APPENDIX
I
CLEAN
AIR
STRATEGY
DEVELOPMENT
SAN
ANTONIO
EAC
REGION
ATTAINMENT
DEMONSTRATION
MARCH
2004
I­
2
Appendix
I
Table
of
Contents
Page
Introduction                              
I­
4
Federal
and
State
Rules                        .
I­
4
National
LEV
Program                      
I­
4
On­
board
Refueling
Vapor
Recovery               ..
I­
5
Low
Sulfur
Gasoline                       
I­
6
New
Heavy­
Duty
Diesel
Vehicle
Rates  ..            .
I­
6
TAC
Chapter
106(
T):
Surface
Preparation
             
I­
6
TAC
Chapter
115(
C)(
2):
Filling
of
Gasoline
Storage
Vessels
(
Stage
I)
for
Motor
Vehicle
Fuel
Dispensing
Facilities            ..
I­
8
Rate
of
Progress
Control
Factors.                 
I­
9
TAC
Chapter
117(
B)(
4):
Cement
Kilns               
I­
11
Regional
Rules.                   ..        ..
I­
11
Local
Strategy
Development                       
I­
13
Development
of
Potential
Clean
Air
Measures          .. 
I­
13
Selection
of
Potential
Clean
Air
Measures             ..
I­
13
Evaluation
of
Potential
Clean
Air
Strategies
                
I­
14
Screen
Cell
Design
Value
Scaling                    .
I­
15
Local
Clean
Air
Strategies                 ..      
I­
18
Lower
Reid
Vapor
Pressure
(
RVP)                ..
I­
19
Challenges                       ..
I­
19
Resolution
of
Challenges:
RVP               
I­
19
Stage
I
Vapor
Recovery                     .
I­
20
Degreasing
Controls                      ...
I­
20
Challenges                       ..
I­
21
Resolution
of
Challenges:
Degreasing
Equipment
Controls   
I­
22
Design
Values             ..            
I­
23
Conclusion             .                 .
I­
23
DRAFT
I­
3
Appendix
I
List
of
Tables
Page
Table
I­
1
ORVR
Reductions
for
the
SAER
Counties,
2007;
Percent
Reductions
and
Tons
per
Day
(
TPD)
Reduced               ..
       
I­
5
Table
I­
2
VOC
Emissions
in
the
SAER
due
to
Chapter
106
Degreasing
Controls
                ....
I­
7
Table
I­
3
2007
Emissions
from
Tanker
Unloading
in
San
Antonio
EAC
Region         
      
I­
8
Table
I­
4
Emission
Reduction
due
to
Stage
I
Rule
in
the
95­
county
Region                   ..   ..
I­
9
Table
I­
5
Emission
Reductions
in
the
SAER
due
to
Stage
I
Rule
at
125,000
gallons
Throughput,
2007               
I­
9
Table
I­
6
Rate
of
Progress
Control
Factors   .. .      ..
I­
10
Table
I­
7
2007
SAER
County
Area
Source
Emissions
Using
ROP
Factoring                      .
I­
10
Table
I­
8
Potential
Control
Measures
Selected
for
Modeling    ..
I­
14
Table
I­
9
Modeling
Sequence
Employed
in
Evaluating
Potential
Clean
Air
Strategies
on
an
Individual
Basis
..         ..
I­
16
Table
I­
10
Modeling
Sequence
Employed
in
Evaluating
Potential
Clean
Air
Strategies
in
Various
Combinations         
I­
17
Table
I­
11
List
of
Clean
Air
Strategies
Recommended
for
SIP  .... .
I­
18
Table
I­
12
Design
Values
for
the
CAMS
Stations
After
Clean
Air
Strategy
Analysis           ..     .......
I­
23
DRAFT
I­
4
INTRODUCTION
Prior
to
the
establishment
of
Early
Action
Compacts
in
2002,
areas
that
violated
the
NAAQS
were
subjected
to
state
and
federal
law
as
dictated
in
the
Clean
Air
Act.
The
Early
Action
Compact
(
EAC)
has
allowed
areas
that
violated
the
new
8­
hour
NAAQS
to
develop
plans
that
will
solve
their
air
quality
problems
based
on
local
air
quality
analysis
and
planning.
Local
signatories
of
the
EAC
can
select
the
clean
air
measures
that
will
be
implemented.

Investigation
of
emissions
reducing
strategies
is
a
necessary
component
of
the
EAC.
The
Clean
Air
Plan
and
the
Early
Action
Compact
require
the
development
and
modeling
of
emission
reduction
control
strategies
using
the
most
currently
available
tools.
This
is
done
in
order
to
support
the
ongoing
efforts
by
local
authorities
and
citizens
for
maintaining,
or
attaining,
federal
air
quality
standards.
The
following
sections
describe
multiple
strategies
that
will
assist
in
reaching
attainment.
Strategies
noted
below
will
be
implemented
by
2007
or
are
already
implemented
on
the
federal,
state,
or
local
level.

FEDERAL
AND
STATE
RULES
The
on­
going
efforts
by
EPA
and
TCEQ
to
protect
and
preserve
natural
resources
and
human
health
has
led
to
the
development
of
various
regulations
controlling
emissions
in
future
years.
In
some
cases,
enforcement
began
as
early
as
the
year
2000.
These
rules
are
to
be
fully
implemented
by
2007.
The
emission
reductions
as
a
result
of
the
following
strategies
were
accounted
for
in
the
photochemical
model
when
the
2007
future
base
case
projection
was
developed.
The
following
sections
describe
the
state
and
federal
rules
expected
to
influence
the
San
Antonio
EAC
region's
air
quality.

National
LEV
Program
The
National
Low
Emission
Vehicle
(
LEV)
program
was
initiated
in
1998
as
a
voluntary
program
to
make
new
cars
significantly
cleaner
burning
than
previously
mandated
by
federal
regulations.
Substantial
pollution
reductions
would
be
achieved
with
this
program
while
at
the
same
time
providing
automotive
industry
flexibility
to
meet
program
standards.

When
states
and
automotive
manufacturers
opted
into
the
program,
the
standards
were
enforced
as
federal
vehicle
standards.
In
return
for
manufacturer
participation,
the
EPA
agreed
to
provide
regulatory
stability
and
provide
emissions
standards
based
on
a
combination
of
California
and
federal
motor
vehicle
standards.

The
program
is
projected
to
reduce
NOx
in
2007
by
496
tons
per
day
on
a
national
level
and
allows
emission
reductions
without
the
need
of
a
state­
by­
state
adoption
of
California's
motor
vehicle
regulations.
(
USEPA,
1997)
The
rule
was
placed
into
effect
in
the
northeastern
states
for
the
1999
vehicle
model
year
and
went
into
effect
on
a
national
level
for
2001
vehicles.
(
USEPA,
1998a)
Since
the
national
LEV
program
became
effective
in
Bexar
County
with
model
year
2001,
this
program
is
included
in
the
2007
photochemical
model
runs.

The
Texas
Transportation
Institute
(
TTI)
calculated
credits
for
this
program.
The
TTI
created
the
on­
road
mobile
source
modeling
emissions
inventories
for
1999,
2007
and
2012.
Their
technical
report
is
available
as
Appendix
C,
On­
Road
Mobile
Emissions
Inventory
Development
(
TTI
Report),
of
this
document
set.
Using
MOBILE6
model,
TTI
modeled
all
federal
motor
vehicle
control
programs
in
its
work.
DRAFT
I­
5
On­
board
Refueling
Vapor
Recovery
Onboard
refueling
vapor
recovery
(
ORVR)
is
an
emission
control
system
found
on
vehicles
that
inhibits
the
emission
of
fuel
vapors
from
a
vehicle's
gas
tank
during
refueling.
Within
the
gas
tank
and
fill
pipe
of
a
vehicle,
an
activated
carbon­
packed
canister
absorbs
fuel
vapors
during
refueling.
When
the
engine
is
operating,
the
canister
directs
gasoline
vapors
into
the
engine
intake
manifold
to
be
used
as
fuel.

It
is
projected
that
ORVR
controls
will
allow
a
300,000
to
400,000
ton
per
year
reduction
of
volatile
organic
compounds
(
VOC)
nationwide.
ORVR
systems
are
also
projected
to
provide
an
annual
fuel
savings
of
$
2
to
$
4
per
vehicle
for
the
consumer.
(
USEPA,
1998b)

The
Schedule
for
implementation
of
ORVR
is:
 
Automobiles:
40%
of
1998,
80%
of
1999,
and
100%
of
2000
and
beyond
models
will
be
equipped
with
ORVR.
 
"
Light
Duty
Trucks"
and
similar
vehicles:
40%
of
2001,
80%
of
2002,
and
100%
of
2003
and
beyond
models
will
be
equipped
with
ORVR.
 
