Tenth Biannual Report on the 

Early Action Compact for 

Northeast Texas

December 20, 2007

 Tenth Biannual Report on the Early Action Compact for Northeast Texas

December 20, 2007

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 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 Tenth
(December, 2007) progress report covering activities for the second half
of 2007.   

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



Implementing the Clean Air Action Plan

The TCEQ incorporated NETAC’s CAAP into a SIP revision on November 17,
2004.  The TCEQ submitted the SIP revision to EPA on schedule by
December 31, 2004.  On May 16, 2005, the EPA published a proposed rule
for approval and promulgation of the Northeast Texas CAAP (Federal
Register 70(93): 25794-25798).  On August 19, 2005 EPA published the
final rule approving and promulgating the Northeast Texas CAAP with an
effective date of September 19, 2005 (Federal Register 70(160):
48642-48645).

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.  The TCEQ operates three ozone monitors (Continuous Air
Monitoring Station, CAMS) in Northeast Texas at Longview, Tyler, and
Karnack.  NETAC has operated a research ozone monitor that was located
at Waskom in 2002-2003 and in Panola County in 2004-2006. The Panola
research monitor operated from July 9, 2004 to October 30, 2006 and
reported data through the TCEQ as CAMS 627.  EPA designated all five
NETAC counties as 8-hour ozone attainment areas on April 15, 2004 (see
69 FR 23858).  

The annual 4th highest 8-hour ozone values at monitors in Northeast
Texas for recent years are shown in graphical form in Figure 1, and are
listed in Table 2 along with the resulting 2005-2007 8-hour design
values.  The ozone data for the last four years show that 2005 was
relatively high ozone year in Northeast Texas; the 2005 data increased
the three year averages used to calculate the 2004-2006 design values to
the point where the Longview monitor was out of compliance with the
8-hour standard at the end of 2006.    2007, on the other hand, saw the
lowest 4th high ozone values in the last decade at the Northeast Texas
monitors.  The 2005-2007 design values are all 84 ppb or less, which
means that all Northeast Texas monitors are in compliance with the
8-hour ozone standard as of the date of this report.  The ozone data
from January 1, 2005 through November 30, 2007 have been validated by
the TCEQ.  The research monitor at Panola was not active in 2007, so a
design value cannot be calculated for 2005-2007 for this monitor.

Table 2.  Annual 4th highest 8-hour ozone values (ppb) and 2007 8-hour
ozone design values for Northeast Texas

Year	Longview	Tyler	Karnack	Panola

2004	83	81	77	75

2005	88	83	84	79

2006	84	82	78	79

2007	81	77	69	N/A

2005-2007 Design Value	84	80	77	N/A

	

The recent trends in 8-hour ozone design values for Northeast Texas
monitors are shown in Table 3.  The Karnack design value has declined
steadily over the last few years to its current value of 77 ppb.  The
Karnack monitor is located in a rural area near the Texas-Louisiana
border; the reduction in the Karnack design value suggests that regional
transport of ozone into Northeast Texas is decreasing as regional
control strategies for ozone take effect.  The design value at the Tyler
monitor fell by 2 ppb to 80 ppb for 2005-2007. The Tyler design value
has been relatively steady over the last four years, with only small
changes that may be attributed to variability in the weather.  The
design value at Longview increased by 1 ppb per year during the
2002-2006 period, and the 2004-2006 design value of 85 ppb was out of
compliance with the 8-hour standard.  During 2007, the 4th highest ozone
value recorded at Longview was 81 ppb. This low value for 2007 brought
the Longview design value for 2005-2007 to 84 ppb, which is in
compliance with the 8-hour ozone standard.  

Table 3.  Recent trends in 8-hour ozone design values (ppb) for
Northeast Texas

Design Value for Years	Longview	Tyler	Karnack	Panola

2002-2004 	83	81	81	N/A

2003-2005 	84	81	80	77

2004-2006	85	82	79	77

2005-2007	84	80	77	N/A







Figure 1. Trends in annual 4th highest 8-hour ozone values (ppb) at the
Longview, Tyler, and Karnack monitors in Northeast Texas



Analysis of 2007 Ozone Data

NETAC has reviewed 2007 ozone concentrations recorded at the Longview,
Karnack, and Tyler ozone monitors through the date of this report. 
Although 2007 is not yet over, an ozone exceedance has never been
recorded in December at the Longview, Tyler, or Karnack monitors;
therefore, we present a preliminary analysis of the 2007 ozone season. 
For the purposes of the analysis presented below, we define a high ozone
day to be one on which the daily maximum 8-hour average ozone
concentration was greater than 80 ppb at one or more of the three
Northeast Texas monitors.  There were six such days in 2007.  One
additional day with peak 8-hour ozone 77 ppb is included as a high ozone
day because the Longview monitor had a 1-hour concentration of 97 ppb on
this day (May 12).

