Guidance
for
Growth
Factors,
Projections,
and
Control
Strategies
for
the
15
Percent
Rate­
of­
Progress
Plans
Ozone/
Carbon
Monoxide
Programs
Branch
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
NC
27711
ADDENDUM
TO
"
GUIDANCE
FOR
GROWTH
FACTORS,
PROJECTIONS,
AND
CONTROL
STRATEGIES
FOR
THE
15
PERCENT
RATE­
OF­
PROGRESS
PLANS"

The
purpose
of
this
addendum
is
to
provide
information
on
the
status
of
issues
that
have
been
raised
regarding
the
15
percent
rate­
of­
progress
plans.
These
issues
are
divided
into
three
categories:
clarification
of
resolved
issues,
status
of
previously
identified
issues,
and
identification
of
new
issues.

Clarification
of
Resolved
Issues
Inspection/
Maintenance
(
I/
M)

Section
4.2
of
the
document
titled
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plans,
EPA­
452/
R­
92­
005,
discussed
the
credit
that
can
be
allowed
for
improvements
to
I/
M
programs.
As
indicated
in
that
discussion,
credit
can
be
allowed
for
improvements
in
I/
M
programs
that
go
beyond
EPA's
basic
I/
M
requirements
or
the
program
that
was
approved
in
the
SIP
at
the
time
of
enactment,
whichever
is
more
stringent.
Therefore,
States
can
not
get
credit
for
bringing
an
I/
M
program
up
to
the
basic
I/
M
standards,
even
where
EPA
never
issued
a
pre­
enactment
SIP
call
to
correct
the
I/
M
program
and
where
the
I/
M
program
had
been
approved
in
the
SIP.
This
interpretation
is
based
on
the
language
in
sections
182(
b)(
1)(
D)(
iv)
and
182(
a)(
2)(
B)(
i)
of
the
Act.

Reid
Vapor
Pressure
(
RVP)

Several
questions
have
been
raised
concerning
what
RVP
States
should
use
in
developing
the
15
percent
plan,
particularly
for
areas
that
had
an
actual
RVP
less
than
9.0
psi
in
1990.
The
reductions
that
must
be
subtracted
from
the
"
rate­
of­
progress
base
year
inventory"
are
calculated
exactly
as
discussed
in
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plans,
page
13.
This
means
that
in
determining
the
reductions
that
would
be
achieved
by
the
FMVCP
and
RVP
requirements,
all
areas,
including
areas
that
had
an
actual
RVP
less
than
9.0
psi
in
1990,
should
use
the
actual
RVP
for
the
1990
case
and
the
allowable
RVP
(
9.0
or
7.8
psi)
for
the
MOBILE5.0
run
that
will
be
used
to
calculate
the
1990
adjusted
base
year
inventory.
Although
this
might
at
first
appear
to
result
in
a
target
that
is
more
difficult
to
meet,
in
reality
it
does
not.
The
reductions
that
are
subtracted
to
get
the
adjusted
base
year
inventory
are
later
added
to
other
reductions
to
get
the
total
required
reductions.
The
effect
of
subtracting
a
smaller
number
from
the
rate­
ofprogress
inventory
is
compensated
by
adding
a
smaller
number
to
the
total
reductions.
iv
Nonroad
Mobile
Source
Emissions
Factors
A
number
of
States
have
questioned
the
accuracy
of
the
nonroad
mobile
source
emissions
factors
and
emissions
provided
by
the
Office
of
Mobile
Sources
(
OMS).
Although
the
factors
are
higher
than
previous
estimates,
OMS
believes
that
they
are
more
accurate.
They
have
indicated
that
they
are
willing
to
work
with
any
State
that
has
identified
problems
regarding
activity
factors
related
to
distribution
and/
or
usage
of
equipment.

Status
of
Previously
Identified
Issues
Waivers
Issue:
What
does
"
all
measures
that
can
feasibly
be
implemented...
in
light
of
technological
achievability"
include?
[
Section
182(
b)(
1)(
A)(
ii)(
III)]

Status:
One
interpretation
of
the
Act
is
that
"
all
measures
that
can
feasibly
be
implemented...
in
light
of
technological
achievability"
includes
only
those
measures
that
are
achieved
in
practice
in
nonattainment
areas
of
the
next
higher
classification.
The
EPA
is
still
considering
whether
this
is
the
preferred
interpretation.

Issue:
If
a
State
is
granted
a
waiver,
based
on
the
fact
that
it
has
submitted
a
plan
that
includes
all
measures
that
can
feasibly
be
implemented,
is
the
State
still
required
to
submit
contingency
measures?
If
so,
what
would
be
available
as
contingency
measures?

Status:
If
the
interpretation
above
is
used,
other
measures
such
as
those
achieved
in
areas
of
even
higher
classification
will
be
available
as
contingency
measures.
For
an
area
classified
as
severe,
there
would
be
no
measures
readily
identifiable
since
there
is
only
one
classification
above
severe,
although
these
areas
are
still
required
to
submit
contingency
measures.
If
a
more
stringent
interpretation
is
used,
EPA
will
have
to
consider
whether
it
is
reasonable
to
require
contingency
measures.

Issue:
In
determining
the
feasibility
of
I/
M
for
the
purposes
of
a
waiver,
can
a
State
consider
the
population
of
an
area?

Status:
This
issue
is
still
under
review
by
OMS.
v
RVP
Issue:
What
RVP
should
be
assumed
for
projecting
1996
emissions?

Status:
This
issue
is
under
review
by
OMS.
They
are
evaluating
whether
there
is
justification
for
allowing
States
to
assume
that
actual
emissions
are
expected
to
be
less
than
future
allowable
emissions.

Federal
Measures
Issue:
Will
EPA
approve
15
percent
plans
that
are
based
on
commitments
to
adopt
new
CTG
RACT
rules
and/
or
forthcoming
national
rules
(
e.
g.,
auto
refinishing)?

Status:
The
EPA
will
be
providing
guidance
to
the
States
concerning
the
credit
that
can
be
allowed
from
these
programs.

Vehicle
Miles
Traveled
(
VMT)
Growth
Projections
Issue:
Can
States
use
more
recent
estimates
or
actual
VMT
growth
rates
where
available?

Status:
The
OMS
has
indicated
that
areas
may
be
able
to
show
that
regionally­
specific
factors
may
be
more
appropriate
in
some
circumstances,
and
plans
to
provide
clarification
of
this
issue.

Nonroad
Mobile
Sources
Issue:
How
much
credit
can
be
allowed
for
the
use
of
reformulated
gasoline
in
nonroad
engines?

Status:
The
OMS
plans
to
provide
guidance
to
the
States
on
how
to
determine
credit
for
use
of
reformulated
gasoline
in
nonroad
sources.

Issue:
How
should
States
project
emissions
from
nonroad
mobile
sources
into
the
future?

Status:
The
OMS
plans
to
issue
guidance
on
projections
for
nonroad
mobile
sources.

New
Issues
The
following
issues
have
recently
been
raised
to
EPA
and
we
are
trying
to
resolve
these
as
soon
as
possible:

!
To
what
extent
will
EPA
accept
committal
SIP's
for
the
measures
necessary
to
achieve
the
15
percent
reduction?
vi
!
Will
EPA
accept
committal
SIP's
for
the
contingency
measures?

!
Can
the
contingency
measures
be
for
NO
x
as
well
as
(
or
instead
of)
VOC?
vii
CONTENTS
Page
ADDENDUM
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
iii
LIST
OF
FIGURES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
x
LIST
OF
TABLES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
x
ABBREVIATIONS
AND
ACRONYMS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
xi
EXECUTIVE
SUMMARY
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1.0
INTRODUCTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
1.1
Purpose
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
1.2
Background
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8
2.0
GENERAL
ASPECTS
OF
EMISSIONS
PROJECTIONS
.
.
.
.
.
.
.
.
13
2.1
Use
of
Emissions
Projections
.
.
.
.
.
.
.
.
.
.
.
13
2.2
Rate­
of­
Progress
Emissions
Projections
.
.
.
.
.
.
13
2.3
Emissions
Factor
Adjustments
.
.
.
.
.
.
.
.
.
.
.
13
2.4
Actual
and
Allowable
Emissions
.
.
.
.
.
.
.
.
.
.
14
2.5
Effect
of
Rule
Penetration
and
Rule
Effectiveness
.
17
3.0
ECONOMIC
ACTIVITY
AND
GROWTH
.
.
.
.
.
.
.
.
.
.
.
.
.
.
19
4.0
GROWTH
PROJECTIONS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
21
4.1
Growth
and
Retirement
Relationships
.
.
.
.
.
.
.
.
21
4.2
Emissions
Preprocessor
System
(
EPS)
.
.
.
.
.
.
.
.
22
4.3
Economic
Growth
Analysis
System
(
E­
GAS)
.
.
.
.
.
.
22
5.0
CONTROL
STRATEGIES
FOR
VOC's
.
.
.
.
.
.
.
.
.
.
.
.
.
.
25
5.1
Stationary
Source
Controls
.
.
.
.
.
.
.
.
.
.
.
.
25
Add­
on
VOC
Controls
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
25
Process
Modifications
and
Substitution
.
.
.
.
.
.
26
5.2
Motor
Vehicles
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
27
Federal
Motor
Vehicle
Control
Program
(
FMVCP)
.
.
.
27
RVP
Limits
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
27
Stage
II
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
28
Clean
Fuel
Fleet
Program
.
.
.
.
.
.
.
.
.
.
.
.
.
30
Reformulated
Gasoline
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
31
Inspection
and
Maintenance
.
.
.
.
.
.
.
.
.
.
.
.
31
On­
Board
Diagnostic
Systems
.
.
.
.
.
.
.
.
.
.
.
.
31
Transportation
Control
Measures
(
TCM's)
.
.
.
.
.
.
31
5.3
Other
Mobile
Sources
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
33
5.4
Control
Strategy
Documentation
for
Stationary
Sources
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
33
Group
I
CTG
Documents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
35
Group
II
CTG
Documents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
36
Group
III
CTG
Documents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
37
Model
RACT
Rules
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
37
viii
New
CTG
Documents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
38
Non­
CTG
RACT
Rules
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
40
ACT
Documents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
40
New
Source
Performance
Standards
.
.
.
.
.
.
.
.
.
41
Section
112
Standards
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
42
Other
Federal
Control
Measures
.
.
.
.
.
.
.
.
.
.
43
5.5
Rule
Effectiveness
Improvements
.
.
.
.
.
.
.
.
.
.
44
Agency
Compliance
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
45
Source
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
46
Improvements
in
Technology
.
.
.
.
.
.
.
.
.
.
.
.
46
Education
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
46
Rules
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
46
5.6
Quantification
of
Rule
Effectiveness
Improvement
Programs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
46
6.0
CONTROL
STRATEGY
DEVELOPMENT
PROJECTIONS
.
.
.
.
.
.
.
.
49
6.1
Introduction
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
49
6.2
Purpose
and
Elements
of
Emissions
Projections
.
.
.
50
6.3
Types
of
Emissions
Projections
.
.
.
.
.
.
.
.
.
.
51
6.4
Methods
for
Calculating
Point,
Area,
and
Mobile
Source
1996
Projection
Year
Emissions
.
.
.
.
.
.
.
51
Point
Source
Emissions
Projections
.
.
.
.
.
.
.
.
52
Area
Source
Emissions
Projections
.
.
.
.
.
.
.
.
.
66
Mobile
Source
Emissions
Projections
.
.
.
.
.
.
.
.
69
Emissions
Preprocessor
System
(
EPS)
.
.
.
.
.
.
.
.
70
6.5
Effects
of
Equipment
Replacement
and
New
Source
Requirements
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
72
6.6
Submitting
Projection
Year
Inventories
and
Supporting
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
73
7.0
CONTROL
STRATEGIES
FOR
NO
x
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
75
7.1
Stationary
Source
Controls
.
.
.
.
.
.
.
.
.
.
.
.
75
7.2
Area
Source
Controls
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
76
7.3
Mobile
Source
Controls
.
.
.
.
.
.
.
.
.
.
.
.
.
.
76
8.0
ATTAINMENT
DEMONSTRATION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
77
8.1
Requirements
for
Moderate
and
Above
Nonattainment
Areas
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
77
8.2
Requirements
for
Serious
and
Above
Nonattainment
Areas
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
78
8.3
Modeling
Considerations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
78
Empirical
Kinetic
Modeling
Analysis
(
EKMA)
.
.
.
.
78
Urban
Airshed
Model
(
UAM)
.
.
.
.
.
.
.
.
.
.
.
.
.
78
8.4
Special
Air
Quality
Situations
.
.
.
.
.
.
.
.
.
.
78
Areas
Requiring
Emissions
Reductions
in
Excess
of
15
Percent
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
78
Areas
Requiring
Emissions
Reductions
Less
Than
15
Percent
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
79
Rural
Nonattainment
Areas
.
.
.
.
.
.
.
.
.
.
.
.
.
79
Multi­
State
Nonattainment
Areas
.
.
.
.
.
.
.
.
.
.
79
International
Border
Areas
.
.
.
.
.
.
.
.
.
.
.
.
80
ix
9.0
CONTINGENCY
MEASURES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
81
9.1
Marginal
Areas
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
81
9.2
Moderate
and
Above
Areas
.
.
.
.
.
.
.
.
.
.
.
.
.
82
9.3
Serious
and
Severe
Areas
.
.
.
.
.
.
.
.
.
.
.
.
.
85
9.4
Nonclassifiable
Areas
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
86
9.5
Examples
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
87
REFERENCES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
89
APPENDIX
A:
DEFINITION
OF
TERMS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
A­
1
APPENDIX
B:
REFERENCES
FOR
CTG
AND
ACT
DOCUMENTS
FOR
STATIONARY
VOC
SOURCES
.
.
.
.
.
.
.
.
.
.
.
.
.
B­
1
APPENDIX
C:
BACKGROUND
INFORMATION
DOCUMENTS
FOR
STATIONARY
VOC
SOURCES
SUBJECT
TO
NEW
SOURCE
PERFORMANCE
STANDARDS
(
NSPS)
AND
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
(
NESHAP)
C­
1
APPENDIX
D:
CONTROL
MEASURES
FROM
THE
AIR
QUALITY
MANAGEMENT
PLAN
FOR
THE
SOUTH
COAST
AIR
QUALITY
MANAGEMENT
DISTRICT
OF
CALIFORNIA
.
.
.
.
.
.
.
D­
1
APPENDIX
E:
CURRENT
ACT
DOCUMENTS
AND
OTHER
FEDERAL
CONTROL
MEASURES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
E­
1
APPENDIX
F:
PROCEDURES
FOR
CALCULATING
THE
1996
TARGET
LEVEL
OF
EMISSIONS
AND
DISCUSSION
OF
CONTROL
STRATEGY
DEVELOPMENT
.
.
.
.
.
.
.
.
.
.
.
.
.
.
F­
1
APPENDIX
G:
CHECKLISTS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
G­
1
APPENDIX
H:
MILESTONE
AND
ATTAINMENT
FAILURES
FOR
MARGINAL
AND
MODERATE
OZONE
NONATTAINMENT
AREAS
.
.
.
.
.
H­
1
APPENDIX
I:
MODEL
MULTI­
STATE
LETTER
.
.
.
.
.
.
.
.
.
.
.
.
I­
1
APPENDIX
J:
ALTERNATIVE
CONTROL
TECHNIQUE
(
ACT)
DOCUMENTS,
NEW
SOURCE
PERFORMANCE
STANDARDS
(
NSPS),
AND
TWO
SCAQMD
AREA
SOURCE
RULES
FOR
CONTROLLING
NITROGEN
OXIDE
(
NO
x)
EMISSIONS
.
.
.
.
.
.
.
.
.
J­
1
x
LIST
OF
FIGURES
Number
Page
Figure
1.
Flowchart
for
rate­
of­
progress
calculations.
.
.
9
Figure
2.
Flowchart
for
a
moderate
ozone
nonattainment
area
attainment
demonstration.
.
.
.
.
.
.
.
.
.
11
Figure
F­
1.
Flowchart
for
example
rate­
of­
progress
calculations.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
F­
2
Figure
H­
1.
Marginal
area
attainment
process
flowchart.
.
.
H­
1
Figure
H­
2.
Moderate
area
attainment
process
flowchart.
.
.
H­
2
LIST
OF
TABLES
Number
Page
A­
1.
MAJOR
SOURCE
THRESHOLDS
AND
MINIMUM
EMISSIONS
OFFSET
RATIO
REQUIREMENTS
FOR
OZONE
NONATTAINMENT
AREA
CLASSIFICATIONS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
A­
3
F­
1:
SUGGESTED
FORMAT
FOR
15
PERCENT
RATE­
OF­
PROGRESS
CONTROL
STRATEGY
SUMMARY
SUBMITTAL
.
.
.
.
.
.
.
.
.
.
F­
12
F­
2:
SUGGESTED
FORMAT
FOR
ATTAINMENT
CONTROL
STRATEGY
SUMMARY
SUBMITTAL
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
F­
13
F­
3:
SUGGESTED
FORMAT
FOR
CONTINGENCY
MEASURE
SUBMITTAL
.
.
F­
15
F­
4:
SUMMARY
OF
EMISSIONS
REDUCTIONS
FOR
THE
15
PERCENT
RATE­
OF­
PROGRESS
PLAN
AND
THE
ATTAINMENT
DEMONSTRATION
F­
16
F­
5:
SUGGESTED
FORMAT
FOR
SUBMITTAL
OF
RULE
EFFECTIVENESS
(
RE)
IMPROVEMENT
MEASURES
.
.
.
.
.
.
.
F­
17
F­
6:
SUGGESTED
FORMAT
FOR
SUBMITTAL
OF
STATIONARY
SOURCE
CONTROL
MEASURES
FOR
THE
15
PERCENT
RATE­
OF­
PROGRESS
PLAN
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
F­
17
F­
7:
SUGGESTED
FORMAT
FOR
SUBMITTAL
OF
STATIONARY
SOURCE
CONTROL
MEASURES
FOR
THE
ATTAINMENT
DEMONSTRATION
.
.
F­
17
F­
8:
SERIOUS
NONATTAINMENT
AREA
EXAMPLE
FOR
15
PERCENT
RATEOF
PROGRESS
CONTROL
STRATEGY
SUMMARY
SUBMITTAL
.
.
.
.
F­
24
F­
9:
SUGGESTED
FORMAT
FOR
CONTINGENCY
MEASURE
SUBMITTAL
.
.
F­
25
xi
ABBREVIATIONS
AND
ACRONYMS
Act
Clean
Air
Act
ACT
Alternative
Control
Technique
AFS
AIRS
Facility
Subsystem
AFUE
Annual
Fuel
Utilization
Efficiency
AIRS
Aerometric
Information
Retrieval
System
AMS
Area
and
Mobile
Source
Subsystem
ANSI
American
National
Standards
Institute
ASTM
American
Society
for
Testing
and
Materials
APCD
Air
Pollution
Control
District
AQMD
Air
Quality
Management
District
ASC
Area
Source
Category
Code
ATM
Atmosphere
BACT
Best
Available
Control
Technology
BEA
Bureau
of
Economic
Analysis
BID
Background
Information
Document
BTU
British
Thermal
Units
CAAA
1990
Clean
Air
Act
Amendments
CFR
Code
of
Federal
Regulations
CO
Carbon
monoxide
CTC
Control
Technology
Center
CTG
Control
Technique
Guidelines
Cu.
Ft.
Cubic
Foot
DOE
Department
of
Energy
DOT
Department
of
Transportation
E­
GAS
Economic
Growth
Analysis
System
EKMA
Empirical
Kinetic
Modeling
Analysis
EPA
U.
S.
Environmental
Protection
Agency
EPS
Emissions
Preprocessor
System
FIP
Federal
Implementation
Plan
FMVCP
Federal
Motor
Vehicle
Control
Program
GACT
Generally
Available
Control
Technology
gal
Gallon(
s)
HAP
Hazardous
Air
Pollutant
HON
Hazardous
Organic
NESHAP
I/
M
Inspection
and
Maintenance
in.
hg
Inches
of
Mercury
IRS
Internal
Revenue
Service
LADCO
Lake
Michigan
Air
Directors
Consortium
LAER
Lowest
Achievable
Emissions
Rate
lb
Pound(
s)
lb/
day
Pounds
per
day
lb/
hr
Pounds
per
hour
LDT
Light­
duty
trucks
LDV
Light­
duty
vehicles
LEV
Low­
emission
vehicle
MACT
Maximum
Achievable
Control
Technology
NAAQS
National
Ambient
Air
Quality
Standard
NESCAUM
Northeast
States
for
Coordinated
Air
Use
Management
xii
NESHAP
National
Emission
Standard
for
Hazardous
Air
Pollutants
NO
x
Oxides
of
nitrogen
NSPS
New
Source
Performance
Standard
NSR
New
Source
Review
NTIS
National
Technical
Information
Service
OAQPS
Office
of
Air
Quality
Planning
and
Standards
of
EPA
ppm
Parts
per
million
psi
Pounds
per
square
inch
RACT
Reasonably
Available
Control
Technology
RCRA
Resource
Conservation
and
Recovery
Act
RE
Rule
Effectiveness
RFP
Reasonable
Further
Progress
rpm
Revolutions
per
minute
RVP
Reid
Vapor
Pressure
SAS
Statistical
Analysis
System
SCAQMD
South
Coast
Air
Quality
Management
District
SIC
Standard
Industrial
Classification
SIP
State
Implementation
Plan
SOCMI
Synthetic
Organic
Chemicals
Manufacturing
Industry
SSCD
Stationary
Source
Compliance
Division
of
EPA's
Office
of
Air
Quality
Planning
and
Standards
TCM
Transportation
Control
Measures
tpy
Tons
per
year
TSDF
Hazardous
Waste
Treatment,
Storage,
and
Disposal
Facility
UAM
Urban
Airshed
Model
VMT
Vehicle
Miles
Traveled
VOC
Volatile
Organic
Compound
1
EXECUTIVE
SUMMARY
Section
182(
b)(
1)
of
the
Clean
Air
Act
(
Act)
requires
all
ozone
nonattainment
areas
classified
as
moderate
and
above
to
submit
a
State
implementation
plan
(
SIP)
revision
by
November
15,
1993,
which
describes,
in
part,
how
the
areas
will
achieve
an
actual
volatile
organic
compound
(
VOC)
emissions
reduction
of
at
least
15
percent
during
the
first
6
years
after
enactment
of
the
Clean
Air
Act
Amendments
of
1990
(
CAAA)
(
i.
e.,
up
to
November
15,
1996).
In
addition,
the
SIP
revision
must
describe
how
any
growth
in
emissions
from
1990
through
1996
will
be
fully
offset.
The
portion
of
the
SIP
revision
that
illustrates
the
plan
for
the
achievement
of
these
emissions
reductions
is
subsequently
defined
in
this
document
as
the
"
rate­
of­
progress
plan."

