Third
Biannual
Report
on
the
Early
Action
Compact
for
Northeast
Texas
June
30,
2004
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1
Third
Biannual
Report
on
the
Early
Action
Compact
for
Northeast
Texas
June
30,
2004
Background
On
December
20,
2002
local
governments
in
a
five
county
area
of
Northeast
Texas
(
Gregg,
Harrison,
Rusk,
Smith,
and
Upshur
counties)
entered
into
an
Early
Action
Compact
(
EAC)
with
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
the
Texas
Commission
on
Environmental
Quality
(
TCEQ).
The
purpose
of
the
EAC
is
to
develop
and
implement
a
Clean
Air
Action
Plan
(
CAAP)
that
will
reduce
ground
level
ozone
concentrations
throughout
the
five
county
area
to
comply
with
the
8­
hour
ozone
standard
by
December
31,
2007
and
maintain
the
standard
beyond
that
date.
The
EAC
includes
a
series
of
milestones
to
guide
progress
toward
the
development
of
the
CAAP
and
as
shown
in
Table
1.
The
area
also
must
submit
progress
reports
to
EPA
documenting
progress
in
implementing
the
EAC
and
achieving
the
milestones.
The
requirements
for
the
progress
reports
are
given
in
EPA's
April
4,
2003
guidance.
This
is
the
third
(
June
2004)
progress
report
covering
activities
for
the
first
half
of
2004.

Table
1.
Key
milestone
dates
for
the
Northeast
Texas
Early
Action
Compact
(
EAC).
Date
Item
December
31,
2002
Signed
EAC
agreement
June
16,
2003
Identify/
describe
potential
local
emission
reduction
strategies
November
30,
2003
Initial
modeling
emission
inventory
completed
Conceptual
model
completed
Base
case
(
1999)
modeling
completed
December
31,
2003
Future
year
(
2007)
emission
inventory
completed
Emission
inventory
comparison
for
1999
and
2007
Future
case
modeling
completed
January
31,
2004
Schedule
for
developing
further
episodes
completed
Local
emission
reduction
strategies
selected
One
or
more
control
cases
modeled
for
2007
Attainment
maintenance
analysis
(
to
2012)
completed
Submit
preliminary
Clean
Air
Action
Plan
(
CAAP)
to
TCEQ
and
EPA
March
31,
2004
Final
revisions
to
2007
control
case
modeling
completed
Final
revisions
to
local
emission
reduction
strategies
completed
Final
attainment
maintenance
analysis
completed
Submit
final
CAAP
to
TCEQ
and
EPA
December
31,
2004
State
submits
SIP
incorporating
the
CAAP
to
EPA
December
31,
2005
Local
emission
reduction
strategies
implemented
no
later
than
this
date
December
31,
2007
Attainment
of
the
8­
hour
ozone
standard
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Ozone
Attainment
Status
The
Northeast
Texas
ozone
monitoring
data
determine
whether
the
area
is
in
compliance
with
the
National
Ambient
Air
Quality
Standards
(
NAAQS)
for
ozone.
There
have
been
no
exceedences
of
the
1­
hour
ozone
standard
in
Northeast
Texas
in
the
past
3
years
and
so
the
area
is
monitoring
attainment
of
the
1­
hour
ozone
NAAQS
in
2003.
The
annual
4th
highest
8­
hour
ozone
values
at
monitors
in
Northeast
Texas
are
shown
in
Table
2
along
with
the
resulting
2001­
2003
8­
hour
design
values.
Since
Karnack
and
Waskom
do
not
have
3
years
of
complete
data
they
were
not
used
by
EPA
for
attainment
designation,
but
they
have
2
year
design
values
that
are
below
the
level
of
the
8­
hour
ozone
NAAQS.
The
monitors
at
Longview
and
Tyler
have
complete
2001­
2003
data
and
are
monitoring
attainment
of
the
8­
hour
ozone
NAAQS
in
2003.
EPA
has
designated
all
five
NETAC
counties
as
8­
hour
ozone
attainment
areas.

