# Identification and Evaluation of

Candidate Control Measures

Final Technical Support Document Prepared for: Seth Barna Ozone Transport Commission (OTC) 444 North Capitol Street, NW, Suite 638 Washington, DC 20001 (202) 508 - 3840 Prepared by: MAC TEC Federal Programs, Inc. 560 Herndon Parkway, Suite 200 Herndon, VA 20170 (703) 471 - 8383 February 28, 2007



## ______________________ ______________________ Edward Sabo Douglas A. Toothman Principal Scientist Principal Engineer

### (Page in tentionally left blank)TSD for 2006 OTC Control Measure Evaluation February 28, 2007 Page i

MACTEC Federal Programs, Inc. 

## Table of Contents 1.0 EXECUTIVE SUMMAR Y ................................ ................................ ................................ . 1 - 1 2.0 INTRODUCTION ................................ ................................ ................................ ................ 2 - 1 3.0 VOC ANALYSIS MET HODS ................................ ................................ ............................ 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 - 3 3.1.3 Emission Benefit Analysis Methods ................................ ................................ ......... 3 - 4 3.1.4 Cost Estimates ................................ ................................ ................................ .......... 3 - 4 3.2 CUTBACK AND EMULSIFIED ASPHALT PAVING ................................ .............. 3 - 5 3.2.1 Existing Federal and State Rules ................................ ................................ ............. 3 - 5 3.2.2 Description of the OTC 2006 Model Rule ................................ ............................... 3 - 7 3.2.3 Emission Benefit An alysis Methods ................................ ................................ ......... 3 - 7 3.2.4 Cost Estimates ................................ ................................ ................................ .......... 3 - 7 3.3 CONSUMER PRODUCTS ................................ ................................ .......................... 3 - 8 3.3.1 Existing Federal and State Rules ................................ ................................ ............. 3 - 8 3.3.2 Description of the OTC 2006 Model Rule ................................ ............................... 3 - 9 3.3.3 Emission Benefit Analysi s Methods ................................ ................................ ....... 3 - 10 3.3.4 Cost Estimates ................................ ................................ ................................ ........ 3 - 11 3.4 PORTABLE FUE L 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 - 14 3.4.4 Cost Estimates ................................ ................................ ................................ ........ 3 - 15 3.5 REGIONAL FUELS ................................ ................................ ................................ .. 3 - 15 3.5.1 Existing Federal and State Rules ................................ ................................ ........... 3 - 16 3.5.2 Description of the OTC 2006 Control Measure ................................ .................... 3 - 16 3.5.3 Emission Benefi t Analysis Methods ................................ ................................ ....... 3 - 16 3.5.4 Cost Estimates ................................ ................................ ................................ ........ 3 - 16 3.6 VOC EMI SSI ON REDUCTION SUMMARY ................................ .......................... 3 - 17 4.0 NOX ANALYSIS MET HODS ................................ ................................ ............................ 4 - 1 4.1 HEAVY - DUTY TRUCK DIESEL ENGINE CHIP REFLASH ................................ .. 4 - 1TSD for 2006 OTC Control Measure Evaluation February 28, 2007 Page ii

MACTEC Federal Programs, Inc. 

### 4.1.1 Existing Federa l and State Rules ................................ ................................ ............. 4 - 1 4.1.2 Description of the OTC 2006 Control Measure ................................ ...................... 4 - 2 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 a nd State Rules ................................ ................................ ............. 4 - 3 4.2.2 Description of the OTC 2006 Control Measure ................................ ...................... 4 - 3 4.2.3 Emission Benefit Analysis Methods ................................ ................................ ......... 4 - 4 4.2.4 Cost Estimates ................................ ................................ ................................ .......... 4 - 4 4.3 ASPHALT PAVEMENT PRODUCTION PLANTS ................................ .................. 4 - 4 4.3.1 E xisting Federal and State Rules ................................ ................................ ............. 4 - 4 4.3.2 Description of the OTC 2006 Control Measure ................................ ...................... 4 - 4 4.3.3 Emission Benefit Analysis Method s ................................ ................................ ......... 4 - 6 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 - 8 4.4.3 Emission Benefit Analysis Methods ................................ ................................ ......... 4 - 9 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 - 10 4.5.3 Emission Benefit Analysis Me thods ................................ ................................ ....... 4 - 11 4.5.4 Cost Estimates ................................ ................................ ................................ ........ 4 - 11 4.6 IC I BOILERS ................................ ................................ ................................ ............. 4 - 12 4.6.1 Existing Federal and State Rules ................................ ................................ ........... 4 - 12 4.6.2 Description of the OTC 2006 Control Measure ................................ .................... 4 - 13 4.6.3 Emission Benefit Analysis Methods ................................ ................................ ....... 4 - 13 4.6.4 Cost Estimates ................................ ................................ ................................ ........ 4 - 22 4.7 NO X 

### EMI SSI ON REDUCTION SUMMARY ................................ .......................... 4 - 22 5.0 REFERENCES ................................ ................................ ................................ ..................... 5 - 1TSD for 2006 OTC Control Measure Evaluation February 28, 2007 Page iii

MACTEC Federal Programs, Inc. 

### 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

– IC I Boiler Regulations b y S tate

List of Figures List of Tables Page 1 - 1 VOC Emission Reduction Benefits from OTC 2006 Control Measures ............. 1 - 7 1 - 2 NOx Emission Reduction Benefits from OTC 2006 Control Measures .............. 1 - 8TSD for 2006 OTC Control Measure Evaluation February 28, 2007 Page iv

MACTEC Federal Programs, Inc. 

### List of Tables List of Tables Page 1 - 1 Summary of OTC 2006 Control Measures ................................ .......................... 1 - 3 1 - 2 Estimated Emission Reduction Benefits in 2009 by State ................................ ... 1 - 6 3 - 1 Summary of OTC State Rules for Cutback and Emulsified Asphalt ................... 3 - 6 3 - 2 Status of OTC State’s Promulgation of the OTC 2001 Model Rule for Consumer Products ................................ ................................ .............................. 3 - 9 3 - 3 Consumer Products Affected b y C ARB’s July 2005 Rule Amendments .......... 3 - 10 3 - 4 Status of OTC State’s Promulgation o f 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 - 19 3 - 6 OTC 2006 VOC Model Rule Benefits by State for 2009: Cutback and Emulsi fied Asphalt Paving ................................ ........................... 3 - 20 3 - 7 OTC 2006 VOC Model Rule Benefits by State for 2009: Consumer Products ................................ ................................ ............................ 3 - 21 3 - 8 OTC 2006 VOC Model Rule Benefits by State for 2009: Portable Fuel Containers

– Area Sources ................................ .......................... 3 - 22 3 - 9 OTC 2006 VOC Model Rule Benefits by State f or 2009: Portable Fuel Containers

– Nonroad Sources ................................ .................... 3 - 23 3 - 10 OTC 2006 VOC Model Rule Benefits by State for 2009: Regional Fuels ................................ ................................ ................................ ... 3 - 24 3 - 11 OTC 2006 VOC Model Rule Benefits by State for 2009: All Five VOC Categories ................................ ................................ ................... 3 - 25 4 - 1 OTC Resolution 06 - 02 Emis sion Guidelines for Asphalt Plants ......................... 4 - 5 4 - 2 OTC Resolution 06 - 02 Emission Guidelines for Cement Kilns .......................... 4 - 8 4 - 3 OTC Resolution 06 - 02 Emission Guidelines for Glass Furnaces ...................... 4 - 10 4 - 4 OTC Proposal for ICI Boilers ................................ ................................ ............ 4 - 14 4 - 5 Current State Emission Limits and Percent Reduction for OTC Proposal Point Source Natural Gas - fired Boilers ................................ ............................. 4 - 16 4 - 6 Current State Emission Limits and Percent Reduction for OTC Proposal Point Source Distillate Oil - fired Boilers ................................ ............................ 4 - 17 4 - 7 Current State Emission Limits and Percent Reduction for O TC Proposal Point Source Residual Oil - fired Boilers ................................ ............................ 4 - 18 4 - 8 Current State Emission Limits and Percent Reduction for OTC Proposal Point Source Coal Wall - fired Boilers ................................ ................................ 4 - 19 4 - 9 Current State Emission Limits and Percent Reduction for OTC Proposal Point Source Coal Tangential - fired Boilers ................................ ....................... 4 - 20 4 - 10 Current State Emission Limits and Percent Reduction for OTC Proposal Point Source Coal - fired Stoker Boilers ................................ .............................. 4 - 21TSD for 2006 OTC Control Measure Evaluation February 28, 2007 Page v

MACTEC Federal Programs, Inc. 

### List of Tables (continued) List of Tables Page 4 - 11 OTC 2006 NOx Model Rule Benefits by State f or 2009: Heavy- Duty Truck Diesel Engine Chip Reflash ................................ ................ 4 - 24 4 - 12 OTC 2006 NOx Model Rule Benefits by State for 2009: Regional Fuels ................................ ................................ ................................ ... 4 - 25 4 - 13 OTC 2006 NOx Model Rule Benefits by State for 2009: Asphalt Pavement Production Plants ................................ ................................ . 4 - 26 4 - 14 OTC 2006 NOx Model Rule Benefits by State for 2009: Cement Kilns ................................ ................................ ................................ ..... 4 - 27 4 - 15 OTC 2006 NOx Model Rule Benefits by State for 2009: Glass/Fiberglass Furnaces ................................ ................................ .................. 4 - 28 4 - 16 OTC 2006 NOx Model Rule Benefits by State for 2009: IC I Boilers

– Area (minor) Sources ................................ ................................ ... 4 - 29 4 - 17 OTC 2006 NOx Model Rule Benefits by State for 2009: IC I Boilers

– Point (major) Sources ................................ ................................ ... 4 - 30 4 - 18 OTC 2006 NOx Model Rule Benefits by State for 2009: All Seven NOx Categories ................................ ................................ ................. 4 - 31TSD for 2006 OTC Control Measure Evaluation February 28, 2007 Page vi

MACTEC Federal Programs, Inc. 

## Ac rony ms and A bbreviations Acronym Description BOTW Beyond - on -the -W ay – 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 Mo del 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 Coordinated Air Use Management NH3 Ammonia NIF3.0 National Emission Inventory Input Format Version 3.0 NONROAD U.S. EPA’s emission model for certain types of nonroad equipment NOx Oxides of nitrogen OTB/W On -the - Books/On -the -Way

– refers to emission control programs already adopted and proposed emission controls that will result in post - 2002 emission reductions OTC Ozone Transport Commission 

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

### OTC 2006 model rules Model rules developed by the OTC in 2006 PM10 - PRI Particulate matter less than or equal to 10 microns in diameter that includes both the filterable and condensable components of particulate matter PM25 - PRI Particulate matter less than or equal to 2.5 microns in diameter that includes both the filterable and condensable components of particulate matter SI C Standard Industrial Classification code SIP State Implementation Plan SCC Source Classification Code SO2 Sulfur dioxide VOC Volatile organic compoundsTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 1

MACTEC Federal Programs, Inc. 

## 1.0 EXECUTIVE SUMMARY The States of the Ozone Transport Region (OTR) are faced with the requirement to submit attainment demonstration plans for the 8 - hour ozone National Ambient Air Quality Standards (NAAQS). To accomplish this, most of the states will need to implement additional measures to reduce emissions that either directly impact their nonattainment status, or contribute to the nonattainment status in other states. As such, the Ozone Transport Commission (OTC) undertook an exercise to identify a suite of additional control measures that could be used b y the OTR states in attaining their goals. The OTC staff and member states formed several workgroups to identify and evaluate candidate control measures. Initially, the Workgroups compiled and reviewed a list of approximately 1,000 candidate control measures. These control measures were identified through published sources such as the U.S. Environmental Protection Agency’s (EPA’s) Control Technique Guidelines, STAPPA/ALAPCO “Menu of Options” documents, the AirControlNET database, emission control initiatives in member states as well as other states including California, state/regional consultations, and stakeholder input. The Workgroups developed a preliminary list of 30 candidate control measures to be considered for more detailed analysis. These measures were selected to focus on the pollutants and source categories that are thought to be the most effective in reducing ozone air quality levels in the Northeastern and Mid - Atlantic States. The Workgroups discussed the candidate control measures during a series of conference calls and workshops held periodically from the spring of 2004 through the autumn of 2006. The Workgroups collected and evaluated information regarding emission benefits, cost - effectiveness, and implementation issues. Each of the candidate control measures were summarized in a series of “Control Measure Summary Sheets”. Stakeholders were provided multiple opportunities to review and comment on the Control Measure Summary Sheets. Based on the anal ys es b y the OTC Workgroups, the OTC Commissioners made several rec ommendations at the June 2006 Commissioners’ meeting in Boston (OTC 2006a - d) and at the November 2006 Commissioners’ meeting in Richmond (OTC 2006e - g). The Commissioners recommended that States consider emission reductions from the following source categories: · Consumer Products · Portable Fuel Containers · Adhesives and Sealants Application · Diesel Engine Chip Reflash · Cutback and Emulsified Asphalt PavingTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 2

MACTEC Federal Programs, Inc. 

### · Asphalt Production Plants · Cement Kilns · Glass Furnaces · Industrial, Commercial, and Institutional (ICI) Boi lers · Regional Fuels Additionally , the Commissioners directed the OTC to evaluate control measures for Electric Generating Units (EGUs) and high electric demand day units (these measures will be addressed in a separate OTC report) Finally , the Commissioners requested that EPA pursue federal regulations and programs designed to ensure national development and implementation of control measures for the following categories: architectural and maintenance coatings, consumer products, ICI boilers over 100 mmBtu/hour heat input, portable fuel containers, municipal waste combustors, regionall y c onsistent and environmentally sound fuels, small offroad engine emission regulation, and gasoline vapor recovery (OTC 2006d). See Appendix A for a full description of the p rocess used by the OTC to identify and evaluate candidate control measures. Table 1 - 1 summarizes information about the control measures identified b y the OTC Commissioners at the June 2006 and November OTC meetings. Table 1 - 1 identifies the sector, the source category, and a brief description of the control measure. Next is a column that identifies the recommended approach for implementing the rule, such as an OTC model rule or updates to existing state - specific rules. The next two columns show the percent reduction from 2009 emission levels. The final column provides the cost effectiveness estimate in units of dollars per ton of pollutant removed. Table 1 - 2 summarizes the expected emission reductions by pollutant, control measure and State. The emis sion 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 b y s tate for VOC and NOx, respectively.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 3

MACTEC Federal Programs, Inc. 

### Table 1 - 1 Summary of OTC 2006 Control Measures Sector Source Category Control Measure Imple mentation Method Percent Reduction

from 2009 OTB/W Emission Levels Cost Effectiveness NOx VOC ($/ton) Area Adhesives, Sealants,

Adhesive Primers, and Sealant Primers (Industrial) Enact VOC content limits similar to those contained in the CARB RACT/BARCT document for adhesives and sealants (Dec. 1998) Model Rule --- 64 VOC: 2,500 Area Cutback and

Em ulsified Asphalt Paving Prohibits the use of cutback asphalt during the ozone season Limits the use of emulsified asphalt during the ozone season to that which contains not more than 0.5 mL of oil distillate from a 200 mL sample as determined using ASTM Method D244 State Rule Update --- State specific depending on current rules VOC: minimal

Area Consumer Products Adopt the CARB 7/20/05 Amendments which sets new or revises existing VOC limits on 12 consumer product categories (does not include reductions for Tier2 shaving gels and antistatic aerosols since they have a later compliance date). Model Rule --- 2 VOC: 4,800

Area Portable Fuel

Containers Adopt the CARB 2006 Amendments broadening the definition of PFCs to include kerosene and diesel containers and utility jugs used for fuel, and other changes to make OTC Model Rule consistent with CARB requirements. Model Rule --- State specific VOC: 800

to 1,400 Area and Point Asphalt Production

Plants Area/Point Sources Batch Natural Gas 0.02 lb/ton or equivalent ppm Batch Distillate 0.09 lb/ton or equivale nt ppm Drum Natural Gas 0.02 lb/ton or equivalent ppm Drum Distillate 0.04 lb/ton or equivalent ppm or Lo w NOx Burners, Best Management Practices State Rule Update 10 - 35 --- NOx: <500 to 1,250TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 4

MACTEC Federal Programs, Inc. Sector Source Category Control Measure Imple mentation Method Percent Reduction

from 2009 OTB/W Emission Levels Cost Effectiveness NOx VOC ($/ton) Area and Point Industrial/

Commerc ial/ Institutional (ICI) Boilers >250 mmBtu/hour Option 1

– Purchase current year NOx allowances equal to reductions needed to achieve the required emission rates Option 2

– Phase I 2009 emission rate equal to EGUs of similar size; Phase II 2013 emission rate equal to EGUs of similar size Model Rule Boiler and State specific --- NOx: 600 to 18,000

Area and Point ICI Boilers

100 - 250 mmBtu/hour NOx Strategy #1: Nat gas: 0.10 lb/mmBtu #2, #4, #6 Oil: 0.20 lb/mmBtu Coal: 0.08 to 0.22 lb/mmBtu, depending on boiler type NOx Strategy #2: Reductions achievable through LNB/SNCR, LNB/FGR, SCR or some combination of these controls NOx Strategy #3: 60% reduction from uncontrolled NOx Strategy #4: Purchase current year CAIR allowances State Rule Update Boiler and State specific --- NOx: 600 to 18,000

Area and Point ICI Boilers

25 - 100 mmBtu/hour NOx Strategy #1: Nat gas: 0.05 lb/mmBtu #2 Oil: 0.08 lb/mmBtu #4, #6 Oil: 0.20 lb/mmBtu Coal: 0.30 lb /mmB tu NOx Strategy #2: 50% reduction from uncontrolled NOx Strategy #3: Purchase current year CAIR allowances State Rule Update Boiler and State specific --- NOx: 600 to 18,000

Area and Point ICI Boilers

<25 mmBtu/hour Annual boiler tune -up State Rule Update State specific ---TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 5

MACTEC Federal Programs, Inc. Sector Source Category Control Measure Imple mentation Method Percent Reduction

from 2009 OTB/W Emission Levels Cost Effectiveness NOx VOC ($/ton) Point Glass Furnaces Require furnace operators to meet the emission limits in the San Joaquin Valley rule by 2009. These limits are achievable through implementation of “oxyfiring” technology for each furnace at furnace rebuild. If the operator does not rebuild the furnace by 2009 or implement measures to meet the limits in the San Joaquin Valley rule, the operator wo uld be required to purchase NOx allowances equal to the difference between actual emissions and the limits in the San Joaquin Valley rule. Com pliance with Rule 4354 will allow manufacturers to use a mix of control options to meet the suggested limits. Manufacturers may propose alternative compliance methods to meet the specified limits, including emissions averaging. State Rule or Permit Source

specific --- NOx: 1,254 to 2,500

Point Cement Plants Require existing kilns to meet a NOx emission rate of 3.88 lbs/ton clinker for wet kiln 3.44 lbs/ton clinker for long dry kiln 2.36 lbs/ton clinker for pre - heater kiln 1.52 lbs/ton clinker for pre - calciner kiln State Rule Update Source specific --- NOx: <2,500

Onroad Mobile Diesel Truck Chip

Reflash Mandatory program to upgrade the version of software in engine electronic control module (ECM), (also known as “chip reflash) to reduce offcycle NOx emissions. Model Rule 10 --- NOx: 20 - 30 Onroad Mobile Regional Fuel based on

Reformulated Gasoline Options Extend RFG requirements to counties in OTC that currently do not have RFG. Memorandum of Understanding - O TC State

specific State

specific VOC: 5,200

NOx: 3,700TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 6

MACTEC Federal Programs, Inc. 

### Table 1 - 2 Estimated Emission Benefits in 2009 by State Resulting from the OTC 2006 Control Measures VOC Emission Reduction Benefit

(summer tpd) NOx Emission Reduction Benefit (summer tpd)

StateAdhesives & SealantsCutback\EmulsifiedAsphalt PavingConsumer ProductsPFC (Area)aPFCs (Nonroad)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 0.1 0.0 9.7 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 <0.1 0.0 1.4 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 <0.1 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 <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 0.4 3.2 11.8 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 0.5 0.0 29.3 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 0.1 4.3 11.5 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 0.3 0.0 16.7 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 0.8 56.9 101.9 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 0.5 58.0 92.3 12.4 2.0 0.2 14.0 24.3 12.2 9.8 73.9 RI 1.5 1.1 0.2 0.2 <0.1 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 <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 0.1 0.0 1.9 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 3.0 139.4 314.8 63.0 4.8 3.0 42.5 37.3 69.5 37.7 257.8 a) The table shows the estimated emission reduction that will occur in 2009; additional reductions will occur in later years as ne w, less - emitting PFCs that comply with the OTC 2006 control measure penetrate the market. b) The table show the maximum emission reduction from glass/fiberglas s furnaces when the OTC 2206 control measure is fully implemented. No all of the reduction shown will be achieved by 2009. c) The following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County. d) MA proposed rule has a January 1, 2009 effective date and includes the VOC limits from the OTC 2001 model rule and those in the OTC 2006 model rule. The 2009 benefit MA shows the benefit from both sets of limits. For all other States, the 2009 benefit shows the change in emissions from the OTC 2006 model rule only.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 7

MACTEC Federal Programs, Inc. 

### Figure 1 - 1 VOC Emission Reduction Benefits from OTC 2006 Control Measures in 2009



### 0 10 20 30 40 50 60 70 80 90 100 110

CT DE DC ME MD MA NH NJ NY PA RI VT NOV AVOC Reduction (tpsd) 

### Re gion al Fu el PFCs (No nroad) PFCs (A re a) Co ns um er Produ cts As ph al t P avin g Ad he si ve sTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 1

– Executive Summary Page 1 - 8

MACTEC Federal Programs, Inc. 

### Figure 1 - 2 NOx Emission Redu ction Benefits from OTC 2006 Control Measures in 2009



### 0 10 20 30 40 50 60 70 80 90

CT DE DC ME MD MA NH NJ NY PA RI VT NOV ANOx Reduction (tpsd) 

### IC I B oil er (P oin t)

IC I B oil er (A re a) Gl ass F urna ces Ce men t K il ns As ph al t P la nts Ch ip R efla sh Re gion al Fu elTSD for 2006 OTC Control Meaure Evaluation February 28, 2007

Section 2

– Introduction Page 2 - 1

MACTEC Federal Programs, Inc. 