Each high ozone day was analyzed using data for ozone, sulfur dioxide,
NOx, total non-methane hydrocarbon, and wind from the TCEQ CAMS
ground-level monitors at Longview, Tyler and Karnack.  The surface wind
data was supplemented with aloft wind fields measured by the NOAA radar
profiler at the Longview CAMS 19 site.  The radar profiler provides an
independent measurement of the near-surface winds as well as data on
wind speed and direction up to an altitude of approximately 4
kilometers.  Back trajectories were prepared for air arriving at each
monitor that measured high ozone.  The back trajectories were calculated
using NOAA’s HYSPLIT (Hybrid Single-Particle Lagrangian Integrated
Trajectory) model.  Back trajectories are a qualitative tool subject to
theoretical and data limitations and were used only to investigate
possible source regions for pollutants transported to the monitor.

Here follows an analysis of the high ozone days in Northeast Texas in
2007 based on the available data described in the previous paragraph:

Four high ozone days at Longview were associated with northerly winds
and a rapid early morning rise in ozone. These sharp ozone increases
during times of northerly winds are consistent with the impact of a
plume containing highly reactive volatile organic compounds (HRVOCs)
from the chemical plant complex owned by Eastman, Westlake and Flint
Hills (formerly Huntsman).

On several high ozone days at Longview, elevated sulfur dioxide was
observed at the same time as the ozone peak, indicative of plume impacts
from nearby power plants.  On two of these days, winds were northerly,
suggesting possible impacts from power plants in Titus County.  On three
of these days, winds were northeasterly, consistent with possible plume
impacts from the Pirkey Power Plant.

Regional 8-hour ozone levels in air entering the region were 60 ppb or
higher on both of the days when the Longview monitor recorded values of
85 ppb or higher.  

Four high ozone days at Longview and one at Tyler were associated with
ozone production from local sources superimposed on a regional 8-hour
ozone background of 60 ppb or greater.  

The sole high ozone day at the Tyler monitor was likely due to an impact
by the City of Tyler urban plume on a day with high (~70 ppb) regional
background ozone.

2007 was somewhat different from the two preceding years in that high
ozone days were most often associated with northerly or northeasterly
winds.  In 2005 and 2006, winds were frequently from the east or
southeast on high ozone days.  The 1999 episodes modeled for the CAAP
were similar to the easterly/southeasterly high ozone days seen during
2005-2006.  However,  the surface monitoring data from the 2007 ozone
season do not change the conceptual understanding of the factors leading
to ozone levels exceeding the 8-hour ozone standard in Northeast Texas. 
In 2007 as well as 2005, 2006, and the CAAP episodes, high ozone in
Northeast Texas was caused by emissions from sources within Northeast
Texas superimposed on a high regional ozone background.

Emission Reduction Measures

	NETAC’s CAAP includes modeling for a 1999 episode and a demonstration
that the area expects to remain in compliance with the 8-hour ozone
standard through 2007 and 2012 due to a combination of local and
regional emission reduction measures. NETAC has developed a new ozone
model for May-June 2005 and will reevaluate the effectiveness of local
emission reductions and other expected emissions changes through 2012. 
The local measures included in the CAAP attainment demonstration and the
new ozone model are reductions in NOx emissions at several facilities
operated by AEP and Luminant (formerly TXU) in Northeast Texas and both
NOx and VOC reductions at the Eastman Complex.  The local NOx and VOC
reduction measures have been in place since 2005 or earlier.  EPA’s
October 17, 2005 memorandum to EAC areas provided guidance on reporting
progress with implementing local emission reductions.  The status of the
six local measures discussed in the CAAP at the end of 2005 is reviewed
below.

Eastman Chemical Company enhanced leak detection/repair (LDAR)

	

Summary: Enhanced leak detection/repair programs were implemented in the
cracking plants and polyethylene units at Eastman Chemical Company near
Longview.

Status: Measures were implemented by July 11, 2005 and are documented by
Voluntary Emissions Reduction Permits #47007, #48588 and #48590.

Implementation date:  July 11, 2005.

Emission reductions: 0.63 TPD of VOC.

Resources: Eastman Chemical Company implemented the LDAR programs.

Flint Hills Resources (formerly Huntsman Chemical Company) enhanced leak
detection/repair (LDAR)

Summary: Enhanced leak detection/repair programs at Flint Hills
Resources chemical plant near Longview.

Status: Measures were implemented in the first half of 2005 and are
documented by Flexible Plant-wide Applicability Permit Limit (PAL)
Permit # 18105.	