It
is
important
to
note
that
section
182(
b)(
1)
also
requires
the
SIP
for
moderate
areas
to
provide
for
reductions
in
VOC
and
nitrogen
oxides
(
NO
x)
emissions
"
as
necessary
to
attain
the
national
primary
ambient
air
quality
standard
for
ozone"
by
November
15,
1996.
This
requirement
can
be
met
through
the
use
of
EPA­
approved
modeling
techniques
and
the
adoption
of
any
additional
control
measures
beyond
those
needed
to
meet
the
15
percent
emissions
reduction
requirements.
States
with
intrastate
moderate
ozone
nonattainment
areas
will
generally
be
required
to
submit
attainment
demonstrations
with
their
SIP
revisions
due
by
November
15,
1993
[
such
areas
choosing
to
use
the
Urban
Airshed
Model
(
UAM)
to
prepare
their
attainment
demonstrations
will
be
allowed
to
submit
attainment
demonstrations
by
November
15,
1994].
States
choosing
to
run
UAM
for
their
intrastate
moderate
areas
must
submit
by
November
15,
1993,
their
rate­
of­
progress
plan
and
a
committal
SIP
addressing
the
attainment
demonstration.
The
committal
SIP
subject
to
a
section
110(
k)(
4)
approval
would
include,
at
a
minimum,
evidence
that
grid
modeling
is
well
under
way
and
a
commitment,
with
schedule,
to
complete
the
modeling
and
submit
it
as
a
SIP
revision
by
November
1994.
The
completed
attainment
demonstration
would
include
any
additional
controls
needed
for
attainment.

This
guidance
document
focuses
on
the
procedures
for
developing
1996
projected
emissions
inventories
and
control
measures
which
moderate
and
above
ozone
nonattainment
areas
must
include
in
their
rate­
of­
progress
plans.
The
document
provides
technical
guidance
to
support
the
policy
presented
in
the
"
General
Preamble:
Implementation
of
Title
I
of
the
CAAA
of
1990"
(
57
FR
13498).
States
are
asked
to
submit
their
draft
1996
projected
emissions
inventories
and
control
measures
to
EPA
by
May
1993.
States
must
submit
their
fully
adopted
rate­
ofprogress
plans
to
EPA
by
November
1993.
Moderate
ozone
nonattainment
areas
not
using
UAM
must
include
an
attainment
demonstration
in
their
fully
adopted
rate­
of­
progress
plans.
2
This
document
provides
guidance
to
the
States
for
calculating
the
VOC
emissions
reductions
and
for
developing
the
control
measures
necessary
to
meet
the
15
percent
VOC
emissions
reduction
requirements,
net
of
growth,
by
November
1996.
Calculation
of
the
15
percent
VOC
emissions
reduction,
net
of
growth,
includes
the
calculation
of
the
following
three
components:

!
The
15
percent
VOC
emissions
reduction
from
the
1990
adjusted
base
year
emissions
inventory.

!
The
1996
target
level
of
emissions.

!
Emissions
reductions
needed
to
fully
offset
emissions
growth
from
1990
through
1996.

In
October
of
1992,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
issued
a
document
entitled
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plans.
(
See
reference
1.)
The
document
provides
detailed
guidance
for
calculating
the
15
percent
VOC
emissions
reduction
from
the
1990
adjusted
base
year
emissions
inventory,
and
the
1996
target
level
of
emissions.
The
guidance
provided
in
the
October
1992
document
should
be
reviewed
along
with
the
guidance
in
this
document
when
preparing
a
rate­
of­
progress
plan.

The
rate­
of­
progress
plan
must
account
for
the
effects
of
growth
experienced
in
a
nonattainment
area
from
1990
to
1996.
One
purpose
of
this
document
is
to
provide
guidance
on
the
use
of
equations
for
projecting
1990
base
year
emissions
to
1996.
The
document
describes
how
growth
factors,
emissions
reductions
associated
with
regulations,
rule
effectiveness
(
RE),
and
rule
penetration
should
be
used
in
the
equations.
Guidance
is
also
provided
for
determining
whether
projections
should
be
based
on
actual
versus
allowable
emissions.
The
information
sources
for
developing
growth
factors
or
indicators
that
could
be
used
as
part
of
the
preparation
of
the
1996
projected
emissions
inventories
are
also
discussed.
Several
examples
for
calculating
15
percent
VOC
emissions
reduction
requirements,
net
of
growth,
are
provided
for
different
ozone
nonattainment
area
classifications.

A
key
component
of
the
rate­
of­
progress
plan
is
the
control
measures
that
the
State
plans
to
adopt
and
implement
to
reduce
VOC
emissions
to
meet
the
15
percent
VOC
emissions
reduction
requirements,
net
of
growth,
by
November
1996.
One
of
the
purposes
of
this
document
is
to
provide
information
concerning
the
types
of
control
technologies
and
strategies
upon
which
control
measures
can
be
based
to
control
VOC
and
NO
x
emissions
from
point,
area,
and
mobile
sources.
This
document
summarizes
past
and
ongoing
work
by
EPA
in
preparing
Control
Technique
Guideline
(
CTG),
Alternative
Control
Technique
(
ACT),
and
3
background
information
documents
for
specific
industrial
sources
or
processes.
It
also
presents
information
on
existing
and
new
Federal
regulatory
programs
for
VOC
and
NO
x
sources.
The
broad
range
of
mobile
source
control
strategies,
from
vapor
recovery
to
transportation
control
measures
(
TCM's),
is
also
discussed.
A
sample
checklist
is
also
provided
to
aid
States
in
a
step­
bystep
review
of
their
rate­
of­
progress
plans
to
ensure
that
they
contain
all
of
the
necessary
components
required
for
approval
by
EPA.

This
document
also
discusses
the
requirements
for
an
attainment
demonstration
for
marginal
and
moderate
ozone
nonattainment
areas,
and
presents
the
models
involved
in
making
this
demonstration.
Furthermore,
this
document
presents
the
implications
of
attainment
and
milestone
failures
for
marginal
and
moderate
ozone
nonattainment
areas.
In
addition,
this
document
describes
the
requirements
for
contingency
measures
that
must
be
included
in
the
rate­
of­
progress
plans
for
moderate
and
above
ozone
nonattainment
areas,
and
provides
examples
of
possible
contingency
measures.
1The
EPA
recognizes
that
the
Act
terms,
for
both
the
15
percent
VOC
emissions
reduction
requirement
of
section
182(
b)(
1)
and
the
section
182(
c)(
2)(
B)
requirement
for
3
percent
per
year
VOC
emissions
reductions
averaged
over
each
consecutive
3­
year
period
from
November
15,
1996
until
the
attainment
date,
as
reasonable
further
progress
(
RFP)
requirements.
However,
because
the
Act
requires
SIP
revisions
for
the
15
percent
reduction
to
be
submitted
in
1993
and
SIP
revisions
for
the
3
percent
per
year
reductions
to
be
submitted
in
1994,
EPA
believes
that
it
would
be
clearer,
within
the
context
of
both
the
15
percent
rate­
ofprogress
plan
and
post­
1996
rate­
of­
progress
plan
guidance
documents
that
EPA
is
producing,
to
create
distinct
labels
for
these
two
seemingly
similar
reductions.
The
1994
SIP
revisions
describing
the
requirement
for
3
percent
VOC
emissions
reductions
averaged
over
each
consecutive
3­
year
period
from
November
15,
1996
until
the
attainment
date,
constitute
the
"
post­
1996
rateof
progress
plan."

5
1.0
INTRODUCTION
Section
182(
b)(
1)
of
the
Act
requires
all
ozone
nonattainment
areas
classified
as
moderate
and
above
to
submit
a
SIP
revision
by
November
15,
1993,
which
describes,
in
part,
how
the
areas
will
achieve
an
actual
VOC
emissions
reduction
of
at
least
15
percent
during
the
first
6
years
after
enactment
of
the
CAAA
(
i.
e.,
up
to
November
15,
1996).
In
addition,
the
SIP
must
describe
how
any
growth
in
emissions
from
1990
through
1996
will
be
fully
offset.
Emissions
and
emissions
reductions
shall
be
calculated
on
a
typical
weekday
basis
for
the
"
peak"
3­
month
ozone
period
(
generally
June
through
August).
The
15
percent
VOC
emissions
reduction,
net
of
growth,
required
by
November
15,
1996
is
defined
within
this
document
as
"
rate
of
progress."
1
Furthermore,
the
portion
of
the
SIP
revision
that
illustrates
the
plan
for
the
achievement
of
the
emissions
reductions
is
subsequently
defined
in
this
document
as
the
"
rate­
of­
progress
plan."

It
is
important
to
note
that
section
182(
b)(
1)
also
requires
the
SIP
for
moderate
areas
to
provide
for
reductions
in
VOC
and
NO
x
emissions
"
as
necessary
to
attain
the
national
primary
ambient
air
quality
standard
for
ozone"
by
November
15,
1996.
This
requirement
can
be
met
through
the
use
of
EPA­
approved
modeling
techniques
and
the
adoption
of
any
additional
control
measures
beyond
those
needed
to
meet
the
15
percent
emissions
reduction
requirements.
States
with
intrastate
moderate
ozone
nonattainment
areas
will
generally
be
required
to
submit
attainment
demonstrations
with
their
SIP
revisions
due
by
November
15,
1993
(
such
areas
choosing
to
use
UAM
to
prepare
their
attainment
demonstrations
will
be
allowed
to
submit
attainment
demonstrations
by
November
15,
1994).
States
choosing
to
run
UAM
for
their
intrastate
moderate
areas
must
submit
by
6
November
15,
1993,
their
rate­
of­
progress
plan
and
a
committal
SIP
addressing
the
attainment
demonstration.
The
committal
SIP
subject
to
a
section
110(
k)(
4)
approval
would
include,
at
a
minimum,
evidence
that
grid
modeling
is
well
under
way
and
a
commitment,
with
schedule,
to
complete
the
modeling
and
submit
it
as
a
SIP
revision
by
November
1994.
The
completed
attainment
demonstration
would
include
any
additional
controls
needed
for
attainment.

Section
182(
c)(
2)
requires
all
ozone
nonattainment
areas
classified
as
serious
and
above
to
submit
a
SIP
revision
by
November
15,
1994
which
describes,
in
part,
how
each
area
will
achieve
additional
VOC
emissions
reductions
of
3
percent
per
year
averaged
over
each
consecutive
3­
year
period
from
November
15,
1996
until
the
area's
attainment
date.
It
is
important
to
note
that
section
182(
c)(
2)(
C)
allows
for
actual
NO
x
emissions
reductions
(
exceeding
growth)
that
occur
after
the
base
year
of
1990
to
be
used
to
meet
post­
1996
emissions
reduction
requirements
for
ozone
nonattainment
areas
classified
as
serious
and
above,
provided
that
such
NO
x
reductions
meet
the
criteria
outlined
in
forthcoming
substitution
guidance.
The
portion
of
the
SIP
revision
(
due
in
1994)
that
illustrates
the
plan
for
the
achievement
of
these
post­
1996
reductions
in
VOC
or
NO
x
is
subsequently
defined
in
this
document
as
the
"
post­
1996
rate­
ofprogress
plan."
This
plan
must
also
contain
an
attainment
demonstration
based
on
photochemical
grid
modeling.
The
EPA
will
distribute
a
separate
guidance
document
on
the
development
of
the
post­
1996
rate­
of­
progress
plan
in
early
to
mid­
1993.

Demonstrating
achievement
of
the
15
percent
VOC
emissions
reductions
by
November
15,
1996,
and
then
subsequently
demonstrating
achievement
of
the
3
percent
per
year
VOC
emissions
reductions
averaged
over
each
consecutive
3­
year
period
from
November
15,
1996
until
the
attainment
date,
are
termed
milestone
demonstrations.
Achievement
of
the
milestones
must
be
demonstrated
within
90
days
of
the
milestone
date
(
e.
g.,
the
15
percent
VOC
emissions
reductions
must
be
demonstrated
by
February
13,
1997).
The
EPA
is
currently
developing
a
rule
which
will
describe
the
information
and
analysis
required
for
the
milestone
demonstrations.
The
rule
is
scheduled
for
promulgation
in
the
summer
of
1994.
The
rule
will
also
address
summary
data
needs,
detailed
reporting
requirements,
and
consequences
of
submitting
an
inadequate
demonstration
(
in
terms
of
documentation)
as
well
as
consequences
of
failure
to
demonstrate
the
15
percent
VOC
emissions
reduction
requirements,
net
of
growth.

Section
182(
a)(
3)(
A)
requires
the
States
to
submit
periodic
inventories
starting
3
years
after
submission
of
the
base
year
inventory
required
by
section
182(
a)(
1),
and
every
3
years
thereafter
until
the
area
is
redesignated
to
attainment.
The
EPA
recommends
that
States
synchronize
their
schedules
for
developing
7
the
periodic
inventories
so
that
the
second
periodic
inventory
(
which
would
be
due
no
later
than
November
15,
1998)
is
submitted
by
February
13,
1997
and
addresses
emissions
in
1996.
By
accelerating
preparation
and
submittal
of
the
1996
periodic
inventory,
the
milestone
demonstration
that
is
due
for
serious
and
above
areas
by
February
13,
1997
can
be
based
on
this
periodic
inventory.
If
similarly
accelerated,
future
periodic
inventories
would
then
also
coincide
with
subsequent
milestone
demonstrations.
The
periodic
inventory
is
to
be
based
on
actual
emissions
and
will
cover
VOC,
NO
x,
and
carbon
monoxide
(
CO)
emissions
sources.
Like
the
base
year
inventory,
the
periodic
inventory
is
to
be
determined
using
typical
peak
ozone
season
weekday
emissions.

1.1
Purpose
This
document
provides
guidance
on
the
procedures
for
developing
1996
projected
emissions
inventories
and
control
measures
which
moderate
and
above
ozone
nonattainment
areas
must
include
in
their
rate­
of­
progress
plans.
These
elements
of
the
rate­
of­
progress
plan
will
be
due
in
draft
form
to
EPA
by
May
15,
1993.
The
fully
adopted
rate­
of­
progress
plan
is
then
due
by
November
15,
1993.
The
information
provided
in
this
document
contains
references
to
additional
in­
depth
information.

The
rate­
of­
progress
plan
must
account
for
the
effects
of
growth
experienced
in
a
nonattainment
area
from
1990
to
1996.
One
purpose
of
this
document
is
to
provide
guidance
on
the
use
of
equations
for
projecting
1990
base
year
emissions
to
1996.
The
document
describes
how
growth
factors,
emissions
reductions
associated
with
regulations,
RE,
and
rule
penetration
should
be
used
in
the
equations.
Guidance
is
also
provided
for
determining
whether
projections
should
be
based
on
actual
versus
allowable
emissions.
The
information
sources
for
developing
growth
factors
or
indicators
that
could
be
used
as
part
of
the
preparation
of
the
1996
projected
emissions
inventories
are
also
discussed.

A
key
component
of
the
rate­
of­
progress
plan
(
due
to
EPA
by
November
15,
1993)
is
the
control
measures
that
the
State
plans
to
adopt
and
implement
to
reduce
VOC
emissions
to
meet
the
15
percent
VOC
emissions
reductions
requirements,
net
of
growth,
by
November
1996.
One
of
the
purposes
of
this
document
is
to
provide
information
concerning
the
types
of
control
technologies
and
strategies
upon
which
control
measures
can
be
based
to
control
VOC
and
NO
x
emissions
from
point,
area,
and
mobile
sources.
This
document
summarizes
past
and
ongoing
work
by
EPA
in
preparing
CTG,
ACT,
and
background
information
documents
for
specific
industrial
sources
or
processes.
It
also
presents
information
on
existing
and
new
Federal
regulatory
programs
for
VOC
and
NO
x
sources.
The
broad
range
of
mobile
source
control
strategies,
from
vapor
recovery
to
TCM's,
is
also
discussed.
2Section
182(
b)
has
provisions
for
obtaining
less
that
a
15
percent
VOC
emissions
reduction,
if
certain
stringent
requirements
are
met.
See
section
8.4
of
this
document.

8
1.2
Background
The
rate­
of­
progress
plan
must
include
documentation
of
base
year
emissions
inventories,
growth
factors,
projected
emissions
inventories,
and
control
measures
and
associated
emissions
reductions
to
demonstrate
how
a
nonattainment
area
will
achieve
a
15
percent
VOC
emissions
reduction,
net
of
growth,
by
November
1996.2
Calculation
of
the
15
percent
VOC
emissions
reduction,
net
of
growth,
includes
the
calculation
of
the
following
three
components:

!
The
15
percent
VOC
emissions
reduction
from
the
1990
adjusted
base
year
emissions
inventory.

!
The
1996
target
level
of
emissions.

!
Emissions
reductions
needed
to
fully
offset
emissions
growth
from
1990
through
1996.

Figure
1
presents
a
flowchart
of
the
steps
involved
in
calculating
the
required
emissions
reductions
and
the
1996
target
level
of
emissions.
The
15
percent
VOC
emissions
reduction
must
be
calculated
from
the
1990
adjusted
base
year
emissions
inventory.
The
1990
adjusted
base
year
emissions
inventory
must
exclude
the
following:

!
Biogenic
emissions.

!
Emissions
associated
with
anthropogenic
sources
located
outside
of
a
nonattainment
area's
boundaries.

!
Emissions
reductions
that
would
occur
by
1996
as
the
result
of
a
Federal
motor
vehicle
control
program
(
FMVCP)
promulgated
by
January
1,
1990.

!
Emissions
reductions
that
would
occur
by
1996
as
the
result
of
the
Reid
vapor
pressure
(
RVP)
control
program
(
55
FR
23666,
June
11,
1990).

Emissions
reductions
associated
with
corrections
to
a
nonattainment
area's
reasonably
available
control
technology
(
RACT)
rules
and
inspection
and
maintenance
(
I/
M)
program,
and
post­
1990
emissions
reductions
associated
with
the
FMVCP
and
RVP
controls
are
added
to
the
15
percent
VOC
emissions
reduction
to
calculate
total
expected
reductions
by
1996.
Total
expected
reductions
by
1996
are
then
subtracted
from
the
1990
rate­
of­
Figure
1.
Flowchart
for
rate­
of­
progress
calculations.
10
11
progress
em
of
emissions
subtracted
fro
growth
in
the
to
1996
target
level
document
entitled
G
Inventory
and
the
199
Plans.
(
See
reference
guidance
for
calculating
from
the
1990
adjusted
bas
1996
target
level
of
emissi
October
1992
document
should
in
this
document
when
preparing
The
1990
base
year
inventory
emiss
annual
and
seasonal
basis.
For
dete
VOC
emissions
reduction,
net
of
growt
typical
ozone
season
weekday
emissions.

inventory,
these
emissions
are
measured
f
during
the
1990
peak
ozone
season.
The
pe
contiguous
3­
month
period
for
which
the
high
days
have
occurred
in
the
previous
3
to
4
year
on
typical
ozone
season
weekday
VOC
emissions
[

of
the
definition
in
section
182(
b)(
1)(
B)
of
base
emissions
during
the
"
calendar
year"
of
enactment]

with
prior
EPA
guidance.
This
stems
from
the
fact
t
national
ambient
air
quality
standard
(
NAAQS)
is
an
ho
standard
that
is
generally
violated
during
ozone
season
when
conditions
are
conducive
to
ozone
formation.
These
seasons
are
typically
the
summer
months.

Moderate
ozone
nonattainment
areas
must
also
include
in
their
rate­
of­
progress
plans
a
demonstration
that
the
ozone
NAAQ
will
be
attained
by
November
1996.
Figure
2
presents
a
flowchart
of
the
components
for
developing
the
control
measures
that
form
the
basis
of
the
rate­
of­
progress
plan
for
an
attainment
demonstration.
To
determine
achievement
of
the
15
percent
VOC
emissions
reduction,
net
of
growth,
the
1990
rate­
of­
progress
emissions
must
be
subtracted
from
the
1996
projection
year
emissions
for
VOC.
Failure
to
achieve
the
15
percent
VOC
emissions
reduction,
net
of
growth,
will
require
application
of
additional
control
measures
to
1996
projection
year
emissions
for
VOC.
If,
however,
the
15
percent
reduction,
net
of
growth,

is
confirmed
by
this
calculation,
the
next
step
is
to
add
biogenic
emissions
and
emissions
in
the
modeling
domain
but
outside
the
nonattainment
area
into
the
1996
projection
year
inventory,
and
model
the
inventory
using
the
empirical
kinetic
modeling
analysis
(
EKMA).
In
addition,
NOx
emissions
must
also
be
included
in
an
attainment
demonstration
modeling
analysis.

Therefore,
States
will
need
to
develop
a
1990
base
year
and
rate­

of­
progress
emissions
inventory
for
NOx
,
and
then
prepare
a
projected
NOx
1996
for
modeling.
Those
Figure
2.
Flowchart
for
a
moderate
ozone
nonattainment
area
attainment
demonstration.
13
14
States
that
modeling
sho
emissions
inve
Moderate
ozone
no
be
able
to
demonstr
1996
if
they
comply
w
net
of
growth,
require
analysis
demonstrate
att
should
proceed
to
draft
re
needed
to
achieve
the
neces
if
the
results
of
the
modelin
attainment,
additional
control
1996
projection
year
emissions
t
and/
or
NOx
needed
to
demonstrate
a
Serious
and
above
ozone
nonattainment
to
submit
a
post­
1996
rate­
of­
progress
November
15,
1994
which
describes,
in
par
achieve
additional
VOC
emissions
reduction
averaged
over
each
consecutive
3­
year
period
1996
until
the
area's
attainment
date.
The
pl
contain
an
attainment
demonstration
based
on
ph
modeling.
The
EPA
will
distribute
a
separate
gui
on
the
development
of
the
post­
1996
rate­
of­
progres
early
1993.
It
is
important
to
note
that
section
18
allows
for
actual
NOx
emissions
reductions
(
exceeding
that
occur
after
the
base
year
of
1990
to
be
used
to
mee
1996
emissions
reduction
requirements,
provided
that
such
reductions
meet
the
criteria
outlined
in
forthcoming
substi
guidance.
Therefore,
it
is
recommended
that
States
track
the
actual
NOx
emissions
reductions
occurring
between
1990
and
1996
More
specific
guidance
regarding
NOx
substitutions
is
currently
under
development
by
EPA.
The
substitution
guidance
is
planned
for
release
in
the
fall
of
1993.
15
2.0
GENERAL
2.1
Use
of
Emis
Emissions
project
needed­­
in
conjunct
determine
if
the
area
attainment
date.
Emis
determine
if
the
rate­
of
be
met.
See
section
6,
"
C
Projections"
for
a
discussi
1996
projected
inventory.

2.2
Rate­
of­
Progress
Emissions
Pr
The
following
reviews
the
discussion
Adjusted
Base
Year
Emissions
Inventor
the
15
Percent
Rate­
of­
Progress
Plans.

reader
should
be
familiar
with
that
docum
from
the
subsequent
discussion.

The
rate­
of­
progress
plan
requires
the
prepara
several
emissions
inventories:

!
1990
base
year
inventory.

!
1990
rate­
of­
progress
base
year
inventory.

!
1990
adjusted
base
year
inventory.

!
1996
target
level
of
emissions.

A
detailed
discussion
of
the
calculation
of
these
inventories
is
provided
in
the
EPA
document
referenced
above.

Appendix
F
of
this
document
expands
on
the
information
provided
in
the
above
referenced
document
by
describing
the
projection
of
emissions
growth
between
1990
and
1996,
and
the
calculation
of
the
total
amount
of
emissions
reductions
needed
by
1996.

Additionally,
Appendix
F
presents
examples
of
hypothetical
control
strategies.

2.3
Emissions
Factor
Adjustments
Emissions
factors,
as
well
as
inventory
calculation
methodologies,
are
continually
being
revised
and
improved
based
on
field
and
laboratory
measurements.
The
States
should
maintain
close
coordination
with
the
appropriate
EPA
Regional
Office
as
they
prepare
the
base
year
and
other
emissions
inventories
to
insure
that
these
inventories
reflect
current
EPA
guidance.
If
the
emissions
factors
or
methodologies
change
significantly,
EPA
may
advise
the
States
to
correct
their
base
year
emissions
inventories
to
reflect
these
changes.
16
If
emission
before
Novem
of­
progress
pl
to
the
base
year
inventories/
targe
process.