## 2.0 INTRODUCTION The Ozone Transport Commission (OTC) is a multi - state organization created under the Clean Air Act (CAA). The OTC is responsible for advising EPA on transport issues and for developin g and implementing regional solutions to the ground- level ozone problem in the Northeast and Mid- Atlantic regions. To supplement local and state - level efforts to reduce ozone precursor emissions, which may not alone be sufficient to attain federal standards, the OTC member states are considering control measures appropriate for adoption by all states in the region as part of their planning to attain and maintain the 8 - hour ozone National Ambient Air Quality Standards (NAAQS). The development of the control measures described in this document parallels a prior effort. The OTC developed a series of model rules in 2001 for the States to consider in adopting control measures to reduce volatile organic compound (VOC) emissions and oxide of nitrogen (NOx), whi ch are ozone precursors, to (1) assist in the attainment of the one - hour ozone health standard, (2) address the VOC and NOx emission reduction shortfalls identified by EPA, and (3) implement the State Implementation Plans (SIP) commitments to EPA. These m odel rules, which have been adopted in many OTC states, will be referred to as the “OTC 2001 model rules” in this document. The anal ys is in this report provides a description of the control measures identified by the OTC to help states attain the 8 - hour o zone NAAQS. It also describes the associated incremental emission reductions and costs associated with each measure. The control measures analyzed in this report are those that were identified by the OTC Commissioners at the June 2006 OTC annual meeting in Boston (OTC 2006a, OTC 2006b, OTC 2006c) and at the November 2006 OTC fall meeting in Richmond (OTC 2006d, OTC 2006e, OTC 2006f). These control measures will be referred to as the “OTC 2006 control measures” in this document. For some source categorie s, the OTC has amended the OTC 2001 model rules or developed new model rules. These model rules will be referred to as the “OTC 2006 model rules” in this document. The OTC 2006 model rules for volatile organic compounds (VOC) will reduce emissions from adhesives, sealants, adhesive primer, and sealant primer application; cutback and emulsified asphalt paving; consumer products; regional fuels; and portable fuel containers. The OTC 2006 control measures for oxides of nitrogen (NOx) will reduce emissions from asphalt production plants, cement kilns, diesel engine chip reflash, regional fuels, electric generating units (EGUs), glass and fiberglass furnaces, and industrial, commercial, institutional (ICI) boilers. Section 3 describes the methods used to es timate the emission benefits of the VOC control measures. For each source category, there are subsections that describe the existing Federal and OTC StateTSD for 2006 OTC Control Meaure Evaluation February 28, 2007

Section 2

– Introduction Page 2 - 2

MACTEC Federal Programs, Inc. 

### regulations that affect the VOC emissions, summarize the major elements of the control measures, dis cuss how the emission benefits were quantified, and present information on anticipated costs and cost - effectiveness. VOC emissions and reductions by State and source category in 2002 and 2009 are presented at the end of Section 3. Section 4 presents simi lar 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 description of the process that the O TC followed in identifying and evaluating candidate control measures. Appendix B lists the approximately 1,000 control measures that were initially anal yz ed. Appendix C contains the control measure summary sheets that were developed during this analysis. Appendices D, E, and F present the emission benefits by county for VOC, NOx, and SO2 respectivel y. Each appendix contains a tabulation of the 2002 base emissions, the projected 2009/2012/2018 emissions and expected emission reduction benefit from the additional control measures in 2009/2012/2018). Appendix G contains a listing of State ICI boiler regulations.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 1

MACTEC Federal Programs, Inc. 

## 3.0 VOC ANALYSIS METHODS This Section describes the anal ys is of the 2006 OTC control measures to reduce VOC emissions from five source categories: adhesives, sealants, adhesive primer, and sealant primer application; cutback and emulsified asphalt paving; consumer products; regional fuels; and portable fuel containers. For each of the five categories, there are separate subsections that discuss ex isting Federal/state rules, summarize the requirements of the 2006 OTC control measure, describe the methods used to quantify the emission benefit, and provide an estimate of the anticipated costs and cost - effectiveness of the control measure. At the end of Section 3, we provide the estimated emissions for 2002 and 2009 by source category and State. Appendix D provides county-by- county summaries of the emission reductions for each of the categories and projection years. 3.1 ADHESIVES, SEALANT, ADHESIVE PRIM ER, AND SEALANT PRIMER

APPLICATION Adhesives, sealants, adhesive primer, and sealant primer are used in product manufacturing, packaging, construction, and installation of metal, wood, rubber, plastic, ceramics, or fiberglass materials. In general, an adh esive is any m aterial used to bond two surfaces together. In general, a sealant is a material with adhesive properties that is used primarily to fill, seal, waterproof or weatherproof gaps or joints between two surfaces. VOC emissions from this category result from evaporation of solvents during transfer, drying, surface preparation and cleanup operations. These solvents are the media used to solubilize the adhesive, sealant, or primer material so that it can be applied. The solvent is also used to compl etely wet the surface to provide a stronger bond. In plastic pipe bonding, the solvent dissolves the poly

vinyl chloride pipe and reacts with the pipe to form a bond. Solvents used to clean the surface before bonding and to clean the application equipment after bonding also contribute to VOC emissions. VOC emissions in this category are primaril y from industrial and commercial operations such as wood product manufacturers, upholstery shops, adhesives retailers and architectural trades, such as building cons truction, floor covering installation and roof repair. 3.1.1 Existing Federal and State Rules EPA published the consumer and commercial products rule on September 11, 1998 (40 CFR Part 59 Subpart D) under authority of Section 183(e) of the Clean Air Act. The Fe deral Part 59TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 2

MACTEC Federal Programs, Inc. 

### Subpart C requirements for consumer products regulate five types of “household” adhesives (aerosols, contact, construction and panel, general purpose and structural waterproof). The VOC content limits for these products appl y only to “househ old products”, defined as “any consumer product that is primarily designed to be used inside or outside of living quarters or residences, including the immediate surroundings, that are occupied or intended for occupation by individuals.” Thus, the Part 59 rule applies onl y t o adhesives used in household settings and not to adhesives used in industrial or commercial applications. The OTC developed a model rule for consumer and commercial products in 2001 (referred to as the “OTC 2001 model rule for consum er products” in this document) to regulate additional consumer product categories by requiring more stringent VOC content limits than the Federal rule. The OTC 2001 model rule for consumer products contains VOC limits for adhesives and sealants. However, with the exception of aerosol adhesives, the definitions of these products generall y ex empt products sold in larger containers. Specificall y, the OTC 2001 model rule includes the following definitions (italics added for emphasis):

· 

### Section 2(8) Adhesive. "Adhesive" means any p roduct that is used to bond one surface to another b y attachment. “Adhesive” does not include products used on humans and animals, adhesive tape, contact paper, wallpaper, shelf liners, or any other product with an adhesive incorpo rated onto or in an inert substrate. For “Contact Adhesive,” adhesive does not include units of product, less packaging, which consist of more than one gallon . For “Construction, Panel, and Floor Covering Adhesive,” and “General Purpose Adhesive”, adhesive does not include units of product, less packaging, which weigh more than one pound and consist of more than 16 fluid ounces . This limitation does not apply to aerosol adhesives. · Section 2(148) Sealant and Caulking Compound. "Sealant and Caulking Compound" means any product with adhesive properties that is designed to fill, seal, waterproof, or weatherproof gaps or joints between two surfaces. “Sealant and Caulking Compound” does not include roof cements and roof sealants; insulating foams; removable caulking compounds; clear/paintable/water resistant caulking compounds; floor seam sealers; products designed exclusively for automotive uses; or sealers that are applied as continuous coatings. “Sealant and Caulking Compound” also does not include units of product, less packaging, which weigh more than one pound and consist of more than 16 fluid ounces. For the purposes of this definition only , “removable caulking compounds” means a compound which temporaril y s eals windows or doors for three to six month time intervals, and “clear/paintable/water resistant caulking compounds” means a compound which contains no appreciable level of opaque fillers or pigments; transmits most or all visible light through the caulk when cured; is paintable; and is immediately resis tant to precipitation upon application. Thus, the same products sold in containers larger than the above thresholds are not covered b y the OTC 2001 model rule for consumer products.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 3

MACTEC Federal Programs, Inc. 

### 3.1.2 Description of the OTC 2006 Model Rule The OTC 2006 model rule for adhesives and sealants is based on the reasonably available control technology (RACT) and best available retrofit control technology (BARCT) determination b y the California Air Resources Board (CARB) developed in 1998. The OTC 2006 model rule has the following requirements: A. Regulates the application of adhesives, sealants, adhesive primers and sealant primers by providing options for appliers to either to use a product with a VOC content equal to or less than a specified limit or to use add- on controls; B. Limits the VOC content of aerosol adhesives to 25 percent b y wei ght; C. Requirements for cleanup solvents; D. A VOC limit for surface preparation solvents; E. An alternative add - on control system requirement of at least 85 percent overall control efficiency (capture and de struction efficiency), b y weight; F. VOC containing materials must be stored or disposed of in closed containers; G. Prohibits the sale of any adhesive, sealant, adhesive primer or sealant primer which exceeds the VOC content limits listed in the model rule; H. Manufacturers must label containers with the maximum VOC content as supplied, as well as the maximum VOC content on an as - applied basis when used in accordance with the manufacturer’s recommendations regarding thinning, reducing, or mixing with any other V OC containing material; and I. Prohibits the specification of any adhesive, primer, or sealant that violates the provisions of the model rule. Several adhesive and sealant applications and products are exempt from this model rule: tire repair, assembly and manufacturing of undersea -based weapon s ys tems, testing and evaluation associated with research and development, solvent welding operations for medical devices, plaque laminating operations, products or processes subject to other state rules, low - VOC product s (less than 20 g/l), and adhesives subject to the state rules based on the OTC 2001 consumer products model rule. Additionally , the model rule provides an exemption for adhesive application operations at stationary sources that use less than 55 gallons p er calendar year of noncomplying adhesives and for stationary sources that emit not more than 200 pounds of VOCs per year from adhesives operations.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 4

MACTEC Federal Programs, Inc. 

### 3.1.3 Emission Benefit Analysis Methods Emissions from this category are classified as both point sources and are a sources. About 96 percent of adhesive and sealant VOC emissions in the OTC states fall into the area source category . The remaining four percent of the VOC emissions are included in the point source inventory . The emission reduction benefit estimation methodology for area sources is based on information developed and used b y C ARB for their RACT/BARCT determination in 1998. CARB estimates that the total industrial adhesive and sealant emissions in California to be about 45 tons per day (tpd). Solvent -b ased emissions are estimated to be about 35 tpd of VOC and water-based adhesive and sealant emissions are about 10 tpd of VOC. CARB indicated that the emission reductions would be achieved mainl y due to the switch from high - VOC to low - VOC products rather than from the use of add - on control devices. CARB estimated that emission reductions achieved b y s tatewide compliance with the VOC limits in the RACT/BARCT determination will range from approximately 29 to 35 tpd (CARB 1998, pg. 18). These emission reductions correspond to a 64.4 to 77.8 percent reduction from uncontrolled levels. For OTC modeling purposes, we used the lower end of this range (i.e., 64.4 percent reduction) to estimate the emission benefit for area sources due to the OTC 2006 model rule. For point sources, we first identified those sources that were applying adhesives and sealants (using the source classification code of 4 - 02 - 007 - xx, adhesives application). Next, we reviewed the MANEVU inventory to determine whether sources had existing capture and control s ys tems. Several sources reported capture and destruction efficiencies in the 70 to 99 percent range. A few sources reported capture and destruction efficiencies of 99+ percent. Most of the controlled sources reported capture and de struction efficiencies in the 90 - 98 percent range. Sources with existing control systems that exceed an 85 percent overall capture and destruction efficiency would meet the OTC 2006 model rule provision for add - on air pollution control equipment; no additional reductions were calculated for these sources. For point sources without add- on control equipment, we used the 64.4 percent reduction discussed in the previous paragraph based on the CARB determination. 3.1.4 Cost Estimates The cost of compl ying with the new requirements includes the cost of using alternative formulations of low - VOC or water-based adhesives, sealants, adhesive primers, and sealant primers and cleanup products. Based on information provided by the Ventura County Air Pollution Control District, CARB determined that the cost - effectiveness of their adhesives ruleTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 5

MACTEC Federal Programs, Inc. 

### 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 likel y to be less in the OTR, because some of the one - time res earch 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 equip ment to comply with the requirements. 3.2 CUTBACK AND EMULSIFIED ASPHALT PAVING Asphalt paving is used to pave, seal and repair surfaces such as roads, parking lots, drives, walkways and airport runways. Asphalt paving is grouped into three general categories : hot mix, cutback, and emulsified. Hot - mix asphalt is the most commonly used paving asphalt. Hot mix asphalt produces minimal VOC emissions because its organic components have high molecular weights and low vapor pressures. Cutback asphalt is used in tack and seal operations, in priming roadbeds for hot - mix application and for paving operations for pavements up to several inches thick. In preparing cutback asphalt, asphalt cement is blended or “cut back” with a diluent, ty

pically from 25 to 45 percent by volume of petroleum distillates, depending on the desired viscosity . Emulsified asphalt is used in most of the same applications as cutback asphalt but is a lower emitting alternative to cutback asphalt. Instead of blending asphalt cement with petroleum distillates, emulsified asphalts use a blend of asphalt cement, water and an emulsifying agent, such as soap. Some emulsified asphalts contain virtually no VOC diluents; however, some emulsified asphalts may contain up to 12 percent VOC by volume. 3.2.1 Ex isting Federal and State Rules The EPA published a Control Technique Guideline (CTG) for the use of cutback asphalt in December 1977. The CTG recommended replacing cutback asphalt binders with emulsified asphalt during the ozone season. In 1979, EPA adde d a specification for emulsified asphalt to the CTG recommendations to limit the content of oil distillate in emulsified asphalt to no higher than 7 percent oil distillate. Table 3 - 1 summarizes the current asphalt paving rules for the 13 OTR states. Mos t 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 greatl y. The VOC content of emulsified asphalt is limited to 0 - 12 percent, depending on the State and the ty pe of emulsified asphalt. Delaware completely bans the use of emulsified asphalt that contains any VOC.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 6

MACTEC Federal Programs, Inc. 

### Table 3 - 1 Summary of OTC State Rules for Cutback a nd 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 exceptio ns 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 app roval 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 O ctober 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 volumeTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 7

MACTEC Federal Programs, Inc. 

### 3.2.2 Description of the OTC 2006 Model Rule The OTC 2006 model rule for the asphalt paving control mea sure prohibits the use of cutback asphalt during the ozone season and limits the use of emulsified asphalt to that which contains not more than 0.5 mL of oil distillate from a 200 mL sample (as determined using American Society for Testing and Materials {A STM} Method D244 - Test Methods for Emulsified Asphalts) regardless of application. This is equivalent to a VOC content of 0.25 percent. Exemptions may be granted under certain circumstances upon the approval of the State commissioner. 3.2.3 Emission Benefit Analysis Methods The OTC 2006 control measure for asphalt paving calls for a complete ban on the use of cutback asphalt during the ozone season. As shown in Table 3 - 1, current state regulations generall y ban the use of cutback asphalt during the ozone se ason. 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 ex emptions and totally eliminates any VOC emissions from the us e of cutback asphalt during the ozone season. The emission reductions resulting from OTC 2006 control measure for emulsified asphalt vary by State. The two percent VOC content limit on emulsified asphalt depend on the baseline VOC content of emulsified asphalt. The control measure limits emulsified asphalt to not more than 0.5 mL of oil distillate from a 200 mL sample as determined using ASTM Method D244. This is equivalent to a VOC content of 0.25 percent. The baseline VOC content may range from 0 to 1 2 percent. New Jersey used a VOC content of 8 percent in their baseline emission calculations (based on the 8 percent limit in their current rule). Reducing the VOC content to 0.25 percent in New Jersey will result in a 96.9 percent reduction. Delaware already b ans the use of emulsified asphalt that contains any VOC, so there is no reduction in Delaware. Several other states used an average VOC content of 2.5 percent when developing their emission inventory. Thus, reducing the average VOC content from 2.5 percent to 0.25 percent results in a 90 percent reduction in VOC emissions. For States that did not supply a baseline VOC content for asphalt paving, we used the 90 percent reduction in VOC emissions from emulsified asphalt paving during the ozone sea son. 3.2.4 Cost Estimates Low - VOC alternatives are currently available and no additional costs are expected from their use.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 8

MACTEC Federal Programs, Inc. 

### 3.3 CONSUMER PRODUCTS Consumer and commercial products are those items sold to retail customers for personal, household, or automotive use, along with the products marketed b y wholesale distributors for use in commercial or institutional settings such as beauty shops, schools and hospitals. VOC emissions from these products are the result of the evaporation of propellant and organic solvents during use. Consumer and commercial products include hundreds of individual products, including personal care products, household products, automotive aftermarket products, adhesives and sealants, FIFRA - related insecticides, and other miscellaneous products. 3.3.1 Existing Federal and State Rules EPA published the Federal consumer and commercial products rule on September 11, 1998 (40 CFR Part 59 Subpart D) under authority of Section 183(e) of the Clean Air Act. This rule limits the VOC content of 24 product categories representing 48 percent of the consumer and commercial products inventory nationwide. According to EPA, VOC emissions from those 24 product categories were reduced b y 20 percent. But since over half of the inventory is unaffected b y the rule, the Federal rule is estimated to yield VOC reductions of 9.95 percent of the total consumer products inventory (Pechan 2001, pg 7). Since over half of the inventory is unregulated by the Federal Part 59 rule, the OTC developed a model rule for consumer and commercial products in 2001 (referred to as the “OTC 2001 model rule for consumer products” in this document) to be used by the OTC jurisdictions to develop regulations for additional consumer product categories and to specify more stringent VOC content limits than the Federal rule. The VOC content limits and products covered in the OTC 2001 model rule are similar to the rules developed by CARB in the late 1990s. The OTC 2001 model rule for consumer products provides background for OTC jurisdictions to develop programs to regulate approximately 80 consumer product categories and includes technologicall y 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.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 9

MACTEC Federal Programs, Inc. 

### Table 3 - 2 Status of OTC State’s Promulgation of the OTC 2001 Model Rule for Consumer Products. State Effective Date of VOC Limits Regulatory Citation CT a Initiated process to adopt in 2006 R.C.S.A. section 22a - 174 - 40 D E 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 Janaury 1, 2005 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 V T Under Consideration n/a VA c Effective July 1, 2005 Chapter 40, Article 50 a) Connecticut’s proposed rule includes both the VOC limits from the OTC 2001 model rule and the new and revised VOC emissions limits and related provisions that were adopted by the California Air Resources Board on July 20, 2005. These new and revised VOC limits are identical to those in the OTC 2006 model rule. b) Massachusett’s proposed rule includes the VOC limits from the OTC 2001 model rule and those in the OTC 2006 mo del rule. c) Virginia’s rule applies only in Northern Virginia VOC Emission Control Area (10 northern Virginia jurisdictions in the OTR)



### 3.3.2 Description of the OTC 2006 Model Rule The OTC 2001 model rule for consumer products closely mirrored a series of five CARB consumer products rules. CARB recently amended their consumer products rules in July 2005. As shown in Table 3 - 3, these amendments to the CARB rule affected 18 categories of consumer products (14 new categories, including subcategories, with new product category definitions and VOC limits; one previously regulated category with a more restrictive VOC limit; and two previously regulated categories with additional requirements).TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 10

MACTEC Federal Programs, Inc. 

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

N ew 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 Speci al Purpose 

### Most of these new CARB limits become effective in California by December 31, 2006. Two of the limits, anti - static products (aerosol) and shaving gels, have effective dates in either 2008 or 2009. For shaving gels, there is a VOC limit that be comes effective on December 31, 2006, with a more stringent second tier limit that becomes effective on December 31, 2009. The anti - static product (aerosol) limit becomes effective on December 31, 2008. The OTC 2006 model rule will modify the OTC 2001 model rule based on the CARB July 20, 2005 amendments. The OTC is not including the anti - static aerosol products and the second tier shaving gel limit in its revisions to the OTC 2001 model rule because of industry concerns that meeting these limits may not be feasible. CARB acknowledged these concerns b y requiring a technology review of these product categories in 2008 to determine whether the limits are achievable. 3.3.3 Emission Benefit Analysis Methods The emission reduction benefit estimation methodology is based on information developed b y CARB. CARB estimates 6.05 tons per day of VOC reduced in California from their July 2005 amendments (CARB 2004a, pg. 8), excluding the benefits from the two products (anti - static products and shaving gels) with complianc e dates in 2008 or 2009. This equates to about 2,208 tons per year in California. The population of California as of July 1, 2005 is 36,132,147TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 11

MACTEC Federal Programs, Inc. 

### (Census 2006). On a per capita basis, the emission reduction from the CARB July 2005 amendments equals 0.122 lbs/capita. Since the OTC’s 2006 control measure is very similar to the CARB July 2005 amendments (with the exclusion of the anti - static products and shaving gel 2008/2009 limits), the per capita emission reductions are expected to be the same in the OTR . The per capita factor after the implementation of the OTC 2001 model rule is 6.06 lbs/capita (Pechan 2001, pg. 8). The percentage reduction from the OTC’s 2006 control measure was computed as shown below:

Current OTC Emission Factor = 6.06 lbs/capita Benefit from CARB 2005 amendments = 0.122 lbs/capita

Percent Reduction =

= 100%*(1 - (6.06

– 0.122)/6.06) 2.0% 3.3.4 Cost Estimates CARB estimates that the cost effectiveness of VOC limits with an effective date of December 31, 2006, to be about $4000 per ton of VOC reduced (CARB 2004, pg. 21). CARB further estimates that the average increase in cost per unit to the manufacturer to be about $0.16 per unit. Assuming CARB’s estimates for the OTR provides a conservative estimate, because some of the one - time res earch and reformulation costs incurred for products sold in California will not have to be incurred again for products sold in the OTR. 3.4 PORTABLE FUEL CONTAINERS Portable fuel containers (PFCs) are designed for transporting and storing fuel from a retail distribution point to a point of use and the eventual dispensing of the fuel into equipment. Commonly referred to as “gas cans,” these products come in a variety of shapes and sizes with nominal capacities ranging in size from less than one gallon to over six gallons. Available in metal or plastic, these products are widely used to refuel residential and commercial equipment and vehicles when the situation or circumstances prohibits direct refueling at a service station. PFCs are used to refuel a broad range of small off - road engines and other equipment (e.g., lawnmowers, chainsaws, personal watercraft, motorcycles, etc.). VOC emissions from PFCs are classified b y five different activities:

· 

### Transport- spillage emissions from PFCs occur when fuel escapes f rom PFCs that are in transit. · 

### Diurnal emissions result when stored fuel vapors escape to the air through any possible openings while the container is subjected to the daily cycle of increasing and decreasingTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 12

MACTEC Federal Programs, Inc. 