"
Medium
Duty
Trucks"
and
similar
vehicles:
40%
of
2004,
80%
of
2005,
and
100%
of
2006
and
beyond
models
will
be
equipped
with
ORVR.
 
Heavy
Duty
Trucks
and
other
Vehicles:
At
this
time,
it
is
not
required
in
these
vehicles.

To
estimate
the
effect
of
ORVR,
the
NO
CLEAN
AIR
ACT
command
was
used
in
MOBILE6
to
model
vehicle
emissions
as
if
the
Federal
Clean
Air
Act
Amendments
of
1990
had
not
been
implemented.
MOBILE6
assumes
that
the
Clean
Air
Act
(
CAA)
Amendments
of
1990
did
occur
and
includes
a
number
of
vehicle
and
fuel
requirements
mandated
by
the
1990
Clean
Air
Act
Amendments
in
its
forecasts
and
analyses
of
future
year.
These
include
Tier1,
low
emissions
vehicle
(
LEV),
and
Tier2
tailpipe
exhaust
emission
standards,
and
new
evaporative
emission
test
procedure
requirements.

The
following
table
indicates
the
exact
reduction/
adjustment
values
for
VOC
emissions
for
each
county
in
San
Antonio
region.

Table
I­
1.
ORVR
Reductions
for
the
SAER
Counties,
2007;
Percent
Reductions
and
Tons
Per
Day
(
TPD)
Reduced
Bexar
Comal
Guadalupe
Wilson
Date
Percent
Reductions
TPD
Percent
Reductions
TPD
Percent
Reductions
TPD
Percent
Reductions
TPD
Sept.
13
62.3%
7.26
62.7%
0.39
60.3%
0.41
59.7%
0.15
Sept.
14
62.3%
7.26
62.7%
0.39
60.3%
0.41
59.7%
0.15
Sept.
15
62.3%
7.26
62.7%
0.39
60.3%
0.41
59.7%
0.15
Sept.
16
62.3%
7.26
62.7%
0.39
60.3%
0.41
59.7%
0.15
Sept.
17
63.7%
7.42
63.5%
0.39
61.5%
0.42
60.7%
0.15
Sept.
18
64.3%
4.80
64.4%
0.26
62.0%
0.27
61.6%
0.10
Sept.
19
64.0%
2.43
63.7%
0.13
61.4%
0.14
61.1%
0.05
Sept.
20
62.3%
7.26
62.7%
0.39
60.3%
0.41
59.7%
0.15
For
the
study
of
the
effects
of
absence
of
CAA,
AACOG
ran
a
2007
base
year
with
and
without
the
effects
of
CAA
and
calculated
the
differences
in
the
amounts
of
VOC
for
4
DRAFT
I­
6
counties
in
the
SAER
and
for
each
days
of
the
week.
The
amounts
of
VOC
in
2007
for
each
modeled
day
and
for
each
county
in
our
study
area
was
higher
by
approximately
60%
when
the
CAA
requirements
in
MOBIE6
were
disabled.
This
reduction
percentage
was
reflected
in
the
emission
inventory
for
the
photochemical
model
to
account
for
the
presence
of
the
effects
of
CAA
in
the
year
2007.
The
reductions
were
applied
to
the
Vehicle
refueling
category
(
SCC
2501060100)

Low
Sulfur
Gasoline
In
2000,
the
EPA
enacted
a
ruling
supporting
the
production
of
a
gasoline
with
a
lower
sulfur
content.
Such
a
strategy
was
developed
because
sulfur
in
the
gasoline
reduces
the
effectiveness
of
a
vehicle's
emission
control
system.
Gasoline
refiners
would
be
required
to
produce
gasoline
with
an
average
sulfur
level
of
30
ppm
by
2004,
down
from
the
sulfur
content
average
of
300
ppm.
(
USEPA,
1999)
In
2006,
refiners
will
be
required
to
produce
gasoline
with
a
30
ppm
average
sulfur
level
with
a
maximum
cap
of
80
ppm.
Gasoline
produced
for
sale
in
parts
of
the
Western
U.
S.
will
be
allowed
to
meet
a
150
ppm
refinery
average
and
a
300
ppm
cap
through
2006
but
will
have
to
meet
the
30
ppm
average/
80
ppm
cap
by
2007.
(
USEPA,
2000)

The
Texas
Transportation
Institute
(
TTI)
calculated
credits
for
this
program.
The
TTI
created
the
on­
road
mobile
source
modeling
emissions
inventories
for
1999,
2007
and
2012.
Their
technical
report
is
available
as
Appendix
C,
On­
Road
Mobile
Emissions
Inventory
Development
(
TTI
Report),
of
this
document
set.
Using
MOBILE6
model,
TTI
modeled
all
federal
motor
vehicle
control
programs
in
its
work.

New
Heavy­
Duty
Diesel
Vehicle
Rates
In
October
1997,
the
EPA
promulgated
a
new
combined
emission
standard
for
emissions
of
oxides
of
nitrogen
(
NOx)
and
non­
methane
hydrocarbons
(
NMHC)
from
model
year
2004
and
later
heavy­
duty
diesel
engines
used
in
trucks
and
buses.
This
new
standard
will
lead
to
a
50
percent
reduction
in
NOx
in
the
new
engines
appearing
in
2004,
as
compared
to
the
1998­
2003
model
year
engines
meeting
the
current
NOx
standard.
By
2020,
it
is
projected
that
1.1
million
tons
of
ozone
precursors
will
be
reduced
in
one
year
nationally.
(
USEPA,
1997)
Since
these
standards
will
apply
to
the
2007
fleet,
the
input
files
for
the
2007
MOBILE
runs
included
the
appropriate
emission
rate
changes
in
the
Heavy­
Duty
Diesel
Vehicle
class.
(
USEPA,
1998c)

The
Texas
Transportation
Institute
(
TTI)
calculated
credits
for
this
program.
The
TTI
created
the
on­
road
mobile
source
modeling
emissions
inventories
for
1999,
2007
and
2012.
Their
technical
report
is
available
as
Appendix
C,
On­
Road
Mobile
Emissions
Inventory
Development
(
TTI
Report),
of
this
document
set.
Using
MOBILE6
model,
TTI
modeled
all
federal
motor
vehicle
control
programs
in
its
work.

Texas
Administrative
Code
(
TAC),
Chapter
106
(
T):
Surface
Preparation
Permits
By
Rule
§
106.1
identifies
facilities
or
changes
within
facilities
that
have
been
determined
not
make
a
significant
contribution
of
air
pollution.
Subchapter
T
of
Chapter
106
addresses
degreasing
units
that
may
be
subject
to
permit
by
rule.
Permits
By
Rule
§
106.454
states
that
degreasing
units,
regardless
of
the
county
in
which
it
is
located,
shall
meet
the
requirements
of
Control
of
Air
Pollution
from
Volatile
Organic
Compounds
§
115.412­
415.
Since
this
rule
was
promulgated
in
1994,
degreasing
units
built
on
or
after
1994
are
subject
to
adhering
to
Chapter
115
specifications.

Solvent
degreasing
is
the
physical
process
of
using
organic
solvents
to
remove
grease,
fats,
oils,
wax
or
soil
from
various
metal,
glass,
or
plastic
items.
The
types
of
equipment
used
in
DRAFT
I­
7
this
method
are
categorized
as
cold
cleaners,
open
top
vapor
degreasers,
or
conveyorized
degreasers.
Nonaqueous
solvents
such
as
petroleum
distillates,
chlorinated
hydrocarbons,
ketones,
and
alcohols
are
used.
Solvent
selection
is
based
on
the
solubility
of
the
substance
to
be
removed
and
on
the
toxicity,
flammability,
flash
point,
evaporation
rate,
boiling
point,
cost,
and
several
other
properties
of
the
solvent.
The
following
bullets
are
examples
of
requirements
for
controlling
degreasing
equipment:

 
Cold
Cleaning
Machines:
A
cover
shall
be
provided
for
each
cleaner
which
shall
be
kept
close
whenever
parts
are
not
being
handled
in
the
cleaner.
The
system
shall
be
equipped
with
a
freeboard
that
provides
a
ratio
equal
to
or
greater
than
0.7,
or
a
water
cover
(
solvent
must
be
insoluble
in
and
heavier
than
water).

 
Open­
top
Vapor
Degreasing:
A
cover
that
can
be
opened
and
closed
easily
without
disturbing
the
vapor
zone.
A
freeboard
provides
a
ratio
equal
to
or
greater
than
0.75
and,
if
the
degreaser
opening
is
greater
than
10
ft2
(
1m2),
a
powered
cover.