The
following
guidance
Title
I
for
emissions
fa
after
November
15,
1993
(
w
nonattainment
areas,
but
ha
above
nonattainment
areas):

15
percent
demonstration
is
sub
1996,
then
the
States
would
not
purposes
of
reconciling
attainment
Serious
areas
should
also
refer
to
t
discussion
on
the
rate­
of­
progress
pl
III.
A.
4(
f);
57
FR
13516­
8]
for
guidance
occur
before
November
15,
1994,
and
the
i
of­
progress
plan
demonstration.

2.4
Actual
and
Allowable
Emissions
Actual
emissions
from
a
source
are
the
emissions
the
source's
actual
operating
hours,
production
rat
control
equipment
for
the
processes
carried
out
at
t
Actual
emissions
take
into
consideration
instances
whe
operations
are
consistent
and
when
deviations
from
norma
operating
conditions
occur.
Allowable
emissions
are
a
re
element
of
the
operating
permit
granted
to
the
source
or
el
of
the
applicable
regulation
which
represents
a
regulatory
li
on
emissions
that
can
be
emitted
from
the
source.

By
permit
provision,
the
actual
emissions
cannot
exceed
the
allowable
emissions
permitted
by
the
regulatory
agencies
except
under
very
narrow
conditions,
such
as
upsets
at
the
source.
The
value
of
the
allowable
emissions
for
a
source
is
a
regulatory
element
important
in
the
inspection
and
enforcement
programs
and,

like
a
speed
limit
on
the
highway,
is
a
gauge
for
the
enforcement
agencies
to
determine
compliance
by
the
source.
Allowable
emissions
are
also
an
accounting
tool
for
the
regulatory
agencies
in
their
effort
to
balance
industrial
activity
within
overall
emissions
targets
for
a
particular
air
basin
to
insure
compliance
with
the
NAAQS
or
other
statutory
requirements.
As
discussed
below,
the
projections
for
the
rate­
of­
progress
plan
will
generally
be
based
on
allowable
emissions
limits
(
the
enforceable
emissions
rate
multiplied
by
the
expected
activity
level)
for
the
sources
within
a
nonattainment
area
whose
allowable
emissions
will
be
reduced
to
meet
the
progress
requirements.
17
It
is
impor
allowable
em
multiplied
by
purpose
for
usin
projections
is
to
rate­
of­
progress
re
their
allowable
emiss
The
purpose
of
projectin
future
is
not
solely
to
pr
rather
to
test
the
ability
strategy
to
meet
RFP
goals
an
ozone
NAAQS.
To
adequately
tes
believes
it
is
necessary
to
proj
are
allowed
to
do
and
to
evaluate
However,
EPA
also
recognizes
that
1
related
to
assimilating
allowable
usable
format
and
2)
the
assumption
tha
nonattainment
area
will
operate
at
their
limit
may
not
be
valid.

Therefore,
as
an
alternative
to
using
allowabl
projections,
EPA
believes
it
is
appropriate
emissions
in
certain
circumstances.
For
sources
categories
that
are
currently
subject
to
a
regulati
State
does
not
anticipate
subjecting
the
source(
s)
t
regulation,
the
projected
emissions
may
be
based
on
ac
emissions.
In
addition,
for
sources
or
source
categorie
are
currently
unregulated
and
are
not
expected
to
be
subj
future
regulations,
the
projected
emissions
may
be
based
on
actual
emissions.
For
all
other
sources,
i.
e.,
sources
that
expected
to
be
subject
to
additional
regulation,
the
projectio
should
be
based
on
the
new
allowable
emissions
(
including
RE)
as
defined
above.
Where
a
State
chooses
to
project
emissions
using
a
different
approach
than
described
above,
the
State
should
get
the
approval
of
the
appropriate
EPA
Regional
Office
before
proceeding.
In
addition,
the
State
must
provide
complete
documentation
of
the
approach
and
documentation
and
technical
justification
of
any
assumptions.

It
is
important
to
note
that,
regardless
of
whether
the
projected
emissions
are
based
on
actual
or
allowable
emissions,

future
emissions
trades,
including
offsets,
must
be
based
on
assumptions
that
are
consistent
with
the
projected
inventory.
In
other
words,
if
the
projected
emissions
from
a
source
are
based
on
actual
emissions,
that
source
must
use
actual
emissions
in
determining
the
amount
of
credit
available
for
offsets
or
emissions
trading.
The
EPA's
Emissions
Trading
Policy
Statement
(
51
FR
43814,
December
4,
1986)
provides
EPA's
policy
on
emissions
trading.
Also,
the
proposed
rules
for
economic
incentive
programs
(
58
FR
11110,
February
23,
1993)
will
provide
additional
guidance
in
this
area.
18
The
followi
future
tradi
process
under
!
Example
1:
Source
remain
uncontrolled
In
this
example,
the
b
calculated
based
on
actu
source
is
currently
emitti
1990
with
no
controls
in
th
required
in
the
projection
ye
are
determined
by
applying
the
[
Bureau
of
Economic
Analysis
(
BE
Analysis
System
(
E­
GAS)
growth
fac
Assuming
that
the
for
manufacturer
is
1.2,
the
baseline
for
180
lb/
day.

!
Example
2:
Source
currently
uncontrolled
t
controlled.

In
this
example,
the
baseline
for
future
tradin
calculated
based
on
allowable
emissions.
If
the
manufacturer
in
Example
1
is
required
to
install
a
device
reducing
emissions
by
75
percent
(
with
a
RE
o
80
percent),
future
baseline
emissions
for
trading
are
determined
by
applying
the
applicable
growth
factor
(
1.2
plus
the
future
control
efficiency.
Future
uncontrolled
emissions
would
be
180
lb/
day.
Future
allowable
emissions,

the
baseline
for
future
trading,
are
calculated
by
applying
the
control
efficiency
to
the
uncontrolled
future
level.

This
results
in
a
baseline
of
72
day
for
future
trading.

!
Example
3:
Source
currently
controlled
that
will
not
be
subject
to
additional
control.

In
this
example,
the
baseline
for
future
trading
is
calculated
based
on
actual
emissions.
For
example,
if
the
chemical
manufacturer
in
Example
1
currently
has
a
control
device
installed
reducing
emissions
by
50
percent
(
with
an
80
percent
RE),
base
year
emissions
would
be
90
lb/
day.
The
baseline
for
future
trading
would
be
calculated
by
applying
the
growth
factor
of
1.2
which
results
in
108
lb/
day
as
the
baseline
for
future
trading.

In
this
example,
the
projection
based
on
allowable
emissions
may
be
higher
than
the
projection
based
on
actual
emissions.
For
example,
if
the
regulatory
or
permit
requirement
for
this
source
mandated
an
overall
reduction
of
40
percent
(
with
an
80
percent
RE),
emissions
projected
based
on
allowable
conditions
would
be
calculated
by
19
substitutin
50
percent
c
allowable
emis
future
trading
m
projection
to
ens
!
Example
4:
Sources
cu
subject
to
additional
In
this
example,
the
basel
calculated
based
on
allowab
manufacturer
in
Example
3
is
control
with
an
overall
efficie
80
percent
RE),
the
baseline
for
calculated
by
applying
the
growth
year
emissions
and
adjusting
the
con
the
90
percent
required
control.
In
baseline
for
future
trading
would
be
50
Because
the
basis
of
allowing
credit
is
of
sources
in
the
State,
the
State
must
be
cert
adequate
notice
(
e.
g.,
during
the
public
heari
sources
as
to
what
the
baseline
for
future
emis
be.
This
is
of
particular
concern
where
the
proj
are
based
on
actual
rather
than
allowable
emissions
Using
this
approach,
EPA
has
made
concessions
in
two
w
First,
the
projections
will
be
based
on
expected
activit
not
maximum
operating
capacity.
Second,
EPA
is
not
requi
that
projections
be
based
on
allowable
emissions
limits
all
sources,
only
sources
for
which
allowable
emissions
are
expected
to
change.

The
States
will
have
the
responsibility
to
adequately
document
which
projection
methodology
is
used
so
that
EPA
will
have
access
to
the
documentation
during
the
SIP
review
process
and
for
subsequent
review
of
emissions
reduction
credits.

2.5
Effect
of
Rule
Penetration
and
Rule
Effectiveness
Rule
penetration
and
RE
concern
the
ability
to
have
all
sources
included
in
a
particular
regulatory
requirement
incorporate
and
implement
that
requirement.
Penetration
is
a
measure
of
how
many
applicable
sources
are
complying;

effectiveness
is
a
measure
of
how
well
the
complying
sources
apply
the
required
control
strategy
or
technology
or
how
well
the
required
control
strategy
or
technology
works
to
reduce
emissions.
Assumptions
concerning
these
two
elements
of
a
regulatory
program
can
have
major
impacts
on
the
nature
and
scope
of
the
program.
For
example,
an
underestimation
of
the
penetration
and
effectiveness
of
a
control
strategy
can
overstate
the
need
for
other
control
strategies
to
show
compliance
with
20
regulatory
these
factor
monitoring
sta
of
compliance.

of
the
actual
emi
impossible
to
ensur
(
i.
e.,
meeting
the
ru
100
percent
of
the
tim
discussion
of
RE
improve
21
3.0
ECONOMIC
Economic
activ
of
anthropogenic
determined
by
the
determined
by
speci
printing
or
rotogravu
(
e.
g.
low
solvent
inks
output
[
e.
g.,
gallons
(
g
change
in
the
utilization
processes
are
anticipated,

emissions
seen
in
the
past
sh
future.
If,
however,
EPA
expec
new
processes
to
be
adopted,
or
relationship
between
output
level
may
not
be
an
appropriate
assumption
emissions.

Note
that
growth
factors
are
not
included
calculations
of
the
1990
adjusted
base
yea
target.
Growth
factors
are
needed,
however,

VOC
emissions
reduction
demonstration
as
part
progress
plan
that
is
due
on
November
15,
1993
above
nonattainment
areas.
Growth
factors
ar
for
the
attainment
demonstration
due
on
November
15
moderate
ozone
nonattainment
areas
using
EKMA
and
on
1994
for
moderate
ozone
nonattainment
areas
using
UAM
serious
and
above
ozone
nonattainment
areas.
States
sho
include
the
draft
rate­
of­
progress
growth
factors
in
both
computer
and
written
formats
to
EPA
by
November
15,
1992.

sets
of
growth
factors
should
be
provided.
One
set
is
used
t
project
the
growth
between
1990
and
1996
for
rate­
of­
progress
plan
purposes,
other
set
is
used
to
project
growth
through
the
year
of
attainment
for
the
attainment
demonstration
for
modeling
purposes.
(
These
sets
are
basically
the
same
for
moderate
areas,
which
must
demonstrate
attainment
by
1996.)
The
computer
format
for
growth
factor
submittals
is
presented
in
Table
1
of
the
document
entitled
Guidance
on
the
Adjusted
Base
Year
Emissions
Inventory
and
the
1996
Target
for
the
15
Percent
Rate­
of­
Progress
Plans.
(
See
reference
1.)
The
following
should
also
be
included
with
the
list
of
growth
factors:
State
identification
(
ID),
county
ID,
zone
code
(
if
the
growth
factor
is
to
be
used
for
a
specific
zone
within
a
county),
source
category
code
[
either
Standard
Industrial
Classification
(
SIC),

AFS
source
classification
code,
or
Area
and
Mobile
Source
Subsystem
(
AMS)
source
category
code],
growth
factor
reference
[
e.
g.,
BEA,
plant­
supplied],
and
control
information
discussed
below.
Any
information
not
contained
in
the
spreadsheet
file
(
e.
g.,
which
agency
submitted
the
growth
information
and
assumptions
made
in
preparing
the
information)
should
be
submitted
on
paper
accompanying
the
PC
disk.
22
Sources
of
projections
references
2,

Emissions
Projec
discusses
the
dev
and
lists
the
57
in
available
(
pages
17­
2
better
information
tha
specific
information
reg
source
resulting
in
an
emi
their
own
growth
factors.
23
4.0
GROWTH
P
This
section
p
factors
for
use
This
section
disc
Emissions
Preproces
nonattainment
areas
t
demonstrate
attainment
documentation
for
projec
both
VOC
and
NOx
in
their
to
account
for
CO
emissions
provide
documentation
for
a
p
1996
in
their
SIP
submittals.

account
for
VOC,
NOx
,
and
CO
emis
will
need
to
develop
growth
and
re
and
CO
emissions.

4.1
Growth
and
Retirement
Relationships
Industry
growth
and
the
addition
of
new
pl
accompanied
by
the
retirement
of
aging
facil
important
to
account
for
retirement
rates
when
projected
emissions
and
future
control
levels
f
First,
projections
can
only
be
made
when
net
grow
retirement
is
determined.
Second,
controls
are
oft
for
new
sources
and
existing
sources
of
VOC.

There
are
several
sources
of
retirement
rates
for
segmen
industry.
One
that
is
generally
available
is
the
late
version
of
the
Internal
Revenue
Service
(
IRS)
Publication
5
Depreciation
(
used
for
the
preparation
of
income
tax
returns
(
See
reference
6.)
In
this
publication,
the
IRS
develops
retirement
rates
from
its
depreciation
guidelines,
in
which
annual
retirement
rates
estimated
as
the
reciprocal
of
the
depreciation
period
in
years
multiplied
by
2.
These
retirement
rates
may
be
combined
with
growth
rates
to
determine
projected
emissions.
(
Note
that
the
BEA
projected
earnings
data
are
calculated
net
of
plant
retirements.
That
is,
retirement
of
existing
sources
has
been
taken
into
account.)
The
EPA
publication
entitled
A
Projection
Methodology
for
Future
State
Level
Volatile
Organic
Compound
Emissions
(
VOC)
from
Stationary
Sources
Version
2.0
(
see
reference
7.),
also
provides
IRS
retirement
rates
and
discusses
their
application
for
projecting
VOC
emissions.
However,
the
latest
version
of
the
IRS
Publication
534
should
be
consulted
in
case
the
IRS
has
changed
the
basis
for
depreciation
rates
from
which
retirement
rates
are
calculated.

Growth
and
retirement
rates
also
affect
the
emissions
levels
due
to
different
control
requirements
for
new
and
existing
sources.
Older
facilities
will
often
have
less
stringent
control
standards
than
newer
facilities.
As
older
facilities
are
24
retired,
an
output,
but
different
reti
must
be
made
for
factor
for
future
base
year
due
to
a
growth
and
retirement
4.2
Emissions
Preprocesso
The
EPA
has
upgraded
the
EP
future
growth
and
controls.

county­
level
by
source
category
utility
will
allow
better
growth
regional
projections.
Other
enhan
flexible
and
easier
to
operate.

The
revised
version
of
EPS
(
EPS
2.0,
Ju
based
system,
with
a
graphics
option
prog
Statistical
Analysis
System
(
SAS)
language
Projection
factors,
which
represent
estim
activity
levels
between
the
base
and
projection
assigned
based
on
the
first
two
digits
of
the
SIC
sources
and
the
first
four
digits
of
the
area
sourc
(
ASC)
code
for
area
and
mobile
sources.
The
EPS
2.0
allows
for
projections
of
actual
and/
or
allowable
emis
system
recognizes
four
types
of
allowable
emissions
inve
(
1)
allowables
based
on
activity
level
limits;
(
2)
allowa
based
on
emissions
limits;
(
3)
allowables
based
on
emission
factor
limit;
and
(
4)
allowables
based
on
both
activity
and
emissions
factor
limits.
The
EPS
2.0
assumes
projection
facto
apply
to
all
allowable
types
except
those
that
represent
emissions
limits.
(
The
user
can
override
this
feature
if
desired.)

The
projection
factors
currently
available
with
EPS
2.0
are
generated
by
the
user
using
a
provided
BEA
earnings
and
population
data
base
along
with
an
SIC(
ASC)/
BEA
data
cross
reference
data
file.
This
relates
the
BEA
categories
to
the
appropriate
SIC
or
ASC
emissions
categories.
Detailed
explanations
of
this
process
and
data
files
can
be
found
in
the
documentation
for
EPS
2.0.
(
See
reference
8.)

4.3
Economic
Growth
Analysis
System
(
E­
GAS)

A
key
component
of
rate­
of­
progress
plan
emissions
inventories
and
inventories
for
use
in
photochemical
grid
modeling
is
the
development
of
credible
growth
factors
for
the
existing
inventories.
Credible
growth
factors
will
require
accurate
forecasts
of
economic
variables
and
associated
activities
related
to
ozone
precursor
emissions.
The
EPA's
Air
25
and
Energy
forecast
gro
activities.
T
ozone
nonattainm
modeling
(
i.
e.,
s
moderate
interstate
consumption,
vehicle
The
modules
translate
activities
associated
wi
are
the
primary
precursors
not
intended
to
provide
areas
because
E­
GAS
will
not
deadline
for
these
areas.

The
E­
GAS
project
is
being
coordin
groups
at
the
Office
of
Air
Quality
(
OAQPS);
these
are
the
Technical
Supp
Inventory
Branch,
the
Technical
Support
Analysis
Branch,
and
the
Air
Quality
Mana
Programs
Branch.
In
addition,
the
current
developing
projection
inventories
(
see
refer
reviewed
to
maintain
consistency
between
it
an
The
system
is
being
developed
for
the
PC­
AT
class
The
anticipated
minimum
hardware
requirements
are
8
(
though
80386
CPU
is
strongly
suggested),
with
math
EGA
card/
monitor,
4
MB
RAM,
100
MB
hard
disk,
and
DOS
higher.

The
anticipated
schedule
for
completion
of
E­
GAS
has
two
major
milestones:
(
1)
the
first
milestone,
completed
in
September
1992,
is
a
first
generation
"
beta
version"
of
the
system,
and
(
2)
the
second
milestone
is
the
final
version
of
the
system
scheduled
for
completion
in
March
1993.

The
EPA
is
not
requiring
the
use
of
E­
GAS
because
there
may
not
be
enough
time
to
revise
control
strategies
for
the
rate­
of­

progress
plans
and
still
meet
the
November
15,
1993
statutory
deadline.
Nevertheless,
States
that
can
adequately
incorporate
new
growth
factors
generated
from
the
E­
GAS
into
their
1996
projected
inventories
are
encouraged
to
do
so.
27
5.0
CONTROL
This
section
f
measures
and
the
documentation
tha
5.1
Stationary
Source
Stationary
source
VOC
co
classified
into
the
follow
!
Add­
on
controls
that
recover
!
Process
modifications,
equipmen
practices,
or
material
substitutio
eliminate
VOC
emissions.

Add­
on
VOC
Controls
The
most
widely
used
add­
on
controls
inclu
adsorption,
absorption,
and
condensation.
T
add­
on
controls
often
requires
inclusion
of
eq
and
route
VOC
emissions
to
an
add­
on
control
de
efficiency
of
the
add­
on
control
depends
on
the
c
efficiency
as
well
as
the
control
device
efficiency
boilers,
and
thermal
incinerators
have
been
shown
to
uncontrolled
VOC
emissions
by
at
least
98
percent.
Th
controls
work
equally
well
on
many
types
of
VOC
streams
efficiency
of
adsorption,
catalytic
incineration,
absorpt
condensers
are
more
dependent
on
the
VOC
stream
characteris
The
cost
effectiveness
of
these
devices
is
highly
dependent
on
the
process
to
which
they
are
applied.
Overall
costs
will
depend
on
whether
or
not
a
capture
system
is
required,
on
the
flowrate
and
organic
content
of
the
VOC
stream.
The
OAQPS
Control
Cost
Manual
(
see
reference
11),
provides
guidance
on
estimating
the
cost
of
incinerators
(
thermal
and
catalytic)
and
carbon
adsorbers,
the
most
common
add­
on
controls
for
reducing
VOC
emissions.

Combustion
Combustion
devices
simply
burn
or
destroy
VOC
emissions.

This
technique
is
generally
applied
if
the
stream
has
little
or
no
recovery
value.
Combustion
control
devices
include
flares,

thermal
incinerators,
catalytic
incinerators,
boilers,
and
process
heaters.
Incinerators
can
achieve
control
efficiencies
of
at
least
98
percent
when
properly
operated.
Additional
fuel
may
be
needed
if
the
pollutant
streams
are
not
capable
of
sustaining
combustion.
Flares
are
often
used
when
disposing
of
gas
streams
do
not
require
supplemental
fuel.
Flares
have
been
28
shown
to
ac
emissions.

Adsorption
Adsorption
uses
a
s
trap
organic
vapo
steam
stripping.
Carb
combustion
for
stream
of
increases
the
need
for
sup
Efficiencies
of
95
percent
carbon
adsorption.

Absorption
Absorption
uses
a
liquid
to
trap
the
process
is
usually
not
as
economical
because
the
low
concentrations
of
organ
times
and
large
quantities
of
absorbent.

Condensation
Condensation
changes
the
organics
on
the
exhaus
vapor
to
the
liquid
phase.
It
is
often
used
concentrations
of
the
exhaust
gas
prior
to
routing
other
add­
on
devices.

Process
Modifications
and
Substitution
Process
modifications
and
raw
material
changes
are
another
class
of
techniques
for
reducing
VOC
emissions.
Surface
coat
emissions
in
many
industries
have
been
reduced
by
lowering
the
VOC
content
of
the
coatings
and
solvents
in
the
process.

A
common
process
change
in
the
surface
coating
industry
has
been
the
use
of
more
efficient
spray
techniques
(
improved
transfer
efficiency)
which
reduces
the
amount
of
paint
used
and
thus
the
VOC
emissions.

Material
substitution
occurs
in
a
case
such
as
substituting
waterborne
paints
for
solvent­
borne
paints
in
surface
coating
operations.
Some
examples
of
housekeeping
practices
resulting
in
VOC
reductions
are
as
follows:

!
Keeping
lids
on
open
tank
cold
degreasers
when
not
in
use.

!
Ensuring
the
connection
of
the
vapor
recovery
line
in
gasoline
loading
and
unloading.

!
Detecting
and
repairing
leaks
at
synthetic
organic
chemicals
manufacturing
industry
(
SOCMI)
facilities
and
refineries.
29
5.2
Motor
Ve
Motor
vehicle
reducing
the
per
thus
overall
emis
commonly
classified
The
CAAA
mandate
a
mix
vehicle
control
measures
National
measures
include
revised
to
conform
with
the
controls,
and
tailpipe/
extend
specific
measures
include
Stage
refueling)
controls,
clean
fuel
general
clean
fuels
program,
refor
enhanced
I/
M.

Federal
Motor
Vehicle
Control
Program
(

Tailpipe/
Extended
Useful
Life
Standards
The
EPA
has
promulgated
a
final
rule
for
new
e
standards
for
1994
and
later
model
year
light­
d
(
LDV's)
and
light­
duty
trucks
(
LDT's)
(
56
FR
2572
1991).
The
standards
will
be
phased­
in:
affecting
the
model­
year
1994
vehicle
fleet,
80
percent
of
1995
vehicle
fleet,
and
100
percent
of
the
model­
year
later
vehicle
fleets.
The
MOBILE5.0
model,
which
was
re
December
1992,
incorporates
the
new
standards
into
future
emissions
factors.

California
has
adopted
more
stringent
motor
vehicle
standards,
referred
to
as
the
California
Low­
Emission
Vehicle
(
LEV)
program.
For
information
on
the
cost
and
effectiveness
of
the
LEV
program,
contact
the
California
Air
Resources
Board.