Table
2.
Annual
4th
highest
8­
hour
ozone
values
(
ppb)
and
2003
8­
hour
ozone
design
values
for
Northeast
Texas
Year
Longview
Tyler
Karnack
Waskom
2001
82
82
Partial
season
Not
Operating
2002
84
84
88
86
2003
82
79
80
82
2003
Design
Value
82
81
N/
A
N/
A
I.
Stakeholder
Process
In
1995
local
elected
officials
and
other
leaders
in
local
government,
business
and
industry
created
Northeast
Texas
Air
Care
(
NETAC)
in
order
to
provide
leadership
and
guidance
in
addressing
ozone
air
quality
issues
in
a
five
county
area
consisting
of
Gregg,
Harrison,
Rusk,
Smith,
and
Upshur
counties.
A
26­
member
policy
committee
consisting
of
representatives
of
local
government,
business
and
industry,
the
general
public
and
environmental
interest
groups
governs
NETAC.
(
Attachment
1)

From
its
inception
NETAC
has
placed
significant
emphasis
on
the
need
to
ensure
that
air
quality
planning
activities
are
developed
using
scientifically
sound
techniques.
In
order
to
achieve
this
objective
NETAC
created
a
Technical
Advisory
Committee
to
undertake,
supervise,
and
guide
technical
studies
such
as
emission
inventory
development,
air
quality
modeling
and
control
strategy
development,
and
specialized
monitoring
studies.
The
Technical
Advisory
Committee
reports
to
the
policy
committee.
The
Technical
Advisory
Committee
consists
of
representatives
from
local
government,
local
business
and
industry,
EPA
technical
staff,
TCEQ
technical
staff,
Texas
Department
of
Transportation
planning
staff,
and
the
general
public
and
environmental
interest
groups.
(
Attachment
2)

NETAC
is
actively
involved
in
public
education
and
outreach
programs
concerning
ozone
air
quality
issues.
This
work
is
guided
by
NETAC's
Public
Education/
Outreach
Committee,
which
consists
of
representatives
from
local
government,
local
business
and
industry,
TCEQ
staff,
and
environmental
interest
groups.
(
Attachment
3)
The
Public
Education/
Outreach
Committee
reports
to
the
NETAC
Policy
Committee.
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NETAC
receives
staff
support
for
its
activities
from
the
East
Texas
Council
of
Governments
(
ETCOG),
which
receives
and
administers
grant
funds
provided
by
the
Texas
Legislature
for
air
quality
planning
activities.

NETAC
and
its
subcommittees
meet
on
an
as­
needed
basis.
All
meetings
are
open
to
the
public
and
are
posted
at
the
East
Texas
Council
of
Governments
and
advertised
through
the
distribution
of
information
packets
to
local
media
outlets.

During
the
first
half
of
2004
NETAC
held
Technical
Advisory
Committee
held
six
meetings
on
January
22,
March
19,
March
26,
April
23,
June
7,
and
June
25.
The
NETAC
Policy
Committee
met
on
January
22
and
March
26,
2004.
The
January
22
Technical
and
Policy
Committee
meetings
discussed
and
approved
submission
of
the
draft
Clean
Air
Action
Plan
(
CAAP)
to
the
TCEQ
and
EPA
at
the
end
of
January
2004.
The
March
19
Technical
Committee
meeting
discussed
revisions
to
the
draft
CAAP.
The
March
26
Technical
and
Policy
Committee
meetings
discussed
and
approved
the
final
CAAP
submitted
to
the
TCEQ
and
EPA
at
the
end
of
March
2004.
The
Technical
Committee
meetings
held
in
April
and
June
discussed
the
implementation
of
additional
local
emission
reductions
and
plans
for
air
quality
monitoring
activities.

The
NETAC
Public
Education
Committee
met
on
April
6,
2004
to
discuss
activities
for
2004
and
preparations
for
the
ozone
season
awareness
kickoff
event
held
on
April
30,
2004.

II.
Public
Outreach
NETAC
is
actively
engaged
in
public
education
and
outreach
activities
concerning
ozone
air
quality
issues.
NETAC
held
an
ozone
season
awareness
kickoff
event
on
April
30,
2004
to
raise
public
awareness
of
ozone
air
quality
issues
and
encourage
public
support
for
programs
designed
to
minimize
ozone
formation.

Public
education
and
outreach
programs
that
have
been
established
and
that
continue
on
an
ongoing
basis
include:

1.
Production
and
distribution
of
public
service
announcements
broadcast
on
local
radio
stations
providing
information
on
ozone
air
quality
issues
and
recommending
actions
to
reduce
ozone
levels
on
ozone
action
days.

2.
Printing
and
distribution
to
local
public
schools
book
covers
designed
to
increase
public
awareness
of
ozone
air
quality
issues.

3.
Establishment
and
maintenance
of
a
website
(
http://
www.
netac.
org)
to
provide
information
concerning
ozone
air
quality
issues
and
NETAC's
ongoing
activities.
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4.
Annual
sponsorship
of
an
ozone
awareness
event
prior
to
the
commencement
of
ozone
season
in
order
to
highlight
ozone
air
quality
issues
and
encourage
public
support
for
programs
designed
to
minimize
ozone
formation.