 
Conveyorized
Degreasing:
A
properly
sized
refrigerated
chiller,
a
drying
tunnel
of
other
means,
such
as
rotating
(
tumbling)
basket
to
prevent
solvent
liquid
or
vapor
carry­
out;
a
condenser
flow
switch
and
thermostat
which
will
shut
off
sump
heat
if
the
condenser
coolant
is
not
circulating
or
if
the
condenser
coolant
discharge
temperature
exceeds
the
solvent
manufacturer's
recommendation.

Chapter
106
affects
degreasing
units
throughout
Texas
and
subjects
emission
controls
to
the
units
as
specified
in
Control
of
Air
Pollution
from
Volatile
Organic
Compounds
§
115.412­
415,
therefore,
a
reduction
of
85%
of
VOC
emissions
between
1999
to
2007.
Since
Chapter
106
rules
was
promulgated
in
1994,
it
allows
for
some
degreasing
equipment
emission
credit
for
time
periods
before
1999;
however
for
the
SAER,
credits
were
calculated
for
the
time
period
between
1999
and
2007.
This
calculation
is
described
as
following:

Unregulated
2007
Degreasing
Emissions
 
Base
1999
Degreasing
Emissions
=
Growth
from
1999
to
2007
Growth
from
1999
to
2007
*
0.85
Reduction
Factor
=
Emission
Reductions
due
to
Chapter
106
Regulation
1999
Degreasing
Emissions
+
Emission
reductions
=
2007
Regulated
Degreasing
Emissions
Table
I­
2
indicates
the
amount
of
reductions
in
the
2007
degreasing
emissions
resulted
from
the
above
calculations
in
the
4­
county
SAER.

Table
I­
2.
VOC
Emissions
in
the
SAER
due
to
Chapter
106
Degreasing
Controls
2007
Unregulated
Degreasing
Emissions
1999
Unregulated
Degreasing
Emissions
Growth
from
1999
to
2007
2007
Emission
Reductions
due
to
Chapter
106
2007
Regulated
Degreasing
Emissions
County
Tons/
Day
Tons/
Day
Tons/
Day
Tons/
Day
Tons/
Day
Bexar
14.03
8.99
5.04
4.28
9.74
Comal
0.85
0.54
0.30
0.26
0.59
Guadalupe
0.01
0.01
0.00
0.00
0.01
Wilson
0.20
0.13
0.07
0.06
0.14
Total
15.09
9.67
5.42
4.61
10.48
DRAFT
I­
8
TAC
Chapter
115(
C)(
2):
Filling
of
Gasoline
Storage
Vessels
(
Stage
I)
for
Motor
Vehicle
Fuel
Dispensing
Facilities
Stage
I
vapor
recovery
systems
are
designed
to
control
the
escape
of
gasoline
vapors
from
gasoline
storage
tanks.
The
vapors
escape
by
being
displaced
by
liquid
gasoline
unloaded
from
refueling
trucks.
Such
systems
have
shown
to
reduce
hydrocarbon
emission
by
98%.
The
vapors
are
captured
by
a
vapor
return
hose,
which
is
connected
to
the
storage
tank
and
the
refueling
truck.

As
a
tank
of
volatile
fuel
such
as
gasoline
is
gradually
emptied,
the
empty
space
will
be
occupied
by
vapors
of
the
fuel,
or
by
a
mixture
of
air
and
vapors,
if
an
inlet
air
vent
is
provided.
When
a
tanker
truck
delivers
fuel
to
a
gas
station,
the
new
fuel
entering
the
underground
tank
would
force
accumulated
gasoline
vapors
out
of
the
tank
into
the
air.
With
the
Stage
I
vapor
recovery
system,
vapors
are
forced
out
of
the
underground
storage
tank
into
the
tanker
truck
through
a
vapor
recovery
line.
The
recovered
vapors
in
the
tanker
truck
can
then
be
recycled.

Gasoline
vapors
are
present
in
the
air
space
of
the
storage
tank.
When
the
tank
is
refilled,
the
vapors
are
displaced
by
liquid
gasoline
and
can
enter
the
atmosphere,
thus
contributing
to
the
formation
of
ozone.
Stage
I
vapor
recovery
systems
are
designed
to
control
the
escape
of
these
vapors,
and
can
achieve
a
98%
reduction
in
hydrocarbon
emissions
once
they
are
put
into
use.
The
vapors
are
captured
by
a
vapor
return
hose,
which
is
connected
to
the
storage
tank
and
the
gasoline
delivery
truck.
Once
captured,
the
vapors
are
stored
in
a
vapor
cargo
department
in
the
gasoline
delivery
trucks
and
transported
to
the
refinery
for
recovery
or
incineration
Currently,
Stage
I
systems
are
required
in
the
San
Antonio
EAC
Region
for
facilities
that
dispense
125,000
or
more
gallons/
month
of
gasoline,
as
stipulated
in
Control
of
Air
Pollution
From
Volatile
Organic
Compounds,
§
115.221­
229.
The
effectiveness
of
the
Stage
I
vapor
recovery
system
strategy
was
measured
by
calculating
the
current
release
of
hydrocarbon
emissions
due
to
tank
unloading
for
the
San
Antonio
MSA.
These
emissions
would
be
eliminated
if
all
of
the
gasoline
stations
in
the
region
were
required
to
have
Stage
I
vapor
recovery
system.
The
projected
amount
of
VOC
emission
from
unloading
tankers
within
the
San
Antonio
EAC
Region
for
the
year
2007
is
9.99
tons
per
a
day
as
displayed
in
table
I­
3.

Table
I­
3.
2007
Emissions
from
Tanker
Unloading
in
San
Antonio
EAC
Region
(
AACOG,
2001)
County
VOC
tons/
day
VOC
tons/
year
Bexar
8.81
2750.89
Comal
0.47
145.81
Guadalupe
0.52
160.78
Wilson
0.19
58.51
Total
SA
MSA
9.99
3115.99
However,
this
projection
does
not
take
into
account
the
use
of
Stage
I
vapor
recovery
systems
for
throughput
greater
than
125,000
gallons
per
month,
which
is
already
in
place
in
the
San
Antonio
EAC
Region.
In
order
to
refine
these
projections
with
the
results
of
the
125,000
gallons/
month
rule,
the
results
of
a
previous
analysis
for
the
95
counties
east
of
I­
35
were
used.
The
results
of
this
study
are
displayed
in
Table
I­
4.
DRAFT
I­
9
Table
I­
4.
Emission
Reduction
due
to
Stage
I
Rule
in
the
95­
county
Region
(
AACOG,
1999)

Gasoline
Throughput
Gallons/
Month
Number
of
Gas
Stations
%
of
Total
Stations
VOC
Reductions
Tons/
Year
%
of
Total
VOC
Reductions
Less
than
10,000
1,607
18.6%
0
0.0%
10,000
 
25,000
2,436
28.3%
1,210
11.8%
25,000
 
50,000
2,287
26.5%
2,480
24.1%
50,000
­
125,000
1,599
18.6%
3,510
34.1%
Greater
than
125,000
691
8.0%
3,090
30.0%
Total
8,620
100%
10,290
100%

As
displayed
in
Table
I­
4,
facilities
with
125,000
gallons
per
month
throughput,
which
have
their
Stage
I
systems
in
place,
can
reduce
the
VOC
emissions
by
30%.
Removing
this
amount
of
reduction
from
the
total
projected
amount
of
VOC
emissions
in
SA
MSA
from
tanker
truck
unloading
results
in
bringing
the
2007
projected
estimates
down
to
6.99
tons
per
day.
This
calculation
is
shown
in
the
formula.

2007
SAER
total
VOC
X
Percentage
of
VOC
Reduction
=
VOC
Reduction,
Tons/
Year
9.99
X
0.30
=
6.99
The
following
table
indicates
the
exact
reduction/
adjustment
values
for
VOC
emissions
for
each
county
in
San
Antonio
region.

Table
I­
5.
Emission
Reductions
in
the
SAER
due
to
Stage
I
Rule
at
125,000
gallons
Throughput,
2007
Unregulated
2007
Emissions
Emission
Reductions
due
to
Stage
I
Rule
2007
Emission
with
Stage
I
Rule
County
Tons/
Day
Tons/
Day
Tons/
Day
Bexar
8.81
2.64
6.17
Comal
0.47
0.14
0.33
Guadalupe
0.52
0.15
0.37
Wilson
0.19
0.06
0.13
Total
9.99
2.99
7.00
Note
that,
as
a
locally
preferred
air
quality
control
strategy,
the
Stage
I
at
25,000
gallons
per
month
throughput
has
been
discussed
in
the
Local
Clean
Air
Strategies
section
of
this
appendix.