Evaporative/
Running
Loss
Controls
The
new
Federal
evaporative
test
procedure
will
account
for
hot
soak
and
diurnal
emissions,
running
losses,
and
resting
losses.
The
MOBILE5.0
model
contains
guidance
on
estimating
the
effectiveness
of
evaporative/
running
loss
controls.

RVP
Limits
The
gasoline
volatility
limits
(
RVP
Phase
I),
effective
from
1989
through
1991,
set
gasoline
RVP
to
10.5
in
American
Society
for
Testing
and
Materials
(
ASTM)
Class
C
regions,
and
the
equivalent
in
other
regions.
The
ASTM
volatility
class
represents
the
ASTM­
recommended
limits
on
the
volatility
of
gasoline
sold
in
that
state.
There
are
five
volatility
classes:

A,
B,
C,
D,
and
E,
where
Class
A
is
the
least
volatile
and
3Although
Stage
II
vapor
recovery
control
systems
for
gasoline
service
stations
are
discussed
under
section
5.2
(
Motor
Vehicles)

of
this
document,
the
emissions
from
gasoline
service
stations
are
generally
inventoried
as
an
area
source.

30
Class
E
is
and
geograph
in
June
and
a
(
more
volatile)

summer
months.

Phase
II
limits
are
m
The
Phase
II
regulatio
with
the
CAAA,
place
lim
than
9.0
psi
RVP
in
attain
used
to
estimate
the
eff
Stage
II
3
Stage
II
systems
are
vapor
recover
pumps
to
reduce
vehicle
refueling
em
of
the
Act
requires
that
all
ozone
no
as
moderate
or
above
implement
a
Stage
as
a
control
measure.
Section
202(
a)(
6)

exemption
from
the
Stage
II
requirement
fo
nonattainment
areas
after
EPA
promulgates
on
standards.
After
consulting
with
the
U.
S.
Dep
Transportation,
EPA
published
in
the
Federal
Re
decision
against
promulgating
on­
board
vapor
reco
(
57
FR
13220,
April
15,
1992),
removing
the
possibi
Stage
II
exemption
for
moderate
areas.
However,
on
1993,
the
United
States
Court
of
Appeals
for
the
Distr
Columbia
Circuit
ruled
that
EPA's
decision
not
to
requir
board
vapor
recovery
controls
be
set
aside
and
on­
board
v
recovery
standards
be
promulgated
pursuant
to
section
202(
a
of
the
Act.
The
EPA
is
currently
studying
a
schedule
for
complying
with
the
court's
ruling.

States
are
required
to
adopt
Stage
II
rules
for
such
areas
under
sections
182(
b)(
3).
Section
202(
a)(
6)
states
that
"
the
requirements
of
section
182(
b)(
3)
(
relating
to
Stage
II
gasoline
vapor
recovery)
for
areas
classified
under
section
181
as
moderate
for
ozone
shall
not
apply
after
promulgation
of
such
standards
(
i.
e.,
on­
board
controls)
..."

These
provisions
of
the
Act
indicate
that
a
State's
obligation
to
adopt
Stage
II
rules
for
moderate
areas
continues
until
on­
board
rules
are
actually
promulgated.
When
on­
board
rules
are
promulgated,
a
State
may
withdraw
its
Stage
II
rules
for
moderate
areas
from
the
SIP
consistent
with
its
obligation
under
sections
182(
b)(
3)
and
202(
a)(
6).
Further
guidance
on
31
Stage
II
re
redesignatio
There
are
compel
requirements
even
Vehicles
equipped
w
enter
the
market
unti
requirement
is
adopted
the
fleet
to
turn
over
t
on­
board
controls.
It
cou
controls
achieve
the
same
o
reductions
as
Stage
II
contro
above
nonattainment
areas
must
a
15
percent
VOC
emissions
reduc
areas
are
required
to
achieve
atta
November
1996.
Stage
II
is
one
of
t
comply
with
this
requirement.

The
EPA
is
further
considering
how
this
c
a
State's
obligation
under
section
184(
b)(

or
measures
that
get
equivalent
emissions
re
Northeast
ozone
transport
region.
The
section
requirement
applies
to
all
areas
in
the
region
ozone
designation
or
classification.
Guidance
co
Northeast
ozone
transport
region
will
be
issued
at
In
addition,
the
CAAA
mandate
a
study
identifying
cont
measures
capable
of
achieving
emissions
reductions
compa
those
achievable
by
Stage
II
controls.
All
areas
within
Northeast
Ozone
Transport
Region
[
defined
in
section
184(
a)

the
Act]
must
adopt
Stage
II
or
comparable
measures
within
1
of
completion
of
the
study.
The
study
is
to
be
completed
in
November
1993.
Although
Stage
II
is
not
specifically
mandated,

controls
achieving
equivalent
reductions
must
be
adopted.

The
EPA
has
published
two
documents
relating
to
Stage
II
controls:

!
Technical
Guidance
­
Stage
II
Vapor
Recovery
Systems
for
Control
of
Vehicle
Refueling
Emissions
at
Gasoline
Dispensing
Facilities.
(
See
reference
12.)

!
Enforcement
Guidance
for
Stage
II
Vehicle
Refueling
Control
Programs.
(
See
reference
13.)

The
EPA
has
interpreted
the
Stage
II
requirement
to
mean
that
controls
must
have
a
demonstrated
efficiency
of
95
percent.

The
EPA
believes
that
this
is
a
realistic
requirement
because
it
has
been
achieved
in
California.
The
Stage
II
program
in­
use
efficiency
(
accounting
for
associated
wear
and
tear,
malfunctions
or
system
problems
that
result
in
reduction
of
the
certified
efficiency)
depends
upon
the
applicability
cut­
off
of
a
State's
32
regulation
example,
as
guidance,

annual
inspectio
10,000
gals
or
mo
Stage
II
technical
efficiency
for
other
Inspections
identify
m
to
the
reduction
from
th
The
CAAA
establish
a
size
c
dispensed
per
month
with
the
business
marketers.
The
size
c
business
marketers
is
50,000
gal
business
marketers
are
defined
in
10,000/
50,000
gal
exemptions
will
ex
10
percent
of
gasoline
consumption
fr
not
prohibit
States
from
establishing
l
independent
small
business
marketers.
Wi
determining
stations
that
fall
under
the
d
independent
small
business
marketer,
many
ar
have
a
separate
exemption
level
for
this
group
of
10,000
gals
per
month
would
exclude
an
avera
2.8
percent
of
gasoline
consumption.

The
emissions
inventory
guidance
document
entitled
Procedures
for
Emission
Inventory
Preparation
­
Volume
Mobile
Sources,
(
see
reference
14),
recommends
use
o
MOBILE5.0
emissions
factors
for
modeling
the
effects
of
S
controls
on
refueling
emissions.
Further
guidance
on
the
i
requirements
can
be
found
on
pages
43
through
45
of
the
guida
document.

Clean
Fuel
Fleet
Program
Serious,
severe,
and
extreme
ozone
nonattainment
areas
[
and
CO
areas
with
design
values
of
16.0
parts
per
million
(
ppm)
or
greater]
with
1980
populations
of
at
least
250,000
must
adopt
the
clean
fuel
fleet
program
mandated
by
the
CAAA.
The
phase­
in
schedule
for
this
program
is
as
follows:

Model­
Year
Model­
Year
Model­
Year
Vehicle
Type
1998
1999
2000
LDV's
and
LDT's
30%
50%
70%

Heavy­
duty
trucks
50%
50%
50%

Specific
standards
that
must
be
met
are
listed
in
sections
243
and
245
of
the
Act.
33
Reformulate
Reformulated
g
with
the
most
se
other
nonattainme
in
toxic
VOC
em
1995,
increasing
to
a
reductions
from
reform
MOBILE5.0
model.

Inspection
and
Maintenance
The
EPA
has
promulgated
a
rule
program
requirements
(
57
FR
5295
rule
includes
an
I/
M
option
includ
program
with
vehicles
tested
both
in
In
addition,
a
transient
exhaust
emis
canister
purge
system
check,
and
an
eva
test
would
also
be
required
as
well
as
a
tampering.
Benefits
of
enhanced
I/
M
progr
using
MOBILE5.0.

On­
Board
Diagnostic
Systems
The
EPA
has
proposed
a
rule
that
will
require
on­
bo
diagnostic
systems
in
all
LDV's
and
LDT's
beginning
1994
(
56
FR
48272,
September
24,
1991).
On­
board
diag
systems
monitor
emission­
related
components
for
malfunct
deterioration
before
such
events
cause
emissions
increase
According
to
the
proposed
rule,
on­
board
diagnostic
systems
be
inspected
as
part
of
a
State's
I/
M
program.
Therefore,

emissions
reductions
resulting
from
the
use
of
on­
board
diagnostic
systems
will
not
be
separately
creditable
toward
the
15
percent
VOC
emissions
reduction
requirements.

Transportation
Control
Measures
(
TCM's)

The
EPA
has
recently
developed
guidance
on
an
assortment
of
TCM's.
The
TCM's
attempt
to
decrease
traffic
congestion,

especially
during
peak
commuting
hours,
by
providing
alternatives
to
using
motor
vehicles.
An
EPA
document
entitled,

Transportation
Control
Measure
Information
Documents
(
see
reference
15),
includes
a
list
of
the
following
TCM's:

!
Programs
for
improved
public
transit.

!
Restriction
of
certain
roads
or
lanes
to,
or
construction
of
such
roads
or
lanes
for
use
by,

passenger
buses
or
high­
occupancy
vehicles.

!
Employer­
based
transportation
management
plans,

including
incentives.
34
!
Trip­
redu
!
Traffic
flow
emissions
reduct
!
Fringe
and
transpo
serving
multiple
occu
service.

!
Programs
to
limit
or
res
areas
or
other
areas
of
emi
particularly
during
periods
o
!
Programs
for
the
provision
of
a
occupancy,
shared­
ride
services.

!
Programs
to
limit
portions
of
road
s
sections
of
the
metropolitan
area
to
th
nonmotorized
vehicles
or
pedestrian
use,

time
and
place.

!
Programs
for
secure
bicycle
storage
and
othe
facilities,
including
bicycle
lanes,
for
the
convenience
and
protection
of
bicyclists
in
both
and
private
areas.

!
Programs
control
extended
idling
of
vehicles.

!
Programs
to
reduce
motor
vehicle
emissions,
consistent
with
Title
II,
which
are
caused
by
extreme
cold
start
conditions.

!
Employer­
sponsored
programs
to
permit
flexible
work
schedules.

!
Programs
and
ordinances
to
facilitate
nonautomobile
travel,
provision
and
utilization
of
mass
transit,
and
to
generally
reduce
the
need
for
single­
occupant
vehicle
travel,
as
part
of
transportation
planning
and
development
efforts
of
a
locality,
including
programs
and
ordinances
applicable
to
new
shopping
centers,

special
events,
and
other
centers
of
vehicle
activity.

!
Programs
for
new
construction
and
major
reconstructions
of
paths,
tracks,
or
areas
solely
for
use
by
pedestrian
or
other
nonmotorized
means
of
transportation
when
economically
feasible
and
in
the
public
interest.

!
Programs
to
encourage
the
voluntary
removal
from
use
and
the
marketplace
of
pre­
1980
model
light­
duty
vehicles
and
trucks.
35
The
TCM
imp
guidance
doc
State
Implemen
source
also
cont
Additional
travel
congestion
may
o
Transportation
(
DOT)

Demand
Management
Meas
reference
17.)

The
EPA's
Office
of
Policy,

significant
work
in
this
area
in
the
Spring
of
1993.
Please
Will
Schroeer
(
202­
260­
1126)
wit
5.3
Other
Mobile
Sources
Fewer
control
measures
exist
for
other
Most
control
technology
for
these
sources
reductions
from
diesel
engines.
Informati
available
for
controls
for
railroads,
constr
farm
equipment.
The
EPA's
Office
of
Mobile
So
provide
guidance
on
emissions
reductions
that
m
from
off­
road
sources
due
to
the
use
of
reformula
Controlling
emissions
from
diesel
engines
can
usuall
accomplished
by
tailoring
the
air
induction,
fuel
inje
fuel­
air
mixing,
and
other
elements
of
the
combustion
pr
Additionally,
after­
treatment
of
the
exhaust
gases
may
be
possible
in
some
cases.
Diesel
engine
controls
should
be
adaptable
to
most
off­
road
sources.
(
See
reference
18.)
Alth
no
specific
controls
have
been
required
to
date,
EPA
has
targe
nonroad
diesel
engines
for
first­
time
regulation.
Heavy­
duty
nonroad
(
farm
and
construction)
equipment
is
specifically
targeted,
but
recreational
boats
and
small
farm
and
garden
equipment
may
also
be
affected
by
future
regulations.

5.4
Control
Strategy
Documentation
for
Stationary
Sources
The
EPA
has
implemented
several
VOC
control
programs
either
through
the
promulgation
of
regulations,
or
by
issuing
guideline
documents
for
States
to
use
in
developing
their
own
regulations.

Under
section
111
of
the
Act,
EPA
has
promulgated
new
source
performance
standards
(
NSPS)
for
several
VOC
source
categories.

The
NSPS
are
national
standards
that
affect
new,
modified,
or
reconstructed
stationary
sources.
Under
section
112
of
the
Act,

EPA
has
promulgated
national
emission
standards
for
hazardous
air
pollutants
(
NESHAPS).
The
NESHAPS
are
national
standards
that
affect
existing
and
new
stationary
sources.
Some
of
the
NESHAPS
control
VOC
emissions
from
stationary
sources
because
the
NESHAPS
regulate
hazardous
air
pollutants
that
are
classified
as
VOC.
As
a
result
of
the
CAAA,
section
112
of
the
Act
was
amended
to
36
authorize
E
(
MACT)
stand
sources,
EPA
c
control
technolo
MACT.
The
MACT
a
standards
that
will
Information
on
altern
costs
used
to
support
NESHAPS
is
published
in
for
the
proposed
standards
technologies
and
associated
basis
for
future
NSPS,
NESHAP
also
expected
to
published
i
The
EPA
has
issued
CTG
documents
f
categories.
The
CTG
documents
recom
RACT
that
States
must
use
as
a
guidel
SIP's.
The
RACT
rules
adopted
by
State
sources.
The
CTG
documents
issued
before
into
Group
I,
II,
and
III
source
categorie
continuing
to
develop
CTG
documents
for
addi
categories.
The
EPA
also
publishes
alternativ
(
ACT)
documents
for
VOC
source
categories.
The
provide
technical
and
cost
information
on
emissio
techniques,
but
do
not
recommend
presumptive
levels
stationary
sources.
States
may
use
the
ACT
document
development
of
their
own
regulations.

The
purpose
of
section
5.4
of
this
document
is
to
provide
brief
overview
of
the
regulatory
programs
that
EPA
has
and
continue
to
implement,
and
to
provide
references
for
the
technical
and
cost
documentation
that
has
or
will
be
published
support
the
basis
for
the
regulatory
programs.

Information
on
the
status
of
EPA's
VOC
control
programs
is
available
through
the
Control
Technology
Center
(
CTC)
at
(
919)

541­
0800.
Copies
of
BID's
and
CTG
and
ACT
documents
can
be
obtained
for
a
fee
from
the
National
Technical
Information
Service:

National
Technical
Information
Service
(
NTIS)

5285
Port
Royal
Road
Springfield,
VA
22161
(
703)
487­
4600.

Information
on
control
technologies
is
also
available
through
certain
State
and
local
air
pollution
control
agencies.

The
EPA
focuses
its
efforts
on
controlling
VOC
emissions
from
source
categories
or
subcategories
that
have
a
larger
impact
on
national
VOC
emissions.
State
and
local
agencies
can
focus
efforts
on
source
categories
or
subcategories
important
in
their
specific
areas.
California's
South
Coast
Air
Quality
Management
37
District
(
S
stationary
(

its
1991
Air
Q
control
measures
list
of
stationar
Appendix
D
is
for
s
documents.
Copies
of
the
SCAQMD.

The
EPA
recognizes
that
so
Federal
regulations
for
oth
MACT)
may
not
be
promulgated
develop
and
adopt
RACT
rules
or
final
rate­
of­
progress
plans
(
du
In
general,
a
State
may
only
credi
toward
meeting
the
15
percent
VOC
em
requirements,
net
of
growth,
if
the
e
associated
with
control
measures
that
t
developed,
adopted,
and
included
in
its
r
In
general,
a
State
may
not
take
credit
fo
reductions
associated
with
Federal
regulatio
promulgated.
A
State
may
choose
to
revise
its
plan
after
November
15,
1993,
to
replace
existi
measures
with
new
control
measures
based
on
newly
documents
or
Federal
regulations.
The
EPA
is
curre
investigating
whether
and
under
what
circumstances
a
able
to
take
credit
for
unadopted
control
measures
in
of­
progress
plan.
Further
guidance
from
EPA
may
be
fort
Group
I
CTG
Documents
Prior
to
January
1978,
EPA
published
11
CTG
documents
for
15
source
categories.
These
Group
I
CTG
documents
were
summarized
in
a
December
1978
document
entitled
Summary
of
Group
I
Control
Technique
Guideline
Documents
for
Control
of
Volatile
Organic
Compound
Emissions
from
Stationary
Sources.
(
See
reference
19.)
The
summary
document
provides
the
main
ideas
found
in
the
actual
CTG
documents,
including
information
on
affected
facilities,
VOC
emissions,
available
control
technologies,
recommended
emissions
limits,
and
expected
control
costs.
The
information
in
the
summary
document
is
also
presented
in
the
EPA
document
entitled
Issues
Relating
to
VOC
Regulation
Cutpoints,
Deficiencies,
and
Deviations:
Clarification
to
Appendix
D
of
November
24,
1987
Federal
Register.
(
See
reference
20.)
The
VOC
source
categories
covered
by
the
Group
I
CTG
documents
are
as
follows:

!
Surface
coating
of
cans.

!
Surface
coating
of
metal
coils.

!
Surface
coating
of
paper
products.

!
Surface
coating
of
fabrics.

!
Surface
coating
of
automobiles
and
light­
duty
trucks.
38
!
Surface
co
!
Surface
coa
!
Surface
coati
!
Tank
truck
gaso
!
Bulk
gasoline
pl
!
Design
criteria
fo
gasoline
service
stat
!
Storage
of
petroleum
!
Refinery
vacuum
process
separators,
and
process
un
!
Solvent
metal
cleaning.

!
Use
of
cutback
asphalt.

Appendix
B
of
this
document
prov
of
the
Group
I
CTG
documents.

Group
II
CTG
Documents
The
EPA
published
eight
CTG
documents
bet
and
January
1979.
These
Group
II
CTG
docu
in
a
December
1979
document
entitled
Summary
Technique
Guideline
Documents
for
Control
of
V
Compound
Emissions
from
Stationary
Sources.
(
Se
The
summary
document
provides
the
main
ideas
foun
CTG
documents,
including
information
on
affected
fa
emissions,
available
control
technologies,
recommend
limits,
and
expected
control
costs.
The
information
i
summary
document
is
also
presented
in
the
EPA
document
e
Issues
Relating
to
VOC
Regulation
Cutpoints,
Deficiencies
Deviations:
Clarification
to
Appendix
D
of
November
24,
19
Federal
Register.
(
See
reference
22.)
The
VOC
source
categor
covered
by
the
Group
II
CTG
documents
are
as
follows:

!
Leaks
from
petroleum
refinery
equipment.

!
Surface
coating
of
miscellaneous
metal
parts
and
products.

!
Surface
coating
of
flat
wood
paneling.

!
Manufacture
of
synthesized
pharmaceutical
products.

!
Manufacture
of
pneumatic
rubber
tires.

!
Graphic
arts
­
rotogravure
flexography.

!
Petroleum
liquid
storage
in
external
floating
roof
tanks.

!
Leaks
from
gasoline
tank
trucks
and
vapor
collection
systems.

Appendix
B
of
this
document
provides
the
references
for
each
of
the
Group
II
CTG
documents.
39
Group
III
C
Since
Septembe
five
additional
prepared
for
the
entitled
Issues
Rel
Deficiencies,
and
Dev
November
24,
1987
Fede
affected
facilities,
VOC
technologies,
recommended
costs
presented
in
the
actu
The
VOC
source
categories
cov
are
as
follows:

!
Manufacture
of
high­
density
polye
polypropylene,
and
polystyrene
resin
!
Leaks
from
synthetic
organic
chemica
manufacturing
equipment.

!
Large
petroleum
dry
cleaners.

!
Air
oxidation
processes
in
synthetic
orga
manufacturing
industry.

!
Equipment
leaks
from
natural
gas/
gasoline
pro
plants.

Appendix
B
of
this
document
provides
the
references
of
the
Group
III
CTG
documents.

Model
RACT
Rules
On
June
24,
1992,
EPA's
Ozone/
Carbon
Monoxide
Programs
Branch
of
OAQPS
issued
a
final
set
of
model
RACT
rules
to
the
Regional
Offices.
(
See
reference
23.)
The
model
RACT
rules
co
29
CTG
source
categories.
The
model
rules
are
to
be
used
by
EPA's
Regional
Offices
as
a
template
for
proposing
Federal
implementation
plans
(
FIP's)
under
section
110(
c)(
1)
of
the
Act
for
areas
that
fail
to
submit
approvable
RACT
corrections
required
under
section
182(
a)(
2)(
A)
of
Act.
States
may
obtain
copies
of
the
model
rules
from
their
EPA
Regional
Office.

However,
the
model
rules
should
not
be
construed
to
be
operational
guidance
on
the
approvability
of
State
rules.
States
may
adopt
rules
that
are
different
from
the
model
rules
that
are
fully
approvable
for
a
SIP.
The
basis
by
which
State
rules
are
evaluated
and
findings
are
made
are
published
in
the
document
entitled
Issues
Relating
to
VOC
Cutpoints,
Deficiencies,
and
Deviations:
Clarification
to
Appendix
D
of
November
24,
1987
Federal
Register.
(
See
reference
24.)

A
generic
non­
CTG
RACT
rule
is
also
included
in
the
set
of
model
rules.
Where
insufficient
information
is
available
to
determine
RACT
for
a
source
or
source
category,
the
generic
non­

CTG
RACT
rule
may
be
considered
as
default
RACT.
However,
it
is
recommended
that
those
using
the
guidance
seek
additional
40
information
category
bec
RACT
is
on
a
c
Several
of
the
mo
measuring
capture
e
issued,
EPA's
OAQPS
w
reevaluate
EPA's
posit
Additional
guidance
will
Although
the
model
rules
ar
for
EPA
Regional
Offices
to
u
use
the
model
rules
as
examples
consistent
with
EPA
guidance.
A
rules
should
be
directed
to
Mr.
Da
(
919)
541­
3356.

New
CTG
Documents
Section
183(
a)
of
the
Act
requires
EPA
to
documents
for
11
stationary
VOC
source
categ
1993.
The
EPA
published
the
11
source
categor
will
develop
CTG
documents
in
Appendix
E
of
the
(
57
FR
18077).
The
source
categories
are
as
foll
!
SOCMI
distillation.

!
SOCMI
reactors.

!
SOCMI
batch
processing.

!
Wood
furniture.

!
Plastic
parts
coating
(
business
machines).

!
Plastic
parts
coating
(
other).

!
Web
offset
lithography.

!
Industrial
wastewater.

!
Autobody
refinishing.

!
Volatile
organic
liquid
storage
in
floating
and
fixed­

roof
tanks.

!
Clean­
up
solvents.

Draft
CTG
documents
have
been
prepared
for
SOCMI
batch
processing,
SOCMI
reactors
and
distillation,
autobody
refinishing,
volatile
organic
liquid
storage
in
floating
and
fixed­
roof
tanks,
coating
of
wood
furniture,
coating
of
plastic
parts,
and
web
offset
lithography.
The
references
for
these
draft
CTG
documents
are
presented
in
Appendix
B
of
this
document.