In
cooperation
with
the
Texas
Commission
on
Environmental
Quality,
NETAC
and
local
governments
in
the
area
provide
"
ozone
action
alerts"
for
the
public
on
days
when
TCEQ
predicts
meteorological
conditions
are
favorable
for
high
ozone
formation.
Notification
is
provided
through
the
NETAC
website,
local
government
public
access
channels,
and
the
display
of
ozone
alert
flags.

III.
Technical
Activities
NETAC
technical
activities
in
the
first
quarter
of
2004
(
January
to
March)
were
focused
on
preparing
the
Clean
Air
Action
Plan
(
CAAP)
for
submission
to
the
TCEQ
and
EPA
in
accordance
with
the
schedule
of
EAC
deliverables
shown
in
Table
1.
The
draft
CAAP
was
completed
in
January
2004
by
the
Technical
Advisory
Committee,
approved
by
the
Policy
Committee,
and
submitted
by
January
31,
2004.
The
final
CAAP
was
completed
in
March
2004
by
the
Technical
Advisory
Committee,
approved
by
the
Policy
Committee,
and
submitted
by
March
31,
2004.

The
NETAC
CAAP
concludes
that
the
area
expects
to
remain
in
attainment
of
the
8­
hour
ozone
standard
through
2012.
This
conclusion
is
based
on:

1.
A
modeling
attainment
demonstration
for
2007
with
projected
2007
design
values
of
Tyler
(
77
ppb),
Longview
(
80
ppb),
Karnack
(
81
ppb)
and
Waskom
(
82
ppb).

2.
A
weight­
of­
evidence
analysis
supporting
the
2007
modeling
attainment
demonstration.

3.
A
maintenance
for
growth
analysis
of
emissions
in
2012
showing
further
reductions
in
ozone
precursor
emission
levels
from
2007
to
2012.

The
NETAC
8­
hour
ozone
attainment
demonstration
for
2007
is
based
on
local,
State
and
Federal
emissions
reduction
strategies
that
are
currently
enforceable.
The
NETAC
CAAP
also
includes
additional
local
control
measures
to
further
reduce
ozone
levels
and
safeguard
ozone
attainment
for
the
region.
NETAC
technical
activities
in
the
second
quarter
of
2004
(
April
to
June)
have
been
analyzing
the
impacts
of
these
strategies
and
making
progress
toward
their
implementation.
Two
strategies
have
been
the
main
focus:

1.
HRVOC
reductions
at
chemical
plants
near
Longview
owned
by
Eastman
Chemical
Company
and
Huntsman.
NETAC
modeled
the
ozone
impacts
of
these
HRVOC
reductions
and
they
are
estimated
to
reduce
the
8­
hour
ozone
design
value
for
Longview
by
0.1
ppb
in
2007.
These
HRVOC
reductions
will
result
from
improved
leak
detection
and
repair
(
LDAR)
programs
made
enforceable
by
permits.
The
applicable
permits
for
Eastman
Chemical
Company
(
Voluntary
Emissions
Reduction
Permit
numbers
47007,
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48588
and
48590)
have
been
approved
by
the
TCEQ.
Huntsman's
permit
(
State
of
Texas
permit
number
18105)
is
under
review
by
the
TCEQ.

2.
NOx
reductions
from
compressor
engines
used
in
the
natural
gas
production
industry.
NETAC
has
identified
these
engines
as
a
significant
source
of
NOx
emissions
in
the
five
County
NETAC
area
for
which
there
are
efficient
and
cost­
effective
retrofit
technologies
available
now.
NETAC's
approach
to
reducing
these
emissions
is
to
encourage
the
engine
owner/
operators
to
apply
for
grants
from
the
Texas
Emissions
Reduction
Program
(
TERP)
to
install
retrofit
technologies.
This
is
discussed
further
in
the
next
section
on
emission
reduction
measures.

IV.
Emission
Reduction
Measures
The
HRVOC
reductions
at
the
Eastman
Chemical
Company
and
Huntsman
facilities
in
Gregg
County
were
included
in
NETAC's
Clean
Air
Action
Plan
as
enforceable
measures.
As
noted
above
the
Eastman
reductions
are
federally
enforceable
through
permits
number
47007,
45588,
and
48590.
The
Huntsman
permit
is
currently
under
review
by
TCEQ.
No
obstacles
in
implementing
these
measures
are
anticipated.