Rate
of
Progress
Control
Factors
Rate
of
Progress
(
ROP)
control
factors
were
also
used
on
several
categories,
as
directed
by
TCEQ
and
ENVIRON.
Table
I­
6
shows
applicable
ROP
control
factors
for
the
AACOG
2007
emissions
inventory
(
ENVIRON,
2001).
These
control
factors
account
for
the
amount
of
emission
reductions
due
to
use
of
improved
techniques
and/
or
implementation
of
new
regulations.
DRAFT
I­
10
Table
I­
6.
Rate
of
Progress
Control
Factors
Category
SCC
Control
Factor
Leaking
Underground
Tanks
2660000000
0.0
Architectural
Coatings
2401001000
0.8
Traffic
Markings
2401008000
0.8
High­
Performance
Maintenance
2401100000
0.8
Other
Specific
Purpose
Coatings
2401200000
0.8
All
Solvent
Types
2465000000
0.8
Personal
Care
Solvents
2465100000
0.8
Household
Solvents
2465200000
0.8
TSDF's
2640000000
0.07
Automotive
Aftermarket
Coatings
2465400000
0.8
Adhesives
&
Sealants
2465600000
0.8
To
forecast
the
amount
of
emission
for
each
area
source
category,
the
emission
amount
for
each
category
in
1999
EI
was
reduced
by
the
given
2007
and
a
2012
projection
factors.
The
results
were
then
factored
by
the
ROP
factors
to
account
for
improvements
in
applications
techniques
and
changes
in
regulations.
To
give
a
demonstration
of
this
procedure,
the
following
table,
which
is
prepared
for
the
2007
Bexar
County,
is
presented
in
this
appendix.
The
last
column
in
this
table
indicates
the
net
amount
of
change
between
before
and
after
application
of
ROP
factors.
The
table
includes
the
results
of
the
following
calculation.

Category
Specific
Base
Year
1999
Emissions
X
ROP
Factor
=
Emission
Reductions
due
to
ROP
Controls
Category
Specific
Base
Year
1999
Emissions
­
Emission
Reductions
due
to
ROP
Controls
=
2007
emissions
Table
I­
7.
2007
SAER
County
Area
Source
Emissions
Using
ROP
Factoring
Base
Year
1999
Emissions
Emission
Reductions
due
to
ROP
Controls
2007
Emissions
with
Controls
County
Tons/
Day
Percentage
Reductions
due
to
ROP
Controls
Tons/
Day
Tons/
Day
Architectural
Coatings
11.10
20%
2.22
8.88
Traffic
Markings
0.03
20%
0.01
0.02
High­
Performance
Maintenance
3.41
20%
0.68
2.73
Other
Spec.
Purpose
Coatings
2.62
20%
0.52
2.10
Personal
Care
Solvents
4.21
20%
0.84
3.37
Household
Solvents
2.79
20%
0.56
2.23
Automotive
Solvents
1.80
20%
0.36
1.44
Leaking
Tanks
0.71
100%
0.71
0.00
DRAFT
I­
11
TAC
Chapter
117
(
B)(
4):
Cement
Kilns
Chapter
117
addresses
various
regulations
on
the
control
of
air
pollution
from
NOx.
Subchapter
B,
Division
4
addresses
emission
regulations
of
various
cement
kilns.
Regulations
stipulated
by
Control
of
Air
Pollution
From
Nitrogen
Compounds
§
§
117.260,
117.261,
117.265,
117.273,
117.279,
and
117.283,
which
affect
the
cement
industry
in
Texas
were
accounted
for
in
the
attainment
demonstration.

REGIONAL
RULES
Many
of
the
rules
applied
to
the
Houston/
Galveston
and
Beaumont/
Port
Arthur
and
other
non­
attainment
areas
have
regional
implications.
The
emission
control
strategies
implemented
in
these
areas
would
affect
the
ambient
air
quality
in
the
San
Antonio
region.
Photochemical
models
have
indicated
that
emissions
from
eastern
parts
of
Texas
affect
emission
levels
in
other
downwind
parts
of
Texas.
Information
about
these
rules
and
regulations
were
collected
from
various
regulating
agencies
and
organized
into
electronic
files
and
used
as
input
data
for
the
photochemical
model
runs
to
better
reflect
emission
reductions
due
to
the
implementation
of
these
regional
emission
control
policies.
The
followings
are
descriptions,
provided
by
TCEQ,
of
these
files.

HGA's
NOx
cap
packet:
This
packet
provides
a
revision
to
the
cap
on
HGA's
NOx
emissions.
It
is
to
be
applied
to
year
2000
emissions.
This
packet
also
includes
3.8
tpd
of
reductions
due
to
the
Emission
Reduction
Credit
(
ERC)
and
Discrete
Emission
Reduction
Credit
(
DERC)
programs
for
the
HGA
as
of
October
14,
2002.

BPA's
bank
packet:
This
control
packet
applies
the
banked
ERC
and
DERC
VOC
total
of
3.3
tpd
and
NOx
total
of
29.2
to
all
of
the
2000
Aug.
29
base4a
Non
Electric
Generating
Units
(
NEGU)
totaling
60.3
tpd
VOC
and
92.7
tpd
NOx
in
BPA,
except
for
Special
Inventory
sources
and
those
with
Science
Coordinating
Committee,
beginning
with
TAC
Chapter
101
and
Chapter
201.

HGA
bank
packet:
This
control
packet
applies
the
banked
ERC
and
DERC
VOC
total
of
17.9
tpd
to
all
of
the
2000
Aug.
29
base4a
scenario
for
NEGUs
in
HGA
totaling
176.5
tpd
VOC.
Except
for
special
inventory
sources
and
those
with
the
Science
Coordinating
Committee,
beginning
with
TAC
Chapter
101
and
Chapter
201.

Tier3
Emission
Specifications
for
Attainment
Demonstration:
This
packet
takes
the
HGA's
EGUs
from
the
~
90
revised
ESAD
level
to
the
~
80%
of
Business
Coalition
for
Clean
Air
alternate
ESAD
level.
Hence,
this
packet
is
meant
to
be
applied,
in
addition
to
the
revised
(~
90%)
ESAD
level.
And
the
revised
packet
was
to
be
applied
to
the
HGA
30
day
highest
heat
input
packet.
The
"
auxiliary
boilers"
are
located
at
the
top
section
of
this
file.

Revised
ESAD:
This
packet
is
to
be
applied
after
the
control
"
HGegu30day"
packet.
It
corrects
areas
whose
ESAD
rates
went
from
.01
to
.02
and
from
.03
to
.04.
This
packet
represents
the
future
base
EGU
controls
for
the
entire
domain.

SB7
NOx
Rule:
This
packet
represents
the
future
base
EGU
controls
for
the
entire
domain.
It
includes
50%
reduction
for
95
county
area
 
attainment
counties
East
of
I­
35
and
I­
37.
The
file
also
addresses
controls
for
various
states
affected
by
the
NOx
SIP
rule,
including
Indiana,
Kentucky,
Ohio,
Tennessee,
Alabama,
Georgia,
and
Missouri.
DRAFT
I­
12
Tier1for
BPA:
Developed
on
10/
15/
02,
this
control
packet
for
BPA
EGUs
ESAD
includes
0.10
lbNOx/
mmBtu.
The
calculation
is
based
on
the
percentage
reductions
in
the
1997
annual
Acid
Rain
Scorecard.

Tier
2
for
DFW:
Developed
on
0/
15/
02,
in
this
control
packet
Handley
utility
plant's
unit
5
was
changed
to
match
the
1997
EGUs.
This
packet
accounts
for
the
new
control
on
EGU
boilers
with
limit
of
0.033
lb/
MMBTU
for
TXU,
and
0.06
lb/
MMBtu
for
plants
in
Garland
and
Denton.
The
small
boilers
at
Denton
and
Garland
get
controlled
based
on
their
AP­
42
emission
rate
0.28
controlled
to
0.06
lb/
MMBt.
This
gives
79%
control.
TXU
gets
89%
control,
Garland
gets
72%,
and
Denton
gets
86%
control
for
an
overall
control
of
88%.
On
4/
19/
2000
the
stack
and
point
numbers
for
HANDLEY
5
had
been
changed
so
that
it
would
work
in
"
cntlem"
file.
On
4/
19/
2000
a
second
boiler
was
added
to
the
Mountain
Creek
3B
unit.