A
reference
best
available
control
technology
(
BACT)/
lowest
achievable
emission
rate
(
LAER)
determinations
for
industrial
wastewater
processes
is
also
provided
in
Appendix
B
of
this
document.

In
addition,
section
183(
b)
of
the
Act
requires
EPA
to
prepare
CTG
documents
for
two
additional
stationary
VOC
sources
by
November
15,
1993.
Section
183(
b)(
3)
requires
EPA
to
issue
a
41
CTG
documen
solvents.
S
to
control
VOC
in
ship
building
work
on
the
CTG
d
provided
in
Appendi
status
of
the
develop
copies
the
draft
an
be
obtained
through
EPA'

Section
182(
b)(
2)
of
the
Ac
implementation
of
RACT
ru
nonattainment
areas.
For
sourc
between
the
date
of
enactment
of
1990)
and
the
attainment
date
rules
must
be
implemented
according
the
CTG
document.
For
sources
covere
prior
to
enactment
of
the
CAAA
and
for
not
covered
by
a
CTG
document,
RACT
rules
EPA
by
November
15,
1992,
and
implemented
EPA
recognizes
the
potential
schedule
proble
RACT
rules
for
major
stationary
sources
by
Nov
which
may
be
covered
by
one
of
the
CTG
document
issue
in
November
1993.
Therefore,
EPA
has
estab
following
general
time
table
for
States
to
submit
t
rules
for
sources
that
are
identified
in
a
November
submittal
as
being
covered
by
a
post­
enactment
CTG
doc
!
On
November
15,
1992,
the
State
must
submit
a
list
of
major
stationary
sources
that
it
anticipates
will
be
subject
to
one
of
the
CTG
documents
being
prepared
for
the
13
stationary
VOC
source
categories
identified
above,
which
EPA
plans
to
issue
by
November
15,
1993.

!
For
those
major
sources
on
the
list
submitted
by
the
State
in
the
1992
submittal
that
are
not
covered
by
a
CTG
document
that
EPA
has
issued
by
November
15,
1993,

the
State
must
submit
a
RACT
rule
by
November
15,
1994
that
requires
implementation
of
RACT
by
May
15,
1995.

!
For
sources
covered
by
a
CTG
document
issued
under
section
183(
a)
and
for
which
the
State
has
not,
by
the
date
of
such
issuance,
adopted
an
approvable
RACT
rule,

the
State
must
submit
a
RACT
rule
in
accordance
with
the
time
schedule
set
forth
in
the
relevant
CTG
document.

!
For
sources
subject
to
a
RACT
rule
that
the
State
adopted
and
EPA
approved
under
section
182(
b)(
2)
prior
to
EPA's
issuance
of
an
applicable
CTG
document,
EPA
will
work
with
the
State
to
determine
whether
42
existing
ru
issued
that
For
further
deta
schedule
required
referred
to
Appendi
also
a
memorandum
fro
"
Determining
Applicabi
Control
Technique
Guidel
Non­
CTG
RACT
Rules
Prior
to
enactment
of
the
CAAA
require
non­
CTG
major
stationary
nonattainment
areas
that
emit
or
h
100
tons
per
year
(
tpy)
or
more
of
V
182
of
Act
lowered
the
emissions
of
"
major
stationary
source"
for
many
o
classifications.
The
major
stationary
so
serious,
severe,
and
extreme
ozone
nonatta
respectively,
50,
25,
and
10
tpy
or
more
of
major
stationary
source
threshold
for
marginal
nonattainment
areas
in
an
ozone
transport
regio
more
of
VOC
and
100
tpy
or
more
of
NOx
.
The
majo
source
threshold
for
attainment
areas
in
an
ozone
t
region
is
also
50
tpy
or
more
of
VOC
and
100
tpy
or
The
major
stationary
source
threshold
for
intrastate
m
moderate
areas
and
all
other
nonattainment
areas
(
i.
e.,

submarginal,
transitional,
and
incomplete/
no
data)
remain
100
tpy
or
more
of
VOC
or
NOx
.
Lowering
the
threshold
for
stationary
sources
will
increase
the
number
of
sources
subjec
non­
CTG
RACT
rules.
Emissions
reductions
associated
with
lowering
the
threshold
in
non­
CTG
RACT
rules
that
occur
prior
to
November
15,
1996
in
a
nonattainment
area
are
creditable
toward
the
15
percent
VOC
emissions
reduction
requirements,
net
of
growth.

ACT
Documents
The
EPA
has
published
ACT
documents
for
halogenated
solvent
cleaners,
application
of
traffic
markings,
automobile
refinishing,
ethylene
oxide
sterilization/
fumigation
operations,

and
organic
waste
processes.
The
references
for
ACT
documents
are
presented
in
Appendix
B
of
this
document.
The
ACT
documents
are
good
sources
of
technical
information,
including
emissions
control
technologies
and
expected
costs.
Unlike
CTG
documents,
ACT
documents
do
not
provide
recommended
RACT
limits.

The
five
ACT
documents
published
to
date
have
been
briefly
summarized
in
Appendix
E
of
this
document.
Information
on
these
and
new
ACT
documents
that
EPA
publishes
may
be
obtained
from
the
CTC.
43
New
Source
Under
section
control
VOC
emis
categories:

!
Bulk
gasoline
termin
!
Municipal
waste
combu
!
On­
shore
natural
gas
pr
leaks.

!
Petroleum
dry
cleaners.

!
Petroleum
refineries:
equip
!
Petroleum
refinery
wastewater
!
Polymer
manufacturing.

!
Publication
rotogravure
printing.

!
Rubber
tire
manufacturing.

!
Storage
vessels
for
petroleum
liquid
!
Storage
vessels
for
volatile
organic
l
!
Synthetic
fiber
production.

!
Surface
coating
operations:

!
Automobiles
and
light­
duty
trucks.

!
Beverage
cans.

!
Flexible
vinyl
and
urethane
coating
and
printing
!
Large
appliances.

!
Magnet
tape.

!
Metal
coil.

!
Metal
furniture.

!
Plastic
parts
for
business
machines.

!
Polymeric
coating
of
supporting
substrates.

!
Pressure
sensitive
tapes
and
labels.

!
SOCMI
air
oxidation
unit
processes.

!
SOCMI
distillation
unit
operations.

!
SOCMI
equipment
leaks.

Appendix
C
of
this
document
provides
the
Code
of
Federal
Regulation
(
CFR)
citations
for
the
NSPS,
and
EPA
publication
numbers
for
the
BID's
developed
to
support
the
technical
basis
for
the
NSPS.
The
BID's
contain
technical
information
on
the
emissions
sources
and
emissions,
alternative
controls
considered
during
the
development
of
the
NSPS,
the
performance
of
the
alternative
controls
evaluated,
and
estimated
control
costs.

On
May
30,
1991,
EPA
proposed
an
NSPS
to
control
air
emissions
from
municipal
waste
landfills
(
56
FR
24468).
The
NSPS
is
expected
to
be
promulgated
in
the
fall
of
1993.
The
proposed
NSPS
would
limit
emissions
from
certain
new
and
modified
landfills
and
would
establish
guidelines
for
States
to
follow
in
preparing
plans
to
limit
emissions
from
existing
landfills.

Technical
information
on
emissions
estimates
and
control
techniques
for
municipal
solid
waste
landfills
is
presented
in
44
the
documen
Landfills
­

Emission
Guide
regulations
shou
facilities
and
co
the
NSPS,
contact
E
Section
112
Standards
The
EPA
has
promulgated
NE
pollutants
from
followi
!
Vinyl
chloride
production
plan
!
Benzene
emissions
from
equipmen
!
Benzene
emissions
from
benzene
st
!
Benzene
emissions
from
coke
by­
prod
!
Benzene
emissions
from
benzene
trans
!
Benzene
waste
operations.

Appendix
C
of
this
document
provides
the
C
the
NESHAPS,
and
provides
EPA
publication
nu
developed
to
support
the
technical
basis
for
t
BID's
contain
technical
information
on
the
emis
emissions,
alternative
controls
considered
during
of
the
NESHAPS,
the
performance
of
the
alternative
evaluated,
and
estimated
control
costs.

The
EPA
will
be
developing
several
programs
to
control
hazardous
air
pollutants
under
section
112
of
the
Act.
M
the
hazardous
air
pollutants
are
covered
by
the
definition
VOC.
The
document
entitled
Guidance
on
the
Relationship
Betw
the
15
Percent
Rate­
of­
Progress
Plans
and
Other
Provisions
of
Clean
Air
Act
(
to
be
released
in
the
spring
of
1993)
provides
a
detailed
description
of
the
Federal
programs
that
will
be
developed
under
Section
112
of
the
Act.
The
programs
include
MACT
standards,
early
reduction
programs,
major
modifications
to
existing
sources,
and
standards
more
stringent
than
MACT
to
protect
the
public
health.
The
following
documents
have
been
published
for
early
reduction
programs:

!
Enabling
Document
for
Regulations
Governing
Compliance
Extensions
for
Early
Reductions
of
Hazardous
Air
Pollutants.
(
See
reference
26.)

!
Questions
and
Answers
about
the
Early
Reductions
Program.
(
See
reference
27.)

!
Procedures
for
Establishing
Emissions
for
Early
Reduction
Compliance
Extensions.
(
See
reference
28.)
45
On
July
16
revised
list
which
it
inten
September
24,
19
proposed
schedule
174
categories
and
schedule
for
preparin
in
September
of
1993.

The
EPA
proposed
a
rulemak
NESHAP
(
HON)
on
December
31
is
expected
to
be
promulgated
proposed
rule
would
regulate
th
air
pollutants,
all
of
which
are
processes
and
from
equipment
leaks
The
SOCMI
processes
include
process
storage
vessels,
and
wastewater
opera
processes
are
as
follows:

!
Styrene/
butadiene
rubber
products.

!
Polybutadiene
rubber
products.

!
Chlorine
production.

!
Pesticide
production.

!
Chlorinated
hydrocarbon
use.

!
Pharmaceutical
production.

!
Miscellaneous
butadiene
use.

Controls
must
installed
to
control
SOCMI
emissions
po
other
than
equipment
leaks
within
3
years
after
promulgat
the
rule.
The
compliance
schedule
for
the
equipment
leaks
SOCMI
and
the
seven
non­
SOCMI
processes
is
staggered,
startin
6
months
after
promulgation.
The
reader
is
referred
to
the
Federal
Register
notice
of
proposed
rulemaking
for
further
details.

The
EPA
proposed
a
NESHAP
for
coke
oven
batteries
in
1987.

On
December
4,
1992,
EPA
withdrew
the
1987
proposal
(
57
FR
57403)

and
proposed
a
new
NESHAP
for
coke
oven
batteries
(
57
FR
57534).

Although
the
BID
for
the
original
proposal
(
see
reference
29)
has
not
been
updated,
some
of
the
information
in
the
BID
is
still
relevant
to
the
new
proposal.
Materials
prepared
to
support
the
new
proposal
are
contained
in
the
docket
for
the
proposed
rulemaking.
The
NESHAP
is
expected
to
be
promulgated
in
the
spring
of
1993.

Other
Federal
Control
Measures
The
EPA
is
planning
to
prepare
VOC
control
measures
for
consumer
and
commercial
products,
adhesives,
application
of
agricultural
pesticides,
marine
vessel
loading
operations,

architectural
and
industrial
coatings,
autobody
refinishing,
and
ship
building
operations
and
ship
repair.
The
control
measures
4For
example,
some
RACT
rule
corrections
that
result
in
improved
RE
may
be
creditable;
a
discussion
of
this
appears
in
section
III.
3.
a.
4
of
the
General
Preamble
(
57
FR
13509).

46
for
these
s
documents,
o
status
of
the
issuing
to
suppo
these
source
document.

The
EPA
is
also
prepar
Conservation
and
Recover
emissions
from
hazardous
w
facilities
(
TSDF's).
Phase
June
21,
1990
(
55
FR
25454).

equipment
leaks
and
process
ven
emissions
estimates
and
control
by
the
Phase
I
standards
are
prese
Hazardous
Waste
TSDF's
­
Technical
G
Emissions
Standards
for
Process
Vents
reference
30.)
Phase
II
standards
were
(
56
FR
33490).
The
Phase
II
standards
ha
cover
tanks,
surface
impoundments,
contain
units.
Technical
information
on
emissions
e
techniques
for
facilities
covered
by
the
Phase
presented
in
the
document
entitled
Hazardous
Wa
Background
Information
for
Proposed
RCRA
Air
Emis
(
See
reference
31.)
The
Phase
II
standards
are
exp
promulgated
in
the
fall
of
1993.
The
Phase
I
and
II
should
be
consulted
for
the
definitions
of
the
affecte
facilities.
For
further
information
on
the
Phase
I
and
standards,
contact
EPA's
Emission
Standards
Division
of
O
5.5
Rule
Effectiveness
Improvements
Many
States
with
preexisting
nonattainment
areas
have
already
adopted
rules
defining
RACT
for
most
of
the
larger
sources,
including
major
non­
CTG
categories.
In
such
cases,

there
is
considerable
concern
about
what
additional
measures
are
needed
to
meet
the
15
percent
VOC
rate­
of­
progress
requirement.

One
method
of
achieving
creditable
emissions
reductions
from
stationary
sources
in
such
areas
is
to
improve
the
implementation
of
existing
regulations.
This
is
referred
to
as
RE
improvement.

These
improvements
are
subject
to
the
same
creditability
constraints
as
are
the
other
emissions
reductions.
4
Rule
effectiveness
improvements
must
reflect
real
emissions
reductions
resulting
from
specific
implementation
program
improvements.

Actual
emissions
reductions
must
result
from
improving
RE;
simply
calculating
a
higher
RE
using
a
different
methodology
is
not
creditable.
47
Rule
effect
minimum
by
c
implementation
emissions
study
creditable
RE
imp
implementation
Stat
Protocol
Study
be
con
post­
RE
improvement
im
For
example,
if
the
RE
i
the
emissions
reductions
a
be
creditable.
The
second
value
of
80
percent
for
R
effectiveness
improvement
progr
SSCD
protocol
study
show
85
perc
increase
in
emissions
reductions
a
from
80
to
85
percent
would
be
credi
rate­
of­
progress
requirement.
Additi
including
provisions
for
the
calculatio
specific
RE
factors,
is
available
in
Guid
and
Applying
Rule
Effectiveness
for
Ozone/

Plan
Base
Year
Inventories.
(
See
reference
3
If
a
State
can
show
an
improvement
in
the
RE
of
provision
(
for
further
information
refer
to
the
D
memorandum
from
John
B.
Rasnic,
Director
SSCD,
to
R
Division
Directors,
regarding
"
Revised
Rule
Effectiv
National
Protocol")
above
the
default
value
through
th
EPA
protocol
test,
then
the
emissions
reductions
associa
the
improvement
would
be
creditable
toward
meeting
the
15
VOC
emissions
reduction
requirement.
If
the
EPA
protocol
t
for
the
effectiveness
of
a
SIP
rule
indicates
that
the
RE
was
less
than
the
default
value,
further
reductions
would
be
necessary
to
meet
the
statutory
requirements.

The
EPA
plans
to
issue
guidance
on
the
quantification
of
RE
improvements
in
early
Spring
1993.
Suggested
measures
for
improving
RE
are
as
follows:

Agency
Compliance
!
Increase
number
of
people
in
inspection
program.

!
Increase
frequency
and
nature
of
inspections.

!
Implement
and
improve
recordkeeping
requirements
(
perhaps
automated
to
estimate
that
they
are
in
compliance
over
time).

!
Improve
follow­
up
program
once
violations
are
found.

!
Establish
a
formal
documentation
and
enforcement
system.

!
Implement
an
SSCD
protocol
which
is
self­
monitoring.

!
Facilitate
communication
through
publicity.
48
Source
!
Implement
int
and
trigger
reme
program.

!
Improve
adequacy
o
!
Assign
responsible
p
!
Implement
a
periodic
follow­
up
to
evaluate
th
!
Implement
an
SSCD
protoco
Improvements
in
Technology
!
Implement
an
operation
and
main
control
equipment
(
e.
g.,
monitorin
for
the
equipment).

Education
!
Increase
training
of
plant
operators.

!
Require
qualified
and
trained
inspectors.

!
Implement
periodic
updating
of
training
prog
periodic
training.

Rules
!
Revise
complex
and
ambiguous
rules.

!
Create
methodologies
to
simplify
rules.

The
following
items
provide
several
suggestions
for
what
EP
will
accept
in
a
State's
SIP
to
demonstrate
adoption
and
implementation
of
RE
improvements:
adoption
of
a
rule,
a
lett
to
the
Governor,
additional
staff,
or
incorporation
of
the
activity
in
a
permit.
The
RE
improvements
will
be
evaluated
on
a
case­
by­
case
basis.
Other
guidance
on
evidence
of
adoption
and
commitment
is
found
on
pages
218­
220
in
Workshop
on
Requirements
for
Nonattainment
Area
Plans.
(
See
reference
33.)

5.6
Quantification
of
Rule
Effectiveness
Improvement
Programs
In
order
to
estimate
the
amount
of
creditable
emissions
reductions
from
RE
improvements,
States
will
need
to
calculate
the
RE
values
associated
with
their
improvement
programs.
These
values
will
be
developed
using
a
methodology
similar
to
that
for
calculating
the
base
year
RE
values.

The
EPA
is
currently
developing
a
list
of
specific
control
measures
that
will
yield
real
improvements
in
RE.
A
group
of
experienced
compliance
experts,
comprising
State
and
local
agencies,
EPA
Regional
Offices,
and
EPA
Headquarters,
will
assess
the
relative
weights
for
the
groups
of
measures.
Furthermore,

some
groups
of
measures
will
also
contain
several
different
49
possible
le
regulation,"

in
rule").
Th
relative
to
one
Delphi
method
to
method
involves
the
subject,
the
compilat
of
an
average
opinion
opinions.)
The
States
w
group
by
multiplying
the
w
weight
of
its
group.
The
v
score,
which
would
be
an
init
value.

The
table
will
also
include
instru
decreasing
the
weight
if
it
is
deter
activities
or
conditions
performed
si
enhanced
or
decreased
effect
on
RE.

improvement
measures,
the
weights
that
EP
measures,
and
the
description
of
how
the
s
compute
the
improved
RE
will
be
provided
in
guidance
expected
in
Spring
1993.
51
6.0
CONTROL
6.1
Introductio
This
section
disc
projections,
ty
developed
to
meet
the
plans,
and
several
alt
used
to
calculate
the
19
for
point,
area,
and
mobil
nonattainment
areas
that
wi
demonstrate
attainment
with
t
documentation
for
projected
emi
both
VOC
and
NOx
in
their
SIP
sub
plan
to
account
for
CO
emissions
i
also
provide
documentation
for
a
pro
for
1996
in
their
SIP
submittals.
Th
section
is
applicable
for
projecting
VO
In
general,
projection
year
emissions
are
allowable
ozone
season
typical
weekday
emiss
discussed
in
section
2.4
of
this
document,
EPA
1)
there
are
time
constraints
related
to
assimi
allowable
emissions
limit
data
into
a
usable
form
assumption
that
all
sources
in
a
nonattainment
area
at
their
allowable
emissions
limit
may
not
be
valid.

as
an
alternative
to
using
allowable
emissions
for
pro
EPA
believes
it
is
appropriate
use
actual
emissions
i
circumstances.
For
sources
or
source
categories
that
are
currently
subject
to
a
regulation
and
the
State
does
not
anticipate
subjecting
the
source(
s)
to
additional
regulation
projected
emissions
may
be
based
on
actual
emissions.
In
addition,
for
sources
or
source
categories
that
are
currently
unregulated
and
are
not
expected
to
be
subject
to
future
regulations,
the
projected
emissions
may
be
based
on
actual
emissions.
For
all
other
sources,
i.
e.,
sources
that
are
expected
to
be
subject
to
additional
regulation,
the
projections
should
be
based
on
the
new
allowable
emissions
(
including
RE).

The
reader
is
referred
to
section
2.4
of
this
document
for
detailed
guidance
on
EPA's
policy
concerning
the
use
of
actual
or
allowable
emissions
for
emissions
projections.

The
States
will
have
the
responsibility
to
adequately
document
which
projection
methodology
is
used
so
that
EPA
will
have
access
to
the
documentation
during
the
SIP
review
process
and
for
subsequent
review
of
emissions
reduction
credits.
The
purpose
of
this
section
is
to
describe
and
illustrate
the
various
projection
methodologies
which
States
can
use
for
preparing
emissions
projections.
52
6.2
Purpose
The
purpose
of
determine
the
em
reasonable
furthe
NAAQS.
After
the
e
must
then
prepare,
ad
control
measures
neede
Projection
year
emission
weekday
emissions.

Actual
emissions,
for
purpose
based
on
a
source's
actual
oper
control
equipment
for
the
proces
Actual
emissions
take
into
conside
operations
are
consistent
and
when
d
operating
conditions
occur.

Allowable
emissions,
for
the
purposes
of
be
based
on
expected
future
operating
cond
or
throughput
and
hours
of
operation)
ma
limits.
Maximum
emissions
may
be
proce
factors
[
e.
g.,
pounds
of
VOC
per
gallon
(
lb
VOC
applied,
lb
VOC/
ton
processed],
capture
and/
or
co
efficiencies,
or
emissions
rate
limits
(
e.
g.,
tpy,

Emissions
factor
limits
and
capture
and/
or
control
d
efficiency
limits
should
take
precedence
over
(
time­
based)
when
both
are
available.
In
determi
maximum
emissions
limit,
existing
regulations
and
permits
considered
in
addition
to
future
planned
regulations
and
pe
modifications.

Emissions
rate
limits
(
mass/
time)
should
only
be
used
if
there
are
procedures
for
demonstrating
compliance
with
these
limits.
Emissions
rate
limits
may
be
expressed
as
annual
ton­

per­
year
limits
(
long­
term)
or
short­
term
limits
on
a
monthly,

daily,
or
hourly
basis
(
e.
g.,
lb/
day).
The
permit
must
contain
a
method
for
determining
compliance
with
these
limits.
Long­
term
(
e.
g.,
annual
average)
limits
should
be
used
in
the
calculation
of
projection
year
emissions.
Short­
term
limits
[
e.
g.,
lb/
day
or
pounds
per
hour
(
lb/
hr)]
may
be
based
on
maximum
operating
conditions
to
allow
for
fluctuations
in
operation.
If
an
emissions
rate
limit
(
mass/
time)
is
used,
annual
long­
term
limits
should
be
converted
to
daily
limits
based
on
the
source's
operating
schedule.
The
long­
term
limits
are
more
representative
of
expected
activity,
while
the
short­
term
limits
are
more
representative
of
maximum
activity.
53
The
followi
projections
!
Growth
factors
!
Control
efficien
!
RE.

!
Rule
penetration.

6.3
Types
of
Emissions
Pr
The
Current
Control
Project
emissions,
accounti
by
November
1990
(
whether
or
no
and
growth.
The
Control
Strateg
year
allowable
emissions
accountin
(
those
that
are
not
yet
in
the
SIP)

Control
Projection
incorporates
growt
adjusts
the
emissions
to
reflect
existi
conditions.
The
Control
Strategy
Project
Current
Control
Projection
by
incorporatin
strategies.
These
future
control
strategies
areawide
regulations
affecting
a
source
catego
source.