### ambient temperatures. Diurnal emissions depend on the closed - or open - storage condition of the PFC. · 

### Permeation emissions are produced after fuel has been stored long enough in a container for fuel molecules to infiltrate and saturate the container material, allowing vapors to escape through the walls of containers made from plastic. · 

### Equipment refueling vapor displacement and spillage emissions result when fuel vapor is displaced from nonroad equipment (e.g., lawnmowers, chainsaws, personal watercraft, motorcycles, etc.) and from gasoline spillage during refueling of the equipment with PFCs. These VOC emissions are already t aken 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 b y C ARB in 2000. The OTC 2001 model rule provides background for OTC jurisdictions to develop regulatory programs that require spill -proof containers to meet performance standards that reduce VOC emissions. The performance standards include a requirement that all PFCs to have an automatic shut - off feature preventing overfilling and an automatic closing feature so the can will be sealed when it is not b eing used. The performance standards also eliminate secondary venting holes and require new plastics to reduce vapor permeation through container walls. There is no requirement for owners of conventional PFCs to modify their PFCs or to scrap them and buy new ones. Compliance will be accomplished primarily through attrition. As containers wear out, are lost, damaged, or destroyed, consumers will purchase new spill -proof containers to replace the conventional containers. CARB determined that the average useful life of a PFC is five years. The OTC chose to assume a more conservative ten - ye ar turnover rate, with 100 percent rule penetration occurring 10 years after adoption of the rule. CARB estimated that the performance standards would reduce VOC emiss ions by 75 percent. CARB’s 2004 anal ys is (CARB 2004b) reevaluated the estimate reductions due to some unforeseen issues with the new cans and new survey information. Based on CARB’s updated data, CARB estimated that VOC emissions would be reduced b y 65 p ercent from the first set of amendments. CARB has also adopted a second set of amendments in two phases. The first phase was filed on January 13, 2006, effective February 12, 2006. For Phase I, CARM amended their PFC regulation to address the use of utility jugs and kerosene containers that are sometimes used byTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 13

MACTEC Federal Programs, Inc. 

### consumers for gasoline. The second phase of the amendments was filed on September 11, 2006, effective October 11, 2006. These amendments (CARB 2006) will: · Establish a mandatory certification p rogram and accompanying test procedures; · Amend the existing performance standards to eliminate the automatic shutoff performance standard effective July 1, 2007; · Amend the existing performance standards to eliminate the fill height and flow rate performanc e 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 

### ; · Establish a voluntary consumer acceptance - labeling program that allows participating manufacturers to label their PFCs with an ARB “Star Rating” indicating how consumers rate their products’ ease of use; and · Combine the currentl y s eparate evaporation requirement and permeation standard and test method into a single diurnal standard and test method. In Feb ruary 2007, EPA finalized a national regulation to reduce hazardous air pollutant emissions from mobile sources. Included in the final rule are standards that would reduce PFC emissions from evaporation, permeation, and spillage. EPA included a performance -based standard of 0.3 grams per gallon per day of hydrocarbons, determined based on the emissions from the can over a diurnal test cycle specified in the rule. The standard applies to containers manufactured on or after January 1, 2009. The standards are based on the performance of best available control technologies, such as durable permeation barriers, automatically closing spouts, and cans that are well - sealed. 3.4.2 Description of the OTC 2006 Model Rule As shown in Table 3 - 4, most states in the OTR hav e already adopted PFC regulations based on the OTC 2001 model rule. The OTC 2001 model rule for PFCs closel y mirrors the 2000 version of CARB’s PFC rule. CARB recentl y amended their gas can regulation as discussed above in Section 3.4.1. The OTC 2006 mo del rule closel y mirrors these CARB amendments. The 2006 amendments are estimated to reduce VOC emissions by 18.4 tons per day in California at full implementation in the year 2015, in addition to the benefits from the existing regulation. The OTC 2006 m odel rule will modify the OTC 2001 model rule based on the recent CARB amendments.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 14

MACTEC Federal Programs, Inc. 

### Table 3 - 4 Status of OTC State’s Promulgation of the OTC 2001 Model Rule for Portable Fuel Containers State Date When New Containers are Required Regulatory Citation CT Effective May 1, 2004 Section 22a - 174 - 43 DE Effective January 1, 2004 Reg. No. 41, Section 3 DC Effective November 15, 2003 Rule 720 ME Effective January 1, 2004 Chapter 155 MD Effective January 1, 2003 COMAR 26.11.13.07 MA a In progress (effective dat e will be January 1, 2009) n/a NH Effective March 1, 2006 Env -A 4000 NJ Effective January 1, 2005 Subchapter 24 (7:27 - 24.8) NY Effective January 1, 2003 Part 239 PA Effective January 1, 2003 25 Pa. Code Chapter 130, Subchapter A RI In progress (late 2006 target date for final rule) n/a VT Under Consideration n/a VAb Effective January 1, 2005 Chapter 40, Article 42 a) Massachusetts’ proposed rule will be based only on the OTC 2006 model rule; Massachessetts will not adopt the OTC 2001 model rule. b) Virginia’s rule applies only in Northern Virginia VOC Emission Control Area (10 northern Virginia jurisdictions in the OTR) 

### 3.4.3 Emission Benefit Analysis Methods Emissions from PFCs are accounted for in both the area and nonroad source inventories. The NONROAD model accounts for equipment refueling vapor displacement and spillage emissions result when fuel vapor is displaced from nonroad equipment (e.g., lawnmowers, chainsaws, personal watercraft, motorcycles, etc.) and from gasoline spillage during refueling of the equipment with PFCs. The area source inventory accounts for diurnal and permeation emissions associated with the fuel present in stored PFCs and transport- spillage emissions associated with refueling of a gas can at the gasoline pump. Based on the OTC 2001 model rule (Pechan 2001, pg. 11) roughly 70 percent of the VOC emissions are accounted for in the area source inventory, while the remaining 30 percent is from equipment refueling vapor displacement and spillage that is accounted for in the no nroad inventory .TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 15

MACTEC Federal Programs, Inc. 

### The emission benefits have been calculated for the emissions accounted for in both the area and nonroad source inventory. Emissions from the nonroad category were estimated to be 30 percent of the PFC emissions accounted for in the area source inventory . Also note that the OTC baseline emissions (i.e., 2002 emissions) do not include changes to the emission estimation methodology made b y C ARB in 2004. CARB conducted a new survey of PFCs in 2004, which included kerosene containers and util ity jugs. Using this survey data, CARB adjusted their baseline emissions; a similar adjustment to the OTC baseline inventory has not been made. Estimated emission reductions were based on information compiled by CARB to support their recent amendments. CARB estimated that PFC emissions in 2015 will be 31.9 tpd in California with no additional controls or amendments to the 2000 PFC rules (CARB 2005a, pg. 10). CARB further estimates that the 2006 amendment will reduce emission from PFCs by 18.4 tpd in 20 15 in California compared to the 2000 PFC regulations (CARB 2005a, pg. 23). Thus, at full implementation, the expected incremental reduction is approximately 58 percent, after an estimated 65 percent reduction from the original 2000 rule. The OTC calculations assume that States will adopt the rule by July 2007 (except in Massachusetts) and provide manufacturers one year from the date of the rule to comply. Thus, new compliant PFCs will not be on the market until July 2008. Assuming a 10 - ye ar 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 b e 5.8 percent in 2009. 3.4.4 Cost Estimates CARB estimates that the cost - effectiveness of the 2005/2006 amendments will range from $0.40 to $0.70 per pound of VOC reduced, or $800 to $1,400 per ton of VOC reduced (CARB 2005a, pg. 27). Assuming CARBs costs for the OTR provides a conservative estimate, because some of the one - time research and reformulation costs incurred for products sold in California will not have to be incurred again for products sold in the OTR. 3.5 REGIONAL FUELS The Clean Air Act Amendments o f 1990 required significant changes to conventional fuels used by motor vehicles. Beginning in 1995, “reformulated” gasoline must be sold in certain non attainment areas and other states with non - attainment areas are permitted to opt - in.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 16

MACTEC Federal Programs, Inc. 

### Reformulated gas oline results in lower VOC emissions than would occur from the use of normal “baseline” gasoline. 3.5.1 Existing Federal and State Rules All but two states in the OTR are participating, in whole or in part, with the federal reformulated gasoline program. However, nearl y one - third of the gasoline sold in the OTR is not reformulated gasoline. NESCAUM has estimated the following fraction of gasoline that is reformulated b y 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% 

### 3.5.2 Description of the OTC 2006 Control Measure The Energy Policy Act of 2005 provides the opportunity for the OTR to achieve a single clean burning gasoline and is consistent with what OTR states have promoted through the long debate over MTBE/ethanol/RFG. Approximately one - third of the gasoline currently sold in the OTR is not reformulated. The new authority plus the potential for emission reductions from the amount of non - reformulated gasoline sold in the OTR provides an opportunity for additional emission reductions in the region as well as for a reduced number of fuels, and possibly a single fuel, to be utilized throughout the region. The OTC Commissioners recommended that the OTC member states pursue a region fuel program consistent with the Energy Act of 2005 (OTC 2006b). 3.5.3 Emission Benefit Analysis Methods Emission benefits resulting from extending reformulated gasoline to all areas of the OTR have been calculated for 2006 by NESCAUM (NESCAUM 2006a). 3.5.4 Cost Estimates According to USEPA’s regulatory impact analysis for reformulated gasoline (USEPA 1993), the cost per ton of VOC reduced for Phase I RFG is $5,200 to $5,900. USEPA also estimated theTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 17

MACTEC Federal Programs, Inc. 

### cost of Phase II RFG was $600 per ton of VOC reduced

– this reflects the incremental cost over the cost of implementing Phase I of the RFG program. 3.6 VOC EMISSION REDUCTION SUMMARY The results of the emission benefit calculations for the OTC states are described in this subsection. The s tarting point for the quantification of the emission reduction benefits is the MANEVU emission inventory , Version 3 (Pechan 2006, MACTEC 2006a) and the VISTAS emission inventory , BaseG (MACTEC 2006b), for the northern Virginia counties that are part of the OTR. The MANEVU and VISTAS inventories include a 2002 base year inventory as well as projection inventories for 2009 and 2018 (MANEVU also has projections for 2012, but VI STAS does not). The projection inventories account for growth in emissions based on growth indicators such as population and economic activity . The projection inventories also account for “on - the -books/on - the - way” (OTB/W) emission control regulations that have (or will) become effective between 2003 and 2008 that will achieve post - 2002 emission reductions. For example, many States have already adopted the 2001 OTC model rules for consumer products and portable fuel containers. The emission reduction benefit from the 2001 OTC model rules are already accounted for in the MANEVU and VI ST AS projection inventories. Emission reductions from existing regulations are already a ccounted for to ensure no double counting of emission benefits occurs. Note that the emission reductions contained in this Section are presented in terms of tons per s ummer day . The MANEVU base and projection emission inventories do not contain summer day emissions for all States and source categories; the VI STAS inventory only contains annual values. When States provided summer day emissions in the MANEVU inventory , these values were used directl y to quantify the emission benefit from the 2006 OTC control measure. When summer day emissions were missing from the MANEVU or VI STAS inventories, the summer day emissions were calculated using the annual emissions and the s easonal throughput data from the NIF Emission Process table. If the seasonal throughput data was missing, the summer day emissions were calculated using the annual emissions and a summer season adjustment factor derived from the monthly activity profiles contained in the SMOKE emissions modeling system. Tables 3 - 5 to 3 - 10 show State summaries of the emission benefits from the OTC 2006 VOC control measures described previousl y in this Section. For each of the source categories, the Tables show four columns: (1) the actual 2002 summer daily emissions; (2) the summer dail y emissions for the 2009 OTB/W scenario that accounts for growth and for the emission control regulations that have (or will) become effective between 2003 and 2008 that will achieve post2 002 emission reductions; (3) the summer dail y e missions for 2009 with the implementation ofTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 18

MACTEC Federal Programs, Inc. 

### the OTC 2006 control measures identified in this Section, and (4) the emission benefit in 2009 resulting from the OTC 2006 control measure. Table 3 - 11 shows the same information for the total of all six source categories. The largest estimated VOC emission reductions are in the most populous States

– New York and Pennsylvania. The emission benefits listed for Virginia just include the Virginia counties in the north ern Virginia area that are part of the OTR. Benefit estimates for all other States include the entire state. The emission benefits also assume that all OTC members will adopt the rules as described in the previous sections. The requirement for a regional fuel throughout the OTR provides the largest emission benefit, about 139.4 tons per day across the OTR. The adhesives and sealants application model rule provides the second largest emission benefit in 2009

– 82.3 tons per day across the OTR. The incremental benefits accrued from the amendments to State’s existing consumer products and portable fuel container model rules are not as large, since the States already have accrued substantial benefits from the adoption of these rules. Appendix D provides c ounty-by- county s ummaries of the VOC emission benefits from the OTC 2006 VOC model rules described previously in this Section. Appendix D also provides additional documentation regarding the data sources and emission benefit calculations that were perform ed. These tables can be used b y the States to create additional summaries, for example, by nonattainment area.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 19

MACTEC Federal Programs, Inc. 

### 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 based on the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdi ctions that are part of the OTR). 2009 Base Inventory emissions are based on 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 - the - way control measures described in this Section. 2009 Emission Reduction Benefit is the incremental emission re duction from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions).TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 20

MACTEC Federal Programs, Inc. 

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

Cutback and Emulsified Asphalt Paving

Cutbac k 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 based on 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 based on 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 - the - way control measures described in this Section. 2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). * CT and MA provided revised emission estimates that differ from those in the MANEVU Version 3 inventories.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 21

MACTEC Federal Programs, Inc. 

### 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 based on 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 based on 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 - the - way control measures described in this Section. 2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this section (i.e., the difference b etween 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 benefi t from both sets of limits. For all other States, the 2009 benefit shows the change in emissions from the OTC 2006 model rule only.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 22

MACTEC Federal Programs, Inc. 

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

Portable Fuel Containers – Area Sources

Portable Fuel Cont ainers 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 based on the MANEVU 2002 Version 3 inventory and VISTAS 2002 Base G inventory (for the 10 no rthern Virginia jurisdictions that are part of the OTR). 2009 Base Inventory emissions are based on 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 - the - way control measures described in this Section. 2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). Note: The table shows the estimated emission reduction that will occur in 2009; additional reductions will occur in later years as ne w, less - emitting PFCs that comply with the OTC 2006 control measure penetrate the market. * MA PFC regulation will be based on only the OTC 2006 model rule (which updates the provisions of the OTC 2001 model rule) and will have an effective date of January 1, 2009. The 2009 base emissions in MA are uncontrolled emissions. The 2009 emission benefits represent the total emission reductions from the MA rule.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 23

MACTEC Federal Programs, Inc. 

### Table 3 - 9 OTC 2006 VOC Model Rule Benefits by Stat e for 2009

Portable Fuel Containers – Nonroad Sources

Portable Fuel Containers Summer VOC Emissions (tpd) State 2002

Actual 2009

Base 2009

Control 2009

Benefit CT 2.9 1.9 1.8 0.1 DE 0.9 0.6 0.6 0.0 DC 1.1 0.8 0.7 0.0 ME 1.1 0.7 0.7 0.0 MD 11.9 7 .4 6.9 0.4 MA* 5.4 5.6 5.1 0.5 NH 1.1 0.9 0.8 0.1 NJ 7.3 5.3 5.0 0.3 NY 23.0 13.5 12.7 0.8 PA 14.1 8.3 7.8 0.5 RI 0.9 0.8 0.8 0.0 VT 0.5 0.5 0.4 0.0 NOVA 2.6 1.8 1.7 0.1 OTR 72.8 48.0 45.1 3.0 2002 Actual emissions estimated to be 30 percent of area source emissions (based on Pechan 2001, pg. 11) 2009 Base Inventory emissions estimated to be 30 percent of area source emissions, and account for grow th and any emission reductions associated with on - the -books/on - the - way co ntrols measures. 2009 Cont rol Inventory emissions are the emissions remaining after implementation of the beyond - on - the - way control measures described in this Section. 2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). Note: The table shows the estimated emission reduction that will occur in 2009; additional reductions will occur in later years as ne w, less - emitting PFCs that com ply with the OTC 2006 control measure penetrate the market. * MA PFC regulation will be based on only the OTC 2006 model rule (which updates the provisions of the OTC 2001 model rule) and will have an effective date of January 1, 2009. The 2009 base e mi ssions in MA are uncontrolled emissions. The 2009 emission benefits represent the total emission reductions from the MA rule.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 24

MACTEC Federal Programs, Inc. 

### Table 3 - 10 OTC 2006 VOC Model Rule Benefits by State for 2009 Regional Fuels Regional Fuels Summer VOC Emissions (tpd) S tate 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 46 5.0 408.1 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 availableTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Section 3

– VOC Analysis Methods Page 3 - 25

MACTEC Federal Programs, Inc. 

### Tabl e 3 - 11 OTC 2006 VOC Model Rule Benefits by State for 2009

All Six VOC Categories

All Six Categories Summer VOC Emissions (tpd) State 2002

Actual 2009

Base 2009

Control 2009

Benefit CT 149.9 142.9 133.2 9.7 DE 39.3 37.7 36.3 1.4 DC 19.6 17.6 17.2 0. 4 ME 83.5 83.6 60.9 22.6 MD 270.0 248.1 236.3 11.8 MA 253.3 260.1 230.8 29.3 NH 70.0 70.3 58.8 11.5 NJ 354.1 334.6 317.9 16.7 NY 814.2 758.4 656.5 101.9 PA 576.8 546.7 454.3 92.3 RI 39.5 38.6 35.6 3.0 VT 48.0 48.7 36.5 12.1 NOVA 88.8 87.4 85.4 1. 9 OTR 2,807.0 2,674.6 2,359.8 314.8 2002 Actual emissions based on 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 based on the emi ssions 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 e mi ssions 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 reduc tion from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions). Assumes that 2009 reductions from RFG are the same as those calculated for 2006.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 1

MACTEC Federal Programs, Inc. 

## 4.0 NOx ANALYSIS METHODS This Se ction describes the anal ys is of the 2006 OTC control measures to reduce NOx emissions from six source categories: diesel engine chip reflash, regional fuels, asphalt production plants, cement kilns, glass/fiberglass furnaces, ICI boilers. For each of the categories, there are separate subsections that discuss existing Federal/state rules, summarize the requirements of the 2006 OTC control measure, describe the methods used to quantify the emission benefit, and provide an estimate of the anticipated costs and cost effectiveness of the control measure. At the end of Section 4, we provide the estimated emissions for 2002 and 2009 by source category and State. Appendix E provides countyby- county s ummaries of the emission reductions for each of the categorie s. 4.1 HEAVY-DUTY TRUCK DIESEL ENGINE CHIP REFLASH In the mid - 1990s, the U.S. Department of Justice (DOJ), EPA, and CARB determined that seven major engine manufacturers had designed their 1993 through 1998 model heavyduty diesel engines to operate with adv anced electronic engine controls that resulted in excessive NOx emissions. W 

### hen these engines were operated in the vehicle under “real world” conditions, the electronic calibration would change, altering the fuel delivery characteristics and resulting in elevated NOx levels. DOJ, EPA and ARB developed Consent Decrees that required the manufacturers to provide software (the “Low -NOx Rebuild Kit” or “chip reflash”) that modifies the injection timing adjustment that caused the excess NOx emissions. The kits are to be installed at the time the vehicle is brought in for a major engine rebuild/overhaul. The rate of rebuild has been considerably lower than what was envisioned under the Consent Decrees; the primary reasons being that engine rebuilds occur at con siderably higher elapsed vehicle mileage than what was contemplated when the Consent Decrees were negotiated, and there is no federal oversight program to ensure that individual rebuilds are occurring at the time of rebuild. In response to this low rebuil d rate, CARB has adopted a mandatory program, not tied to the time of rebuild, but rather to a prescribed period of time, within which owners must bring their vehicles into the dealer to have the reflash operation performed, with all costs borne by the engine manufacturers. (NESCAUM 2006b). 4.1.1 Existing Federal and State Rules California entered into Settlement Agreements, separate from the federal Consent Decrees, but with analogous requirements for low -NOx rebuilds. The slow rate of progress inTSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 2

MACTEC Federal Programs, Inc. 

### California mirrored the progress nationall y. Accordingl y, California embarked upon its own program, b y rule, to accelerate and ultimately complete the rebuilds for trucks registered in California and for out - of - state registered trucks traveling on roadways within the state. The ARB rule, effective March 21, 2005, mandates that rebuilds occur over a prescribed time period, with a final rebuild compliance date of December 31, 2006. The CARB mandatory program faced two separate legal challenges, alleging that CARB has b reached its settlement agreement and alleging that CARB is illegall y establishing different emissions standards on “new engines”. The Sacramento County Superior Court ruled that the Low NOx Software Upgrade Regulation is invalid. CARB indicates that it will not appeal that ruling and is suspending further enforcement of this regulation. 4.1.2 Description of the OTC 2006 Control Measure NESCAUM developed a model rule for consideration by its member states to implement a low -NOx rebuild program, similar Califor nia’s program. The regulation applies to the engine manufacturers and to owners, lessees, and operators of heavy- duty vehicles powered b y the engines that are required to have the low -NOx rebuild. Consistent with the Consent Decrees, the engine manufacturers are required to provide the rebuild kits at no cost to dealers, distributors, repair facilities, rebuild facilities, owners, lessees, and operators, upon their request and to reimburse their authorized dealers, distributors, repair facilities and rebuild facilities for their labor costs. 4.1.3 Emission Benefit Analysis Methods NESCUAM estimated potential NOx emissions reductions (tons per day) if the Northeast States were to adopt a rebuild program similar to the California program. These estimates are ba sed on the ratio of Northeast to California in - state heavy- duty vehicle registrations, and ARB - estimated California NOx reductions of 35 TPD (NESCAUM 2006b, pg. 5). NESCAUM also estimated potential NOx emissions reductions for the Mid - Atlantic States by s caling the NESCAUM projections based on population. For the Mid - Atlantic States, the NOx benefit was calculated based on the per capita factors of a one ton per day reduction for each one million people (NESCAUM 2005). 4.1.4 Cost Estimates The cost associated with the reflash has been estimated at $20 - $30 per vehicle, which is borne b y the engine manufacturer. There may be costs associated with potential downtime to the trucking firms, and record - keeping requirements on the dealer performing the reflashTSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 3

MACTEC Federal Programs, Inc. 

### and the vehicle owner. The MRPO estimated cost effectiveness to be $1,800 to $2,500 (depending on vehicle size) due to incremental “fuel penalty” of 2 percent increase in fuel consumption (ENVIRON 2006). 4.2 REGIONAL FUELS The Clean Air Act Amendments of 1990 required significant changes to conventional fuels used by motor vehicles. Beginning in 1995, “reformulated” gasoline (RFG) 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. Phase II of the RFG program began in 2000. 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 RFG program. However, nearly one - third of the gasoline sold in the OTR is not RFG. NESCAUM has estimated the following fraction of gasoline that is reformulated by State:

State Current RFG Fraction State Current RFG Fraction CT 100% NJ 100% DC 100% NY 54% DE 100% PA 24% MA 100% RI 100% MD 86% NoVA 100% ME 0% VT 0% NH 64% 

### 4.2.2 Description of the OTC 2006 Control Measure The Energy Policy Act of 2005 provides the opportunity for the OTR to achieve a single clean -burning gasoline and is consistent wi th what OTR states have promoted through the long debate over MTBE/ethanol/RFG. Approximately one - third of the gasoline currentl y sold in the OTR is not reformulated. The new authority plus the potential for emission reductions from the amount of non - ref ormulated 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).TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 4

MACTEC Federal Programs, Inc. 