Milan
County
CO
Emission:
Control
factors
set
to
provide
28.50
TCEQ
tpd
to
26.66
tpd.
for
NEGU
point
sources
in
Milan
County,
48331.
This
control
package
was
provided
by
CAPCO.
DRAFT
I­
13
LOCAL
STRATEGY
DEVELOPMENT
Development
of
Potential
Clean
Air
Measures
Control
strategies
aimed
at
reducing
emissions
from
transportation
sources,
area
sources,
and
point
sources
were
considered
and
analyzed
based
on
their
emission
reducing
capacity
and
cost
of
implementation.
The
list
of
emission
reducing
strategies
was
compiled
by
gathering
information
on
control
measures
currently
employed
in
the
Dallas­
Ft.
Worth
and
Houston/
Galveston
nonattainment
areas
and
studying
measures
that
are
recommended
by
the
TCEQ,
or
are
employed
in
other
states.
The
control
measure
description,
emission
reduction
associated
with
the
measure,
and
the
cost
for
the
measure
to
be
implemented
were
used
in
developing
the
list
of
potential
clean
air
measures.

Throughout
the
duration
of
selection
process,
AACOG's
technical
staff
continuously
updated
emission
reductions
and
cost
analysis
for
relevancy
to
the
region's
air
quality.
Updates
to
the
emission
reduction
estimates
and
cost
estimates
were
performed
by
various
means
and
methods.
Emission
factors
were
often
updated
through
the
use
of
EPA
approved
models,
such
as
MOBILE6
or
the
NONROAD
model.
Frequent
revisions
were
necessary
due
to
the
updated
data
provided
by
TCEQ
or
other
near
nonattainment
areas
that
would
improve
model
performance
thus
providing
realistic
outputs.

The
list
of
potential
clean
air
strategies
was
provided
to
the
AIR
Technical
Committee
for
review
and
additional
input,
as
agencies
may/
may
not
be
affected
by
the
suggested
control
measures.

Selection
of
Potential
Clean
Air
Measures
The
AIR
Technical
Committee
reviewed
approximately
100
strategies
aimed
at
reducing
emissions
and
assisting
the
SAER
in
reaching
attainment
of
the
8­
hour
ozone
standard.
The
strategies
were
assessed
based
on
the
criteria
of
creditability
(
quantifiable,
enforceable,
and
permanent)
and
effectiveness
at
reducing
ozone
precursors
while
being
cost
efficient.

The
AIR
Technical
Committee
met
twice
a
month
to
discuss
various
technical
issues
and
review
the
list
of
control
strategies.
The
committee
considered
several
factors
when
analyzing
various
control
strategies.
These
factors
included
whether
the
strategies
were
currently
implemented
in
the
area,
the
emission
reducing
capacity
in
the
San
Antonio
MSA,
and
possible
costs
associated
with
strategy
implementation.
The
AIR
Technical
Committee
provided
draft
copies
and
reports
of
the
progress
of
control
strategy
selection
to
the
AIR
Executive
Committee
during
the
selection
process.
Whenever
necessary,
the
AIR
Executive
Committee
would
then
provide
comments
to
the
AIR
Technical
Committee
in
regards
to
their
selections.
Table
I­
8
lists
the
strategies
that
fulfilled
the
prescribed
criteria
and
were
feasible
for
the
San
Antonio
area.
Also,
selected
control
strategies
were
combined
to
enhance
the
potential
emission
reductions.
DRAFT
I­
14
Table
I­
8.
Potential
Control
Measures
Selected
for
Modeling
Control
Measure
Ton
per
Day
(
NOx+
VOC)
Reduction
Cost
per
Ton
Acceleration
Simulation
Mode
Test
with
On
Board
Diagnostics
Systems
Test
(
OBD­
II)
13.33
$
10,620
Two
Speed
Idle
Test
(
TSI)
together
with
OBD­
II
10.42
$
9,425
OBD­
II
8.52
$
8,419
Lower
7.0
RVP
for
all
counties
east
of
I35
and
I37
corridor
3.13
for
the
SAER
only
Not
Calculated
Lower
7.0
RVP
3.13
$
11,402
Lower
7.2
RVP
2.15
$
7,717
Stage
I
vapor
recovery
at
25,000
for
all
counties
east
of
I35
and
I37
corridor
5.81
for
the
SAER
only
$
4,471
Stage
I
vapor
recovery
at
50,000
3.41
$
2,894
Stage
I
vapor
recovery
at
25,000
5.81
$
4,471
Degreasing
solvents*
14.34
$
1,400
Degreasing
equipment*
12.83
$
0
Wood
spray
technique
0.131
$
0
Removal
of
5.93
tons
of
NOx
from
Spruce
1
power
plant**
5.93
Not
Calculated***

*
Calculated
based
on
the
assumption
that
Chapter
106
was
not
implemented
in
the
SAER
**
Was
used
to
simulate
the
ozone
levels
with
the
shutting
down
of
a
power
plant
in
this
location
***
Rough
estimates
indicate
that
shutting
down
a
coal
power
plant
would
be
many
factors
more
expensive
then
any
other
control
strategy
considered
on
this
list
EVALUATION
OF
POTENTIAL
CLEAN
AIR
STRATEGIES
The
elimination
of
inadequate
control
measures
resulted
in
a
list
of
feasible
and
applicable
control
measures
that
were
to
be
evaluated
through
performance
of
the
photochemical
model.
The
strategies
that
were
to
be
evaluated
in
this
manner
were
thought
to
be
most
effective
in
reducing
emissions
in
the
San
Antonio
area.
At
the
request
of
the
Air
Improvement
Resources
(
AIR)
Committee,
the
strategies
previously
listed
in
table
I­
8
were
evaluated
in
the
photochemical
model
2007
demonstration.
Tables
I­
9
and
I­
10
detail
the
sequence
of
modeling
runs
when
the
strategies
were
evaluated.
DRAFT
I­
15
This
evaluation
of
the
strategies
allowed
local
officials
and
technical
staff
to
understand
the
effectiveness
of
each
individual
strategy.
Understanding
the
effects
of
the
control
measures
in
this
manner
would
allow
officials
to
formulate
possible
combinations
of
control
measures
that
would
best
affect
San
Antonio's
air
quality.

Screen
Cell
Design
Value
Scaling
Since
the
modeled
attainment
test
provides
no
indication
of
future
ozone
concentrations
at
locations
without
monitors,
the
EPA
recommends
a
supplementary
screening
analysis
to
support
an
attainment
demonstration.
The
predicted
8­
hour
daily
maximum
for
the
SA
region
exceeded
the
highest
predicted
8­
hour
daily
maximum
near
a
monitor
by
more
than
5%
on
only
two
day
of
the
episode
(
15th
&
16th).
Since
the
5%
threshold
was
not
exceeded
on
"
50%
or
more
modeled
days,"
a
screening
test
is
unnecessary
for
demonstration
purposes.
DRAFT
I­
16
Table
I­
9.
Modeling
Sequence
Employed
in
Evaluating
Potential
Clean
Air
Strategies
on
an
Individual
Basis
Control
Strategy
Emission
Control
Options
Base
Case
SA1
SA2
SA3
SA4
SA5
SA6
SA7
SA8
SA9
SA10
SA11
SA12
ASM
with
OBDII
4
TSI
with
OBDII
4
OBDII
4
RVP
7.0
(
Regional)
95
RVP
7.0
4
On
Road
Sources
RVP
7.2
4
Stage
I
(
50K)
4
Stage
I
(
25K)
4
Stage
I
(
25K
Regional)
95
Degreasing
Solvent*
4
Degreasing
Equipment*
4
Area
Sources
Wood
Spray
Technique
Point
Sources
Removal
of
5.93
tons
of
NOx
from
Spruce
1
Power
Plant
1
CAMS
23
adjusted
2007
Design
Value**
84.52
84.14
84.22
84.30
84.42
84.44
84.46
84.44
84.40
84.33
84.22
84.26
84.42
*
Does
not
include
Chapter
106
controls
in
future
case
**
Adjusted
to
final
Base
Case
model
(
numbers
are
not
truncated
to
show
differences)

Key:
"
4"
 
4­
county
San
Antonio
EAC
region
"
95"
 
95­
county
area
east
of
I­
35
and
I­
37
(
not
including
Houston,
BPA
or
Dallas)

"
1"
 
Bexar
County
only
DRAFT
I­
17
Table
I­
10.
Modeling
Sequence
Employed
in
Evaluating
Potential
Clean
Air
Strategies
in
Various
Combinations
Control
Strategy
Emission
Control
Options
Base
Case
SA13
SA14
SA15
SA16
SA17
SA18
SA19
SA20
SA21
SA22
ASM
with
OBDII
4
TSI
with
OBDII
4
OBDII
4
4
RVP
7.0
(
Regional)

RVP
7.0
4
4
4
4
4
4
4
On
Road
Sources
RVP
7.2
4
4
4
Stage
I
(
50K)
4
4
4
4
4
Stage
I
(
25K)
4
4
4
4
4
Stage
I
(
25K
Regional)