The
Current
Control
Projection
is
used
to
assess
th
additional
reductions
needed
by
an
area
to
meet
1996
progress
(
moderate
and
above
areas
must
meet
the
15
pe
emissions
reduction
requirements,
net
of
growth)
and/
or
attainment
date
deadlines
(
November
1993
for
marginal
are
November
1996
for
moderate
areas).
The
Current
Control
Projection
reflects
existing
control
levels,
which
are
adjust
to
reflect
the
allowable
emissions
factors
or
mass
emissions
rates.

The
Control
Strategy
Projection
will
reflect
the
controls
mandated
by
the
CAAA,
plus
additional
controls
needed
to
meet
rate­
of­
progress
targets.
It
is
anticipated
that
several
iterations
of
the
Control
Strategy
Projection
will
be
completed
to
determine
the
mix
of
control
measures
needed
to
meet
the
rate­

of­
progress
targets,
taking
into
account
the
costs
of
these
measures.

6.4
Methods
for
Calculating
Point,
Area,
and
Mobile
Source
1996
Projection
Year
Emissions
The
following
discussion
is
divided
into
separate
sections
for
point,
area,
and
mobile
sources,
because
the
methods
for
calculating
the
1996
projection
year
emissions
differ
for
these
three
emissions
source
types.
Detailed
projection
equations
are
presented
for
point
sources.
The
equations
presented
for
area
and
mobile
sources
parallel
those
used
within
AIRS­
AMS.
The
last
section
is
a
brief
discussion
of
the
projection
equations
from
54
EPS,
which
projections.

sources
can
be
emissions.

The
EPA
is
in
the
p
projections
computer
projected
inventories.

parallel
those
used
in
E
be
used
strictly
for
prepa
as
a
preprocessor
for
prepa
produce
transaction
files
for
AIRS
after
the
necessary
data
e
States
may
also
complete
their
p
equations
presented
in
the
followi
that
these
detailed
equations
will
p
projections.
However,
projection
yea
of
these
options
will
be
accepted
by
EP
Point
Source
Emissions
Projections
This
section
presents
five
equations
for
calcu
1996
projection
year
emissions.
The
equations
assume
that
the
calculations
will
be
on
a
source­

The
following
data
are
needed
to
calculate
1996
pro
emissions:

!
Base
Year
(
1990)
Data:

$
Operating
rate
(
ozone
season).

$
Emissions
(
ozone
season).

$
Emissions
factor.

$
Control
efficiency
(
capture
and
control
device
efficiency).

$
RE.

!
Projection
Year
Data:

$
Growth
factor.

$
Allowable
limits
­­
emissions
factor.

control
efficiency.

emissions
rate.

$
RE.

All
of
the
base
year
data
may
not
be
appropriate
for
the
projection
year
emissions
calculations.
If
the
base
year
emissions
are
calculated
by
using
emissions
factors,
the
projection
year
emissions
can
be
calculated
in
the
same
manner
using
the
operating
rate
(
with
consideration
of
RE)
(
e.
g.,

emissions
factor
*
operating
rate
*
RE
factor
*
growth
factor
=

emissions
for
projection
year).
If
other
methods
were
used
to
estimate
base
year
emissions
(
e.
g.,
material
balance,
stack
test),
the
emissions
projection
calculation
will
be
obtained
by
55
S
PY

ORATE
BY,
O

EMF
PY,
pc

1

CE
PY
100
RE
PY
100

(
1)
applying
RE
being
based
The
calculation
depends
on
the
me
(
factor
m
the
form
of
the
allow
presented
below
for
pr
followed
by
examples
ill
equations
are
appropriate
Some
of
the
following
equatio
coating
sources
that
are
expres
unit
of
production
(
e.
g.,
lb
VOC
VOC
RACT
rules
should
already
be
e
as
lb
VOC/
gal
of
coating
minus
water
calculating
base­
or
future­
year
emis
maintain
consistency
between
the
VOC
co
units.
If
volume
of
coating,
including
w
solvents,
is
the
only
form
of
records
kept
production,
then
the
VOC
content
must
be
adj
regulatory
limit
to
be
consistent
with
the
uni
used
to
calculate
base­
or
future­
year
emission
Equation
1
­
Projection
calculated
from
base
year
operating
rate,
uncontrolled
or
precontrol
emissions
factor,
control
efficiency,
RE,
and
growth
factor
This
equation
should
be
applied
when
the
base
year
emissi
are
calculated
by
the
emissions
factor
method
and
control
efficiencies
are
used
to
reflect
current
or
future
control
strategies.
In
these
cases,
the
base
year
emissions
are
calculated
from
the
operating
rate,
base
year
emissions
factor,

control
efficiency
(
current
or
future),
and
RE.

The
equation
for
projecting
emissions
in
this
case
is:

where:
EMISPY
=
Projection
year
emissions
­
ozone
season
typical
weekday
(
mass
of
pollutant/
day)

ORATEBY,
O
=
Base
year
operating
rate
(
activity
level)
­
ozone
season
daily
(
production
units/
day)

EMFPY,
pc
=
Projection
year
precontrol
emissions
factor
(
mass
of
pollutant/
production
unit)

CEPY
=
Projection
year
control
efficiency
(
percent)
56
EMIS
PY

ORATE
BY,
O

EMF
PY

(
200

RE
PY)
100

GF
(
2)
REPY
=
Projec
GF
=
Growth
fa
The
precontrol
e
of
VOC
per
produc
the
control
is
refl
than
through
a
reduce
If
the
projection
year
c
reflect
current
regulatory
projection
year
emissions
w
If
the
control
efficiency
and
strategies,
then
the
emissions
Strategy
Projection.

Equation
2
­
Projection
calculated
from
base
year
operating
rate,
allowable
(
post­
control)
emissions
factor,
RE,
and
growth
factor
This
equation
should
be
applied
when
the
are
calculated
by
the
emissions
factor
met
factor
accounts
for
the
control
level
for
th
The
equation
for
projecting
emissions
in
this
c
where:
EMISPY
=
Projection
year
emissions
­
ozone
season
typical
weekday
(
mass
of
pollutant/
day)

ORATEBY,
O
=
Base
year
operating
rate
(
activity
level)
­
ozone
season
daily
(
production
units/
day)

EMFPY
=
Projection
year
(
post­
control)
emissions
factor
(
mass
of
pollutant/
production
unit)

REPY
=
Projection
year
RE
(
percent)

GF
=
Growth
factor
(
dimensionless)

Current
Control
Projection
emissions
in
this
case
are
calculated
if
the
projection
year
emissions
factor
and
RE
values
represent
current
regulatory
or
permit
conditions
and/
or
actual
conditions
where
appropriate
(
see
section
2.4
of
this
document).

Control
Strategy
Projection
emissions
in
this
case
are
calculated
if
the
projection
year
emissions
factor
and
RE
values
represent
future
control
strategies
or
regulations
developed
to
meet
rate­

of­
progress
targets.

Equation
(
2)
will
be
used
for
emissions
factor­
based
control
measures
such
as
solvent
content
limits
on
surface
coating.

These
projections
must
also
account
for
RE.
The
factor
[(
200
­

REPY
)/
100]
adjusts
emissions
for
RE.
With
a
RE
of
80
percent,
57
EMIS
PY

EMIS
BY,
O

1

CE
PY
100
RE
PY
100
1

CE
BY
100
RE
BY
100

GF
(
3)
emissions
w
applying
RE
follows:

Uncontrolled
Emissions
(
lb/
day)
Control
Efficiency
(%)
Controlled
Emissions
(
100%
RE)
Controlled
Emissions
(
80%
RE)

RE
Factor
100
99
1
20.8
20.8
100
98
2
21.6
10.8
100
95
5
24.0
4.8
100
90
10
28.0
2.8
100
80
20
36.0
1.8
100
50
50
60.0
1.2
100
30
70
76.0
1.1
The
factor
[(
200
­
RE)/
100]
is
equivalent
emissions)
of
applying
RE
to
a
50
percent
If,
for
instance,
the
allowable
(
post­
contro
is
converted
to
a
percentage
reduction
from
th
emissions
factor
and
used
as
the
projection
yea
efficiency
in
equation
(
1),
different
results
may
depending
on
how
much
the
resulting
percentage
redu
from
50
percent.
The
[(
200
­
REPY
)/
100]
factor
is
no
low
RE
values.

Equation
3
­
Projection
calculated
from
base
year
actual
emissions,
future
control
levels,
RE,
and
growth
factor
This
equation
will
be
used
for
processes
where
the
base
year
emissions
are
calculated
by
material
balance,
stack
test,
or
any
method
other
than
an
emissions
factor.
This
equation
can
be
applied
without
using
the
process
or
operating
rate
for
the
source.

The
equation
for
projecting
emissions
in
this
case
is:

where:
EMISPY
=
Projection
year
emissions
­
ozone
season
typical
weekday
(
mass
of
pollutant/
day)

EMISBY,
O
=
Base
year
ozone
season
actual
emissions
(
mass
of
pollutant/
day)
58
EMIS
PY

EMIS
BY,
O

(
200

RE
PY)
100
(
200

RE
BY)
100

EMF
PY
EMF
BY

G
(
4)
CEPY
=
Projec
(
percent)

REPY
=
Projection
CEBY
=
Base
year
c
REBY
=
Base
year
RE
GF
=
Growth
factor
(
d
Current
Control
Projec
calculated
if
the
projec
existing
regulatory
or
per
projection
year
and
base
ye
equivalent
if
the
base
year
c
conditions.
Since
base
year
em
allowable
conditions,
the
base
y
higher
than
allowable
efficien
mandated
by
existing
regulations/

Control
Strategy
Projection
emissions
i
calculated
if
the
projection
year
control
future
control
measures.

Equation
4
­
Projection
calculated
from
base
year
actual
emissions,
emissions
factor­
based
control
levels,
RE,
and
growth
factor
This
equation
will
be
used
for
processes
where
the
b
emissions
are
calculated
by
material
balance,
stack
te
method
other
than
emissions
factors.
Equation
(
4)
must
for
emissions
factor­
based
control
measures
such
as
solve
content
limits
on
surface
coating
if
the
operating
rate
is
unavailable.
This
equation
differs
from
equation
(
3)
in
that
control
levels
are
represented
by
emissions
factors
rather
tha
control
efficiencies.

The
equation
for
projecting
emissions
in
this
case
is:

where:
EMISPY
=
Projection
year
emissions
­
ozone
season
typical
weekday
(
mass
of
pollutant/
day)

EMISBY,
O
=
Base
year
ozone
season
actual
emissions
(
mass
of
pollutant/
day)

REPY
=
Base
year
RE
(
percent)

REBY
=
Projection
year
RE
(
percent)

EMFPY
=
Projection
year
emissions
factor
(
mass
of
pollutant/
production
unit)
59
EMIS
PY

ER
PY

EMIS
BY,
O
EMIS
BY,
Annual
(
5)
EMFBY
=
Base
of
pollutant
GF
=
Growth
fact
Emissions
for
the
are
calculated
when
values
represent
exis
the
Current
Control
Pr
factor
may
be
equivalent
actual
conditions
are
equi
than)
regulatory
or
per
Control
Strategy
Projection
emi
calculated
by
using
the
future
c
and
RE
values
in
equation
(
4).

These
projections
must
also
account
f
[(
200
­
RE)/
100]
adjusts
emissions
for
80
percent,
emissions
will
be
adjusted
by
This
is
equivalent
to
the
impact
(
on
emiss
80
percent
RE
to
a
50
percent
control
effici
instance,
the
allowable
emissions
factor
is
co
percentage
reduction
from
the
precontrol
emissi
and
used
as
the
projection
year
control
efficienc
(
3),
different
results
may
be
produced
depending
on
the
resulting
percentage
reduction
varies
from
50
pe
The
[(
200
­
RE)/
100]
factor
is
not
valid
for
low
RE
va
Equation
5
­
Projection
calculated
from
permitted
emissions
rates
Permits
often
express
limitations
in
terms
of
mass
emissions
rates
(
hourly,
daily,
monthly,
or
annual
maximums).
These
emissions
rates
will
require
different
processing
than
the
emissions
factor
limits
described
for
equations
(
1),
(
2),

and
(
4).
Long­
term
(
e.
g.,
annual)
rates
should
be
used
as
an
estimate
of
the
allowable
emissions.
The
long­
term
limit
must
be
converted
to
an
ozone
season
typical
weekday
limit.

The
equation
for
projecting
emissions
in
this
case
is:

where:
EMISPY
=
Projection
year
emissions
ozone
season
typical
weekday
(
mass
of
pollutant/
day)

ERPY
=
Projection
year
annual
emissions
cap
(
mass
of
pollutant/
year)

EMISBY,
O
Base
year
ozone
season
typical
weekday
emissions
(
mass
of
pollutant/
day)
60
EMISBY,
Annual
=

pollutant/
ye
The
factor
EMISB
emissions
cap
to
using
the
ratio
of
annual
emissions.
No
must
be
equivalent
in
Emissions
for
the
Current
in
this
case
if
the
annual
permit
conditions.
Emissions
are
calculated
if
the
annual
em
emissions
cap
for
the
source.
I
conditions
are
in
the
form
of
emis
efficiencies,
then
the
Control
Strat
should
be
calculated
using
either
equ
(
4).

Special
Cases
­
Use
of
several
equations
Some
situations
will
not
fall
under
a
single
m
identified
above,
but
will
require
the
use
of
s
One
situation
requiring
special
processing
is
for
do
not
have
process­
specific
limits
but
do
have
fac
limits.
An
allocation
should
be
developed
to
estima
specific
limits
for
the
facility.
The
equations
above
be
used
to
calculate
projection
year
emissions.

Emissions
Projections
Examples
for
Point
Sources
The
following
examples
illustrate
the
application
of
the
above
equations
for
projecting
emissions.

1.
Surface
Coating:
Solvent
Content
Based
Regulations
Base
Year
Ozone
Season
Operating
Conditions:

Operating
rate
=
10
gal
coating/
day
Emissions
factor
=
2.6
lb
VOC/
gal
coating
(
Base
year
emissions
are
calculated
from
the
solvent
usage
rate
and
the
emissions
factor.
The
emissions
factor
must
be
in
terms
of
VOC,
excluding
water
and
exempt
solvents)

Projection
Year
Conditions:

Growth
factor
=
1.2
(
dimensionless)

Current
regulatory
emissions
limit
=
2.8
lb
VOC/
gal
coating
Control
efficiency
=
not
required
for
equation
RE
=
80
percent
61
EMIS
PY

ORATE
BY,
O

EMF
PY

(
200

RE
PY)
100

GF
(
2)

EMIS
PY

10

2.8

200

80
100

1.2

40.3
lb
VOC/
day
Control
Strategy
Emissions
Factor

2.6
lb
VOC/
gal
coating
EMIS
PY

10

2.6

200

80
100

1.2

37.4
lb
VOC/
day
Since
the
e
emissions
fa
projection
yea
ORATEBY,
O
=
10
gal
co
EMFPY
=
2.8
lb
VOC/
gal
GF
=
1.2
(
dimensionless
REPY
=
80
percent
Projection
year
emissions
Since
the
emissions
factor
represents
current
reg
conditions,
this
projection
reflects
the
Current
Co
Projection
for
this
case.
Rule
effectiveness
must
b
for
in
the
emissions
projection
since
not
all
sources
complying
and
future
emissions
are
not
calculated
by
dir
determination.

The
State
may
decide
to
restrict
this
operation
to
the
2.6
lb
VOC/
gal
coating
emissions
level
(
2.8
lb
VOC/
gal
coating
the
requirement)
or
lower
through
a
new
regulation
or
by
permit
conditions.
The
State
would
use
this
new
emissions
factor
limit
to
calculate
projection
year
emissions
for
the
Control
Strategy
Projection
for
this
case
as
follows:

If
the
throughput
is
in
units
incompatible
with
the
emissions
factor
(
VOC
content)
limit,
then
one
of
the
parameters
must
be
converted
for
use
in
the
equation.
For
example,
flatwood
coaters
may
report
operating
rates
in
terms
of
1,000
square
feet
coated.
These
units
are
compatible
with
the
Federal
(
AP­
42)
62
EMIS
PY

EMIS
BY,
O

(
200

RE
PY)
100
(
200

RE
BY)
100

EMF
PY
EMF
BY

G
(
4)

EMIS
PY

40

(
200

80)

100
/
(
200

80)

100

2.8
2.6

1.2

51.7
lb
VOC/
day
emissions
f
In
most
case
coating
used
f
gallons
of
coati
yield
a
limit
in
be
used
in
equation
This
example
illustrat
emissions
projections.

factor­
based
controls
such
be
used
if
the
base
year
op
example
also
illustrates
the
Control
Projection
and
the
Cont
2.
Surface
Coating:
No
Throughput
If
the
throughput
is
unavailable,
or
incompatible
with
the
base
year
and
all
equation
(
4)
must
be
used
to
calculate
al
Material
balances
may
be
used
to
calculate
rather
than
emissions
factor
methods
which
u
emissions
factors.

Base
Year
Operating
Conditions:

Emissions
=
40
lb
VOC/
day
Emissions
factor
=
2.6
lb
VOC/
gal
coating
Projection
Year
Conditions:

Growth
factor
=
1.2
(
dimensionless)

Current
regulatory/
permit
emissions
limit
=
2.8
lb
VOC/
gal
coating
Variables
in
equation
(
4)
are
EMISBY,
O
=
40
GF
=
1.2
REPY
=
80
REBY
=
80
EMFPY
=
2.8
EMFBY
=
2.6
63
3.5
lb
VOC/
gal
coating

gal
coating
0.524
gal
solids

6.68
lb
VOC/
gal
solids
60
gal
solids/
day

6.68
lb
VOC/
gal
solids

400.8
lb
VOC/
day
Since
the
c
in
the
emiss
Projection
emi
This
example
uses
Equation
(
4)
is
use
strategies
such
as
VO
operating
rates
are
un
available,
equation
(
2)

3.
Surface
Coating:
Control
Limits
Surface
coating
regulatory
condi
control
device
or
by
the
use
of
lo
emissions
factor
should
be
converted
applied"
basis
for
calculating
emissi
widely
in
VOC
content
will
also
vary
in
lower­
solids
coating
would
be
required
to
area.
This
factor
is
accounted
for
by
con
lb
VOC/
gal
solids
basis.
(
In
example
1,
whi
2.8
lb
VOC/
gal
coating
to
the
2.6
lb
VOC/
gal
c
assumed
that
the
solids
contents
were
equivalen
of
this
assumption
decreases
as
the
difference
increases.)

Base
Year
Operating
Conditions:

Operating
Rate
=
60
gal
solids/
day
VOC
content
=
3.5
lb
VOC/
gal
coating
Control
efficiency
=
0
percent
RE
=
N/
A
Solids
content
=
52.4
percent
Solvent
content
=
47.6
percent
The
base
year
emissions
factor
is
calculated
as:

The
base
year
emissions
are
calculated
as:

In
the
first
case,
assume
the
coater
meets
the
regulatory
condition
of
2.8
lb
VOC/
gal
coating
by
using
low­
solvent
coating.

The
projection
year
emissions
would
be
calculated
using
equation
(
2).

Projection
Year
Conditions:

Growth
factor
=
1.2
(
dimensionless)

VOC
content
limit
=
2.8
lb
VOC/
gal
coating
VOC
density
=
7.36
lb
VOC/
gal
VOC
64
RE
=
80
perce
65
2.8
lb
VOC/
gal
coating

1
gal
VOC
7.36
lb
VOC

0.380
gal
VOC/
gal
coating
1

0.380

0.620
gal
solids/
gal
coating
2.8
lb
VOC/
gal
coating

1
gal
coating
0.620
gal
solids

4.52
lb
VOC/
gal
solids
EMIS
PY

ORATE
BY,
O

EMF
PY

(
200

RE
PY)
100

GF
(
2)

EMIS
PY

60

4.52

(
200

80)

100

1.2

390.5
lb
VOC/
day
S
PY

ORATE
BY,
O

EMF
PY,
pc

1

CE
PY
100
RE
PY
100

(
1)

EMIS
PY

60

6.68

1

50
100
80
100

1.2

288.6
lbs
VOC/
day
The
project
Projection
year
emissions
are
In
the
second
case,
assume
the
regulatory
condition
is
the
form
of
a
control
efficiency.

Projection
Year
Conditions:

Growth
factor
=
1.2
(
dimensionless)

Control
efficiency
=
50
percent
RE
=
80
percent
Equation
(
1)
is
used
to
calculate
projection
year
emissions
as
follows:

This
example
illustrates
the
difference
in
the
calculation
of
projection
year
emissions
for
surface
coating
when
a
control
efficiency
rather
than
a
lower
VOC
content
coating
is
specified
in
the
control
measure.
66
EMIS
PY

EMIS
BY,
O

1

CE
PY
100
RE
PY
100
1

CE
BY
100
RE
BY
100

GF
(
3)

EMIS
PY

120

(
1

(
0.95)(
0.80))

(
1

(
0.98)(
0.80))

1.05

140
lb/
day
4.
Control
E
Some
permits
a
efficiency
with
equation
(
1)
or
e
availability
of
the
In
some
cases,
the
reg
exceeded
by
the
source.

Current
Control
Projection
permitted
rather
than
actua
Base
Year
Conditions:

Emissions
120
lb
VOC/
day
Control
efficiency
=
98
percent
RE
=
80
percent
Operating
rate
=
not
available
Projection
Year
Conditions:

Growth
factor
=
1.05
(
dimensionless)

Permitted
efficiency
=
95
percent
RE
=
80
percent
Equation
(
3)
is
used
to
calculate
Current
Control
emissions
as
follows:

In
order
to
retain
the
base
year
efficiency
of
98
percent,
a
permit
modification
would
have
to
be
made
or
a
new
regulation
would
have
to
be
promulgated
changing
the
legally
enforceable
efficiency
to
98
percent.
This
would
then
be
reflected
in
the
Control
Strategy
Projection.

This
example
illustrates
the
use
of
equation
(
3)
for
control
device/
efficiency­
based
control
strategies.
Equation
(
1)
or
(
3)

should
be
used
for
control
efficiency­
based
strategies.

Equation
(
3)
is
used
if
the
operating
rate
is
unavailable.
67
S
PY

ORATE
BY,
O

EMF
PY,
pc

1

CE
PY
100
RE
PY
100

(
1)

EMIS
PY

30

90

1

60
100
80
100

1.3

1,825
lb
VOC/
day

0.9
tons
VOC/
day
S
PY

ORATE
BY,
O

EMF
PY,
pc

1

CE
PY
100
RE
PY
100

(
1)
5.
Synthetic
Equation
(
1)
c
base
year
operat
The
base
year
ope
using
the
growth
fa
The
base
year
operatin
product
per
day.
The
un
VOC
per
ton
of
product.
T
install
a
carbon
adsorber
w
efficiency
of
60
percent.
Th
follows:

ORATEBY,
O
=
30
tons
product/
day
EMFPY,
pc
=
90
lb
VOC/
ton
product
CEPY
=
60
percent
REPY
=
80
percent
GF
=
1.3
(
dimensionless)

These
are
applied
to
equation
(
1)
as
follows
Since
this
reflected
a
future
control
strategy,
the
emissions
projection
will
be
the
Control
Strategy
Projection.