### 4.2.3 Emission Benefit Analysis Methods Emission benefits resulting from extending reformulated gasoline to all areas of the OTR have been calculated for 2006 by NESCAUM (NESCAUM 2006a). 4.2.4 Cost Estimates According to USEPA’s regulatory impact analysis for reformulated gasoline (USEPA 1993), the cost per ton of NOx reduced for Phase II RFG is $5,200 to $3,700. 4.3 ASPHALT PAVEMENT PRODUCTION PLANTS Hot mix asphalt (HMA) is created b y mixing and heating size - graded, high quality aggregate (which can include reclaimed asphalt pavement) with liquid asphalt cement. HMA can be manufactured by batch mix, continuous mix, parallel flow drum mix, or counterflow drum mix plant s. The dryer operation is the main source of pollution at hot mix asphalt manufacturing plants. Dryer burner capacities are usually less than 100 mmBtu/hr, but may be as large as 200 mmBtu/hr. Natural gas is the preferred source of heat used b y the indu stry, although oil, electricity and combinations of fuel and electricity are used. The reaction of nitrogen and oxygen in the dryer creates nitrogen oxide (NOx) emissions in the combustion zone, 4.3.1 Existing Federal and State Rules Only two of the OTR states have regulations that specificall y address NOx emissions from asphalt pavement manufacturing plants. New Hampshire limits NOx emissions to 0.12 pound per ton of asphalt produced, or 0.429 lb per mmBtu 

### { Chapter Env -A 1211.08 (c)} for units greater than 26 mmBTU/hour in size. New Jersey limits NOx emissions to 200 ppmvd at seven percent oxygen {7:27 - 19.9(a)}. Asphalt plants in other OTR states are subject to more general 

### fuel combustion requirements or case -by - case RACT determinations. 

### 4.3.2 Description of the O TC 2006 Control Measure NOx emissions from asphalt plants can be reduced through installation of low -NOx burners and flue gas recirculation (FGR). The OTC Commissioners recommended that OTC member states pursue as necessary and appropriate state - specific rulemakings or other implementation methods to establish emission reduction percentages, emission rates or technologies that are consistent with the guidelines shown in Table 4.1 (OTC 2006b).TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 5

MACTEC Federal Programs, Inc. 

### 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 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 M ix Plant

– Distillate/Waste Oil 0.04 35 or Best Management Practices 

### Industry leaders have identified a number of Best Management Practices that allow for substantial reduction in plant fuel consumption and the corresponding products of combustion inc luding 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. · Effective stockpile management to reduce aggregate moisture content : Current information indicates that effective stockpile management can reduce aggregate moisture content by about 25 percent, corresponding to a reduction in fuel consumption by a pproximately 10 - 15 percent. There are a number of ways to reduce aggregate moisture: covering stockpiles, paving under stockpiles, and sloping stockpiles are all ways that prevent aggregate from retaining moisture. Best Practices are plant - and geographi c locale - specific. · Lowering mix temperature : A Technical Working Group of FHWA is currently investigating a number of newer formulation technologies, to understand the practicality and performance of lowering mix temperatures. Substantial reductions in mix temperatures, on the order of 20 percent or more, appear to be plausible. Lowering mix temperatures, by this amount, may reduce fuel consumption, as less heat is needed to produce the mix. · 

### Other maintenance and operational best practices : Additional practices can be employed throughout the plant to help optimize production and operations. For example, regular inspection of drum mixing flites and other measures can be taken

– all in the effort to make a plant operate more efficiently , thereb y using less fue l.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 6

MACTEC Federal Programs, Inc. 

### 4.3.3 Emission Benefit Analysis Methods The emission rates and percent reductions estimates shown above for major sources were developed the state of New York based on the use of low -NOx burners and FGR. For minor sources, the requirement is the use of low -N Ox burner technology . NOx emissions can be reduced b y 35 to 50 percent with low -NOx burners and FGR, and by 25 to 40 percent with low -NOx burners alone. For modeling purposes, a 35 percent reduction was assumed to apply all ty

pes of asphalt plants. The reductions estimated for this category onl y include emissions included in the MANEVU point source emission inventory. Only emissions from major point sources are ty picall y included in the MANEVU point source database. Emissions from non - major sources are not explicitly contained in the area source inventory . The emissions from non major asphalt plants are likely lumped together in the general area source industrial and commercial fuel use category . Reductions from area source emissions at asphalt production plants are included in the IC I boiler source category . Therefore, there is some uncertainty r egarding 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 c ontrol are similar to those of small to midsize boilers 

### or process heaters . Low NOx burners range from $500 to $1,250 per ton and low -NOx burners in combination with FGR range from $1,000 to $2,000 per ton. 

### These cost - effectiveness data were provided b y NYSDEC. These control efficiencies and cost - effectiveness estimates for low -NOx burners plus FGR are generall y consistent EPA’s published data for small natural gas - fired and oil - fired process heaters and boilers (Pechan 2005). 4.4 CEMENT KILNS Portland cem ent manufacturing is an energy intensive process in which cement is made by grinding and heating a mixture of raw materials such as limestone, clay , sand and iron ore in a rotary kiln. Nationwide, about 82 percent of the industry ’s energy requirement is p rovided b y coal. Waste - derived fuels (such as scrap tires, used motor oils, surplus printing inks, etc.) provide about 14 percent of the energy. NOx emissions are generated during fuel combustion by oxidation of chemically- bound nitrogen in the fuel and by thermal fixation of nitrogen in the combustion air.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 7

MACTEC Federal Programs, Inc. 

### There are four main types of kilns used to manufacture portlant cement: long wet kilns, long dry kilns, dry kilns with preheaters, dry kilns with precalciners. Wet kilns tend to be older units and are often located where the moisture content of feed materials from quarries tends to be high. Cement kilns are located in Maine, Maryland, New York, and Penns ylvania. There are no cement kilns in the other OTR states. According to the MANEVU 2002 inventory (Pechan 2006), the number of cement kilns operating in 2002 by size and type was: State Number of Facilities Number of

Long Wet Kilns Number of

Long Dry Kilns Number of

Preheater or Precalciner Kilns Maine 1 1 0 0 Maryland 3 2 2 0 New York 3 2 1 0 P ennsylvania 10 5 11 5 

### 4.4.1 Existing Federal and State Rules The NOx SIP Call required states to submit revisions to their SIPs to reduce the contribution of NOx from cement kilns. All kilns in the OTR, except for the one kiln in Maine, are subject to the NOx SIP Call. Based on its SIP Call analysis, EPA determined 30 percent reduction of baseline uncontrolled emission levels was highl y co st - effective for cement kilns emitting greater than 1 ton/day of NOx. Some states elected to include cement kilns in their NOx Budget Trading Programs. For example, requirements in Pennsylvania’s regulations in 25 Pa. Code Chapter 145 set a kiln allowable limit of 6 pounds per ton of clinker produced, and require sources to purchase NOx allowances for each ton of NOx actual emissions that exceed the allowable limits. Maryland did not include kilns in the trading program but instead provided two options for reducing NOx emissions: · Option 1

– for long wet kilns, meet NOx emission limit of 6.0 pounds per ton of clinker produced ; for long dry kilns, meet limit of 5.1 pounds per ton of clinker produced; and for pre - heater/pre - calciner or pre - calciner kilns, meet limit of 2.8 pounds per ton of clinker produced; · Option 2

– install low NOx burners on each kiln or modify each kiln to implement mid - kiln firing.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 8

MACTEC Federal Programs, Inc. 

### The one kiln in Maine is a wet process cement kiln and has been licensed to modernize by converting to the more efficient dry cement manufacturing process. The new kiln is subject to BACT requirements. 4.4.2 Description of the OTC 2 006 Control Measure There is a wide variety of proven control technologies for reducing NOx emissions from cement kilns. Automated process control has been shown to lower NOx emissions by moderate amounts. Low -NOx burners have been successfull y used, esp ecially in the precalciner kilns. CemStarSM is a process that involves adding steel slag to the kiln, offering moderate levels of NOx reduction by reducing the required burn zone heat input. Mid - kiln firing of tires provides moderate reductions of NOx emissions while reducing fuel costs and providing an additional revenue stream from receipt of tire tipping fees. SNCR technology has the potential to offer significant reductions on some precalciner kilns. SNCR is being used in numerous cement kilns in Europe. A recent study (EC 2001a) indicates that there are 18 full - scale SNCR installations in Europe. Most SNCR installations are designed and/or operated for NOx reduction rates of 10 - 50% which is sufficient to comply with current legislation in some countries. Two Swedish plants installed SNCR in 1996/97 and have achieved a reduction of 80 - 85%. A second recent study (ERG 2005) of cement kilns in Texas has identified a variety of NOx controls for both wet and dry cement kilns, with reductions in the 40 to 85% range. The OTC Commissioners recommended that OTC member states pursue, as necessary and appropriate, state - specific rulemakings or other implementation methods to establish emission reduction percentages, emission rates or technologies that are c onsistent with the guidelines shown in Table 4.2 (OTC 2006b). The guidelines were presented in terms of both an emission rate (lbs/ton of clinker by kiln type) as well as a percent reduction from uncontrolled levels. Table 4.2 OTC Resolution 06 - 02 Emiss ion 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 60TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 9

MACTEC Federal Programs, Inc. 

### 4.4.3 Emission Benefit Analysis Methods To calculate the additional reductions from the OTC 2006 Control Measure, MACTEC calculated the 2002 emission rate (lbs NOx per ton of clinker produced) for each kiln. The 2002 emission rate was compared to the OTC 2006 control measure emission rate list above to calculate a kiln - specific percent reduction. The kiln - specific percent reduction was then applied to the 2002 actual emissions to calculate the emissions remaining after implementation of the control measure. 4.4.4 Cost Estimates The TCEQ study (ERG 2005) estimated a cost - effectiveness of $1,400 - 1,600 per ton of NOx removed for an SNCR system achieving a 50 percent reduction on modern dry preheat precalcination kilns. The study also estimate a cost - effectiveness of $2,200 per ton of NOx removed for SNCR systems achieving a 35 percent reduction on wet kilns. The most recent EPA report (EC/R 2000) shows data for two SNCR technologies, biosolids injection and NOXOUT®. These technologies showed average emission reductions of 50 and 40 percent, respectively . The cost effectiveness was estimated to be $1,000 - 2,500/ton depending on the size of the kiln. Costs and the cost effectiveness for a specific unit will vary depending on the kiln ty pe, characteristics of the raw material and fuel, uncontrolled emission rate , and other source - specific factors. 4.5 GLASS/FIBERGLASS FURNACES The manufacturing process requires raw materials, such as sand, limestone, soda ash, and cullet (scrap and recycled glass), be fed into a furnace where a temperature is maintained in the 2,70 0°F to 3,100°F range. The raw materials then chemically react creating a molten material, glass. The reaction of nitrogen and oxyg en in the furnace creates NOx emissions. The main product types are flat glass, container glass, pressed and blown glass, and fiberglass. In the OTR, the preponderance of glass manufacturing plants is in Pennsylvania. New York and New Jersey also have several plants. Massachusetts, Maryland, and Rhode Island each have one glass manufacturing plant. 4.5.1 Existing Federal and Sta te Rules Only Massachusetts and New Jersey have specific regulatory limits for NOx emissions from glass melting furnaces. Massachusetts has a 5.3 pound per ton of glass removed limit for container glass melting furnaces having a maximum production of 15 tons of glass perTSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 10

MACTEC Federal Programs, Inc. 

### day or greater. New Jersey has a 5.5 pound per ton of glass limit for commercial container glass manufacturing furnaces and an 11 pound per ton of glass for specialty container glass manufacturing furnaces. New Jersey also required boros ilicate 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 I sland) do not contain specific emi ssion 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 NO x emissions (MACTEC 2005). These options include combustion modifications (low NOx burners, ox y- fuel firing, ox ygen - enriched air staging), process modifications (fuel switching, batch preheat, electric boost), and post combustion modifications (fuel rebur n, SNCR, SCR). O xyfiring is the most effective NOx emission reduction technique and is best implemented with a complete furnace rebuild. This strategy not only reduces NOx emissions by as much as 85 percent, but reduces energy consumption, in creases prod uction rates by 10 - 15 percent, and improves glass quality by reducing defects. Oxyfiring is demonstrated technology and has penetrated into all segments of the glass industry. 

### The OTC Commissioners recommended that OTC member states pursue, as necessary and appropriate, state - specific rulemakings or other implementation methods to establish emission reduction percentages, emission rates or technologies that are consistent with the guidelines shown in Table 4.3 (OTC 2006g). The guidelines were presented in terms of both an emission rate (lbs/ton of glass produced) as well as a percent reduction from uncontrolled levels for the different ty pes of glass manufactured. Table 4.3 Addendum to OTC Resolution 06 - 02 Guidelines for Glass Furnaces Type of Glass Emissi on 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.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 11

MACTEC Federal Programs, Inc. 

### 4.5.3 Emission Benefit Analysis Methods The NOx emission reduction benefit calculation varied by St ate depending upon the availability of data:

· New Jersey DEP evaluated the existing controls at each facility . NJDEP identified furnaces that have closed, indicated whether the facility requested banking of emissions, and specified whether the emissions from the closed furnace should remain in the projection year inventory. NJDEP also identified furnace - specific projected emission rates based on the use of oxyfu el technology . · Pennsylvania DEP provided 2002 throughput (tons of glass pulled) and emission rate data (lbs NOx/ton of glass pulled). The 2002 emission rate was compared to the OTC 2006 control measure emission rate list above to calculate a furnace - specific percent reduction. The furnace - specific percent reduction was then applied to the 2002 actual emissions to calculate the emissions remaining after implementation of the control measure. If a furnace had an emission rate below the OTCC 2006 control measure emission rate, then no incremental reduction was calculated. PADEP also identified several furnaces that have shut down

– emissions from these furnaces were set to zero in the projection year inventory. · For all other States with glass furnaces (MA, MD, NY, and RI), furnace specific data were not available. The NOx emission reduction benefit was calculated b y applying an 85 percent reduction for oxyf iring 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 2 001b) reports a 75 to 85 percent reduction in NOx based on ox yf iring technology , resulting in emission rates of 1.25 to 4.1 pounds of NOx per ton of glass produced. The cost effectiveness was determined to be $1,254 to $2,542 depending on the size of the furnace. EPA’s Alternative Control Techniques Document (USEPA 1994) estimated an 85 percent reduction in NOx emissions for ox yfiring with a cost - effectiveness of $2,150 to $5,300. Other technologies may be used to meet the limits in Table 4.3. The cost s associated with meeting those limits are source - specific and depend on the existing controls in place and the emission rates being achieved. Site - specific factors greatly influence the actual achievable performance level and control costs at a particular facility .TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 12

MACTEC Federal Programs, Inc. 

### 4.6 ICI BOILERS Industrial/commercial/institutional (I CI) boilers combust fuel to produce heat and process steam for a variety of applications. Industrial boilers are routinel y found in applications the chemical, metals, paper, petroleum, food production and other industries. Commercial and institutional boilers are normall y used to produce steam and heat water for space heating in office buildings, hotels, apartment buildings, hospitals, universities, and similar facilities. Industrial boiler s are generall y s maller than boilers in the electric power industry , and typically have a heat input in the 10 - 250 mmBtu/hr range; however, industrial boilers can be as large as 1,000 mmBtu/hr or as small as 0.5 mmBtu/hour. Most commercial and institution al boilers generally have a heat input less than 100 mmBtu/hour. It is estimated that 80 percent of the commercial/institutional population is smaller than 15 mmBtu/hour. The ICI boiler population is highly diverse

– encompassing a variety of fuel ty pes, boiler designs, capacity utilizations and pollution control systems

– that result in variability in emission rates and control options. For emission inventory purposes, emissions from ICI boilers are included in both the point and area source emission inventories. Generall y, the point source emission inventory includes all ICI boilers at major facilities. The point source inventory lists individual boilers, along with their size and associated emissions. The area source inventory generall y includes emissions for ICI boilers located at non - major facilities. It does not provide emissions by the size of boiler, as is done in the point source inventory . Area sources emissions are calculated based on the fuel use not accounted for in the point source inventory . This is done by taking the total fuel consumption for the state (by fuel ty pe and category), as published by the U.S. Department of Energy , and subtracting out the fuel usage reported in the point source inventory . Emissions are then calculated on a countyby- county basis using the amount of fuel not accounted for in the point source inventory and average emission factors for each fuel type. 4.6.1 Existing Federal and State Rules IC I 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 ty pe, boiler age, boiler size, boiler design, and geographic location.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 13

MACTEC Federal Programs, Inc. 

### The OTC developed a draft model rule in 2001 with the following thresholds and limits:

OTC 2001 Model Rule ICI Boiler Thresholds and Limits Applicability Threshhold Emission Rate Limit Percent NOx Reduction 5 - 50 mmBtu/hr None Tune -up Only 50 - 100 mmBtu/hr Gas - fired: 0.10 lbs/mmBtu Oil - fired: 0.30 lbs/mmBtu Coal - fired: 0.30 lbs/mmBtu 50% 100 - 250 mmBtu/hr Gas - fired: 0.10 lbs/mmBtu Oil - fired: 0.20 lbs/mmBtu Coal - fired: 0 .20 lbs/mmBtu 50% >250 mmBtu/hr* Gas - fired: 0.17 lbs/mmBtu Oil - fired: 0.17 lbs/mmBtu Coal - fired: 0.17 lbs/mmBtu 50% 

### * Only for boilers not subject to USEPA’s NOx SIP Call Implementation of the OTC 2001 model rule limits varied b y S tate

– some OTC stat es adopted these limits while others did not. MACTEC researched current State regulations affecting ICI boilers and summarized the rules in Appendix F. The specific requirements for each state were organized into a common format to efficientl y include th e State -byState differences b y fu el ty pe and boiler size. This organization oversimplifies the source categories and size limitations that differ from State - to - State. This simplification was necessary to match the rules to the organization of the emissi on data bases (i.e., Source Classification Codes) being used in the anal ys is. 4.6.2 Description of the OTC 2006 Control Measure The OTC Commissioners recommended that OTC member states pursue as necessary and appropriate state - specific rulemakings or other implementation methods to establish emission reduction percentages, emission rates or technologies for ICI boilers (OTC 2006b). These guidelines have undergone revision based on a more refined anal ys es. Table 4.4 provides the current OTC proposal for ICI boilers. 4.6.3 Emission Benefit Analysis Methods The emission reduction benefits resulting from the OTC I CI boiler control measure were calculated differently for point and area sources. For point sources, the emission reductions were estimated by comparing the emis sion limits in the existing (2006) state regulations with the limits contained in the OTC ICI boiler proposal.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 14

MACTEC Federal Programs, Inc. 

### Table 4.4 Addendum to OTC Resolution 06 - 02 Guidelines for ICI Boilers ICI Boiler Size (mmBtu/hr) Control Strategy/

Compliance Option NOx Con trol Measure 5 - 25 Annual Boiler Tune -Up

Option #1 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 Coal: 0.30 lb NOx/mmBtu** Option #2 50% reduction in NOx emissions from uncontrolled baseline 25 - 100 Option #3 Purchase current year CAIR NOx allowances equal to reducted needed to acheiv the required emission rates Option #1 Natural Gas: 0.10 lb NOx/mmBtu

#2 Fuel Oil: 0.20 lb N Ox/mmBtu #4 or #6 Fuel Oil: 0.20 lb NOx/mmBtu Coal: Wall - fired 0.14 lb NOx/mm Btu Tangential 0.12 lb NOx/mm Btu Stoker 0.22 lb NOx/mm Btu Fluidized Bed 0.08 lb NOx/mm Btu Option #2 LNB/SNCR , LNB/FGR, SCR, or some

combination of these controls in conjunction with Low NOx Burner technology Option #3 60% reduction in NOx emissions from uncontrolled baseline 100 - 250

Option #4 Purchase current year CAIR NOx allowances equal to reducted needed to ache iv the required emission rates >250 Option #1 Purchase current year CAIR NOx allowances equal to reducted needed to acheiv the required emission rates Option #2 Phase I

– 2009

Emission rate equal to EGUs of similar size

Phase II

– 2012 Emission rate equal to EGUs of similar sizeTSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 15

MACTEC Federal Programs, Inc. 

### Tables 4 - 5 through 4 - 10 shows the current state emission limits by size range and fuel ty pe, and the percentage reduction from the OTC proposed limits to the current state requirement. In cases where a state did not have a sp ecific limit for a given size range, then the more general percent reduction from uncontrolled values in Table 4 - 4 was used. The fuel types/boiler typ es shown in Tables 4 - 5 through 4 - 10 were matched to SCCs in the point source inventory . MACTEC used the SCC and design capacity (mmBtu/hour) from the MANEVU and VISTAS emission inventories to apply the appropriate state specific reduction factor to estimate the emission reduction benefit. The emission limits shown in Tables 4 - 5 through 4 - 10 generally appl y only to ICI boilers located at major sources (i.e. point sources). ICI boilers located at minor sources (i.e., area sources) are generally not subject to the emissions limits. In general, emissions from area source ICI boilers are uncontrolled (except possibly for an annual tune - up requirement). The one exception is New Jersey : beginning on March 7, 2007, N.J.A.C. 27.27 - 19.2 requires any IC I boiler of at least 5 mmBtu/hr heat input to comply with applicable NOx emission limits whether or not it is located at a major NOx facility . To calculate the reductions from area source ICI boilers, MACTEC applied the general percent reduction from uncontrolled values in Table 4 - 4 to the area source inventory (i.e., 10 percent reduction for annual tune - ups for boi lers < 25 mmBtu/hr, and a 50 percent reduction for boilers between 25 and 100 mmBtu/hr). The area source inventory does not provide information on the boiler size. To estimate the boiler size distribution in the area source inventory , we first assumed that there were no boilers > 100 mmBtu/hr in the area source inventory . Next, we used boiler capacity data from the USDOE’s Oak Ridge National Laboratory (EEA 2005) to estimate the percentage of boiler capacity in the < 25 mm Btu/hr and 25 - 100 mm Btu/hr categories. Third, we assumed that emissions were proportional to boiler capacity. Finally, we calculated the weighted average percent reduction for area source ICI boilers based on the capacity in each size range and the percent reduction b y s ize range di scussed in the previous paragraph. For industrial boilers, the weighted average reduction was 34.5 percent; for commercial/institutional boilers, the weighted average reduction was 28.1 percent.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 16

MACTEC Federal Programs, Inc. 

### Table 4.5 Current State Emission Limits and Percent Reduc tion 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 Th reshold 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 0.2 0 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 0.0 0.0 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 4 0.0 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 Spe cific RACT 29.4 0.0 50.0 50.0 10.0 RI 0.10 0.10 0.10 NL NL 0.0 0.0 50.0 50.0 10.0 VT 0.20 NL NL NL NL 40.0 60.0 50.0 50.0 10.0 NOVA 0.2 0.2 0.2 0.2 0.2 40.0 50.0 75.0 75.0 10.0 NL indicates no limit specified in a state rule; in those cases, the mo re general percent reduction from Table 4 - 4 was used. Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were determined on a case -by - case basis); in those cases, the more general percent reduction fro m Table 4 - 4 was used. SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 17

MACTEC Federal Programs, Inc. 