Degreasing
Solvent*
4
Degreasing
Equipment*
4
4
4
4
4
4
4
4
Area
Sources
Wood
Spray
Technique
4
4
4
Point
Sources
Removal
of
5.93
tons
of
NOx
from
Spruce
1
Power
Plant
CAMS
23
adjusted
2007
Design
Value**
84.52
84.17
84.07
84.10
83.70
84.07
83.62
83.83
84.01
84.01
84.04
*
Does
not
include
Chapter
106
controls
in
future
case
**
Adjusted
to
final
Base
Case
model
(
numbers
are
not
truncated
to
show
differences)

Key:
"
4"
 
4­
county
San
Antonio
EAC
region
"
95"
 
95­
county
area
east
of
I­
35
and
I­
37
(
not
including
Houston,
BPA
or
Dallas)

"
1"
 
Bexar
County
only
DRAFT
I­
18
Based
on
the
technical
analysis
of
the
various
clean
air
strategies
and
the
performance
of
the
1999
photochemical
model
for
the
2007
projections,
several
strategies
were
recommended
by
technical
staff
to
the
AIR
Technical
Committee.
The
2007
projection
of
the
1999
episode
was
demonstrating
an
8­
hour
ozone
slightly
below
the
8­
hour
NAAQS
of
85
ppb.
Therefore,
the
strategies
of
low
RVP
gasoline
of
either
7.0
or
7.2,
the
implementation
of
Stage
I
vapor
recovery
on
area
service
stations
that
dispense
at
least
25,000
gallons
or
50,000
gallons,
and
degreasing
controls
were
recommended
for
inclusion
to
the
Clean
Air
Plan.
The
following
table
lists
the
recommended
clean
air
strategies
by
the
AIR
Technical
Committee.
The
list
was
subsequently
recommended
to
the
AIR
Executive/
Advisory
Committee
and
received
full
endorsement
by
its
body.

Table
I­
11.
List
of
Clean
Air
Strategies
Recommended
for
SIP
AIR
Tech
Recommends
AIR
Committee
Recommends
VOC
+
NOx
Reductions
Clean
Air
Strategy
Yes
No
Yes
No
Cost
Per
Ton
(
ton/
day)
Degreasing
Equipment
Operation
Controls
X
X
0
12.83*

Reid
Vapor
Pressure
(
7.2)
X
X
$
7,717
2.15
Stage
I
(
50,000)
X
X
$
2,894
3.41
Reid
Vapor
Pressure
(
7.0)
X
X
$
11,402
3.13
Stage
I
(
25,000)
X
X
$
4,471
5.81
*
Assuming
no
controls/
reductions
due
to
Chapter
106
rules
LOCAL
CLEAN
AIR
STRATEGIES
The
AIR
Committee
recommended
three
Clean
Air
Strategies
for
inclusion
in
the
Clean
Air
Plan
to
local
Early
Action
Compact
signatory
governments
for
their
final
approval.
The
strategies
were:
 
Reid
vapor
pressure
lowered
to
7.2
pounds
per
square
inch
during
the
ozone
season
for
the
San
Antonio
region;
 
Degreasing
Equipment
Operation
Controls,
described
in
TAC,
Title
30,
Ch.
115;
and
 
Stage
I
vapor
recovery
required
of
service
stations
of
25,000
gallons
throughput
of
gasoline
or
more
per
month.
The
eight
local
governments
which
are
signatories
to
the
Early
Action
Compact
for
the
San
Antonio
region
deliberated
these
strategies
during
regularly
scheduled
meetings
of
their
representatives
(
i.
e.,
during
City
Council
meetings
or
during
Commissioners'
Court
sessions).
These
meetings
are
open
to
the
public
and
have
meeting
schedules
published
according
to
the
Texas
Open
Meetings
Act.
All
eight
governments
approved
each
of
the
three
strategies
specified
above.
Copies
of
their
signed
resolutions
to
this
effect
are
attached
to
this
Clean
Air
Plan
document
set.

The
San
Antonio
EAC
Region,
acting
through
the
AIR
Committee,
has
incorporated
these
three
strategies
into
the
Clean
Air
Plan
and
requests
that
the
Texas
Commission
on
Environmental
Quality
take
the
necessary
actions,
including
development
of
enforcement
provisions,
to
implement
these
Clean
Air
Strategies.

The
following
sections
describe
the
clean
air
measures
that
were
selected
by
local
officials
to
clean
the
SAER's
ambient
air.
Along
with
strategy
descriptions,
the
emission
reductions
are
provided.
DRAFT
I­
19
Lower
Reid
Vapor
Pressure
(
RVP)
The
use
of
lower
Reid
vapor
pressure
fuel
will
reduce
the
emission
of
volatile
organic
compounds
(
VOC)
into
the
atmosphere.
The
requirement
for
gasoline
refineries
to
provide
such
gasoline
will
only
be
during
the
months
of
March
through
October,
which
is
traditionally
the
time
of
the
year
ozone
levels
exceed
the
national
standard.
Fuel
with
a
lower
volatility
achieves
emissions
reductions
in
ozone
precursors
by
reducing
aromatic
hydrocarbon
emissions
from
gasoline
thereby
reducing
its
ability
to
evaporate
as
quickly.
Currently,
state
law
caps
the
RVP
levels
sold
in
Texas
at
7.8
during
the
ozone
season.

Reducing
the
RVP
to
7.2
will
provide
a
reduction
of
2.1
tons/
day
of
VOC
and
0.05
tons/
day
of
NOx.
The
cost
benefit
of
such
reductions
is
estimated
to
be
$
7,717
per
ton
of
reduced
VOC
and
NOx.
The
per
ton
costs
of
RVP
7.2
and
7.0
were
calculated
based
on
the
information
that
Valero,
a
local
refinery,
had
submitted
to
AACOG.

Challenges
Facing
the
Lower
RVP
Strategy
This
Clean
Air
Strategy
was
originally
envisioned
as
SIP
creditable.
Information
received
by
AACOG
has
challenged
the
SIP
creditability.
On
January
27,
2004,
communication
from
EPA's
Region
6
office
was
received
regarding
Section
211
of
the
Clean
Air
Act
and
its
possible
implications
to
SAER's
request
for
state
implementation
of
requirements
for
gasoline
with
an
RVP
of
7.2
in
the
region.
Further
clarification
was
necessary
for
the
CAA's
interpretation
on
whether
such
a
provision
is
applicable
to
Early
Action
Compact
areas.
This
possible
challenge,
however,
did
not
deter
the
AIR
Committee's
consideration
of
the
strategy,
and
on
January
28,
2004
lower
RVP
received
formal
endorsement
by
the
committee.
The
strategy,
along
with
the
other
approved
strategies,
were
then
presented
to
the
local
EAC
signatory
governments
for
ratification.
Endorsement
was
given
to
lower
RVP
by
the
EAC
signatory
governments,
first
by
the
City
of
Seguin
on
February
3,
2004.
The
final
government
to
endorse
lower
RVP
was
the
Guadalupe
Commissioner's
Court
on
February
24,
2004.
Thus,
all
eight
local
governments
approved
resolutions
requesting
the
three
strategies
during
that
February
3­
24
period.

On
February
13,
2004,
Candy
Garret1
(
personal
communication,
February
13,
2004)
from
the
TCEQ
provided
AACOG
some
clarification
regarding
the
circumstances
allowing
such
a
measure
to
be
implemented
in
the
local
EAC
SIP.
According
to
the
EPA's
and
TCEQ's
preliminary
investigations,
Section
211(
c)(
4)(
A)
of
the
federal
CAA
prohibits
state
and
federal
governments
from
enforcing
RVP
as
it
was
being
requested.
Such
a
measure
can
only
be
implemented
in
an
EAC
SIP
if
there
are
special
circumstances.
Detailed
descriptions
regarding
Section
211
and
its
effect
on
the
promulgation
of
lower
RVP
rules
are
provided
in
Appendix
K.
On
February
17,
2004,
an
EPA
working
group
confirmed
their
earlier
interpretation
of
this
provision,
supporting
TCEQ's
opinion.

Resolution
of
Challenges
Facing
Lower
RVP
 
Given
the
formal
approval
of
the
EAC
signatory
governments,
the
San
Antonio
EAC
region
is
committed
to
requesting
that
the
state
implement
a
4­
county
EAC
regional
rule
requiring
gasoline
stations
to
dispense
gasoline
with
an
RVP
7.2
during
the
months
of
March
to
October.