An
additional
measure
included
in
the
Clean
Air
Action
Plan
for
Northeast
Texas
is
a
voluntary
measure
that
focuses
on
reducing
NOx
emissions
from
gas
compressor
engines
used
in
natural
gas
production
in
the
five
County
NETAC
areas.
Previous
studies
by
NETAC
indicate
that
an
estimated
32
tons/
day
of
NOx
emissions
are
generated
by
a
large
number
of
relativity
small
gas
compressor
engines
that
are
widely
distributed
throughout
the
five
county
area.
Non­
Selective
Catalytic
Reduction
(
NSCR)
systems
combined
with
an
electronic
air/
fuel
ratio
controller
can
achieve
a
NOx
reduction
of
more
than
90%
for
these
sources.
Owners
and
operators
of
gas
compressor
engines
in
the
five
county
NETAC
area
should
be
eligible
to
receive
grant
funding
from
the
Texas
Emission
Reduction
Plan
(
TERP)
for
installation
of
these
technologies.

East
Texas
Council
of
Governments
(
ETCOG)
has
entered
into
a
grant
agreement
with
the
Texas
Commission
on
Environmental
Quality
that
will
allow
ETCOG
and
NETAC
to
develop
and
implement
a
pilot
project,
which
would
demonstrate
the
effectiveness
of
NOx
reductions
on
gas
compressor
engines
using
catalyst
technology.
This
pilot
program
is
intended
to
encourage
and
facilitate
owners
and
operators
of
gas
compressor
engines
in
the
NETAC
area
applying
for
TERP
grants.

The
NETAC
Technical
Advisory
Committee
has
approved
the
pilot
project
work
plan.
Identification
of
candidate
engines
for
retrofitting
should
occur
before
August
31,
2004.
By
February
1,
2005
NETAC
plans
to
obtain,
install,
and
test
retrofit
equipment
on
up
to
four
gas
compressor
engines.
A
final
report
documenting
the
pilot
project
and
providing
materials
to
be
used
in
public
outreach
is
due
for
completion
by
February
28,
2005.

NETAC
does
not
anticipate
obstacles
in
implementing
its
pilot
program.
However,
unless
sufficient
funds
are
available
under
the
TERP
program
NETAC's
goal
of
encouraging
and
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facilitating
owners
and
operators
of
gas
compressor
engines
to
achieve
broader
reductions
through
individual
TERP
grants
could
be
impaired.

V.
Implementing
the
Clean
Air
Action
Plan
As
discussed
above,
NETAC
met
the
EAC
timeline
for
developing
a
CAAP
by
March
31,
2004.
The
next
stage
in
implementing
the
CAAP
is
for
the
TCEQ
to
incorporate
NETAC's
CAAP
into
a
State
Implementation
Plan
(
SIP)
revision
submitted
to
EPA
by
December
31,
2004.
The
TCEQ
has
developed
a
detailed
timeline
of
the
steps
needed
to
complete
the
SIP
revision
as
shown
in
Appendix
4.
NETAC
is
working
with
the
TCEQ
in
developing
the
SIP
by
supplying
information
needed
for
the
SIP
documents
and
assisting
with
scheduling
public
hearings
in
Northeast
Texas.
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Attachment
1
NETAC
Policy
Committee
 
Mayor
Joey
Seeber,
Co­
Chair,
City
of
Tyler
 
Judge
Bill
Stoudt,
Co­
Chair,
Gregg
County
 
Judge
Becky
Dempsey,
Smith
County
 
Judge
Fowler,
Upshur
County
 
Judge
Wayne
McWhorter,
Harrison
County
 
Judge
Sandra
Hodges,
Rusk
County
 
Mayor
Murray
Moore,
City
of
Longview
 
Mayor
Edward
Smith,
City
of
Marshall
 
Mayor
Foy
Brown,
City
of
Henderson
 
Tony
Williams,
City
Manager,
City
of
Kilgore
 
Greg
Morgan,
Project
Coordinator,
City
of
Tyler
 
Councilman
Johnny
Taylor,
City
of
Gilmer
 
Ricky
Childers,
City
Manager,
City
of
Longview
 
Janet
Cook,
Asst.
City
Manager,
City
of
Marshall
 
Tammy
Campbell,
WE
CAN
 
David
Duncan,
Environmental
Regional
Manager,
TXU
 
Darrell
J.
Rachels,
Eastman
Chemical
Company
 
Keith
Honey,
General
Manager,
AEP/
SWEPCO
 
Eric
Albritton,
Attorney
 
L.
Dale
Rhoades,
Environmental
Supervisor,
LaGloria
Oil
&
Gas
Co.
 
Lou
Ann
Nisbett,
Director,
MEDCO
 
John
M.
Stroud,
Executive
Director,
LEDCO
 
Tom
Mullins,
Executive
Director,
Tyler
Economic
Development
Corporation
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Attachment
2
NETAC
Technical
Advisory
Committee
 