### 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 0.0 0.0 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 1 0.0 NH 0.30 0.30 0.12 NL NL 60.0 33.3 33.3 50.0 10.0 NJ 0.20 0.20 0.12 NL NL 40.0 0.0 33.3 50.0 10.0 NY 0.25 0.30 0.12 NL NL 52.0 33.3 33.3 50.0 10.0 PA Source Specific NOx RACT 29.4 33.3 33.3 50.0 10.0 SE PA 0.17 0.20 Source Specific RACT 29.4 0.0 33.3 50.0 10.0 RI 0.12 0.12 0.12 NL NL 0.0 0.0 33.3 50.0 10.0 VT 0.30 NL NL NL NL 60.0 60.0 50.0 50.0 10.0 NOVA 0.25 0.25 0.25 0.25 0.25 52.0 20.0 68.0 68.0 10.0 NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 4 - 4 was used. Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were determined on a case -by - case basis); in those cases, the more general percent reduction from Table 4 - 4 wa s used. SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 18

MACTEC Federal Programs, Inc. 

### 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 Applica bility 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 0.0 0.0 DC 0.30 0.30 0.30 NL NL 60.0 33.3 33.3 50.0 10.0 ME 0.20 0.30 0.30 NL NL 40.0 33.3 33.3 50.0 10.0 MD 0.25 0.25 0.25 0.25 0.25 52.0 20.0 20.0 20.0 10.0 MA 0.25 0.30 0.30 NL NL 52.0 33.3 33.3 50.0 10.0 NH 0.30 0.30 0.30 NL NL 60.0 33.3 33.3 50.0 10.0 NJ 0.20 0.20 0.30 NL NL 40.0 0.0 33.3 50.0 10.0 NY 0.25 0.30 0.30 NL NL 52.0 33.3 33.3 50.0 10.0 PA Source Specific NOx RACT 29.4 33.3 33.3 50.0 10.0 SE PA 0.17 0.20 Source Specific RACT 29.4 0.0 50.0 50.0 10.0 RI LNB/FGR LNB/FGR LNB/FGR NL NL 0.0 0.0 0.0 50.0 10.0 VT 0.30 NL NL NL NL 60.0 60.0 50.0 50.0 10.0 NOVA 0.25 0.25 0.25 0.25 0.25 52.0 20.0 20.0 20.0 10.0 NL indicates no limit specified in a state rule; in those cases, the more general perc ent reduction from Table 4 - 4 was used. Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were determined on a case -by - case basis); in those cases, the more general percent reduction from Table 4 - 4 was u sed. 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 th e OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 19

MACTEC Federal Programs, Inc. 

### Table 4.8 Current State Emission Limits and Percent Reduction Estimated from

Adoption of OTC ICI Boil er Proposal Point Source Coal Wall - Fi red 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 n/a n/a n/a n/a n/a 0 .0 0.0 0.0 0.0 0.0 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 ICI boilers in the state. NL indicates no limit specified in a state rule; in those cas es, the more general percent reduction from Table 4 - 4 was used. Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were determined on a case -by - case basis); in those cases, the more general percent reduc tion 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 i n Virginia are part of the OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 20

MACTEC Federal Programs, Inc. 

### 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/h our 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 n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 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 1 0.0 RI n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 VT n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 NOVA 0.38 0.38 0.38 0.38 0.38 68.4 68.4 21.1 21.1 10.0 n/a indicates that there are no coal - fired boilers in the state. NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 4 - 4 was used. Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were determined on a case -by - case basis); in those cases, the mo re 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 f

ollowing jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 21

MACTEC Federal Programs, Inc. 

### 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 n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 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 2 9.4 0.0 50.0 50.0 10.0 RI n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 VT n/a n/a n/a n/a n/a 0.0 0.0 0.0 0.0 0.0 NOVA 0.4 0.4 0.4 0.4 0.4 70.0 45.0 25.0 25.0 10.0 n/a indicates that there are no coal - fired boilers in the state. NL indicates no limit specified in a state rule; in those cases, the more general percent reduction from Table 4 - 4 was used. Source Specific NOx RACT indicates that there are no specific limits in the States’ rule (i.e., limits were determined on a case -by - case basis); in those cases, the more general percent reduction from Table 4 - 4 was used. SE PA refers to the five southeastern Pennsylvania counties (Bucks, Chester, Delaware, Montgomery, and Philadelphia) affected by Pennsylvania’s Addition NOx Requirements (129.201) NOVA refers to the following jurisdictions in Virginia are part of the OTR: Arlington County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon County, Manassas City, Manassas Park, and Prince William County.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 22

MACTEC Federal Programs, Inc. 

### 4.6.4 Cost Estimates The OTC recentl y complet ed an anal ys is of I CI boiler NOx control cost estimates (Bodnarik 2006) using detailed information on direct capital equipment costs, direct installation costs, indirect capital costs, and direct and indirect operating costs. The anal ys is examined five ty pes of NOx control technologies

– low -NOx burners (LNB), ultra low -NOx burners (ULNB), LNB plus flue gas recirculation (LNB+FGR), LNB plus selective non - catal ytic reduction (LNB+SNCR), and selective catal ytic reduction (SCR). The anal ys is also considered various fuel ty pes – coal, residual oil, distillate oil, and natural gas. The cost effectiveness varies b y fuel type, boiler size, current regulatory requirements, current control technology , and boiler firing ty pe. The annual cost effectiveness was found as low as $600 per ton and as high as $18,000 per ton. In general, for most scenarios the cost effectiveness was estimated to be less than $5,000 per ton of NOx removed. 4.7 NOx EMISSION REDUCTION SUMMARY The results of the emission benefit calculations for the OTC states are described in this subsection. The starting point for the quantification of the emission reduction benefits is the MANEVU emission inventory , Version 3 (Pechan 2006, MACTEC 2006a) and the VI STAS emission inventory , BaseG (MACTEC 2006b), for the northern Virginia counties that are part of the OTR. The MANEVU and VISTAS inventories include a 2002 base ye ar inventory as well as projection inventories for 2009 and 2018 (MANEVU also has projections for 2012, but VI STAS does not). The projection inventories account for growth in emissions based on growth indicators such as population and economic activity . The projection inventories also account for “on - the -books/on - the - way” (OTB/W) emission control regulations that have (or will) become effe ctive between 2003 and 2008 that will achieve post - 2002 emission reductions. Emission reductions from existing regulations are already accounted for to ensure no double counting of emission benefits occurs. Note that the emission reductions contained in this Section are presented in terms of tons per summer day . The MANEVU base and projection emission inventories do not contain summer day emissions for all States and source categories; the VISTAS inventory onl y contains annual values. When States provi ded summer day emissions in the MANEVU inventory , these values were used directly to quantify the emission benefit from the 2006 OTC control measure. When summer day emissions were missing from the MANEVU or VI STAS inventories, the summer day emissions were calculated using the annual emissions and the seasonal throughput data from the NIF Emission Process table. If theTSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 23

MACTEC Federal Programs, Inc. 

### seasonal throughput data was missing, the summer day emissions were calculated using the annual emissions and a summer season adjustment factor derived from the monthly activity profiles contained in the SMOKE emissions modeling s ys tem. Tables 4 - 11 to 4 - 17 show State summaries of the emission benefits from the OTC 2006 NOx control measures described previousl y in this Section. For each o f the seven source categories, the Tables show four emission numbers: (1) the actual 2002 summer daily emissions; (2) the summer dail y emissions for the 2009 OTB/W scenario that accounts for growth and for the emission control regulations that have (or wil l) become effective between 2003 and 2008 that will achieve post - 2002 emission reductions; (3) the summer daily emissions for 2009 with the implementation of the OTC 2006 control measures identified in this Section, and (4) the emission benefit in 2009 resulting from the OTC 2006 control measure. Table 4 - 18 shows the same information for the total of all seven source categories. The largest estimated NOx emission reductions are in the more industrialized States

– New York and Penns ylvania

– which have most of the cement kilns and glass furnaces in the OTR. These two states also have a large population of ICI boilers. The emission benefits listed for Virginia just include the Virginia counties in the northern Virginia area that are part of the OTR. Benefit estimates for all other States include the entire state. The emission benefits also assume that all OTC members will adopt the rules as described in the previous sections. Appendix E provides county-by- county s ummaries of the NOx emission benefits from the OTC 2006 NOx control measures described previously in this Section. Appendix E also provides additional documentation regarding the data sources and emission benefit calculations that were performed. These tables can be used b y the States to create additional summaries, for example, by nonattainment area.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 24

MACTEC Federal Programs, Inc. 

### 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

Ac tual 2009

Base 2009

Control 2009

Benefit CT 66.7 n/a n/a 3.5 DE 21.8 n/a n/a 0.6 DC 8.1 n/a n/a 0.8 ME 82.8 n/a n/a 1.4 MD 105.0 n/a n/a 5.6 MA 152.7 n/a n/a 6.7 NH 30.5 n/a n/a 2.0 NJ 133.5 n/a n/a 9.7 NY 177.6 n/a n/a 16.1 PA 437.1 n/a n/a 12. 4 RI 8.3 n/a n/a 0.8 VT 13.7 n/a n/a 0.9 NOVA 16.6 n/a n/a 2.5 OTR 1254.5 0.0 0.0 63.0 n/a

– not available due to lack of 2009 emissions data for on - road vehicles in NIF format.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 25

MACTEC Federal Programs, Inc. 

### Table 4 - 12 OTC 2006 NOx Model Rule Benefits by State for 2009 Region al 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 20 02 and 2009 are not currently availableTSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 26

MACTEC Federal Programs, Inc. 

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

Asphalt Pavement Production Plants

Asphalt Pavem ent Production Plants Summer NOx Emissions (tpd) State 2002

Actual 2009

Base 2009

Control 2009

Bene fit 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 co ntrols measures. 2009 Control Inventory emissions are the emissions remaining after implementation of the beyond - on - the way control measures described in this Section. 2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions).TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 27

MACTEC Federal Programs, Inc. 

### 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 44.7 44.7 30.7 14.0 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 101.9 101.9 59.4 42.5 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 to be the same as in 2002 (i.e., no grow th was assumed). 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 e mission reduction from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions).TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 28

MACTEC Federal Programs, Inc. 

### 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 a ssociated with on - the -books/on - the - way co ntrols measures. Maximum Control Inventory emissions are the emissions remaining after full implementation of the beyond - on - the - way co ntrol measures described in this Section. Not all of the anticipated reductions from the glass/fiberglass OTC 2006 control measure will be achieved by 2009. This column shows the emissions remaining after full implementation of the measure, which may not occur until 2012 or 2018. Maximum Emission Reduction Benefit is the incremental emission reduction from the control measures described in this section (i.e., the difference between the base emissions and the maximum control emissions). Note: The table shows the maximum emission reduction from glass/fiberglass furnaces when the OTC 2 006 control measure is fully implemented. Not all of the reduction shown will be achieved by 2009.TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 29

MACTEC Federal Programs, Inc. 

### 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 Emissio ns (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 3 3.8 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 co ntrols 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 reducti on from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions).TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 30

MACTEC Federal Programs, Inc. 

### 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 7.3 0.0 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 invento ry (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 emissio n reductions associated with on - the -books/on - the - way co ntrols measures. 2009 Control Inventory emissions are the emissions remaining after implementation of the beyond - on - the way control measures described in this Section. 2009 Emission Reduction Benefit is the incremental emission reduction from the control measures described in this section (i.e., the difference between the 2009 base emissions and the 2009 control emissions).TSD for 2006 OTC Control Measures February 28, 2007

Section 4

– NOx Analysis Methods Page 4 - 31

MACTEC Federal Programs, Inc. 

### 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 N H 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 874.9 n/a n/a 74.9 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 3252.3 n/a n/a 257.8 n/a

– not available due to lack of 2009 emissions data for on - road vehicles in NIF format.TSD for 2006 OTC Control Measures February 28, 2007

Section 5

– References Page 5 - 1

MACTEC Federal Programs, Inc. 

## 5.0 REFERENCES Bodnarik 2006: Bodnarik, Andrew M., New Hampshire Department of Environmental Services, “ICI Boiler NOx Control Cost Estimates from OTC Methodology”, presented at the OTC Control Strategy /SAS Committee Meeting, November 2, 200 6. CARB 1998: California Air Resources Board, “Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Adhesives and Sealants”, December, 1998. CARB 1999: California Air Resources Board, “Initial Statem ent 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 Resources Board, “Initial Statement of Reasons for Proposed Amendments to the California Aerosol Coating Products, Antiperspirants and Deodorants, and Consumer Products Regulations, Test Method 310, and Airborne Toxic Control Measure for Para- dichlorobenzene Solid Air Fresheners and Toilet/Urinal Care Products Volume I : Executiv e Summary”, June 24, 2004. CARB 2004b: California Air Resources Board, Letter from William V. Loscutoff to Stakeholders, June 7, 2004. CARB 2005a: California Air Resources Board, “Staff Report: Initial Statement of Reasons for Proposed Amendments to the Portable Fuel Container Regulations”, July 29, 2005. CARB 2005b: California Air Resources Board, “Final Statement of Reasons: Public Hearing to Consider Amendments to the Regulations for Portable Fuel Containers”, October 2005. CARB 2006: California Air Resources Board, “Final Statement of Reasons: Public Hearing to Consider Amendments to the Regulations for Portable Fuel Containers”, July 2006. Census 2006: U.S. Census Bureau, web site www.c ensus.gov/popest/counties/tables/ containing county population files for 2005. EC 

### 2001a. European Commission, “Integrated Pollution Prevention and Control (IPPC) Reference Document on Best Available Techniques in the Cement and Lime Manufacturing Indu stries”, December 2001. EC 2001b. European Commission, “Integrated Pollution Prevention and Control (IPPC) Bureau Reference Document on Best Available Techniques in the Glass Manufacturing Industry”, December 2001.TSD for 2006 OTC Control Measures February 28, 2007

Section 5

– References Page 5 - 2

MACTEC Federal Programs, Inc. 

### EC/R 2000. EC/R Incorporated, “NOx Control Technologies for the Cement Industry

– Final Report”, prepared for the U.S. Environmental Protection Agency, September 19, 2000. EEA 2005: Energy and Environmental Anal ys is, Inc. “Characterization of the U.S. Industrial/Commercial Boiler Population”, prepared for Oak Ridge National Laboratory , May 2005. ENVIRON 2006: ENVIRON International Corporation, “Evaluation of Candidate Mobile Source Control Measures”, prepared for Lake Michigan Air Directors Consortium, January 5, 2006. ERG 2005. Eastern Research Group, Inc., “Assessment of NOx Emissions Reduction Strategies for Cement Kilns

– Ellis County ’, prepared for the Texas Commission on Environmental Quality , December 19, 2005. MACTEC 2005: MACTEC Federal Programs, Inc., “Interim White Paper - Midwest RPO Candidate Control Measures: Glass Manufacturing”, prepared for Lake Michigan air Directors Consortium, December 2005. MACTEC 2006a: MACTEC Federal Programs, Inc., “Draft Final Technical Support Document: Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE - VU Region”, prepared for Mid - Atlantic Regional Air Management Association, December 7, 2006. MACTEC 2006b: MACTEC Federal Programs, Inc., “Draft Documentation for the 2002, 2009, and 2018 Emission Inventories for VISTAS”, prepared for Visibility Improvement State and Tribal Association of the Southeast, under development. NESCAUM 2005a: The Clean Air Association of the Northeast States, email from Arthur Marin NESCAUM to Chris Recchia OTC, December 7, 2005. NESCAUM 2005b: The Clean Air Association of the Northeast States, “Low Sulfur Heating Oil in the Northeast States: An Overview of Benefits, Costs and Implementation I ssues,” December 2005. NESCAUM 2006a: The Clean Air A ssociation 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 Software Upgrade for Heavy- Duty Trucks: Draft Model Rule Staff Report, February 20, 2006. OTC 2006a: Ozone Transport Commission, “Memorandum of Understanding Among the States of the Ozone Transport Commission on a Regional Strategy Concerning the Integrated Control of Ozone Precursors from Various Sources”, June 7, 2006.TSD for 2006 OTC Control Measures February 28, 2007

Section 5

– References Page 5 - 3

MACTEC Federal Programs, Inc. 

### OTC 2006b : Ozone Transport Commission, “Resolution 06 - 02 of the Ozone Transport Commission Concerning Coordination and Implementation of Regional Ozone Control Strategies for Certain Source Categories”, June 7, 2006. OTC 2006c: Ozone Transport Commission, “Statement of the Ozone Transport Commission Concerning Multi - Pollutant Emission Control of Electric Generating Units”, June 7, 2006. OTC 2006d: Ozone Transport Commission, “Resolution 06 - 03 of the Ozone Transport Commission Concerning Federal Guidance and Rulemaking for Nationall y- Relevant Ozone Control Measures”, June 7, 2006. OTC 2006e: Ozone Transport Commission, “Modified Charge of the Ozone Transport Commission to the Stationary Area Source Committee Regarding Electric Generating Units”, November 15, 2006. OTC 2006f: Ozone Transport Commission, “Statement of the Ozone Transport Commission Concerning Regional and State Measures to Address Emissions from Mobile Sources”, November 15, 2006. OTC 2006g: Ozone Transport Commission, “Addendum to Resolution 06 - 02 of the Ozone Transport Commission Concerning Coordination and Implementation of Regional Ozone Control Strategies for Various Sources”, November 15, 2006. Pechan 2001: E.H. Pechan & Associates, Inc., “Control Measure Development Support Analysis of Ozone Transport Commission Model Rules”, prepared for Ozone Transport Commission, March 31, 2001. Pechan 2005: E.H. Pechan & Associates, Inc., “AirControlNET Version 4.1 Documentation Report”, prepared for the U.S. Environmental Protection Agency , September, 2005. Pechan 2006: E.H. Pechan & Associates, Inc., “Documentation for 2002 Emission Inventory , Version 3”, prepared for Mid - Atlantic Regional Air Management Association, April 2006. USEPA 1993. U.S. Environmental Protection Agency , “Final Regulatory Impact Anal ys is for Reformulated Gasoline”, EPA - 420/R- 93 - 017, December 1993. USEPA 1994. U.S. Environmental Protection Agency , “Alternative Control Techniques Document

– NOx Emissions from Glass Manufacturing”, EPA - 453/R- 94 - 037, June 1994.TSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A - 1

MACTEC Federal Programs, Inc. 

## 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 (NAAQ S) by June 15, 2008. To accomplish this, most of the states will need to implement additional measures to reduce emissions that either directly impact their nonattainment status, or contribute to the nonattainment status in other states. In addition, the States are conducting attainment planning work to support development of PM2.5 and regional haze State Implementation Plans (SIPs). As such, the Ozone Transport Commission (OTC) undertook an exercise to identify a suite of additional control measures that could be used by the OTR states in attaining their goals. In March 2005, the Ozone Transport Commission (OTC) established the Control Strategies Committee as an ad - hoc committee to assist with coordination of the attainment planning work. The Control Strategies Committee works with three other OTC committees. The Stationary and Area Source (SAS) Committee evaluates control measures for specific stationary source sectors or issues. The Mobile Source Committee examines control measures for on - road and no n - road mobile sources. And the Modeling Committee develops and implements a strategic plan for SIP - quality modeling runs to support attainments demonstrations. The SAS Committee is comprised of various workgroups that evaluate control measures for specifi c sectors or issues. These workgroups included: · Control Measures Workgroup focuses on stationary area sources; · Reasonabl y Available Control Technology (RACT) workgroup focuses on major point sources; · Multi - Pollutant Workgroup focuses on electric generatin g units (EGUs); · High Electric Demand Day (HEDD) examines EGU peaking units; and · Industrial, Commercial, and Institutional (ICI) Boiler Workgroup focuses on control technologies for different fuels and boiler size ranges. The OTC also issued a contract to MACTEC to help the SAS Committee identify and evaluate candidate control measures as well as to quantify expected emission reductions for each control measure.TSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A -2

MACTEC Federal Programs, Inc. 

### Workgroup Activities Initiall y, the Workgroups compiled and reviewed a list of approximately 1,000 candidate control measures. These control measures were identified through published sources such as the U.S. Environmental Protection Agency ’s (EPA’s) Control Technique Guidelines, STAPPA/ALAPCO “Menu of Options” documents, the AirControlNET databa se, emission control initiatives in member states as well as other states including California, state/regional consultations, and stakeholder input. Appendix B provides the initial list of control measures that were evaluated. Based on the review of the 1,000 candidate control measures, the Workgroups developed a short list of measures to be considered for more detailed anal ys is. These measures were selected to focus on the pollutants and source categories that are thought to be the most effective in re ducing ozone air quality l evels in the Northeastern and Mid- Atlantic States. The Workgroups reviewed information on current emission levels, controls already in place, expected emission reductions from the control measures, when the emission reductions would occur, preliminary cost and cost - effectiveness data, and other implementation issues. Each of the candidate control measures on the short list were summarized in a series of “Control Measure Summary Sheets”. The Control Measure Summary Sheets are contained in Appendix C. The Workgroups discussed the candidate control measures during a series of conference calls and workshops to further refine the emission reduction estimates, the cost data, and any implementation issues. The Workgroups also discusse d comments from stakeholders. The Workgroups prioritized the control measures and made preliminary recommendations regarding which measures to move forward on. OTC Commissioners’ Recommendations Based on the anal ys es b y the OTC Workgroups, the OTC Commiss ioners made several recommendations at the Commissioner’s meeting in Boston June 2006 and November 2006. The Commissioners recommended that States consider emission reductions from the following source categories: · Consumer Products · Portable Fuel Containers · Adhesives and Sealants Application · Diesel Engine Chip Reflash · Cutback and Emulsified Asphalt Paving · Asphalt Production PlantsTSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A - 3

MACTEC Federal Programs, Inc. 

### · Cement Kilns · Glass Furnaces · Industrial, Commercial, and Institutional (ICI) Boilers · Regional Fuels · Electric Generating Units ( EGUs) Additionally , the Commissioners requested that EPA pursue federal regulations and programs designed to ensure national development and implementation of control measures for the following categories: architectural and maintenance coatings, consumer p roducts, ICI boilers over 100 mmBtu/hour heat input, portable fuel containers, municipal waste combustors, regionally consistent and environmentally sound fuels, small offroad engine emission regulation, and gasoline vapor recovery . The various recommendations by the OTC Commissioners made from 2004 to 2006 are summarized in Table A - 1. Stakeholder Input Stakeholders were provided multiple opportunities to review and comment on the Control Measure Summary Sheets. Table A - 2 lists the public meetings that were held as an opportunity for stakeholders to review and respond to the Control Measure Summary Sheets and Commissioner’s recommendations. Stakeholders provided written comments, as listed in Table A - 3. In addition to submitting written comments, the W orkgroups conducted teleconferences with specific stakeholder groups to allow stakeholders to vocalize their concerns directly to state staff and to discuss the control options. These stakeholder conference calls and meeting are listed in Table A - 4. The OTC staff and state Workgroups carefully considered the verbal and written comments received during this process.TSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A - 4

MACTEC Federal Programs, Inc. 