1
Ms.
Candy
Garrett
is
a
Director,
Environmental
Planning
and
Implementation,
for
TCEQ.
DRAFT
I­
20
 
Given
also
the
apparent
enforcement
prohibitions
described
above,
the
emissions
reduction
credits
which
would
be
expected
through
such
a
rule
are
not
being
placed
in
the
SIP­
creditable
section
of
this
document.
 
Specifically,
the
credits
which
would
be
available
due
to
seasonal
7.2
RVP
and
the
technical
details
of
such
credit
estimation
methodology
are
relegated
to
the
section
entitled
"
Analysis
of
Additional
Evidence",
Appendix
K.

Stage
I
Vapor
Recovery
Currently,
Stage
I
systems
are
required
in
the
SAER
for
facilities
that
dispense
125,000
or
more
gallons/
month
of
gasoline.
The
local
Early
Action
Compact
signatory
governments
in
their
final
approval
have
requested
to
lower
this
threshold
to
25,000
gallons/
month.
There
is
a
general
consensus
among
the
air
quality
planners
in
the
region
that
implementation
of
this
strategy
would
face
the
least
difficulties,
due
to
the
existing
wide
spread
use
of
Stage
I
technology
in
manufacturing
of
the
underground
gasoline
tanks
and
anticipation
of
such
a
rule
by
the
gas
station
owners.

As
described
in
Table
I­
5,
the
projected
amount
of
VOC
emissions
for
2007
"
Tanker
Truck
Unloading"
in
SAER
is
approximately
7
tons
per
day.
Lowering
the
threshold
for
Stage
I
to
25,000
gallons
per
day
would
reduce
the
2007
"
Tanker
Truck
Unloading"
VOC
emissions
by
5.81
tons
per
day
allowing
for
a
total
VOC
emissions
of
1.18
tpd
for
the
"
Tanker
Truck
Unloading"
category.
The
methodology
for
the
above
calculation
could
be
described
as
followings:

In
the
absence
of
emissions
from
gas
stations
with
125,000
gallon
per
day
throughput,
the
share
(
percentage)
of
the
other
throughput
categories
indicated
in
Table
I­
4
could
be
rearranged
as
shown
below.

10,000
to
25,000
gallon/
day
16.86%
25,000
to
50,000
gallon/
day
34.43%
50,000
to
125,000
gallon/
day
48.71%

If
these
reduction
percentages
are
applied
to
the
total
"
Tanker
Truck
Unloading"
VOC
emissions,
then
we
will
arrive
at
the
followings:

10,000
to
25,000
16.86%
X
6.99
=
1.178
ton/
day
VOC
reduction
25,000
to
50,000
34.43%
X
6.99
=
2.406
ton/
day
VOC
reduction
50,000
to
125,000
48.71%
X
6.99
=
3.405
ton/
day
VOC
reduction
The
25,000
gallons
per
day
throughput
control
strategy
results
in
5.81
ton/
day
of
VOC
reduction
if
we
simply
aggregate
2.406
and
3.405.
Stage
I
Vapor
Recovery
for
service
stations
of
25,000
gallons
throughput
of
gasoline
or
more
per
month
will
be
implemented
and
operational
no
later
than
December
31,
2005.
Implementation
of
this
control
strategy
comes
as
a
formal
request
of
the
eight
local
governments
who
are
signatories
to
the
Early
Action
Compact.
Their
support
for
Stage
I
Vapor
Recovery
as
a
local
clean
air
strategy,
and
their
approval
of
this
proposed
local
State
Implementation
Plan
Revision,
are
attached
as
appendix
N.

Degreasing
Controls
The
Clean
Air
Strategy
endorsed
by
the
San
Antonio
EAC
Region
involves
the
application
of
Chapter
115
of
the
TAC
to
degreasing
units
in
its
four­
county
region.
Chapter
115
addresses
emission
controls
on
degreasing
processes
particularly
in
DRAFT
I­
21
nonattainment
areas
and
it
was
believed
that
such
controls
could
be
applied
to
the
SAER.
Degreasing
Equipment
controls,
as
prescribed
in
Chapter
115,
were
projected
to
provide
VOC
emission
reductions
of
12.83
tons
per
day
in
the
San
Antonio
region.
This
reduction
total
assumes
no
existing
state
degreasing
controls
of
this
type.
This
reduction
total
was
presented
to
the
elected
officials
and
technical
staff
as
the
reductions
available
through
local
enactment
of
a
Chapter
115
Degreasing
Controls
rule
as
identified
in
the
ERG
report.

The
eight
local
Early
Action
Compact
signatory
governments
took
up
the
formal
endorsement
of
Degreasing
Controls
as
one
of
three
Clean
Air
Strategies
for
their
approval.
The
first
government
to
consider
this
Clean
Air
Strategy
set
was
the
City
of
Seguin
on
February
3,
2004.
The
final
government
to
consider
them
was
Guadalupe
Commissioners'
Court
on
February
24,
2004.
All
eight
local
governments
approved
resolutions
requesting
the
three
strategies
during
that
February
3
­
24
period.

Challenges
In
early
February
2004,
TCEQ
staff
from
the
Region
13
office
informed
AACOG
staff
that
Chapter
106
of
the
TAC
contained
a
requirement
to
implement
Chapter
115­
compliant
degreasing
controls
statewide.
Subsequent
investigations
revealed
that
subchapter
T
of
Chapter
106
addresses
degreasing
units
that
may
be
subject
to
permit
by
rule
and
require
the
units,
regardless
of
the
county
in
which
they
are
located,
to
meet
the
requirements
of
§
115.412
and
§
115.415.
(
TAC,
2004b)
Following
the
realization
that
much
of
the
credit
previously
calculated
for
degreasing
controls
as
a
voluntary
Clean
Air
Strategy
might
no
longer
be
available
due
to
Chapter
106,
AACOG
staff
proceeded
to
analyze
Chapter
106
and
Chapter
115
and
assess
how
emission
reductions
should
be
properly
determined
and
allocated.

Eddie
Mack
(
personal
communication,
February
13,
2004)
of
EPA's
Region
6
office
explained
that
the
Chapter
115
degreaser
requirements
have
been
in
place
since
early
in
the
1980'
s
for
certain
other
regions
of
the
state.
Permit
by
rule
(
PBR)
stipulations
in
Chapter
106
(
§
106.454)
require
compliance
with
the
Chapter
115
degreaser
requirements,
regardless
of
location.
Such
compliance
with
Chapter
115
through
106
regardless
of
location
has
only
been
in
place
since
May
1994.

Hence,
the
initial
2007
degreasing
emission
reductions
estimated
through
local
Chapter
115
promulgation,
which
assumed
that
no
such
state
rule
was
in
place,
were
clearly
overestimated.
On
the
other
hand,
since
promulgation
of
Chapter
106
predates
1999,
then
both
the
1999
and
2007
"
uncontrolled"
degreasing
emissions
inventories,
which
heretofore
had
also
assumed
no
effective
degreasing
controls
of
this
type,
were
also
likely
to
be
too
large.

Note
that
Chapters
106/
115
as
existing
state
rules
guarantee
that
reduction
credits
are
available,
not
as
voluntary
credits
available
to
the
region
as
Local
Clean
Air
Strategy
enactment,
but
in
both
the
1999
and
2007
base
case
as
was
the
case
for
other
existing
state
and
federal
rules.

Reductions
in
degreasing
emissions
due
to
both
local
implementation
of
Chapter
115
in
the
Clean
Air
Plan
and
due
to
Chapter
106
are
described
in
two
categories.
1.
Reductions
in
emissions
based
on
the
growth
of
degreasing
emission
between
1999
and
2007,
and
2.
Reductions
in
degreasing
emissions
in
the
1999
(
and
hence,
in
the
2007)
base
case.
DRAFT
I­
22
As
reported
in
Appendix
F,
area
source
emission
projections
were
generally
calculated
for
2007
using
the
Economic
Growth
Analysis
System
(
I­
GAS)
model.
The
EGAS
model
supplied
growth
factors
for
projecting
of
all
area
source
emissions2.
Thus
growth
in
degreasing
emissions
to
2007
was
calculated
based
on
the
1999
emissions
inventory
for
this
category.

Because
Chapter
106
was
in
effect
from
1999
to
2007,
the
growth
in
degreasing
emissions
during
that
period
was
in
fact
limited
by
the
same
factor
as
promulgation
of
the
effective
rule
limited
emissions
in
the
degreasing
operations
themselves.
That
is,
reduction
credits
due
to
the
effective
state
rule
can
be
taken
on
earlier
calculations
for
growth
in
the
degreasing
emissions
category
from
1999­
2007.
This
is
both
a
first
approximation
correction
to
the
2007
base
case
degreasing
emissions
inventory
and
a
source
of
modeling
credit
identified
under
applicable
state
and
federal
rules.
As
mentioned
earlier,
these
reductions
are
not
categorized
as
voluntary
credits
available
to
the
region
as
Local
Clean
Air
Strategy
enactment.

