition of low pressure/vacuum (LP/V) relief valves to 

gasoline storage tanks at service stations with Stage II control systems. LP/V relief valves 
4A-14

prevent breathing emissions from gasoline storage tank vent pipes. Another control based on a 

California South Coast Air Quality Management District (SQAQMD) establishes VOC content 

limits for metal coatings along with application procedures and equipment requirements. 

Switching to Emulsified Asphalts is a generic control measure replacing VOC-containing 

cutback asphalt with VOC-free emulsified asphalt. The Reformulation control measures include 

switching to and/or encouraging the use of low-VOC materials.