### Table A- 1: OTC Formal Actions, 2004 - 2006 Date Action/Synopsis Nov. 10, 2004 Charge to Stationary and Area Sources Committee Directs SAS C ommittee to

continue to seek out innovative programs to address emissions from all stationary and area sources. Nov. 10, 2004 Charge to Stationary and Area Sources Committee Regarding Multi-Pollutant

Emission Control for Electrical Generating Units and La rge Industrial Sources Directs the SAS Committee to develop an implementation strategy for to implement the OTC’s multi

— pollutant position, recommend methods for allocating NOx and SO2 caps, assess methods to advance the OTC’s Multi0Pollutant position beyond the OTR, develop a program implementation structure, and present a Memorandum of Understanding for consideration by the Commission. Nov. 10, 2004 Charge to the Mobile Source Committee Directs the Mobile Source Committee

to identify selected scenarios to be modeled and evaluate strategies including anti - idling programs, voluntary and regulatory retrofit programs, VMT growth strategies, port and marine engine programs, national mobile source programs, California Low Emission Vehicle programs, and model incentive programs. Nov. 10, 2004 Statement on OTC Modeling Directs the Modeling Committee to coordinate

inventories and modeling needed for ozone, regional haze, and PM; seek input for air directors and OTC committees on regional strategies for modeling ; continue to use CALGRID as a screening tool; and continue to explore application of emerging tools. Ju ne 8, 2005 Resolution of the States of the Ozone Transport Commission Regarding

Development of a Regional Strategy for the Integrated Control of Ozone Precursors and Other Pollutants of Concern from Electrical Generating Units (EGUs) and Other Large Sources Resolves that member States: develop a regional Multi - Pollutant program 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. Nov. 3, 2005 Statement of the Ozone Transport Commission With Regard to Advancement of

Potential Regional Control Measures for Emission Reduction from Appropriate Sources and State Attain Planning Purposes Directs the staff of the OTC to continue investigation and modeling work associated with all potential regional control measures. Feb. 23, 2006 Action Items Directs OTC staff to continue efforts on the following issues:

Letter to EPA on Small Engines, Consumer Products, Architectural/Industrial Maintenance Coatings (AIM), Chip Reflash, Diesel Emissions Reductions, Modeling Efforts. Ju ne 7, 2006 Memorandum of Understanding Among the States of the Ozone Transport

Commission on a Regional Strategy Concerning the Integrated Control of Ozone Precursors from Various Sources Commits OTC States to continue toTSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A - 5

MACTEC Federal Programs, Inc. Date Action/Synopsis

work with interested stakeholders and pursue state - specific rulemakings as needed and appropriate regarding the following sectors to reduce emission of ozone precursors: Consumer Products, Portable Fuel Containers, Adhesives and Sealants, and Diesel Engine Chip Reflash. Ju ne 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 address emissions from this sector and to evaluate and recommend options to address emissions associated with high electrical demand days during the ozone season. Ju ne 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 neede d to establish emission reduction percentages, emission rates or technologies as appropriate for the following source categories: asphalt paving (cutback and emulsified), asphalt plants, cement kilns, regional fuels, glass furnaces, and ICI boilers. Ju ne 7, 2006 Resolution 06 - 03 of the Ozone Transport Commission Concerning Federal Guidance and Rulemaking for Nationally-Relevant Ozone Control Measures Resolves that OTC States request that EPA pursue federal regulations and programs for national implementation of control measures comparable to the levels the OTC has adopted; these areas include AIM Coatings, Consumer Products, ICI Boilers over 100 MMBTU, Portable Fuel Containers, Municipal Waste Combustors, Regional Fuels, Small Engine Emission Regulation, and Gasoline Vapor Recovery. Nov. 15, 2006 Modified Charge of the Ozone Transport Commission to the Stationary Area

Source Committee Regarding Electric Generating Units Directs the SAS Committee and workgroups to continue work on EGU emission reduction s trategies to incorporate “CAIR Plus” and High Energy Demand Day (HEDD) emission reduction strategies. Nov. 15, 2006 Statement of the Ozone Transport Commission Concerning Regional and State

Measures to Address Emissions from Mobile Sources Supports the aggressive implementation of a suite of controls through the OTC Clean Corridor Initiative including: diesel retrofits, the Smartways program, California Low Emission Vehicle programs, anti - idling programs, low -NOx diesel alternatives, transportation demand management to reduce the growth in VMT, and voluntary action and outreach programs. Nov. 15, 2006 Addendum to Resolution 06 - 02 of the Ozone Transport Commission Concerning Coordination and Implementation of Regional 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=FormalTSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A - 6

MACTEC Federal Programs, Inc. 

### Table A- 2: OTC Control Measures Public Meetings, 20 04 - 2006 Date Meeting Location Ju ne 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 Ju ne 7 - 8, 2005 OTC Annual Meeting Burlington, VT Oct. 5, 2005 OTC Control 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 Committee Meeting Linthicum, MD Ju ne 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=meetingTSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A - 7

MACTEC Federal Programs, Inc. 

### Table A- 4: Stakeholder Commen ts on OTC Control Strategies Stakeholder Source Category Adhesive and Sealant Council Adhesives and Sealants National Paint & Coatings Association (NPCA) Adhesives and Sealants Ameron International AIM Coatings McCormick Paints AIM Coatings National Paint and Coatings Association (NPCA) AIM Coatings Painting and Decorating Contractors of America (PDCA) AIM Coatings PROSOCO, Inc. AIM Coatings RUDD Company Inc. AIM Coatings TEX COTE AIM Coatings The Master Painters Institute (MPI) AIM Coatings The Society for Protective Coatings (SSPC) AIM Coatings Wank Adams Slavin and Associates, LLC (WASA) AIM Coatings NAPA Asphalt Production Asphalt Production MATRIX Systems Auto Refinishing Auto Refinishing Portland Cement Association (PCA) Cement Kilns St Lawrence Cement Cement Kilns Consumer Specialty Products Association (CSPA) Consumer Products Cosmetic, Toiletry and Fragrance Association (CTFA) Consumer Products National Paint & Coatings Association (NPCA) Consumer Products Clean Air Task Force Diesel Retrofits Center for Energy and Economic Development, Inc. 

### ( CEED) EGUs Chesapeake Bay Foundation EGUs Clean Air Ta sk Force EGUs Conectiv Energy EGUs Dominion EGUs Exelon EGUs International Brotherhood of Electrical Workers , United Mine Workers of America, Center for Energy & Economic Development, Inc., Pennsylvania Coal Association EGUs NRG EGUs PPL Services EGUs The Clean Energy Group EGUs National Lime Association (NLA) Lime Kilns Debra Jacobson, Prof. Lecturer in Energy Law NOx Sources Flexible Packaging Association (FPA)s Printing/Graphic Arts Graphic Arts Coalition Flexography Air Regulations Printing

– Flexography Graphic Arts Coalition Printing & Graphic Arts Printing/Graphic Arts Graphic Arts Coalition Screen Litho Air Regulations Printing

– Lithography 

### Stakeholder comments can be found on the OTC website at the following address: http://www.otcair.org/projects_details.asp?FID=95&fview=stationaryTSD for OTC Control Measure Evaluation February 28, 2007

Appendix A

–

Process for I

dentifying and Evaluating Control Measures Page A - 8

MACTEC Federal Programs, Inc. 

### Table A- 4: OTC Conference Calls and Meetings with Stakeholders, 2006 Source Category Date(s) Industry Lead Adhesives and Sealants Aug. 30, 2006 Adhesives Council Asphalt Paving Mar. 30, 2006 Sep. 21, 2006 Sep. 28, 2006 Oct. 13, 2006 National Asphalt Paving Association (meeting)

National Asphalt Paving Association Asphalt Emulation Manufacturers Association Asphalt Emulation Manufacturers Association Asphalt Production Oct. 25, 2006 National Asphalt Paving Association (meeting) Consumer Products Mar. 24, 2006 Ju ne 22, 2006 Ju ne 22, 2006 Aug. 29, 2006 Consumer Specialty Products Association

American Solvents Council (meeting) Consumer Specialty Products Association Consumer Specialty Products Association Glass Manufacturers July 5, 2006 Aug. 16, 2006 Sep. 14, 2006 Oct. 19, 2006 North American Insulation Manufacturers Assoc.

North American Insulation Manufacturers Assoc. Glass Association of North America Glass Association of North America ICI Boilers Mar. 14, 2006 Mar. 24, 2006 July 18, 2006 Aug. 1, 2006 Council of Industrial Boiler Owners

Institute of Clean Air Companies Council of Industrial Boiler Owners (meeting) Council of Industrial Boiler Owners (conference)TSD for OTC Control Measure Evaluation February 28, 2007

Appendix B

– Initial List of Control Measures Page B - 1

MACTEC Federal Programs, Inc. 

## Appendix B – Initial List of Control Measures The comprehensive list of control measures can be found at: http://www.otcair.orgTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 1

MACTEC Federal Programs, Inc. 

## Appendix C – Control Measure Worksheets This Appendix contains the Control Measure Summary Worksheets for the following source categories: Manufacture and Use of Adhesives and Sealants Architectural and Industrial Maintenance Coatings Asphalt Paving (Emulsified and Cutback) Asphalt Production Plants Automotive Refinish Coatings Cement Kilns Chip Reflash (Heavy Duty Diesel Engines) Consumer Products Glass and Fiberglass Furnaces Industrial, Commercial, Institutional Boilers Industrial Surface Coatings

– Fabric Printing, Coating, and Dyeing Industrial Surface Coatings

– Large Appliances In dustrial Surface Coatings

– Metal Cans Industrial Surface Coatings

– Metal Coils Industrial Surface Coatings

– Metal Furniture Industrial Surface Coatings

– Miscellaneous Metal Parts Industrial Surface Coatings

– Paper and Web Coating Industrial Surface Co atings

– Plastics Parts Industrial Surface Coatings

– Wood Building Products Industrial Surface Coatings

– All Categories Lime Kilns Municipal Waste Combustors Printing and Graphic Arts Portable Fuel Containers Reformulated GasolineTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 2

MACTEC Federal Programs, Inc. 

### CONTROL MEASURE SUMMAR Y Manufacture and Use of Adhesives and Sealants

(SCC - 2440020000) Control Measure Summary The provisions of this model rule limit emissions of volatile organic compounds (VOCs) from adhesives, sealants and primers. The model rule achieves VOC reductions through two basic components: sale and manufacture restrictions that limit the VOC content of specified adhesives, sealants and primers sold in the state; and use restrictions that apply primarily to commercial/industrial applications. By reducing the availability of higher VOC content adhesives and sealants within the state, the sales prohibition is also intended to address adhesive and sealant usage at area sources. Emissions from residential use of regulated products are addressed through the sales re strictions and simple use provisions. A reasonably available control technology determination prepared by the California Air Resources Board (CARB) in 1998 forms the basis of this model rule. In the years 1998 - 2001, the provisions of the CARB determination were adopted in regulatory form in various air pollution control districts in California including the Bay Area, South Coast, Ventura County, Sacramento Metropolitan and San Joaquin Valley. Costs and Emissions Reductions 2002 existing measure: No ex isting limitations for this category Candidate measure: Approximately 75% of VOC emissions originate from solvent -based adhesives and sealants, the remaining 25% of VOC in this category are due to water -based materials. VOC content limits have been enact ed by various APCD in California from 1998 to 2001. Em issions reductions : VOC content limits for the solvent -based materials can result in 64.4% reduction in total emissions from this category. (CARB RACT/BARCT for Adhesives/ Sealants, Dec 1998) Control costs : Costs for control by reformulation are estimated by the CARB at less than $2500 / ton (1999$). Many manufacturers have either reformulated solvent -based products to reduce the VOC content or have developed low -VOC water -based latex and acrylic pro ducts, 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 Im plementation 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 tpdTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 3

MACTEC Federal Programs, Inc. Interaction with other OTC Model Rules The products regulated in this model rule do not overlap with the products regulated by either the architectural and industrial maintenance (AIM) or consumer product rules. A “coating,” as contemplated in the AIM rule, is a “material applied onto or impregnated into a substrate for protective, decorative or functional purposes.” Because the coating is applied only to one substrate, it is clearly distinguished from adhesives and sealants, which are defined in both the consumer product and adhesive rules by application to two surfaces; in the case of adhesives, the two surfaces are directly bonded while in the case of sealants, a ga p between two surfaces is filled. The overlap between the consumer product and adhesive rules is addressed mainly by an exemption in the adhesive rule for adhesives and sealers subject to the state’s consumer products regulation. Reference: California Air Resources Board. Determination of Reasonably Available Control Technology and Best Available Retrofit Technology for Adhesives and Sealants . December 1998. Page 18 provides the emission reduction estimates for California: the ARB emission inventory estimates 45 tons per day pre rule; reductions will range from approximately 29 to 35 tons per day. We used the low end of this range to calculate the percent reduction of 64.4% (i.e. 29 tpd/45 tpd). Page 17 provides the cost - effectiveness information: the cost of complying with the determination reflects the cost of using alternative formulations of low -VOC or water -based adhesives, sealants, and cleanup products. Ventura County APCD staff determined that the cost - effectiveness of their adhesives rule ranges from a savings of $0.53 per pound to a cost of $1.16 per pound of VOC reduced ($1,060 to 2,320). The use of add- on control equipment to comply was $4.50 to $55.00 per pound ($9,000 to $110,000).TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 4

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR

AIM Coatings 

### Co ntrol Measure Summary: VOC emission reductions can be obtained through modifying the current formulation of the coating to obtain a lower VOC content. The regulatory approach for reducing emissions is to establish VOC content limits for specific coatings that manufacturers are required to meet either through reformulating products or substituting products with compliant coatings. 

### Emissions (tons/year) 2001 existing measure: Federal AIM rules 40CFR Part 59 Emission Reductions : 20% reduction from uncontrolled levels Control Cost : $228 per ton Timing of Implementation : Compliance required by September 1999 Implementation Area : Nationwide VOC (with Part 59 limits) 2002 OTR total: 124,173 2009 On - the -Way Measure: OTC Model Rule based on a model rul e 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: 9 9,023 Candidate measure: Follow CARB 2007 Rulemaking. Modify rule as appropriate when complete (in time for 2009) Participate actively in CARB process. Conduct survey in 2006 for 2005 sales data. Emission Reductions : 6% emissions reduction For modeling purposes we split the difference between SCAQMD and OTC model rule. But we go 75% of the way toward SCAQMD on the top four sales products, and set a 250 g/l VOC limit for Industrial Maintenance coatings. The reductions are calculated using the “reg neg” spreadsheet. Control Cost : Cost of OTC Survey (revise with cost data from the future CARB SCM when available in 2007) SCAQMD estimated the overall cost effectiveness for their 1999 Amendments to $13,317 per ton. For Dec. 5 2003 amendments to Rule 1113, SCAQMD estimated the cost - effectiveness to be in the range of $4,229 to $11,405 per ton Timing of Implementation: 01/01/09 Implementation Area : Throughout OTR and MRPO VOC (After CARB 2007 Rule) 2009 Reduction: - 5,941 2009 Remaining: 93,082

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 Suggeste d Control Measure (SCM) for Architectural Coatings this year. They will be using 2004 survey data as an important resource to update the SCM, but 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.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 5

MACTEC Federal Programs, Inc. CARB is developing an analysis of costs for implementing an updated it’s Suggested Control Measure. Results of the analysis will not be available until 2007. Cost information for the South Coast Phase rules were obtained from: South Coast Air Quality Management District. Final Staff Report for Proposed Amended Rule 1113

– Architectural Coatings . December 5, 2003. “estimated the cost - effectiveness to be in the range of $4,229 to $11,405 per ton of VOC reduce d. The low end of the range was determined based on the retail cost of compliant coatings reported by coating manufacturers surveyed by staff. The upper end of the range was derived by estimating the increased cost at the retail level due to the increase in cost of raw materials, reformulation, testing and packaging a new product prior to commercialization.” The Dec. 2003 amendments lowered the VOC limit for the following specialty coating categories: clear wood finishes including varnishes and sanding sealers, roof coatings, stains, and waterproofing sealers including concrete and masonry sealers. South Coast Air Quality Management District. Appendix F Addendum to Staff Report, Final Socioeconomic Impact Assessment, Proposed Amendments to Rule 1113 . M ay 1999. The May 1999 amendments to Rule 1113 lower VOC limits for the coating categories of industrial maintenance; non - flats; primers, sealers, and undercoaters; quick- dry enamels; quick- dry primers, sealers, and undercoaters; roof coatings; floor coatings, rust preventative coatings, stains, and waterproofing wood sealers. The overall cost- effectiveness of the proposed amendments, (total costs/total emission reductions) over the years 2002 - 2015, is estimated to be $13,317 per ton.TSD for 2006 OTC Control Measure Evaluation February 28, 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: OT C Regional Ban on Cutback Asphalt in Ozone Season, with lower VOC/Solvent Contents for Emulsified Asphalt. VOC Emissions in Ozone Transport Region 2002 existing measure s: 1. Cutback asphalt: The OTC states typically ban the use of cutback asphalt during the ozone season. States do provide various exemptions to the ban, most notably allowances may be made for cutbacks which contain less than 5% VOC. 2. Emulsified as

phalt: Ten of the OTC states regulate emulsified asphalt by providing allowable VOC content limits for the various applications. Three of the states do not address emulsified asphalts in their regulation. Control Cost : According to the 1977 CTG (EPA - 450 /2 - 77 - 037), which formed the basis for the existing regulations, the use of emulsified asphalts (no VOC) presented a cost savings. Timing of Implementation : All regulations implemented in 1990s or earlier under the 1 -hour ozone standard. Implementation Area : OTC 1 -hour ozone non - attainment areas. Annual VOC 2002 cutback: 9,154 tpy 2002 emulsified: 10,379 tpy 2002 total: 19,533 tpy Summer VOC 2002 cutback: 17.5 tpd 2002 emulsified: 38.5 tpd 2002 total: 56.0 tpd 

### Candidate measure: For cutback asphalt paving Measure ID: BOTW09 -AP - Cutback Place a complete prohibition on the use of cutback asphalt during the ozone season. Emission Reductions : to be achieved from using lower VOC content emulsified asphalt products or working outside the oz one season. Control Cost : Negligible. Timing of Implementation : 01/01/09 Implementation Area : All OTC 8 - hour ozone non - attainment counties or individual state - wide. Summer VOC 2009 OTB: 19.9 tpd 2009 Reduction: 19.9 tpd 2009 Remaining: 0.0 tpd 

### Candidate measure: For emulsified asphalt paving Measure ID: BOTW09 -AP - Em ulsified 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 metho d regardless of application (which is 0.25% VOC by volume) Emission Reductions : to be achieved from using lower VOC content emulsified asphalt products or working outside the ozone season. Control Cost : Negligible Timing of Implementation : 01/01/09 Implementation Area : All OTC 8 - hour ozone non - attainment counties or individual state - wide. Summer VOC 2009 OTB: 44.2 tpd 2009 Reduction: 39.9 tpd 2009 Remaining: 4.3 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 propo sed control strategy. (2) The control strategy is supported by the 1977 Control Techniques Document EPA - 450/2 - 77 - 037.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 7

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR Asphalt Production Plants Control Measure Summary: NOx emission reductions can be obtained through installation of low NOx burners and flue gas recirculation. SO2 can be reduced by reducing the sulfur in fuel limits for distillate oil to 500 ppm. Emissions (tons/year) in Ozone Transport Region 2002 existing measure: No existing limitations for this speci fic category have been identified. 2002 NOx Base: 2002 SO2 Base: 827 847 Candidate Measure: Em ission 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 - maj or source emissions are likely lumped into the area source inventory with other industrial/commercial boilers/heaters. The point source data projects only 800+ tons per year (TPY) of both NOx and SO2 actual emissions in 2002 for the entire region. New York actual emissions are over 600 TPY of NOx and 400 TPY of SO2. Therefore, it is unknown what the actual reductions will produce as no accurate baseline exists for both major and minor facilities. Control Cost : Costs for control are similar to those of small to midsize boilers or process heaters. Low NOx burners range from $500 to $1250 per ton. While Low NOx burners in combination with FGR range from $1000 to $2000 per ton. Projected cost increase from lowing sulfur in distillate oil is approximately 2 to 3 cents per gallon. Timing of Implementation : Similar to the NOx RACT procedures of 1994. Require a NOx compliance plan by the spring of 2008 with full implementation and compliance within one year (01/01/09). Unknown for sulfur - in - fuel reductions. Im plementation Area : Region -wide NOx 2009 Base: 2009 Red uction: 2009 Remaining:

SO2 2009 Base: 2009 Reduction: 2009 Remaining: 1,276

- 549 727

1,266

- 950 316

Recommended Strategy: States should support rules that encourage a combination of Best Management Practices, Low NOx Burners and FGR in asphalt production plants to achieve a 20 - 35% reduction in NOx emissions form a 2002 base, and encourage the use of low - sulfur oil. Area source emissions from asphalt plants are not included in this summary.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 8

MACTEC Federal Programs, Inc. REFERENCES: Note: The reductions estimated for this category only include emissions from point sources. Area source emissions from fuel combustion at asphalt production plants are not explicitly contained in the area source emissions. These emissions are likely lumped together in the general area s ource 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 V ersion 4.1: Documentation Report, September 2005. Information in this report for small oil - fired process heaters and ICI boilers provide similar levels of control and cost - effectiveness. Candidate Measure (Best Management Practices) Best Practices to Reduce Fuel Consumption and/or Lower Air Emissions: HMA industry leaders have identified a number of Best Practices that, if implemented, allow for substantial reduction in plant fuel consumption and the corresponding products of combustion including NOx. In today’s business environment, there is significant incentive to reduce fuel usage. For this reason, implementing best practices to reduce fuel consumption and NOx emissions, forms the basis of a sustainable strategy. Effective stockpile management to reduce aggregate moisture content: Current information indicates that effective stockpile management can reduce aggregate moisture content by about 25 percent, corresponding to a reduction in fuel consumption by approximately 10 - 15 percent. There are a number of ways to reduce aggregate moisture: covering stockpiles, paving under stockpiles, and sloping stockpiles are all ways that prevent aggregate from retaining moisture. Best Practices are plant - and geographic locale - specific. Burner tune - ups: As identified in OTC Resolution 06 - 02 and companion control measures summaries, a burner tune -up may reduce NOx emissions by up to 10 percent. From a contractor’s perspective, this also is helpful in reducing fuel consumption. In other words, there can be a dire ct pay-back to the business from regular burner tune -ups. Low ering mix temperature: A Technical Working Group of FHWA is currently investigating a number of newer formulation technologies, to understand the practicality and performance of lowering mix tem peratures. Substantial reductions in mix temperatures, on the order of 20 percent or more, appear to be plausible. Lowering mix temperatures, by this amount, may reduce fuel consumption, as less heat is needed to produce the mix. Other maintenance and ope rational best practices: Additional practices can be employed throughout the plant to help optimize production and operations. For example, regular inspection of drum mixing flites and other measures can be taken

– all in the effort to make a plant operate more efficiently, thereby using less fuel.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 9

MACTEC Federal Programs, Inc. Plant Type Emission Rate (lbs NOx/ton asphalt produced) % Reduction Area/Point Sources (State emissions option) 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 (State technology option) Batch/Drum Mix Plant