Correcting
the
1999
EI
to
account
for
the
promulgation
of
Chapter
106,
which
was
effective
in
1994
and
hence
prior
to
1999,
is
challenging.
The
1999
EI
should
be
corrected
to
account
for
the
effects
of
Chapter
106,
just
as
the
1999­
2007
growth
has
been
corrected.
The
preferred
approach
in
taking
credit
for
Chapter
106/
115
emission
reductions
for
1999
involves
using
available
information
and
data
regarding
compliance
to
the
rules
in
1999.
Information
regarding
Safety­
Kleen,
a
Texas
based
company
that
provides
various
environmental
services
throughout
the
nation,
was
utilized
in
this
approach.

Documentation
provided
by
TCEQ
shows
that
Safety­
Kleen
1)
provides
degreasing
equipment
and
solvents
for
approximately
50%
of
the
San
Antonio
market;
2)
Safety­
Kleen
products
are
Chapter
115
compliant;
3)
Safety­
Kleen
provided
these
products
to
their
customers
in
the
San
Antonio
region
consistent
with
the
promulgation
of
Chapter
106.
Hence,
the
85%
reduction
effective
through
Chapter
106/
115
should
act
as
a
first
approximation
correction
to
50%
of
the
degreasing
emissions
in
the
1999
EI.
Since
these
emission
reductions
are
not
reflected
in
the
1999
base
case,
these
emission
reductions
and
potential
credit
are
further
documented
in
Appendix
K,
Additional
Evidence.

Note
that
the
2007
degreasing
EI
is
simply
equal
to
the
sum
of
the
1999
degreasing
EI
plus
the
1999­
2007
growth
in
degreasing
emissions.
Hence,
lowering
the
1999
degreasing
EI
due
to
the
presence
of
Safety­
Kleen
in
the
market
is
necessarily
reflected
also
as
an
adjustment
to
the
2007
degreasing
EI.

Resolution
of
Challenges:
Degreasing
Equipment
Controls
 
Given
the
formal
approval
of
the
EAC
signatory
governments,
the
San
Antonio
EAC
region
is
committed
to
requesting
that
the
state
implement
a
4­
county
EAC
regional
rule
requiring
compliance
with
Degreasing
Equipment
Operation
Controls,
described
in
TAC,
Title
30,
Ch.
115.
 
Given
Chapter
106,
reductions
in
emissions
based
on
the
growth
of
degreasing
emission
between
1999
and
2007
have
been
approximated
and
are
treated
uniquely
as
additional
reductions
due
to
current
State
rule.

2
With
the
exception
of
Architectural
Surface
Coatings
and
Consumer/
Commercial
Solvents
DRAFT
I­
23
 
Reductions
in
the
1999
(
and
2007)
base
case
degreasing
emissions
inventories
have
been
calculated
based
on
Safety­
Kleen's
participation
in
the
regional
market.
These
reductions
are
treated
as
tentative
and
unconfirmed
reductions
and
are
discussed
in
the
Additional
Evidence
section,
Appendix
K.
 
Chapter
106
of
the
TAC
was
adopted
in
1994,
thus
applying
to
degreasing
facilities
that
were
constructed
or
scheduled
to
be
constructed
on
and
after
1994.
This
leaves
degreasing
facilities
that
were
in
existence
prior
to
1994
exempt
from
Chapter
106
rule.
These
uncontrolled
facilities
would
be
subjected
to
the
regulations
of
Chapter
115
due
to
the
passage
of
the
rule
by
local
governments,
therefore
be
a
source
of
additional
emission
reductions,
as
described
in
Appendix
K,
Additional
Evidence.

Local
signatory
governments
were
presented
the
three
clean
air
strategies
recommended
by
the
AIR
Committee
between
the
dates
of
February
3
and
February
24,
2004.
The
EAC
signatory
governments
passed
resolutions
requesting
the
clean
air
measures
in
table
5.4
be
implemented
in
the
SAER.

Design
Values
Once
the
strategies
were
incorporated
into
the
photochemical
model's
2007
projection,
a
design
value
was
analyzed
to
ensure
the
strategies
had
a
positive
impact
on
the
predicted
ozone
values.
These
control
strategy
design
values
are
the
result
of
analyzing
Stage
I
Vapor
Recovery
implementation
on
area
gasoline
stations
that
dispense
at
least
25,000
gallons
a
month
and
are
listed
in
table
I­
8.

Table
I­
12.
Design
Values
for
the
CAMS
Stations
after
Clean
Air
Strategy
Analysis
Monitoring
Station
2007
Design
Value
2007
Design
Value
with
Control
Strategies
CAMS
23
84.52
84.40
CAMS
58
82.12
82.03
CAMS
59
74.48
74.44
CAMS
678
74.46
74.39
CAMS
33
82.57
82.57
CAMS
383
84.41
84.41
The
calculations
for
the
development
of
the
design
values
are
described
in
greater
detail
in
Appendix
H,
Modeled
Attainment
Test.

CONCLUSION
The
San
Antonio
EAC
Region
has
committed
to
pursue
various
clean
air
measures
as
requested
by
the
local
governments.
These
commitments
involve
requesting
lower
RVP
gasoline
implementation,
Stage
I
Vapor
recovery
systems,
and
Degreasing
Equipment
Controls.
Details
regarding
emission
reductions
due
to
gasoline
having
an
RVP
of
7.2
3
CAMS
3
and
CAMS
38
are
located
in
the
Austin
MSA.
Ozone
readings
from
these
monitors
are
included
in
the
modeling
analysis
since
guidance
recommends
analysis
of
monitoring
stations
within
the
4­
km
grid
of
the
modeling
episode.
Due
to
Austin's
close
proximity
to
the
SAER,
reflecting
attainment
of
the
8­
hour
NAAQS
in
this
region
strengthens
SAER's
2007
demonstration.
DRAFT
I­
24
can
be
found
in
Appendix
K,
Additional
Evidence.
Stage
I
vapor
recovery
system
for
retailers
that
dispense
no
less
than
25,000
gallons
per
month
is
SIP
creditable
was
discussed
in
a
previous
section
of
this
appendix.
Degreasing
controls,
through
consideration
of
Chapter
106
and
Chapter
115,
have
various
degrees
of
creditability.
Emission
reductions
achieved
by
Chapter
106
on
growth
in
degreasing
emission
between
1999
and
2007
are
accounted
for
as
emission
reductions
due
to
state
rule
and
were
discussed
in
this
appendix.
Reductions
in
the
1999
base
case
due
to
Chapter
106
are
treated
as
additional
evidence
and
discussed
in
Appendix
K.
Additional
reductions
are
possible
through
local
implementation
of
Chapter
115
to
degreasing
units
that
were
in
existence
prior
to
1999,
described
in
Appendix
K.
DRAFT
I­
25
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Alamo
Area
Council
of
Governments
(
AACOG),
2001.
"
2007
Projected
Emissions
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the
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of
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San
Antonio,
Texas.

Control
of
Air
Pollution
From
Nitrogen
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30
T.
A.
C.
§
§
117.260,
117.261,
117.265,
117.273,
117.279,
and
117.283
(
2000).
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Commission
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Chapter
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­
Control
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229
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Available
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state.
tx.
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rules/
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pdf
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415
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Available
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http://
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tnrcc.
state.
tx.
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pdflib/
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ind.
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On­
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26
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USEPA),
February
20,
2000.
40
CFR
Parts
80,
85,
and
86
Control
of
Air
Pollution
from
New
Motor
Vehicles:
Tier
2
Motor
Vehicle
Emissions
Standards
and
Gasoline
Sulfur
Control
Requirements,
Final
Rule.
Volume
65,
Number
28.
Available
online:
http://
www.
epa.
gov/
fedrgstr/
EPA­
AIR/
2000/
February/
Day­
10/
a19a.
htm.

U.
S.
Environmental
Protection
Agency
(
USEPA),
October
1997.
New
Emission
Standards
for
Heavy­
Duty
Diesel
Engines
Used
in
Trucks
and
Buses.
Ann
Arbor,
Michigan.
Available
online:
http://
www.
epa.
gov/
OMSWWW/
hd­
hwy.
htm
U.
S.
Environmental
Protection
Agency
(
USEPA),
January
30,
1998.
MOBILE5
Information
Sheet
#
5:
Inclusion
of
New
2004
NOx
Standard
for
Heavy­
Duty
Diesel
Engines
in
MOBILE5a
and
MOBILE5b
Modeling.
Ann
Arbor,
Michigan.
Available
online:
http://
www.
epa.
gov/
oms/
m5.
htm