The
Current
Control
Projection
would
be
calculated
using
the
current
control
efficiency
of
zero,
as
follows:
68
EMIS
PY

30

90

1

0
100
80
100

1.3

3,510
lb
VOC/
day

1.8
tons
VOC/
day
EMIS
PY

ER
PY

EMIS
BY,
O
EMIS
BY,
Annual
(
5)
This
example
illustrates
t
emissions
projections.
Equ
efficiency­
based
strategies
w
This
example
also
illustrates
t
Control
Projection
and
the
Contr
6.
Mass
Emissions
Limit­
Based
Permits
Many
permits
simply
present
mass
emissi
process.
These
may
be
hourly
(
lb/
hr),
da
(
tons/
month),
annual
(
tpy),
or
any
combina
Permits
with
more
than
one
limit
may
specify
term
limits
that
allow
for
seasonal
or
other
f
production.
Other
permits
specify
the
short­
te
the
long­
term
limit
divided
by
the
days
or
hours
type
of
specification
does
not
allow
for
large
fluc
operation.

The
long­
term
annual
limits
will
be
used
for
emissions
projections
since
these
are
more
representative
of
expect
rather
than
maximum
activity.
These
limits
must
be
convert
reflect
ozone
season
typical
weekday
conditions.
Annual
limi
are
converted
using
the
ratio
of
base
year
ozone
season
emissi
to
base
year
annual
emissions.

Base
Year
Operating
Conditions
Ozone
season
emissions
=
150
lb/
day
=
0.075
tons/
day
Annual
emissions
=
23
tpy
Projection
Year
Conditions
Current
permit
=
30
tpy
Equation
(
5)
is
used
to
calculate
projection
year
emissions
as
follows:
69
EMIS
PY

30

0.075
23

0.098
tons/
day

196
lb/
day
Since
the
limit
used
emissions
calculated
a
example
demonstrates
the
limit­
based
permits.
If
c
limits
are
available
for
th
4)
should
be
use
instead
of
Under
future
control
strategies,

source
through
specified
emissions
specifications,
or
control
efficienc
the
State
should
use
the
appropriate
equations
(
1)
through
(
4)]
to
calculate
Projection
emissions.
These
limits
would
mass
emissions
rate
limits.
If
the
State
lower
the
permitted
mass
emissions
rate
limi
would
also
be
used
in
the
Control
Strategy
Pro
source.

Area
Source
Emissions
Projections
The
current
repository
for
base
year
area
source
emiss
inventories
is
the
AMS
of
AIRS.
The
AMS
has
incorporate
emissions
projections
into
the
system
design.
The
AMS
pr
emissions
using
the
following
data:

!
Activity
Level
(
actual
and
limits).

!
Emissions
Factor
(
actual
and
limits).

!
Growth
Factor.

!
Control
Information
­­
efficiency.

RE.

rule
penetration.

Emissions
can
be
calculated
and
projected
for
annual,
period,
and
interval
time
periods.
Ozone
season
typical
weekday
and
CO
season
emissions
are
included
as
period
emissions.
Interval
emissions
are
smaller
increments
of
time.

The
basic
projection
equation
for
period
allowable
emissions
is:

PROJ
INV
PERIOD
LIMIT/
NEW
CTRLS
EMISSIONS
=
PROJ
INV
PERIOD
ACTIVITY
LEVEL
LIMIT
NEW
CONTROLS
x
PERIOD
EMISSIONS
FACTOR
LIMIT
NEW
CONTROLS
x
[
1
­
(
CEFF/
100
x
REFF/
100
x
RPEN/
100)]
(
6)
70
where:
PROJ
projection
y
season
typical
PROJ
INV
PERIOD
A
the
projection
year
period.
This
is
calc
ACTIVITY
LEVEL
LIMIT
N
on
operating
parameters.

CONTROLS
is
selected
accor
hierarchy:

PROJ
ACTIVITY
LEVEL
LIMIT
NEW
C
PROJ
ACTIVITY
LEVEL
LIMIT
BASE
ACTIVITY
LEVEL
LIMIT
BASE
ACTIVITY
LEVEL
*
GROWTH
FACTOR
BASE
ACTIVITY
LEVEL
*
GROWTH
FACTOR
Thus,
the
State
may
enter
a
projection
ye
activity
level
for
the
"
new
controls"
proj
differ
from
the
"
base"
projection.
If
activ
are
not
entered,
the
system
will
use
actual
ac
PERIOD
EMISSIONS
FACTOR
LIMIT
NEW
CONTROLS
is
the
period
emissions
factor
limit
for
the
new
controls
projection.
The
hierarchy
for
selecting
the
emissio
factor
is:

PERIOD
EMISSIONS
FACTOR
LIMIT
NEW
CONTROLS
ANNUAL
EMISSIONS
FACTOR
LIMIT
NEW
CONTROLS
PERIOD
EMISSIONS
FACTOR
LIMIT
ANNUAL
EMISSIONS
FACTOR
LIMIT
PERIOD
EMISSIONS
FACTOR
ANNUAL
EMISSIONS
FACTOR
Thus,
the
State
may
enter
a
projection
year
emissions
factor
limit
(
allowable
emissions
factor).
The
factor
may
be
ozone
season
specific,
or,
if
not
entered,
the
annual
factor
will
be
applied.
The
"
limit
new
controls"
reflects
the
control
strategy
projection
whereas
the
"
limit"
reflects
the
baseline
projection.

CEFF
is
the
projected
control
efficiency.

REFF
is
the
projected
RE.

RPEN
is
the
projected
rule
penetration.

The
AMS
equation
also
includes
ash
or
sulfur
content,
the
fuel
loading
factor,
the
percent
reactivity,
and
unit
conversion
factors
as
applicable.
71
The
AMS
inc
Control
Proj
Control
Strate
Current
Control
Factor
Limit
subs
New
Controls.
72
Y

ORATE
BY,
O

GF

EMF
PY

1

CE
PY
100
RE
PY
100
(
7)
The
AMS
equ
presented
in
where:
EMISPY
=
Projection
typical
weekday
allowabl
(
mass
of
pollutant/
day)]

ORATEBY,
O
=
Base
year
activity
rate)
­
ozone
season
daily
(
p
units/
day)

GF
=
Growth
factor
EMFPY
=
Projection
year
emissions
fac
of
pollutant/
production
unit)

CEPY
=
Projection
year
control
efficienc
(
percent)

REPY
=
Projection
year
RE
(
percent)

RPPY
=
Projection
year
rule
penetration
(
percent)

Note
that
while
equation
(
6)
does
not
include
a
factor,
the
projection
year
activity
level
is
use
equation
(
6)
and
may
be
entered
by
the
user.
(
In
o
growth
is
still
considered.)
Alternatively,
the
pro
activity
level
can
be
calculated
in
AMS
from
the
base
activity
and
a
growth
factor.

The
major
difference
between
the
AMS
equation
and
the
point
source
equations
is
the
inclusion
of
the
rule
penetration
fac
The
rule
penetration
accounts
for
the
percentage
of
emissions
within
the
area
source
category
that
are
covered
by
regulation.
For
example,
a
regulation
may
only
affect
sources
above
10
tpy.
The
rule
penetration
would
be
equivalent
to
the
percentage
of
emissions
from
sources
above
10
tpy
within
the
area
source
category.

The
AMS
equation
also
differs
in
that
activity
level
limits
may
be
entered
in
addition
to
actual
or
expected
activity
levels.

States
should
not
enter
activity
level
limits
because
emissions
projections
are
to
be
based
on
maximum
emissions
factors
and
typical
or
expected
actual
activity
levels.

Refer
to
the
following
guidance
documents
for
more
information
on
AMS:

!
AMS
Coding
Manual
(
draft),
under
development,
U.
S.

Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
Technical
Support
Division,

Research
Triangle
Park,
NC.
Final
expected
in
Winter
1992.
73
EMIS
PY

VMT
BY,
O

GF

EMF
PY,
O

CONV
(
8)
!
AIRS
Use
reference
34
Mobile
Source
Em
This
section
is
div
vehicles
and
other
mo
Highway
Vehicle
Emissions
Projections
Highway
vehicle
emissions
a
year
VMT,
VMT
growth
factors,

The
equation
for
calculating
pr
where:
EMISPY
=
Projection
year
emissions
[
o
typical
weekday
allowable
emissions
(
mass
of
pollutant/
day)]

VMTBY,
O
=
Base
year
ozone
season
daily
VMT
GF
=
Growth
factor
EMFPY,
O
=
MOBILE5.0
emissions
factor,
projection
year
(
1996)
ozone
season
CONV
=
Units
conversion
factor
The
effects
of
highway
vehicle
controls
(
i.
e.,
new
vehic
standards,
enhanced
I/
M,
reformulated
gasoline)
will
be
r
in
the
MOBILE5.0
emissions
factors.
The
effects
of
program
designed
to
reduce
VMT
(
e.
g.,
TCM's
such
as
employee
trip
reductions)
should
be
reflected
in
the
growth
factor
for
VMT.

should
be
noted
that
these
measures
may
also
affect
vehicle
speeds
which,
in
turn,
will
affect
the
motor
vehicle
emissions
factors.

Highway
vehicle
projections
should
be
completed
at
a
desegregated
level
represented
by
vehicle
type
roadway
class.

This
is
described
in
more
detail
in
the
motor
vehicle
inventory
guidance.
(
See
reference
35.)
The
VMT
growth
factors
should
be
developed
based
on
the
VMT
forecasting
guidance
developed
by
EPA's
Office
of
Mobile
Sources
(
57
FR
9549,
March
19,
1992).

Highway
vehicle
emissions
projections
can
be
completed
within
AMS.
Period
(
ozone
season)
projected
emissions
for
1996
are
equivalent
to
the
projection
year
emissions.
The
State
should
obtain
additional
information
on
the
data
requirements
and
format
for
AMS
projection
inventories
and
the
interaction
of
MOBILE5.0
and
AMS.
This
information
is
available
in
the
AMS
manuals
referenced
in
the
previous
section.
74
Other
Mobile
Sources
Emissions
must
and
other
nonroa
controls
are
expe
The
1990
emissions
the
expected
growth
i
completed
within
AMS
f
area
sources.
The
EPA's
provide
guidance
on
how
to
equipment
and
vehicles.

Emissions
Preprocessor
System
The
EPS
may
be
used
by
the
States
year
emissions.
The
EPS
accepts
wor
contain
information
on
base
year
emis
equipment,
control
efficiency,
RE,
and
season
daily
emissions
should
be
used
in
requirements
of
the
rate­
of­
progress
plan.

The
Control
Emissions
(
CNTLEM)
module
allows
t
simulate
the
effects
of
various
control
strateg
emissions.
The
user
supplies
projection
factors
changes
in
activity
levels
(
operating
rates)
by
2­
d
the
first
4
digits
of
the
ASC.
The
user
also
suppli
factors
for
CTG's,
MACT,
non­
CTG
RACT,
highway
vehicle
and
other
source­
or
source
category­
specific
controls.

may
also
specify
allowable
emissions
limits;
however,
the
limits
must
be
expressed
as
emissions
rate
limits
(
tons
per
For
the
Current
Controls
Projection,
the
user
should
supply
control
information
for
measures
currently
in
the
SIP
including
CTG's,
non­
CTG
RACT,
and
existing
I/
M
programs.
Motor
vehicle
factors
(
which
represent
ratios
of
future
year
to
base
year
MOBILE4.1
emissions
factors)
are
created
with
a
separate
EPS
utility
(
MVADJ).
Enhancements
to
EPS,
scheduled
for
the
end
of
January
1993,
will
include
updating
the
EPS
motor
vehicle
utility
to
MOBILE5.0.

For
the
Control
Strategy
Projection,
the
user
should
add
CAAA­
mandated
control
measures
and
other
control
measures
which
the
State
wishes
to
test.
In
general,
States
will
begin
with
the
CAAA­
mandated
measures
and
assess
progress
towards
the
15
percent
VOC
emissions
reduction
requirement.
If
shortfalls
in
necessary
reductions
exist,
additional
control
measures
must
be
considered.

The
EPS
applies
all
controls
as
replacement
technologies.

Base
year
uncontrolled
emissions
are
calculated
from
base
year
actual
emissions
and
the
control
parameters.
Emissions
are
then
projected
by
applying
the
projection
factor
(
or
growth
factor)

and
the
projection
year
control
parameters.
The
end
result
is
75
MIS
PY

EMIS
BY

1

CE
PY
100
RE
PY
100
RP
PY
100
1

CE
BY
100
RE
BY
100
RP
BY
100

G
(
9)
that
emissi
equation
(
3)

where:
EMISPY
=
Projection
year
em
pollutant/
time)

EMISBY
=
Base
year
emissions
(
mass
of
pollutant/
time)

CEPY
=
Projection
year
control
efficienc
(
percent)

REPY
=
Projection
year
RE
(
percent)

RPPY
=
Projection
year
rule
penetration
(
percent)

CEBY
=
Base
year
control
efficiency
(
percent)

REBY
=
Base
year
RE
(
percent)

RPBY
=
Base
year
rule
penetration
(
percent)

GF
=
Growth
factor
(
dimensionless)

Since
the
controls
treated
as
replacement
technolo
the
projection
year
control
efficiency
used
may
actually
than
the
base
year
control
efficiency.
In
defining
sourc
category­
specific
controls,
the
user
should
be
aware
of
any
individual
sources
within
the
category
that
are
currently
required
to
achieve
a
greater
reduction.
These
should
be
inpu
as
source
specific
controls.
The
user
should
also
ensure
that
multiple
control
strategies
(
with
the
exception
of
CTG,
non­
CTG
RACT,
and
MACT
strategies)
are
not
applied
to
the
same
source.

This
will
lead
to
double­
counting
of
controls.
For
example,
if
the
user
specifies
a
RACT
reduction
of
50
percent
and
a
discretionary
control
of
90
percent,
CNTLEM
will
first
apply
the
50
percent
control
and
apply
an
additional
90
percent
reduction
to
the
remaining
emissions.

Allowable
emissions
for
projection
purposes
are
to
be
based
on
emissions
factor
or
control
efficiency
limits
in
combination
with
expected
activity.
Allowable
emissions
limits
must
be
input
to
EPS
in
terms
of
mass
per
unit
time
(
tons
per
day).
The
user
must
convert
limits
to
emissions
rate
limits.

Since
control
efficiency
is
a
valid
input,
permitted
control
efficiencies
may
be
input
for
use
in
the
emissions
projections.

For
sources
using
emissions
factor
limits,
the
emissions
limit
may
be
calculated
using
the
detailed
equations
presented
earlier.

The
projection
year
emissions
can
then
be
input
as
the
allowable
emissions
limit
in
EPS.
These
limits
should
be
specified
as
76
Ert

[
(
Eb

En)

(
1

r)
exp
t]
replacement
the
source
w
Refer
to
the
fol
instructions
on
E
!
User's
Guide
for
th
User's
Manual
for
the
System
2.0,
Part
A:
Cor
Interface
and
Emissions
Di
007D(
R)],
U.
S.
Environmenta
of
Air
Quality
Planning
and
S
Triangle
Park,
NC.
June
1992.

6.5
Effects
of
Equipment
Replacemen
Failure
consider
the
effects
of
eq
NSPS
requirements
for
an
affected
facil
stock,
may
result
in
development
of
a
SIP
emissions
reductions
than
necessary
to
mee
milestones
or
NAAQS
attainment
dates.

As
an
existing
facility
wears
out
and
is
replac
equipment,
it
may
become
subject
to
a
NSPS.
To
t
requirements
are
more
restrictive
than
present
requ
the
existing
(
not
modified
or
reconstructed)
facilit
emissions
will
be
reduced.
The
implications
of
such
e
reductions
can
be
assessed
using
the
following
formula:

where:
Ert
=
Emissions
reductions
in
year
t
Eb
=
Emissions
in
the
base
year
En
=
NSPS
emissions
r
=
Annual
replacement
rate
for
worn
out
capital
stock
t
=
Years
from
the
base
year
Consequently,
zero
net
growth
emissions
need
not
be
the
same
as
baseline;
they
might
actually
be
less.

Failure
to
consider
the
effect
of
offset
requirements
may
also
result
in
emissions
reduction
requirements
greater
than
necessary
to
meet
rate­
of­
progress
or
NAAQS
attainment
dates.

As
additions
to
the
existing
capital
stock
become
subject
to
offset
requirements
greater
than
1:
1,
base
emissions
levels
should
decrease.
Such
emissions
reduction
consequences
of
offset
requirements
can
be
assessed
using
the
following
formula:
77
Ert

[
(
1

Or)

Eb]

(
1

g)
exp
t
where:
Ert
=
Emissio
Or
=
Offset
ratio
Eb
=
Emissions
in
the
b
g
=
Annual
growth
rate
t
=
Years
from
the
base
ye
A
State
may
use
the
foregoi
the
previously
presented
equa
reductions
that
occur
due
to
ne
annual
replacement
rate
for
worn
calculated
using
replacement
rates
categories
provided
by
the
Internal
recent
version
of
their
Publication
5
preparation
of
income
tax
returns.
(
See
will
have
to
determine
the
fraction
of
gr
category
that
is
due
to
major
sources,
whi
at
least
the
NSPS
limit
and
which
would
have
offsets.
That
fraction
should
be
based
on
rep
historical
information
(
ratios
of
major
source
growth)
for
the
source
category.

6.6
Submitting
Projection
Year
Inventories
and
Suppor
Submission
of
the
projection
year
inventory
to
EPA
must
include:

!
Hardcopy
summary
of
emissions
estimates.

!
Documentation
of
methodology/
procedures.

!
Emissions
projections
in
computerized
format.

The
level
of
documentation
necessary
will
depend
to
some
extent
on
the
procedures
used
in
the
emissions
projections.
For
example,
if
growth
factors
from
BEA
or
E­
GAS
are
used
in
the
projections,
required
documentation
would
be
limited
to
simply
stating
this,
since
these
are
EPA­
recommended
sources
for
growth
factors.
If
nonrecommended
sources
of
data,
procedures,
or
methodologies
are
used,
documentation
must
be
sufficient
for
EPA
to
duplicate
calculations
and
make
a
judgment
as
to
the
acceptability
of
the
submission.

Emissions
projections
should
be
summarized
in
hardcopy
form
and
also
submitted
in
computerized
format.
The
computerized
format
will
depend
on
whether
projections
are
completed
using
the
detailed
equations,
EPS,
or
the
new
software
being
developed
by
EPA.
Emissions
projections
will
most
likely
be
required
to
be
submitted
through
AIRS.
More
information
on
the
computerized
78
format
for
next
few
mon
Since
the
data
n
include
confident
data
that
can
lead
(
emissions
combined
w
States
to
submit
ratio
base
year)
or
operating
factors/
rates.
States
mus
available
for
EPA
to
spot­
c
the
background
historical
inf
base
year
and
projection
year
e
79
7.0
CONTROL
Nitrogen
oxide
1990­
1996
may
no
the
rate­
of­
progr
reductions
occurrin
since
1990,
may
be
co
reductions
for
the
pos
States
may
choose
pur
some
portion
of
future
VOC
substitution.
The
EPA
expe
of
NOx
for
VOC
emissions
redu
post­
1996
period.

7.1
Stationary
Source
Controls
For
extreme
ozone
nonattainment
areas
the
Act
requires
certain
boilers
to
imp
advanced
control
technology
by
November
1
information
should
be
included
in
a
SIP
re
15,
1993).
Affected
boilers
are
individual
existing
electric
utility,
industrial,
or
commercial/
institutional
boilers
that
emit
more
NOx
.
The
Act
specifies,
for
purposes
of
this
sec
fuels
are
"
natural
gas,
methanol,
or
ethanol
(
or
a
polluting
fuel),"
advanced
control
technology
genera
"
catalytic
control
technology
or
other
comparably
effe
control
methods,"
and
the
clean
fuel
must
be
"
used
90
pe
more
of
the
operating
time."
[
See
General
Preamble,
sect
III.
A.
6.
d
(
57
FR
13523).]

For
further
information
on
applicable
NOx
controls
for
stationary
sources,
States
should
refer
to
NOx
RACT
rules,
as
well
as
NOx
ACT
documents
(
see
Appendix
J
for
list
of
ACT's).
In
the
event
that
the
ACT's
are
not
released
soon
enough,
some
control
strategies
might
be
found
by
consulting
the
BACT/
LAER
Clearinghouse
and/
or
NSPS
(
see
Appendix
J).

Under
Title
IV
of
the
Act,
the
acid
deposition
program
requires
NOx
emissions
reductions
from
tangentially
fired
boilers
and
dry
bottom
wall­
fired
boilers
(
see
Proposed
Rule
57
FR
55632)

and
wet
bottom
wall­
fired
boilers,
cyclones
and
other
utility
boiler
types
(
rules
due
January
1,
1997).
A
range
of
control
techniques
known
as
"
low
NOx
burners"
required
for
the
first
category
of
boilers,
that
is
dry
bottom
wall­
fired
and
tangentially
fired
boilers
(
see
57
FR
55632
for
discussion
of
these
technologies
and
techniques).
The
acid
deposition
proposed
rule
also
allows
for
alternative
technologies
under
certain
conditions
such
as
reburning,
selective
catalytic
reduction,
and
selective
noncatalytic
reduction
(
none
of
these
alternative
technologies
should
be
deemed
covered
by
RACT,
however).
80
The
air
qua
South
Coast,

may
also
incor
These
programs
a
as
controls
on
la
requirement
that
al
[
the
specific
air
qua
information].

7.2
Area
Source
Controls
States
may
also
elect
to
have
sources
even
though
the
CAAA
do
For
instance,
California
has
ado
Appendix
J
contains
two
rules
that
SIP­­
both
are
SCAQMD
rules.
The
gro
new
housing
developments
that
would
u
could
be
particularly
offset
by
such
a
Below
is
a
list
of
present
and
future
NOx
h
rules,
that
either
are
not
currently
part
of
scheduled
for
adoption
in
early
1993
or
1994.

appropriate
Air
Pollution
Control
District
(
APC
Management
District
(
AQMD)
for
more
information.

Ventura
APCD
Gas­
Fired
Water
Heaters
Rule
74.11
El
Dorado
APCD
Residential
Wood
Combustion
1/
93
Residential
Space
Heating
2/
93
Residential
Water
Heating
3/
94
Kern
County
APCD
Residential/
Commercial
Water
1/
93
Heaters
Bay
Area
AQMD
Residential
Water
Heaters
1993
Residential
Wood
Combustion
1993
7.3
Mobile
Source
Controls
States
may
take
credit
for
certain
NOx
emissions
reductions
achieved
through
implementation
of
TCM's
and
enhanced
I/
M
programs.
Emissions
reductions
may
also
occur
through
control
of
nonroad
engines,
but
these
reductions
may
not
be
realized
until
after
2000
due
to
the
phase­
in
schedule
(
note
that
the
CAAA
applies
to
new
engines
only;
the
State
would
have
to
adopt
a
separate
rule
for
rebuilt
engines).
81
8.0
ATTAINME
This
section
e
requirements
for
nonattainment
are
for
attainment
demo
quality
situations
th
demonstration.
It
sho
anthropogenic
emissions
both
must
also
be
included
demonstration.

8.1
Requirements
for
Moderate
an
Section
181(
a)(
1)
establishes
a
sc
the
NAAQS
for
ozone
for
the
nonattai
marginal
and
above,
based
on
the
desi
Section
182(
b)(
1)(
A)
requires
a
SIP
for
nonattainment
areas
to
provide
for
VOC
an
reductions
necessary
to
attain
the
standar
attainment
by
a
SIP
is
the
attainment
demons
moderate
areas
(
other
than
multi­
State
nonatta
requirement
can
be
met
through
the
application
model
and
EPA­
approved
modeling
techniques
descri
current
version
of
the
Guideline
on
Air
Quality
Mod
reference
37.)