– Natural Gas Low -NOx Burner Technology and/or Best Management Practices Batch/Drum Mix Plant

– Distillate/Waste Oil Low -NOx Burner Technology and/or Best Management PracticesTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 10

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR Auto Refinish Coatings – Area Source Control Measure Summary: Limiting the concentration of solvents in Auto Refinishing Coatings in order to reduce VOC emissions. Encourage the use of high transfer - efficiency painting methods (e.g., high volume low pressure spray guns), and controls on emissions from equipment (e.g., spray gun) cleaning, housekeeping activities (e.g., use of sealed containers for clean -up rags), and operator training. Emissions (tons/year) in Ozone Transport Region 2002 existing measure: Federal Auto Body Refinishing rules 40CFR Part 59 Subpart B Emission Reductions : 37% reduction from Part 59 (from Pechan OTC Mo del 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) Co ntrol 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 mea sure: CARB October 20, 2005 SCM Staff Report – Low ers 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

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 P art 59 rule at a cost of $118 per ton (1990$) and a reduction of 37 percent from uncontrolled levels. 2009 On - the - Books Measure (OTC Model Rule): E.H. Pechan & Associates, Inc., Control Measure Development Support Analysis of Ozone Transport Commission Mo del Rules , March 31, 2001. Table II - 6 shows 37% reduction for Federal Part 59 rule and 38% (OTC Model Rule beyond Federal rule). Page 17 presents cost of $1,534 per ton based on estimates used for PA Rule 129.75.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 11

MACTEC Federal Programs, Inc. Candidate Measure (CARB 2005 Suggested Control Measure): California Air Resources Board. Staff Report for the Proposed Suggested Control Measure for Automotive Coatings. October 2005. Table V - 3 shows the estimated 65% reduction from 2002 baseline emissions for new automotive coatings limits. A similar reduction is expected for the OTR. Page VII - 6 indicates that the cost - effectiveness of the SCM is estimated to be $1.43 per pound of VOC reduced ($2,860 per ton). The CARB SCM coating categories and VOC limits are:



### The OTC Model Rule coating categories and VOC limits are: OTC Model Rule Limit Coating Type Grams per Liter Pounds per

gallon Automotive pretreatment primer 780 6.5 Automotive primer - surfacer 575 4.8 Automotive primer - sealer 550 4.6 Automotive topcoat: single stage - top coat 600 5.0 2 stage basecoat/clearcoat 600 5.0 3 or 4 - stage basecoat/clearcoat 625 5.2 Automotive Multi - colored Topcoat 680 5.7 Automotive specialty 840 7.0TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 12

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR

Cem ent Kilns Control Measure Summary: Emissions (tons/ye ar) in Ozone Transport Region 2002 existing measure: NSR; PSD; State RACT. NOx 2002 Base: 31,960 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 reduction s of approximately 25 percent from the cement industry. Control Cost : $2,000 per ton Timing of Implementation : 2004 Implementation Area : OTR NOx 2009 Base: 2009 Reduction: 2009 Remaining: 31,960

- 7,990 23,970 Candidate measure: Use of proven co ntrol technologies (such as SNCR) or other methods to meet recommended emission limits. Emission Reductions : source specific, varies from 0 - 63% based upon 2002 base rates. Control Cost : less than 2,500 per ton Timing of Implementation : 01/01/09 Implemen tation Area: OTR NOx 2009 Base: Candidate Reduction: 2009 Remaining: 31,960

- 13,231 18,279 Policy Recommendation: It is recommended that a program be developed reduces NOx emissions from existing cement kilns by requiring existing kilns to meet a NOx emission rate of 3.88 lbs/ton clinker for wet kiln 3.44 lbs/ton clinker for long dry kiln 2.36 lbs/ton clinker for pre - heater kiln 1.52 lbs/ton clinker for pre - calciner kiln. Trading between facilities would not be permitted, but averaging at a facility would be permissible. Brief Rationale for Recommended Strategy: This limit is consistent with the emission reduction capabilities of SNCR. There are 18 full - scale SNCR installations in Europe. 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, re spectively. For biosolids injection, “Cost effectiveness for this kiln is based on the annualized costs of ($320,000/year), the emission reduction achieved at that facility (emissions decreased from 2.4 lb/ton of clinker to 1.2 lb/ton of clinker), a kiln capacity of 215 tons/hr, and an annual operation of 8,000 hr/yr. Cost effectiveness is a credit of ($310/ton) for installing biosolids injection on this kiln” due to tipping fee for using biosolids (dewatered sewage sludge) For NOXOUT®, “40 percent NOX re duction based on the available test data. Cost effectiveness for the two kilns, using urea as the reagent, is based on an uncontrolled emission rate of 3.8 lb NOX/ton of clinker, kiln capacities of 92 and 130 tons/hr respectively, annual operation of 8,000 hr/yr, and a NOX control efficiency of 40%. Cost effectiveness is $1,000/ton for the smaller kiln and $2,500/ton for the larger kiln.” European Commission. Integrated Pollution Prevention and Control (IPPC) Reference Document on Best Available Techniques in the Cement and Lime Manufacturing Industries . December 2001. These report indicates that there are 18 full - scale SNCR installation in Europe. Most SNCR installations are designed and/or operated for NOx reduction rates of 10 - 50% which is sufficient to comply with current legislation in some countries. Two Swedish plants installed SNCR in 1996/97 and have achieved a reduction of 80 - 85% at both kilns.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 13

MACTEC Federal Programs, Inc. Emission Rates: Table 4 - 5 of the EPA’s NOx Control Technologies for the Cement Industry, September 19, 2000 provides the following uncontrolled emission rates for the four types of cement kilns:

Kiln Type Heat Input

Requirement (mmBtu/ton of clinker) Average

NOx Uncontrolled Emission Rate (lb/ton of clinker) Range of

NOx Uncontrolled Emission Rate (lb/ton of clinker) Wet 6.0 9.7 3.6 to 19.5 Long Dry 4.5 8.6 6.1 to 10.5 Preheater 3.8 5.9 2.5 to 11.7 Precalciner 3.8 3.8 0.9 to 7.0 

### The OTC Control Measure Summary Sheet calls for a 60% reduction from uncontrolled emissions. Using this percent reduction figure and the uncontrolled emission rates above, the following controlled emission rates were calculated:

Kiln Type Percent

Reduction from Uncontrolled Low - End

NOx Controlled Emission Rate (lb/ton of clinker) Average

NOx Controlled Emission Rat e (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 recommended the use of the the average NOx Controlled emission rates in the above table (expressed as lb/ton of clinker).TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 14

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”. Softw are reprograms the vehicle's computer and reduces off - cycle NOx emissions. The installation process typically takes between one -half to one hour. Emissions Reductions (tons/day) 2002 existing measure: No existing measure in the OTR other than the EPA program resulting from the consent decrees on 7 heavy duty engine manufacturers. The results of the EPA program thus far are significantly lower than the level originally projected by the Agency (less than 10% implementation). CARB implemented a voluntary program that did not achieve its expected results, so the Board’s backstop mandatory program was triggered. The CARB mandatory program is facing two separate legal challenges, alleging that CARB has breached its settlement agreement and alleging that CARB is illegally establishing different emissions standards on “new engines”. Candidate measure: Measure ID: Model rule for Mandatory Chip Reflash Program in the OTR Emission Reductions : NOx reduction (TPD) from in - state registered vehicles Control Cost : Moderate

– manufacturers must provide the rebuild kits free to any truck operator who requests it. The cost associated with the reflash has been estimated at $20 - $30 per vehicle, which is borne by the engine manufacturer. There may be costs associated with potential downtime to the trucking firms, and recordkeeping requirements on the dealer performing the reflash and the vehicle owner. For the MRPO, ENVIRON estimated cost effectiveness to be “$1,800 to $2,500 (depending on vehicle size) due to incremental “fuel penalty” of 2% increase in fuel consumption). However, in reality, no fuel penalty has been documented on vehicles that have already been reflashed. Timing of Implementation : The kits are currently available, so once the states adopt the rul e, retrofits can begin according to the schedule. Implementation Area : All OTR and MRPO states (NOx reductions 109 TPD) LADCO Northeast states Mid Atlantic States Total OTR 46 TPD

41 TPD 22 TPD 63 TPD

Policy Recommendation of State/Workgrou p Lead: Expand scope of the model rule for the Northeast states to the entire OTR and MWRPO Brief Rationale for Recommended Strategy: While the EPA program provides a good platform for chip reflash retrofits, the federal program is not even achieving 10% of its estimated emission reductions. The kits are available and must be given to the truckers for free; yet without additional motivation, it is unlikely that the implementation rate will improve due to fuel consumption and/or performance perception s and the ability to extend the time to next major rebuild/overhaul. The states in the OTR do not face the prospect of breach - of - settlement allegations that CARB did in adopting a mandatory program, since they did not participate in the negotiation of the CD settlements. And there are significant emission reductions that can be achieved through a mandatory program, even though installing the kits will not result in the engines operating at the same emission levels required for the EPA engine certification test. Nevertheless, this is a relatively simple fix for a problem that our states will face if they rely on the federal program alone to produce emission reductions from these sources.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 15

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR

Consumer Products Control Measure Summary: Consumer Products This control measure establishes limits on the VOC content of consumer products. It is based on the California Air Resources Board (CARB) consumer products rules, with some region specific modifications. It regulates categories such as hairspray, air fresheners, glass and general purpose cleaners, adhesives, anti -perspirants and deodorants, insecticides and automotive aftermarket products. VOC Emissions in Ozone Transport Region

2002 Existing Measure: The Federal Consumer Pro ducts 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 Im

plementation : 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 2 001 OTC Model Rule for Consumer Products in all OTC states (this model rule was based on a series of five CARB consumer products rules). Emission Reductions : 14.2 % beyond federal rule or a total of 21 % from the uncontrolled state. Control Cost : $800 per ton VOC reduced Timing of Implementation : 1/1/05 effective date of VOC limits (though some states were later and some have yet to adopt) Implementation Area : OTR 2009 Annual Reduction: Remaining: 2009 Summer Reduction: Remaining: 22,916 tpy

209,897 tpy 63.4 tpd 579.5 tpd Candidate Measure #1: Adopt the CARB amendments to their consumer products rule, adopted 7/20/05, with the exception of the 12/31/09 shaving gel, and 12/31/08 anti- static aerosol VOC limits. This rule sets new VOC limits for 11 categories, revises the existing VOC limit for 1 category and includes some additional requirements. See more detailed limits below. Emission Reductions : CARB estimates their rule will achieve a 6.3 ton/day reduction of VOC in California, which is equivalent to about 11.3 tons per day in the OTR or a 2% reduction beyond the on -the books measure. Control Cost : $4,800 per ton of VOC reduced Timing of Implementation : 01/01/09 Implementation Area OTR 2009 Annual Reduction: Remaining: 2009 Summer Reduction: Remaining: 7,453 tpy

202,444 tpy 20.6 tpd 558.9 tpd Candidate Measure #2: Follow and adopt as appropriate CARB ‘s next round of amendments to their consumer products rule, to be developed and proposed by approximately late 2006/early 2007 with limits effective in 2010. Emission Reductions : The CONS - 2 amendments are estimated by CARB to achieve VOC reductions of about 20 - 35 tpd in California by 2010 which is equivalent to about 36 - 63 tpd in the OTR (The midpoint of this range was used in the calculations, 49.5 tpd). Control Cost : Unknown at present; Timing of Implementation : 01/01/10 Implementation Area OTR VOC not modeled: 2009 Annual Reduction: Remaining: 2009 Summer Reduction: Remaining: Not

AvailableTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 16

MACTEC Federal Programs, Inc. Summary of Candidate Measure #1: The proposed VOC limits based on CARB’s 7/20/05 amendments are as follows: 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 LIM IT% 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 categoryTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 17

MACTEC Federal Programs, Inc. 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 Vers ion 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 O zone Transport Commission Model Rules , March 31, 2001. Table II - 6 shows 14.2% reduction (OTC Model Rule beyond Federal rule). Page 8 presents cost of $800 per ton based on CARB’s Sept. 1999 Initial Statement of Reasons for Proposed Amendments to the Cali fornia Consumer Products Regulation. 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 S ummary shows that the CONS - 1 amendments will achieve reductions of about 6.8 tons per day state wide (6.3 tons per day without the 12/31/09 Shaving gel, and 12/31/08 anti - static aerosol regs.. Page 21 states the cost of CONS - 1 will be $2.40 per pound ($4, 800 per ton). Since OTC’s model rule is very similar to the CARB’s rule, and emissions are proportional to population, CARB’s 6.3 ton per day reduction was prorated to the OTC region based on the ratio of OTR 2002 population (63 million) to CA 2002 popula tion (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 simi lar to the CARB’s rule, and emissions are proportional to population, the mid -point of CARB’s 20 - 35 ton per day reduction (i.e., 27.5 tons per day) was prorated to the OTC region based on the ratio of OTR 2002 population (63 million) to CA 2002 population (35 million) yielding approximately 49.5 tons per day in the OTR (18,068 tons per year).TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 18

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. NOx 2002 Base: 18,840 Candidate measure: Use of oxyfiring or other methods to meet recommended emission limits. Emission Reductions : source specific, varies from 0 - 85% depending upon 2002 base rates. Control Cost : $ 924 to 2,232 per ton Timing of Implementation : 01/01/09 Implementation Area : OTR NOx 2009 projected: Reduction at full implementation: Remaining after full implementation: 21,893

- 13,474 8,419 Control Measure Recommendation: Develop a control strategy that re quires implementation of an “oxyfiring” program for each furnace at the next furnace rebuild. Alternatively, states may allow manufacturers to propose compliance methods based on California’s San Joaquin Valley Rule 4354 which allows a mix of control opti ons to meet specified emission limits. Prior to furnace rebuild, owners/operators may be allowed, by the state, to meet emissions limits by purchasing a state specified number of NOx allowances. Continuous emission monitoring systems would be used to determine emissions. This Measure should be modeled at 85% reduction. 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, EPA 453/R- 94 - 037, June 1994. Oxyfiring reduction of 85%, cost - effectiveness of $2,150 to $5,300. Emission rates based on San Joaquin 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 pulle d 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 pulledTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 19

MACTEC Federal Programs, Inc. CONTROL MEA SURE SUMMARY FOR Industrial, Commercial, Institutional (ICI) Boilers – Jointly processed with MANE - VU 

### Addendum to OTC Resolution 06 - 02 Guidelines for ICI Boilers ICI Boiler Size (mmBtu/hr) Control Strategy/

Compliance Option NOx Control Measure 5 - 25 Annual Boiler Tune -Up

Option #1 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 Coal: 0.30 lb NOx/mmBtu** Option #2 50% reduction in NOx emissions from uncontrolled baseline 25 - 100 Option #3 Purchase current year CAIR NOx allowances equal to reducted needed to acheiv the required emission rates Option #1 Natural Gas: 0.10 lb NOx/mmBtu

#2 Fuel Oil: 0.20 lb NOx/mmBtu #4 or #6 Fue l Oil: 0.20 lb NOx/mmBtu Coal: Wall - fired 0.14 lb NOx/mm Btu Tangential 0.12 lb NOx/mm Btu Stoker 0.22 lb NOx/mm Btu Fluidized Bed 0.08 lb NOx/mm Btu Option #2 LNB/SNCR, LNB/FGR, SCR, or so me

combination of these controls in conjunction with Low NOx Burner technology Option #3 60% reduction in NOx emissions from uncontrolled baseline 100 - 250

Option #4 Purchase current year CAIR NOx allowances equal to reducted needed to acheiv the required emiss ion rates >250 Option #1 Purchase current year CAIR NOx allowances equal to reducted needed to acheiv the required emission rates Option #2 Phase I

– 2009

Emission rate equal to EGUs of similar size

Phase II

– 2012 Emission rate equal to EGUs of similar sizeTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -20

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 Fu rniture 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/N SR; 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. - S ubpart 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 ef ficiency 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 Implemen tation 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 paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -21

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR Industrial Surface Coatings Large Appliances Control Measure Summary: This catego ry 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 Product s 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/l iter 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 Optio n 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, 20 06. Brief Rationale for Recommended Strategy: See additional discussion in briefing paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -22

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 f ood 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 : Natio nwide

– $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)TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -23

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 Con trol 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 adj acent 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 paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -24

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/NS R; 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: Sources 10 tons/year uncontrolle d 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 paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -25

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 Ozo ne 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] (minu s H 2 O & exempt solvents) Applicability: Sources 10 tons/year uncontrolled emissions OTC state RACT limits: NH - same limits as CTG VOC Actual 2002: (not available) Metal Furniture

– 2009 On -the - Books measures: MACT Std.

– Subpart RRRR (67 FR 28606 , 5/23/03) EPA MACT limits existing sources : 0.10 kg HAP/liter solids Emission Reductions : Nationwide

– 73% HAP reduction from 1997/1998 baseline MACT Organic HAP control efficiency option: xx% for existing sources Estimated VOC reduction 0% (Pechan Table) Control Cost : Nationwide

– $14.8 million/yr for 16,300 tons/yr = $908/ton Timing of Implementation : Compliance Date (existing) May 23, 2006 Implementation Area : Nationwide VOC Actual 2002: OTB 2009: Reduction from

OTB: (not

available)

Metal Furniture Candidate measure 1: Adopt More Stringent RACT regulations; lower applicability thresholds, extend geographic coverage Measure ID: Permanent Total Enclosure Emission Reductions : Estimated VOC reduction 95%

(Air Control Net 3.0 Table) Control Cost : $20,115/ton Timing of Implementation : Assuming 2007 or 2008 effective date of rule, emission reductions in 2009 or 2010 Implementation Area : (1) 8 -hr ozone nonattainment areas, (2) 8 -hr ozone nonattainment areas plus adjacent counties, or (3) all counties. VOC OTB 2009: BOTW 2009: Reduction from BOTW: (not

available)

Policy Recommendation: 

### Final recommendation not made as of June, 2006. Brief Rationale for Recommended Strategy: See additional discussion in briefing paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -26

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 environmental conditions 3.5 [0.42 kg/l] All other coating s 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 O n -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 fo r 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 Implementa tion 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 paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -27

MACTEC Federal Programs, Inc. CONTROL MEA SURE 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 o f June, 2006. Brief Rationale for Recommended Strategy: See additional discussion in briefing paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -28

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR Industrial Surface Coatings Plastic Parts Control Measure Summary: This category includes several source types: Fab ric, 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 Oz one 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 uncontro lled 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 Assemb led 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 20 09: 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 paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C -29

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR Indust rial 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 co ating; 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 : Na tionwide

–$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 additio nal discussion in briefing paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 30

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR Industrial Surface Coatings All Categories Control Measure Summary: This category includes several source types: Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts coating; Paper and Other Web coating; Plastic Parts coating; & Wood Building Products coating Emissions (tons/year) in Ozone Transport Region Industrial Surface Coatings Category Total - 2002 existing measures: NSPS: PSD/NSR; State RACT rules in 1 -hour non - attainment counties Total VOC Point &Area Actual 2002: 164,445 Industrial Surface Coatings Category Total - 2009 On - the - Books measures: MACT Stds.

– Subpart OOOO (68 FR 32172, 5/29/ 03)

Subpart NNNN (67 FR 48254, 7/23/02) Subpart KKKK (68 FR 64432 , 11/13/03) Subpart SSSS (67 FR 39794 , 6/10/02) Subpart RRRR (67 FR 28606 , 5/23/03) Subpart MMMM (69 FR 130 , 1/2/04) Subpart JJJJ (67 FR 72330 , 12/4/02) Subpart PPPP (69 FR 20968 , 4/19/04) Subpart QQQQ (68 FR 3174 6 , 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 Im plementation 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 paperTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 31

MACTEC Federal Programs, Inc. Background Information Industrial surface coatings are used during the manufacture of a wide variety of products including: fabrics, paper, large appliances, metal cans, metal coils, metal furniture, metal parts, plastic parts, and wood building materials. Surface coating is the process by which paints, inks, varnishes, adhesives or other decorative or functional coatings are applied to a substrate (e.g., fabric, metal, wood, or plastic) to protect or decorate the substrate. Industrial surface coatings can be applied by brushing, rolling, spraying, dipping, flow coating, electro - coating, or combinations and variations of thes e methods. The process used to coat a particular product is dependent on the composition of the coating, the substrate to which the coating is applied and the intended end use of the final product. After a coating is applied, it is dried or cured either by conventional curing through the use of thermal drying ovens, or through the use of radiation. During conventional curing, heat from thermal ovens is used to evaporate the solvents and/or water trapped in the coating and release them into the atmosphere . Two types of radiation curing processes currently in use are ultraviolet (UV) curing and electron beam (EB) curing. Emissions are released by the evaporation of the solvents used in the coatings and the evaporation of any additional solvents used to di lute (thin) the coating prior to application and for cleaning the coating equipment after use. Emissions from surface preparation and coating applications are a function of the VOC content of product used. Emissions are also a function of the type of coa ting process used (rolling, dipping, spraying, etc.) and the transfer efficiency of the process. Transfer efficiency is the percentage of the coating solids that are applied (e.g., sprayed) which actually adhere to the surface being coated. Emissions fro m 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 20 02 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 ca tegory 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 hi ghly uncertain and may be substantially overestimated. The method used to estimate area source VOC emissions relies heavily on employee emission factors and employment data. These emission factors are based on data collected by EPA in the 1980s and may n ot accurately portray the types of coatings, the type of coating equipment, or the type of control technology currently in use. 2) At least nine types of industrial surface coating point sources are already controlled

due to state specific VOC RACT regulati ons or will soon be controlled prior to 2009 as a result of the recently promulgated Maximum Achievable Control Technology (MACT) standards. Since the MACT standards were designed to control air toxic emissions and not necessarily VOC emissions the effe ctiveness of the MACT standards for controlling VOC emissions will vary with the industrial surface coating subcategory (e.g., metal cans, wood building products, etc.) and the type of coating equipment and the type of solvents used in that subcategory. Regulatory History Industrial surface coating processes are currently subject to multiple state and federal regulations pursuant to Titles I and III of the Clean Air Act. Title I imposes Standards of Performance for New Stationary Sources (NSPS) on new and modified large stationary sources. In the early 1990s, EPA promulgated NSPSs for various types of industrial surface coating operations. These regulations appliedTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 32