Mayor
Murray
Moore,
City
of
Longview
 
Robert
Ray,
Assistant
City
Attorney,
City
of
Longview
 
Councilman
Gaylon
Butler,
City
of
Longview
 
Karen
Owen,
Longview
MPO
 
Greg
Morgan,
Projects
Coordinator,
City
of
Tyler
 
Tanya
McCuller,
Tyler
MPO
 
Janet
Cook,
Asst.
City
Manager,
City
of
Marshall
 
Jim
Mathews,
NETAC
General
Counsel
 
Erik
Snyder,
EPA
Region
6
 
Michael
Morton,
EPA­
Region
6
 
Jud
May,
EPA­
Region
6
 
Gerry
Wolfe,
SIP
Coordinator,
TCEQ­
Austin
 
James
Red,
TCEQ­
Austin
 
Charles
Murray,
TCEQ­
Region
5
Air
Program
 
Dale
Spitz,
TXDOT­
Tyler
District
 
Sharon
Wellman,
Eastman
Chemical
Company
 
L.
Dale
Rhoades,
LaGloria
Oil
&
Gas
Company
 
Kelly
Spencer,
AEP/
SWEPCO
 
Howard
Ground,
Manager
Air
Quality,
AEP/
SWEPCO
 
Dick
Robertson,
TXU
Air
Quality
Manager
 
David
Duncan,
TXU
 
Dennis
Leahey,
Huntsman
Chemical
 
Dwight
K.
Shellman,
Jr.,
Caddo
Lake
Institute,
Inc.
 
Ramon
Alvarez,
Ph.
D.,
Environmental
Defense
Fund
 
Eric
Albritton,
Attorney
 
Henry
C.
Bradbury,
Environmental
Solution
 
Micaela
Crooks,
CenterPoint
Energy
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Attachment
3
NETAC
Public
Education/
Outreach
Committee
 
Robert
Ray,
Assistant
City
Attorney,
City
of
Longview
 
Greg
Morgan,
Project
Coordinator,
City
of
Tyler
 
Janet
Cook,
City
of
Marshall
 
Sharon
Wellman,
Eastman
Chemical
Company
 
Don
Montgomery,
TXU
 
Kathy
Bell,
TCEQ­
Region
5
Air
Program
 
Darrell
Powell,
TCEQ­
Austin
 
Kelly
Spencer,
AEP/
SWEPCO
 
Scott
McCloud,
AEP/
SWEPCO
 
Henry
C.
Bradbury,
Environmental
Solution
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Attachment
4
TCEQ
Draft
Timeline
for
Developing
a
Northeast
Texas
SIP
Revision
in
2004
TASK
DATE(
S)

EAC
plans
submitted
to
TCEQ
March
31,
2004
Summarize
plans
in
prep
for
work
session/
Begin
to
draft
rules/
Continue
working
w/
locals
on
outstanding
issues
April
1­
16
Briefings
April
19­
21
Work
Session
executive
summary
due
April
22
Commissioners
Work
Session
­
EAC
plans
presented
for
discussion
April
30
Finalize
rules
(
if
necessary)
and
plans,
incorporate
into
SIP
revision
format
Continue
meeting
w/
locals
May
3­
June
4
Rules
processing
by
Texas
Register
staff
(
if
necessary)
June
7­
11
Final
review/
sign­
off
of
proposed
SIP
revisions
June
14­
18
Pre­
filing
briefings
June
21­
24
Back­
up
due
to
Chief
Clerk's
Office
June
25
Commissioners
agenda
­
proposed
SIP
revision
presented
for
approval
to
publish
July
14
Rules
published
in
the
Texas
Register
(
if
necessary)
July
30
Public
hearings
Aug
23­
27
Close
of
Public
Comment
Period
Aug
30
Analyze
comments,
prepare
final
SIP
revision
packages
including
rules
(
if
necessary)
Aug
30­
Sep
24
Initial
legal/
management
review
Sep
27­
Oct
1
Initial
Briefings
Oct
4­
8
Final
coordination
meetings
w/
locals
Oct
11­
22
Rules
processing
by
Texas
Register
staff
(
if
necessary)
Oct
25­
29
Final
internal
review/
sign­
off
Nov
1­
5
Pre­
filing
briefings
Nov
8­
10
Back­
up
due
to
Chief
Clerk's
Office
Nov
12
Commissioners
agenda
­
adoption
SIP
revisions
presented
for
approval
Dec
1
SIP
revision
submitted
to
EPA
by
Dec
31,
2004