Two
models
are
suggested:
UAM
or
EKMA.
The
General
Preamble
should
be
consulted
regarding
the
attainment
demonstration
implications
of
using
each
model
(
57
FR
13510
EKMA
is
used,
the
attainment
demonstration
is
due
by
November
1993.
States
choosing
to
run
UAM
for
their
intrastate
moderat
areas
must
submit
their
15
percent
rate­
of­
progress
plan
and
a
committal
SIP
addressing
the
attainment
demonstration.
The
committal
subject
to
a
section
110(
k)(
4)
approval
would
include,
at
a
minimum,
evidence
that
grid
modeling
is
well
under
way
and
a
commitment,
with
schedule,
to
complete
the
modeling
and
submit
it
as
a
SIP
revision
by
November
15,
1994.
The
completed
attainment
demonstration
would
include
any
additional
controls
needed
for
attainment.
For
further
discussion
of
committal
SIP's,
see
July
9,
1992
memorandum
from
John
Calcagni,
Director,

Air
Quality
Management
Division,
OAQPS,
to
Regional
Air
Division
Directors,
concerning
"
Processing
of
State
Implementation
Plan
(
SIP)
Submittals."

States
should
plan
to
achieve
emissions
reductions
as
early
in
the
process
as
possible,
since
section
181(
b)(
2)
requires
EPA
to
make
a
determination
as
to
whether
an
area
has
attained
the
ozone
NAAQS
within
6
months
following
an
applicable
attainment
date.
This
requirement
dictates
the
use
of
the
most
recent
3
years
of
air
quality
data,
which
means
EPA
will
use
1994­
1996
82
data
in
det
ozone
NAAQS.

8.2
Requirements
Serious
and
above
n
SIP's,
provide
an
att
The
attainment
demonst
photochemical
grid
model
8.3
Modeling
Considerations
Empirical
Kinetic
Modeling
Anal
The
use
of
EKMA
is
described
in
Gu
Specific
EKMA
in
Preparing
Ozone
SIP
well
as
the
Guideline
on
Air
Quality
and
should
be
consulted,
along
with
the
Office,
before
an
analysis
is
conducted
w
approach.

Urban
Airshed
Model
(
UAM)

The
use
of
UAM,
a
photochemical
grid
model,
is
re
or
required
for
modeling
applications
involving
all
classified
serious
and
above,
and
for
all
interstate
areas.

The
UAM
is
described
in
Guideline
for
Regulatory
Applicat
of
the
Urban
Airshed
Model
(
see
reference
40),
and
the
User
Guide
for
the
Urban
Airshed
Model
(
see
reference
41).
These
documents
and
the
appropriate
EPA
Regional
Office
should
be
consulted
before
an
analysis
is
conducted
with
this
modeling
approach.

8.4
Special
Air
Quality
Situations
Areas
Requiring
Emissions
Reductions
in
Excess
of
15
Percent
There
will
be
circumstances
under
which
a
moderate
area
will
be
able
to
show
attainment
of
the
NAAQS
can
be
achieved
only
through
VOC
emissions
reductions
in
excess
of
the
15
percent
VOC
emissions
reduction
mandated
in
section
182(
b)(
1)(
A)(
i).
This
condition
may
exist
for
an
area
that
has
a
design
value
at
the
top
of
range
(
0.138
to
0.159
ppm)
of
the
moderate
nonattainment
classification,
where
there
is
a
heavy
concentration
of
VOC
sources
in
a
smaller
area
of
the
nonattainment
area,
or
when
atmospheric
conditions
favor
the
formation
of
ozone.
The
underlying
requirement
of
the
SIP
for
these
areas
is
the
attainment
of
the
standard
by
the
attainment
date,
not
solely
the
achievement
of
the
15
percent
VOC
emissions
reduction.
83
Areas
Requi
Section
182(
b)

severe
ozone
non
than
15
percent
i
State
must
demonstr
(
NSR)
program
equival
[
section
182(
e)],
exce
source
that
emits,
or
ha
major
sources
(
down
to
tho
in
the
must
be
require
plan
must
also
include
all
me
implemented
area,
in
lig
To
qualify
for
the
lesser
percen
that
the
SIP
includes
all
measures
that
are
achieved
in
practice
by
sou
category
in
nonattainment
areas
of
th
classification.

Rural
Nonattainment
Areas
Section
182(
h)
addresses
the
situation
of
a
ru
downwind
of
a
larger
urban
area
and
classified
area
due
to
transport
of
ozone
and
ozone
prec
larger
upwind
urban
area.
A
rural
area
is
treated
area
if
EPA
Administrator
finds
that
sources
of
emissions
within
the
area
do
not
make
a
significant
co
to
the
ozone
concentrations
measured
in
the
or
in
o
areas.
The
only
requirements
for
these
areas
are
the
requirements
specified
in
section
182(
a)
for
marginal
areas
assumption
being
that
the
controls
in
the
upwind
area
will
so
the
problem
in
the
rural
transport
area
as
well.

Section
185(
e)
provides
a
further
exemption
for
small
areas
unable
to
attain
the
ozone
standard
due
to
transport
of
ozone
and
its
precursors
from
other
areas.
A
small
area,
defined
as
an
area
with
a
total
population
under
200,000,
is
exempt
from
all
sanctions
if
the
area
can
demonstrate
that
attainment
is
prevented
because
of
ozone
or
ozone
precursors
transported
from
other
areas.
The
exemption
applies
only
if
the
area
has
met
all
other
applicable
requirements
of
the
CAAA.

Multi­
State
Nonattainment
Areas
Section
182(
j)
defines
and
establishes
requirements
for
ozone
nonattainment
areas
covering
areas
in
more
than
one
State
called
multi­
State
nonattainment
areas.
Beyond
the
requirements
in
section
182
for
the
classification
of
the
nonattainment
areas
(
marginal,
moderate,
serious,
severe,
extreme,
transport),

section
182(
j)(
1)
requires
States
in
these
areas
to
coordinate
the
revisions
and
implementation
of
the
SIP's
applicable
to
the
nonattainment
areas
and
to
use
photochemical
grid
modeling
(
or
84
another
met
process.

Each
State
in
a
develop
and
submi
cooperation
and
int
schedule
for
developi
demonstration
for
the
should
also
reference
th
plan
should
be
submitted
b
Regional
Air
Division
Direc
State
should
write
their
own
Regional
Office
and
send
copy
nonattainment
area
for
review
(
s
model
letter).
Please
note
that
S
Regional
Offices
on
appropriate
sche
some
States
may
negotiate
dates
throu
Section
182(
j)(
2)
recognizes
that
an
area
within
multi­
State
nonattainment
area
demonstrate
attainment
"
but
for
the
failure
States,
in
which
other
portions
of
the
area
ar
commit
to
the
implementation
of
all
measures
re
182...."
If
EPA
Administrator
makes
a
findin
situation
is
occurring,
the
sanctions
of
section
17
apply
to
the
petitioning
State.
Section
II.
A.
9
of
t
Preamble
provides
the
primary
guidance
for
these
nonat
area
SIP's.
Appendix
I
of
this
document
contains
a
mode
written
by
EPA
as
guidance
to
multi­
State
planners.

International
Border
Areas
Section
179B
of
the
Act
applies
to
nonattainment
areas
that
are
affected
by
emissions
emanating
from
outside
the
United
States.
This
section
provides
relief
for
nonattainment
areas
along
international
borders
analogous
to
what
is
provided
to
States
within
multi­
State
nonattainment
areas
by
section
182(
j):

EPA
shall
approve
the
SIP
if
it
meets
all
the
requirements
in
the
CAAA
and
if
the
State
establishes
that
the
implementation
of
the
plan
would
be
adequate
to
attain
and
maintain
the
relevant
NAAQS
"
but
for
emissions
emanating
from
outside
the
United
States."

Section
179B
(
created
by
Title
VIII,
section
818
of
the
CAAA)
and
section
V.
C
of
the
General
Preamble
provide
SIP
guidance
for
areas
on
international
borders.
85
9.0
CONTINGE
The
Act
requir
levels
of
nonatt
SIP's
[
sections
1
measures
in
these
p
implemented
in
the
ev
Section
172(
c)(
9)
of
t
failures
to
demonstrate
182(
c)(
9)
requires
SIP
con
area
milestone
failures.

The
SIP's
for
moderate
and
abov
include
provisions
for
the
imple
without
further
State
or
EPA
actio
182(
c)(
9)
specify
that
the
contingen
effect
without
further
action
by
the
The
EPA
interprets
this
requirement
to
rulemaking
activities
by
or
the
implement
the
contingency
measures.
The
E
certain
actions,
such
as
notification
of
sou
of
permits,
would
probably
be
needed
before
a
implemented
effectively.
States
must
show
that
measures
can
be
implemented
with
minimal
further
part
and
with
no
additional
rulemaking
activities
s
hearings
or
legislative
review.
In
general,
EPA
wil
actions
needed
to
affect
full
implementation
of
the
me
occur
within
60
days
after
EPA
notifies
the
State
of
its
attainment
or
milestone
failure.

9.1
Marginal
Areas
Section
182(
a)
specifically
exempts
marginal
nonattainment
areas
from
the
contingency
measures
requirement
stated
in
section
172(
c)(
9).

Although
marginal
areas
are
excluded
from
the
requirement
for
contingency
measures
in
their
SIP's,
marginal
areas
should
carefully
consider
contingency
measures
in
case
an
area
does
not
attain
by
the
1993
date.
This
issue
arises
because
of
the
short
planning
and
implementation
time
frame
(
3
years)
available
between
the
attainment
dates
for
marginal
and
moderate
areas.

If
a
marginal
area
fails
to
attain
by
its
November
15,
1993
date,

it
will
become
subject
to
all
of
the
requirements
for
moderate
areas,
specifically
the
I/
M
program,
RACT,
and
the
15
percent
VOC
emissions
reduction
requirements.
The
additional
moderate
nonattainment
area
requirements
would
have
to
be
met
after
reclassification
and
the
standard
would
have
to
be
attained
by
November
15,
1996,
an
extremely
tight
time
frame
for
these
provisions
if
no
prior
planning
and
adoption
actions
had
occurred.
If
the
area
then
misses
the
November
15,
1996
attainment
date,
the
area
would
again
be
reclassified
and,
86
therefore,

areas.
This
Appendix
H
des
finding
of
a
mil
moderate
areas.

9.2
Moderate
and
Above
Ozone
nonattainment
area
must
include
in
their
SIP
contingency
measures
to
be
attainment
or
milestone
failu
is
appropriate
because
States
m
date
that
show
the
15
percent
VO
achieved
in
1996.
Under
sections
demonstrations
of
milestone
complian
nonattainment
area's
milestone
and
at
and
the
area
is
determined
to
have
atta
that
is
found
to
have
attained
the
standa
is
not
obligated
to
demonstrate
that
the
1
achieved
because
November
15,
1999,
is
also
for
serious
areas).
It
should
be
remembered
t
maintenance
plan
for
an
area
that
is
redesignat
State
must
show
that
its
SIP
was
fully
implemente
The
CAAA
do
not
specify
how
many
contingency
measure
needed
or
the
magnitude
of
emissions
reductions
that
m
provided
by
these
measures.
Assuming
that
all
of
the
St
measures
may
fail
to
produce
their
expected
reductions,
o
interpretation
of
the
CAAA
is
that
a
State
would
have
to
ad
sufficient
contingency
measures
in
the
November
15,
1993,
SIP
submittal
to
make
up
for
this
entire
shortfall.
The
EPA
belie
that
this
would
be
an
unreasonable
requirement
given
the
difficulty
many
States
already
have
in
identifying
and
adopting
sufficient
measures
to
meet
the
rate­
of­
progress
and
other
CAAA
requirements.

Contingency
measures
should,
at
a
minimum,
ensure
that
an
appropriate
level
of
emissions
reduction
progress
continues
to
be
made
while
the
State
plans
additional
control
measures.

Therefore,
as
stated
in
section
III.
A.
3.
c
of
the
General
Preamble
(
57
FR
13498),
EPA
interprets
the
CAAA
to
require
States
with
moderate
and
above
ozone
nonattainment
areas
to
include
sufficient
contingency
measures
the
November
15,
1993
submittal
so
that,
upon
implementation
of
such
measures,

additional
emissions
reductions
of
up
to
3
percent
of
the
emissions
in
the
adjusted
base
year
inventory
would
be
achieved
in
the
year
following
that
in
which
the
attainment
failure
has
been
identified.
These
emissions
reductions
are
in
addition
to
those
that
are
already
scheduled
to
occur
in
accordance
with
the
general
control
strategy
for
the
area.
This
provision
ensures
that
(
1)
progress
toward
attainment
occurs
at
a
rate
similar
to
5Similarly,
if
the
State's
SIP
revision
process
is
shorter
than
1
year,
contingency
measures
providing
proportionally
less
than
3
percent
will
be
acceptable
(
e.
g.,
1.5
percent
reduction
for
a
6­
month
revision
time
frame).

87
that
specif
the
State
wi
implementing
a
shortfall
in
emi
measures
resultin
States
must
identif
will
be
implemented
a
projected
for
each
con
It
is
important
to
note
th
contingency
measures
be
imp
of
failure.
In
other
words,

implementation
of
sufficient
me
2
percent,
not
the
3
percent
(
or
below).
If
EPA
determines
that
a
3
percent
exists
in
a
nonattainment
individual
control
measures
from
the
contingency
plan
as
prioritized
by
the
is
covered.
For
example,
four
measures
e
reduction
from
the
adjusted
base
year
inve
an
area's
contingency
plan.
Contingency
mea
within
the
plan
in
the
order
that
they
would
b
first
two
measures
are
projected
to
result
in
a
reduction
each,
while
the
last
two
are
projected
0.5
percent
reduction
each.
If
a
1
percent
shortfa
identified,
the
first
contingency
measure
would
be
i
if
a
2.5
percent
shortfall
is
identified,
then
the
fir
contingency
measures
would
be
implemented.

Under
this
approach,
the
State
would
have
1
year
to
modify
its
SIP
and
take
other
corrective
action
needed
to
ensure
tha
milestones
are
achieved
and
that
rate­
of­
progress
towards
attainment
continues.
The
EPA
believes
that
1
year
to
revise
th
SIP
is
appropriate
in
most
cases
as
this
is
consistent
with
the
time
frame
of
other
rate­
of­
progress
requirements.
If
a
State
needs
significantly
longer
than
1
year
to
revise
its
SIP
(
perhaps
due
to
the
length
of
the
State's
legislative
process),
then
the
State
is
expected
to
provide
for
additional
contingency
measures
commensurate
with
the
length
of
time
necessary
for
the
SIP
revision.
For
example,
if
the
State
anticipates
that
it
will
require
2
years
to
revise
its
SIP,
then
the
plan
should
include
contingency
measures
that
will
produce
6
percent
emissions
reductions
(
3
percent
per
year).
5
In
the
case
of
moderate
areas,

contingency
measures
would
be
needed
when
an
area
incurs
an
attainment
failure
or,
for
serious
and
above
areas,
if
the
area
incurs
either
an
attainment
or
a
milestone
failure).
If,
for
88
example,
a
a
higher
cla
that
apply
to
would
be
impleme
new
measures
asso
One
way
that
States
c
requirement
is
by
prov
before
the
dates
schedul
That
is,
a
State
may
inclu
requirement
that
control
me
later
years,
would
instead
be
either
does
not
meet
its
milest
applicable
date.
For
example,
a
A
scheduled
for
implementation
in
is
also
included
in
its
contingency
the
1996
milestone
and
elects
to
impl
Control
measure
A
is
then
implemented
i
that
implement
control
measures
from
thei
strategy
as
a
contingency
measure
must
dev
backfill
both
the
control
strategy
and
the
c
Within
1
year
of
the
triggering
of
a
contingen
early
implementation
of
control
measures,
the
S
SIP
revision
containing
whatever
additional
provi
to
backfill
the
SIP
to
remedy
any
eventual
shortfal
occur
as
the
result
of
the
early
use
of
the
control
The
EPA
expects
any
control
measures
that
are
implemen
as
part
of
a
contingency
plan
will
remain
in
place
(
or
b
superseded
by
replacement
control
measures)
until
the
nex
milestone.
At
the
next
milestone,
the
State
can
demonstrat
whether
or
not
these
control
measures
are
needed
to
stay
on
track.

The
EPA
believes
that
a
3
percent
contingency
will
be
adequate
for
most
areas
but,
in
some
cases
3
percent
may
be
inadequate,
especially
if
corrective
action
is
not
instituted
in
a
timely
manner
prior
to
a
milestone
date.
To
address
the
possibility
of
a
greater
than
3
percent
shortfall,
EPA
requires
moderate
and
above
areas
to
submit
contingency
measures
providing
for
a
3
percent
reduction
as
well
as
an
enforceable
commitment
to
submit
an
annual
tracking
program
describing
the
degree
to
which
it
has
achieved
its
projected
annual
emissions
reduction.

Compliance
for
this
requirement
will
be
to
participate
in
EPA's
tracking
efforts
and
respond
accordingly.
Because
EPA
believes
it
is
necessary
to
assess
the
progress
of
States
during
the
interim
periods
between
plan
submittals
and
milestone
compliance
determinations,
it
is
developing
a
computer
system
to
track
the
States'
rate­
of­
progress
plans.
It
is
anticipated
that
this
system
will
be
utilized
by
EPA
to
develop
tracking
reports
that
estimate
the
percentage
reduction
in
VOC
emissions.
States
would
review
these
reports
and
revise
them
if
they
do
not
agree
with
EPA's
tracking
assessment.
Two
options
are
available
to
States
89
when
a
shor
First,
S
actions
it
wil
this
shortfall
(
apart
from
the
c
failure.
For
examp
shortfall,
the
State
report
additional
cont
shortfall)
to
be
impleme
As
an
alternative
to
this
extra
contingency
measures
shortfall
expected
by
the
mil
this
approach,
the
State
must
s
the
submittal
of
the
follow­
up
r
that
will
be
needed
to
remedy
the
3
percent
of
contingency
measures
wo
even
though
EPA
would
only
require
th
measures
be
implemented
to
compensate
f
For
example,
if
annual
tracking
determine
the
State
could
include
in
its
next
annual
additional
contingency
measures
(
equaling
th
shortfall)
to
be
implemented
if
the
milestone
ascertains
a
shortfall
of
more
than
3
percent.

Sections
172(
c)(
9),
182(
c)(
9),
and
187(
a)(
3)
of
the
specify
that
the
contingency
measures
shall
"
take
ef
further
action
by
the
State
or
the
Administrator."
Th
interprets
this
requirement
to
mean
that
no
further
rule
activities
by
the
State
or
EPA
would
be
needed
to
impleme
contingency
measures.
The
EPA
recognizes
that
certain
acti
such
as
notification
of
sources
and
modification
of
permits,

would
probably
be
needed
before
a
measure
could
be
implemented
effectively.
States
must
show
that
their
contingency
measures
can
be
implemented
with
minimal
further
action
on
their
part
and
with
no
additional
rulemaking
actions
such
as
public
hearings
or
legislative
review.
In
general,
EPA
will
expect
all
actions
needed
to
effect
full
implementation
of
the
measures
to
occur
within
60
days
after
EPA
notifies
the
State
of
its
failure.

9.3
Serious
and
Severe
Areas
Within
90
days
of
a
serious
or
severe
area
milestone
failure,
the
CAAA
require
that
States
elect
one
of
three
options.

If
a
State
elects
to
implement
measures
from
the
applicable
contingency
plan,
then
the
EPA
will
review
the
plan
within
90
days
and
make
a
determination
as
to
whether
further
measures
are
necessary
to
meet
the
milestone.
The
contingency
measures
could
be
additional
measures
not
already
adopted
to
meet
RFP
or
other
requirements,
or
the
accelerated
implementation
of
measures
already
planned
to
meet
a
future
milestone.
In
this
later
case,

the
State
would
have
to
adopt
additional
measures
to
backfill
the
SIP
with
replacement
measures
to
replace
those
that
were
90
previously
assure
th
[
See
section
I
States
are
encour
milestone
failure
i
milestone
failure
occ
available
to
implement
milestone
is
met.

9.4
Nonclassifiable
Areas
Nonclassifiable
areas
include
t
incomplete/
no
data
areas.
Secti
areas
from
the
Subpart
2
rules
unt
not
clear
from
the
CAAA,
however,
wh
provisions
are
required
of
transition
if
contingency
measures
are
required.

design
values
that
fall
below
the
moderat
designation,
and
because
marginal
areas
ar
contingency
measure
requirement,
CAAA
ar
requiring
contingency
measures
for
nonclassifi
transitional
areas
are
reclassified
as
a
modera
nonattainment
area,
however,
they
would
be
subjec
contingency
measures
requirement
of
that
particular
classification
(
again,
marginal
areas
are
exempt
fro
requirement).
[
See
section
III.
A.
7.
a.
7
of
the
General
(
57
FR
13498).]

Because
submarginal
and
incomplete/
no
data
areas
generally
present
ozone
problems
that
are
less
serious
than
marginal
ar
which
are
expressly
exempted
from
the
contingency
measures
requirement,
and
contingency
measures
are
not
likely
to
be
necessary
to
ensure
attainment
for
these
areas,
EPA
believes
that
it
is
not
appropriate
to
apply
the
contingency
measure
requirement
for
these
areas
under
a
de
minimis
approach.

Nevertheless,
contingency
measures
are
required
as
part
of
the
maintenance
plan
for
nonclassifiable
or
other
nonattainment
areas
that
are
redesignated
attainment
by
EPA;
these
contingencies
are
discussed
in
a
September
4,
1992
memorandum
from
John
Calcagni,

Director,
Air
Quality
Management
Division,
OAQPS,
to
Regional
Air
Division
Directors,
concerning
"
Procedures
for
Processing
Requests
to
Redesignate
Areas
to
Attainment."
91
9.5
Examples
Some
examples
include:

!
Measures
required
!
Transportation
contr
!
An
employer
trip
reduct
!
An
economic
incentive
progr
"
Notice
of
Proposed
Rulemaking
programs
(
58
FR
11110,
February
rule
will
be
codified
in
40
CFR
Pa
the
proposed
rule
(
58
FR
11130­
11132
of
stationary
and
mobile
source
economic
incentive
programs.
Examples
control
measures
(
discussed
on
pages
1113
the
Federal
Register
notice)
which
could
b
contingency
measures
include,
but
are
not
li
the
following:

Fee
Programs
­­
Road
pricing
mechanisms
are
fee
programs
that
are
available
to
curtail
low
occupanc
vehicle
use,
fund
transportation
system
improvements
and
control
measures,
spatially
and
temporally
shift
driving
patterns,
and
attempt
to
effect
land
usage
changes.
Primary
examples
include
increased
peak
period
roadway,
bridge,
or
tunnel
tolls
(
this
could
also
be
accomplished
with
automated
identification
systems),
and
toll
discounts
for
pooling
arrangements
and
zero­
emitting/
low­
emitting
vehicles.

Tax
Code
Provisions
­­
Mobile
source
tax
code
incentive
strategies
include
waiving
or
lowering
any
of
the
following
for
zero
or
low­
emitting
vehicles:
vehicle
registration
fees,
vehicle
property
tax,
sales
tax,

taxicab
license
fees,
and
parking
taxes.

Subsidies
­­
A
State
may
create
incentives
for
reducing
emissions
by
offering
direct
subsidies,
grants,
or
low
interest
loans
to
encourage
purchase
of
lower­
emitting
capital
equipment
or
a
switch
to
less­
polluting
operating
practices.
Examples
of
such
programs
include
clean
vehicle
conversions,
starting
shuttle
bus
or
van
pool
programs,
and
mass
transit
fare
subsidies.

Preretirement
Reduction
Program
­­
An
example
would
include
an
old
car
scrappage
program.
93
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