MACTEC Federal Programs, Inc. to surface coating operations that were constructed or modified after effective dates specified in each NSPS. In general, surface coating operations constructed or modified after 1980 are subject to NSPS requirements. The NSPS generally established VOC emission rate limits that could be complied with using either compliant coatings or add- on capture and control equipment. For certain source categories the NSPS also set transfer efficiency requirements. New and modified large stationary sources that increase their emissions can also be subject to the New Source Review (NSR) requirements o f Title I. NSR requires a control technology review for large new plants and for modifications at existing plants that result in a significant increase in emissions, subjecting these sources to Best Available Control Technology (BACT) in attainment areas and Lowest Achievable Emission Rate (LAER) in nonattainment areas. BACT and LAER control requirements are updated over time to reflect improvements in control equipment and are reviewed on a case -by - case basis during state permitting process. Criteria p ollutants, 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 located in nonattainment areas must install reasonably available control technol ogy (RACT). RACT levels must be basedon the level of emissions reduction that can be reasonably achieved at a reasonable cost. The U.S. EPA has issued a series of Control Technology Guidelines (CTGs) and Alternative Control Technologies (ACT) documents to assist states in defining RACT for a number of industrial surface coating categories. For categories not covered by a CTG or ACT document, state regulations require that a case -by - case RACT determination be made. Most of the EPA’s CTGs and ACT document s for the industrial surface coating category were developed prior to 1990. While specific RACT requirements will vary from state to state, some OTC states have already adopted RACT regulations that are more stringent than the CTG/ACT requirements. Policy Recommendation As can be noted from the background information, the regulatory history, and the information contained in summary tables, the industrial surface coatings category includes at least nine different major source types and multiple process es for each source type with regulations and emissions limits that vary not only by maj or source type, but also by individual process and individual product. In addition, the industrial surface coatings category is already subject to a variety of regulati ons (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 red

uce emissions of hazardous air pollutants but have the side benefit of reducing VOC emissions as well. Analysis of the potential benefits and costs of adopting additional VOC control measures, Beyond OnThe -Way (BOTW) measures) is further complicated by the following: 1) Uncertainty as to the accuracy of the current (2002) MANE -VU VOC emissions inventory for the industrial surface coatings category; 2) Difference in current VOC RACT limits among the OTC states; 3) Difference in the estimates of the potential VOC reductions from MACT standards; and 4) Difference in the source size and geographic area covered by a specific regulation. The most recent version of the (2002) MANE -VU VOC emissions inventory for the MANE -VU region estimates total VOC emissions fro m the industrial surface coatings category to be 164, 445 tons (24,931 tons of VOC from point sources and 139,512 tons from area sources). Further investigation into the amount of VOC emissions from area sources will most likely reveal that these VOC emi ssions areTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 33

MACTEC Federal Programs, Inc. substantially overestimated due in part to the emission factors and employment data used and in part to the cutpoints used by various states for distinguishing a point source from an area source. A quick sampling of the current VOC RACT limits in the OTC states reveals differences not only in the limits for existing sources (lbs. VOC per gallon of coating minus water and exempt solvents), but also in the size of source to which these limits apply. Several complications arise when trying to calculate the potential VOC reductions from a particular MACT standard including the following: 1) Not all toxics regulated under the MACT are VOCs; 2) MACT standards are expressed as kg HAP/liter of solids or lbs. HAP/gallon of solids not lbs. VOC/gal lon of coating minus water and exempt solvent so the MACT limit applies to all HAPs not just VOCs; and 3) The specific types of processes and coatings regulated under the MACT standards are different than the types of processes and coatings regulated under the RACT standards. These complications have lead to widely varying estimates of the potential additional VOC reductions from the application of a particular MACT requirement (from 0% to as much as 80% VOC reduction nationwide). RACT standards and MACT standards apply to sources located in different geographic areas throughout the Ozone Transport Region. For some OTC states RACT standards apply only to sources located in 1 - hour ozone nonattainment counties while in other OTC states RACT standards apply statewide. MACT standards are applicable nationwide and only to major HAP sources (10 tons/year of individual HAP or 25 tons/year of combined HAPs). Given all of these uncertainties the following options are available: 1) OTC states that currently have higher VOC RACT limits than the EPA CTG/ACT VOC RACT limits can adopt more stringent RACT regulations; 2) OTC states can extend the geographic coverage for RACT limits to statewide; 3) OTC states can lower the RACT applicability thresholds 4) OTC states can adopt more stringent control requirements for specific industrial surface coating categories (e.g., permanent total enclosures for metal can coating processes). Policy recommendations: 1) Due to uncertainty in current MANE -VU VOC emissions inventory for this categ ory, develop an improved, state specific VOC emissions inventory for point and area sources for each subcategory of industrial surface coatings before requiring additional controls beyond MACT.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 34

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR

Lime Kilns Control Measure Su mmary: 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 Em ission 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 Availab le Techniques in the Cement and Lime Manufacturing Industries . December 2001. “ The direct transfer of low -NOx burner technology from cement kilns to lime kilns is not straightforward. In cement kilns, flame temperatures are higher and low -NOx burners have been developed for reducing high initial levels of ‘thermal NOx’. In most lime kilns the levels of NOx are lower and the ‘thermal NOx’ is probably less important.” Northeast States for Coordinated Air Use Management. Assessment of Control Technology Options for BART -Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants, and Paper and Pulp Facilities . March 2005. “Due to the design of the lime kiln, SNCRs and SCRs are not viable NOx reduction techniques. Installing low -NOx burners is also not a practical NOx reduction technique according to a BACT analysis conducted on a new lime kiln in 1997...combustion modification such as decreasing excess air is the best way to reduce NOx emissions”.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 35

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 Subp arts Cb and Eb ). No control technology is mandated to meet the emissions limitations. EPA approved state trading programs for NOx compliance are allowed as is facility- wide averaging for NOx compliance. Emission Reductions : 19,000 Mg NOx/yr nationally ( increment over 1991 40 CFR 60 Subpart Ca standards). Control Cost : $7.2 per Mg municipal solid waste combusted. Timing of Implementation : Compliance required December 19, 2000. Implementation Area : Nationwide. VOC: 2002 Base 473 NOx 2009 Reduction: 2009 Remaining: - 3,610 22,529 SO2 *** Implement Federal Rules: Measure ID: Emission Reductions : Varies per state depending on the number of MWC units, incinerator technology and chosen emissions limitations. In Connecticut, this measure resulted in NOx emissions re ductions of 1.6 tons/summer day and 592 tons/year. Control Cost : $0 to approximately $1,500/MMBtu/hr depending on whether SNCR was installed in response to the federal emissions guidelines and whether SNCR is feasible. Timing of Implementation : Assuming timely adoption of state rule amendments, compliance with emissions limitations could be required by May 1, 2009. Implementation Area : Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York and Pennsylvania report operating MWC units (assuming state NOx emissions limitations are at the level of the federal emissions guidelines). VOC ***

Policy Recommendation of State/Workgroup Lead: Individual states with operating MWCs s hould evaluate the possible reduction of state NOx emissions limitations to produce creditable emissions reductions. At the regional level, this strategy should not be emphasized as it is state - specific in nature (depending on the MWC population, current control level and current state standards); does not require regional implementation to maximize its effectiveness; emissions from MWCs are a minor portion of the regional inventory given MACT -based standards required under Section 129 of the Clean Air Act ; and EPA has proposed more stringent NOx emission limits for MWCs that states will be required to adopt and implement as of April 2009. Recommended Strategy: MWCs are subject to stringent MACT emissions standards, including standards for NOx, under Se ction 129 of the Clean Air Act. To comply with these MACT standards, many MWC owners and operators installed control technologies, including SNCR, to comply with the federal deadline of December 19, 2000. Many MWCs may be operated to reduce emissions to a level below the current federal standards. For example, Connecticut includes a state NOx emission reduction credit (ERC) trading program in its MWC rule. Recognizing that the "excess emissions" produced in Connecticut's MWC NOx ERC trading program coul d yield creditable emissions reductions if the required NOx emissions limits were reduced, in October 2000, the Department amended the state MWC rule to require the MWC owners and operators to meet more stringent NOx emissions limits as of May 1, 2003. Th e resulting emissions reductions of 1.62 tons of NOx per summer day (248 tons per ozone season) were used for compliance with the "shortfall" emission reduction obligationTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 36

MACTEC Federal Programs, Inc. needed for EPA approval of the attainment demonstration for the 1 -hour ozone national ambient air quality standard. Other states in the OTC region have operating MWC units that now comply with MACT -based state emissions limitations. Many MWC units now operate with SNCR to control NOx emissions. For MWC units that do not now have SNCR , SNCR is likely a feasible RACT measure capable of reducing NOx emissions below the state limits. Thus, the reduction of the state MWC NOx limits may produce creditable NOx emissions reductions. Furthermore, since MWCs are not subject to the Clean Air Interstate Rule (CAIR) and may not participate in a CAIR NOx trading program, reduction of state MWC NOx emissions limitations could be considered an equity measure that places MWC owners in a position similar to the owners of large electric generating unit s subject to CAIR. However, the amount of creditable emissions reductions a state may obtain from this strategy is limited given EPA's December 19, 2005 proposal of reduced emissions limitations for MWCs. BACKGROUND INFORMATION In December 1995, EPA adopted new source performance standards (NSPS) (40 CFR 60 subpart Eb) and emission guidelines (subpart Cb) for MWC units with a combustion capacity greater than 250 tons per day. Both the NSPS and emission guidelines require compliance with emission limitations for nine pollutants including NOx that reflect the performance of maximum achievable control technology (MACT). The emission guidelines required compliance by December 2000 for all existing MWCs, while the NSPS apply to new MWCs. On December 19, 20 05, EPA proposed revisions to the emissions guidelines to reflect the levels of performance achieved due to the installation of control equipment (70 FR 75348). This proposal includes reduced NOx emissions limitations that states will be required to adopt and implement by April 2009, if the proposal is finalized. Selective non - catalytic reduction (SNCR) is considered MACT for NOx under both the 1995 guidelines and the 2005 proposal. Connecticut's MWC regulation, section 22a - 174 - 38 of the Regulations of Connecticut State Agencies (R.C.S.A.) (Attachment A), was adopted in June 1999 with NOx emissions limits equivalent to the federal emissions guidelines (Phase I NOx limits). Owners and operators of the state's 15 MWC units were required to comply with th e emissions limits no later than December 19, 2000. R.C.S.A. section 22a - 174 - 38 was amended in October 2000 to include more stringent NOx emissions limits (Phase II NOx limits), for which compliance was required no later than May 1, 2003. The following N Ox emissions reductions, relative to emissions levels under the Phase I NOx limits, are attributed to the Phase II NOx limits in Connecticut: · 592 tons per year; · 248 tons per ozone season; and · 1.62 tons per day during the ozone season. 1 EPA's December 19 , 2005 proposal to update the 1995 emissions standards will substantially reduce the ability of other states to achieve the same level of emissions reductions that Connecticut achieved by implementing this measure in 2003. Add - on NOx Control The number of NOx -reduction technologies for MWCs are limited as these units use a heterogeneous, wet fuel; are less thermally efficient than fossil fuel - fired boilers of comparable heat input; and require larger amounts of excess air and less densely -packed heat rec overy systems. Low -NOx burners, fuel switching and load curtailment are not possible control options.

1 Assumes 100% rule effectiveness, which is reasona ble given that the MW Cs are operated with continuous emissions monitoring.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 37

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 re moving NOx from flue gas. In the SNCR process, a reagent, typically liquid urea or anhydrous gaseous ammonia is injected within a boiler or in ducts in a region where the temperature is between 900 and 1100 degrees Celsius. The reaction converts NOx to nitrogen gas and water vapor. SNCR performance depends on factors specific to each type of combustion equipment, including flue gas temperature, residence time for the reagent and flue gas, amount of reagent injected, reagent distribution, uncontrolled NOx level and carbon monoxide and oxygen concentrations. Some disadvantages arise from the use of SNCR including: the high operating temperatures required; ineffectiveness at high temperatures with low concentrations of NOx; the need to accommodate enough residence time to complete the chemical reaction at high temperatures; and undesirable excess ammonia and urea emissions ("ammonia slip") that arise from an incomplete chemical reaction (Thermal Energy International, 2000). All of Connecticut's large MWC units are equipped with SNCR, including nine mass burn/waterwall units and three refuse - derived fuel units. Two tire - fired units subject to the state MWC rule also operate with SNCR. 3 Similarly, all of New Jersey's large MWC units are equipped with SC R to meet NOx emissions limitations based on the federal emissions guidelines. Cost The capital cost of installing SNCR on a MWC unit is approximately $1,500 MMBtu/hr (see, e.g., Institute of Clean Air Companies, 2000). 4 Most of the cost of using SNCR is in operating expenses (Institute of Clean Air Companies, 2000), which EPA estimates as falling between 680 and 1,200 $/MMBtu (1993 dollars). Thus, SNCR is well suited for seasonal control in that it may provide significant reductions in NOx emissions but incurs little cost when the system is not in use. EPA has assigned an ozone season cost effectiveness to SNCR operated on MWC units of $2,140 per ton of NOx reduced (1990 dollars)(EPA, 1999, Table 16). Emissions reductions In Connecticut, MWC facility owners report emissions reductions of 25 to 50% from the operation of SNCR; a typical reduction of 35 - 40% could be assumed from the installation and operation of SNCR/ammonia injection to MWC units of similar size and type. Other combustors of varying tec hnologies and capacities but with similar baseline NOx emissions have reported reductions ranging from 35 - 75% from the operation of urea -based SNCR (Appendix 1, Institute of Clean Air Companies, 2000). EPA assigns a typical 45% emission reduction to the effectiveness of SNCR at MWCs (EPA, 1999, Table 16).

2 The use of SCR to control NOx emissions from M WC s in North American is limited to very few units (see, e.g., http://www.region.peel.on.ca/pw/waste/facilities/algonquin - power.htm ) because the nature of mu nicipal solid waste requires huge SCR reactor sizes and significant actions to prevent catalyst poisoning. These factors, combined with the rela tively small size of most M WC s, makes the use of SCR prohibitively expensive (EPA 2005, comment by I WS A). 3 Connecticut also has three mass burn refractory units that are classified as small M WC s and do not use SNCR. 4 For comparison, EPA places the c apital cost of SNCR between 1,600 and 3,300 $/MMBtu (1993 dollars). In 2002, the 3 - unit facility (140 MMBTU/hr per unit) owned by the Connecticut Resources Recovery Authority in Bridgeport, Connecticut installed SNCR on all three units at a capital cost o f $2.1 mi llion.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 38

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 Internatio nal 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 IWS A. 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.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 39

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FO R 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 u sed 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: 2 009 Reduction: 2009 Remaining: VOC Point Actual 2002: 2009 Reduction: 2009 Remaining: 5,501

- 121 5,380 31,738

- 0 31,738 Candidate measure: Adopt the requirements of SCAQMD rule 1130 and 1130.1 Emission Reductions : Under evaluation Control Cost : Under evaluation Timing of Implementation : Assuming 2007 or 2008 effective date of rule, emission reductions in 2009 or 2010 Implementation Area : OTR VOC OTB 2009: BOTW 2009: Reduction from BOTW: Under

review Candidate measure: Same option as CM1, except potentially require that publication, packaging and product rotogravure and wide web flexo printers that are equipped with capture and control equipment, meet the capture and control efficiency requirement in the MACT standard for VOC reductions (this would apply to facilities not major for HAPs). Implementation Area: OT R 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: OT R Under Review Policy Recommendation: 

### Final recommendation not made as of June, 2006. Brief Rationale for Recommended Strategy:TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 40

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR Portable Fuel Containers Control Measur e 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 e quipment and vehicles. PFCs are used to refuel a broad range of small off -road engines and other equipment (e.g., lawnmowers, chainsaws, personal watercraft, motorcycles, etc.). VOC Emissions in Ozone Transport Region

2002 Existing Measure: None 2002 Annual: 2002 Summer: 99,919 tpy

315.3 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 pl ace based on the assumed 10 - yr turnover of the sale of the cans, and Total control = 65% when fully implemented after 10 years. Control Cost : $581 per ton Timing of Implementation : State specific with a 10% per year turnover, full reductions are achieved after 10 years. CARB, and the EPA, have estimated a 5 year turnover for the cans, but the OTC used a more conservative 10 year turnover in calculating emission reductions. Implementation Area : OTR Annual: 2009 Reduction: 2009 Remaining: Summer: 2009 Reduction: 2009 Remaining: 33,055 tpy

66,864 tpy 107.1 tpd 208.2 tpd 2009 On - the -Way Measure: Proposed Federal HAP Mobile Source Reg (Feb 28, 2006) Rule

– This rule proposes to regulate PFCs similar to CARBs 2006 rule amendments and will regulate permeability to 0.3 grams of HC per gallon per day (2001 OTC Model Rule has 0.4 grams per gallon per day). It does not contain CARBs amendments regarding kerosene containers and utility jugs. Emission Reductions : EPA estimates about a 9% reduction nationwi de 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

66,864 tpy negligible 208.2 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 ma ke 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 p er ton reduced Timing of Implementation : State specific with a 10% per year turnover, full reductions are achieved after 10 years Implementation Area: OT R Annual: 2009 Base: 2009 Reduction: 2009 Remaining: Summer: 2009 Base: 2009 Reduction: 2009 Remaining: 66,864 tpy

4,152 tpy 62,712 tpy 208.2 tpd 12.8 tpd 195.4 tpdTSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 41

MACTEC Federal Programs, Inc. Summary of Candidate Measure: The California Air Resources Board (CARB) 2000 PFC regulation establishes design and manufacturing specifications for PFCs. PFC emissions are calculated by accounting for emissions from five different components related to gas container use: permeation, diurnal, transport - spillage, refueling spillage and refueling vapor displacement emissions. The permeation, diurnal emissions (associated with storage) and transport - spillage emissions are included in the area source inventory. The equipment refueling spillage and refueling vapor displacement emissions are calculated from the non -road model and are included in the non road inventory. After four years of imp lementation 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 pri ce of kerosene cans could rise to as much as $8.50 per container once the regulations are implemented. CARB also estimates the cost - effectiveness to be between $0.40 to $0.70 per pound. Recommended Strategy: CARB, through their comprehensive history o f research and multiple product surveys, have the best technical data available to create rules to regulate portable fuel containers. Most portable fuel container manufacturers market their products nationally, therefore many will be selling the new products nationally after they have produced cans than conform with the CARB rules. The CARB rule contains some revisions to their original rule to ease consumer acceptance of the cans, for states that have adopted the original OTC model rule. In addition the CARB rule amendments regulate kerosene cans and utility jugs, which the Federal rule proposal does not. References: 2009 On - the - Books Measure (OTC Model Rule): E.H. Pechan & Associates, Inc., Control Measure Development Support Analysis of Ozone Transport Commission Model Rules , March 31, 2001. Much of the analysis in this report was based on CARB’s analysis for CARB’s original 1999 PFC rule , which estimated a 75% reduction that would be fully achieved after 5 years (CARB’s assumed life cycle for PF Cs). The OTC used a more conservative 10 - year turnover rate in its analysis. Table II - 5 of the Pechan report shows the cost of compliance to be $581/ton.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 42

MACTEC Federal Programs, Inc. 2009 On - the -Way Measure (Proposed 2/28/06 Federal Rule): U.S. EPA Office of Transportation and Air Quality. Estimating Emissions Associated with Portable Fuel Containers (PFCs), Draft Report, EPA420 - D - 06 - 003, February 2006. U.S. EPA Office of Transportation and Air Quality. Draft Regulatory Impact Analysis: Control of Hazardous Air Pollutants from Mobile Sources , EPA420 - D - 06 - 004, February 2006. Candidate Measure (CARB 2006 Amendments): California Air Resources Board. Final Statement of Reasons for Rulemaking, Including Summary of Comments and Agency Response: PUBLIC HEARING TO CONSIDER AMENDM ENTS 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 - effectiven ess of the proposed amendments to be $0.40 to $0.70 per pound ($800 to $1,400 per ton)TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix C

– Control Measure Worksheets Page C - 43

MACTEC Federal Programs, Inc. CONTROL MEASURE SUMMARY FOR

Regional Fuel Control Measure Summary: The OTR proposes a common fuel standard for the OTR states that does not require MTBE or Ethanol, but exhibits Environmentally Beneficial Combustion Properties. NOx Emissions (tons/summer day) in OTR 2002 existing measure: Federal program in the CAA requiring RFG in certain non - attainment areas and allowing other states with non - attainment areas to opt - in. All but two states in the OTR are participating, in whole or in part, with the federal program, however nearly 1/3 of the gasoline sold in the OTR is not RFG. Candidate measure: Measure ID: OT R-wide Regional Fuel Emission Reductions : Control Cost : unknown at this time Timing of Implementation : Implementation Area : All states in the OTR NOx VOC ~ 4.8 tpsd

~ 139.4 tpsd Policy Recommendation: Continue to examine the potential for a regional fuel, keeping in mind that some states like PA may have statutory/legislative constraints. Brief Rationale for Recommended Strategy: The Energy Policy Act of 2005 provides the opportunity for the OTR to achieve a single clean burning gasoline without MTBE, as it also eliminates the oxygen content requirement for RFG. The authority provided in Energy Act is consistent with what states promoted through the long debate over MTBE/ethanol/RFG. Approximately one -third of the gasoline currently sold in the OTR is not RFG; most is conventional gasoline. The new authority plus the potential for emission reductions from the amount of non - RFG sold in the OTR provides an opportunity for additional emission reductions in the region as well as for a reduced number of fuels, and possibly a single f

uel, to be utilized throughout the region.TSD for OTC Control Measure Evaluation February 28, 2007

Appendix D

– VOC Emissions by County for 2002 and 2009 Page D - 1

MACTEC Federal Programs, Inc. 

## Appendix D – VOC Emissions by County for 2002 and 2009 Table D - 1 Adhesives and Sealants VOC Area Source Emission Summary for 2002 and 2009 by County Table D - 2 Adhesives and Sealants VOC Point Source Emission Summary for 2002 and 2009 by County Table D - 3 Cutback and Emulsified Asphalt Paving VOC Area Source Emission Summary for 2002 and 2009 b y C ounty 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 Table D - 6 Portable Fuel Containers VOC Nonroad Source Emission Summary for 2002 and 2009 by State Table D - 7 Reformulated Gasoline Emission Summary by State Due to their larg e size, these tables are being transmitted electronicall y in the spreadsheet named Appendix_D_VOC_2009.xls. There are separate tabs for each of the tables listed above.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix E

– N

Ox Emissions by County for 2002 and 2009 Page E- 1

MACTEC Federal Programs, Inc. 

## Appendix E – NOx Emissions by County for 2002 and 2009 Table E - 1 Reformulated Ga soline Emission Summary by State Table E - 2 Chip Reflash Emission Summary by State Table E - 3 Asphalt Production Plant NOx Emission Summary for 2002 and 2009 by County Table E - 4 Cement Kiln NOx Emission Summary for 2002 and 2009 by County Table E - 5 Glass and Fiberglass Furnace NOx Emission Summary for 2002 and 2009 by County Table E - 6 ICI Boiler NOx Area Source Emission Summary for 2002 and 2009 by State Table E - 7 ICI Boiler NOx Point Source Emission Summary for 2002 and 2009 by State Due to their large size, these tables are being transmitted electronically in the spreadsheet named Appendix_E_NOx_2009.xls. There are separate tabs for each of the tables listed above.TSD for 2006 OTC Control Measure Evaluation February 28, 2007

Appendix F

– State ICI Boiler Regulations Page G- 1

MACTEC Federal Programs, Inc. 

## Appendix F – State ICI Boiler Regulations Due to their large size, these tables are bein g transmitted electronicall y 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