Implementation date:  2005	

Emission reductions: 0.08 TPD of VOC by 2005; 0.12 TPD of VOC by 2008	

Resources: Huntsman Chemical Company implemented the LDAR programs

NOx reduction strategies for gas compressor engines

Summary: Implement pilot project to demonstrate the effectiveness of
retrofitting small (< 500 hp), spark-ignited, rich-burn compressor
engines used in natural gas production with exhaust catalysts and
electronic air/fuel ratio controllers in order to facilitate TERP or
other TCEQ funding for such sources.	

Status: 

In 2005, NETAC completed a pilot project to demonstrate the
effectiveness and cost-effectiveness of this strategy on five engines
within the NETAC area.  At the end of 2005, these controls were
achieving an estimated emission reduction of 0.1 TPD NOx.  This emission
reduction is not claimed because the pilot project was a demonstration
project, not an enforceable emissions reduction strategy.  

Based on the success of the pilot project, NETAC sought funding in 2005
for wider and enforceable implementation of this strategy through the
TCEQ "TERP" and "SEP" programs.

In 2006, TCEQ’s TERP program informed NETAC that compressor engine
retrofits with catalyst technology would not be TERP-eligible because
the technology was not certified or verified by EPA.

On January 31, 2007, TCEQ’s SEP coordinator informed NETAC that SEP
funds would not be available for installation of catalyst technology on
compressor engines because that technology lacked EPA certification or
verification.

Senate Bill 2000, filed by Senator Eltife of Tyler, was enacted by the
Texas Legislature on May 25, 2007 and signed by the Governor on June 15,
2007.  This bill authorizes implementation of a program to retrofit gas
compressor engines with catalyst technology.  However, no appropriation
was provided.

On June 21, 2007, TCEQ made available $4 million to fund compressor
engine retrofits with catalyst technology to implement SB 2000.

As of October 30, 2007, 3 compressor engine retrofits had been performed
in all of Texas, and only one of these was located in Northeast Texas.

NETAC has undertaken further outreach in order to promote participation
in the SB2000 program.

Implementation date: NETAC completed its pilot program to demonstrate
gas compressor controls in August 2005.  TCEQ implemented a compressor
engine retrofit program on a wider scale using the funding announced on
June 21, 2007.

Emission reductions: No enforceable emissions reductions to date,
although the one compressor engine retrofit performed in Northeast Texas
(in Harrison County) is a small emission reduction in NETAC’s area.  

DOE “Clean Cities Program” voluntary on-road vehicle emission
reductions

Summary: Funding for clean-fueled propane vans for local transit
agencies.	

Status: 23 propane-fueled vans placed in service by the end of 2005	

Implementation date: On-going	

0.5 TPY VOC 2.5 NOx TPY	

Funded by DOE's Clean Cities program

Public awareness program

ETCOG runs public awareness programs for the NETAC area.  Includes:
ozone watch and warning communications network between local government
& industries to communicate ozone action day forecasts issued by TCEQ; a
NETAC website; public service announcements; school programs and teacher
training workshops; distribution of public information & educational
materials; and an Annual Ozone Season kick-off meeting for the NETAC
area.	

ETCOG runs the NETAC public awareness program in 2007 as in previous
years. 	

Implementation date: On-going through 2008.

Emission reductions: This measure has program-based benefits but
specific emission benefits are not quantified.

Funded by the State of Texas through Rider funding for
near-nonattainment areas (NNAs)

Energy efficiency programs

Summary: The City of Tyler program includes: building lighting; HVAC &
Controls Upgrades; Traffic Light Upgrades; Park Lighting Upgrades; and
Wastewater Plant Motor and Controls Upgrades. The City of Longview
program includes: Improvements in lighting; HVAC systems; swimming pool
operations; and purchase of energy efficiency rated equipment for Public
Safety communications; The City of Marshall is initiating an energy
efficiency plan with assistance from Texas A&M University.

Status: 	 On-going.

Implementation date: 2003-2008

Emission reductions: Emission benefits for the NETAC area are not
quantified because it is difficult to determine where the reduced
electrical generation would occur. 

Additional Measures to Reduce Emissions

Incentive Grants to Reduce Emissions from Gas Compressor Engines.

The CAAP also describes additional local emission reduction strategies
that go beyond the attainment demonstration to further improve air
quality in Northeast Texas.  In particular, NETAC initiated a “pilot
program” to demonstrate NOx emission reduction technologies for gas
compressor engines.  The purpose of this program is to retrofit small (<
500 hp), spark-ignited, rich-burn compressor engines used in natural gas
production with exhaust catalysts and electronic air/fuel ratio
controllers. NETAC’s 1999 emission inventory for the CAAP modeling
estimated that 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.  A recently completed 2005
emission inventory estimated that 44 tons/day of NOx are emitted from
small gas compressor engines in the five county area.  This is a 27%
increase in NOx emissions over a six year period.  Natural gas well and
production data from the Texas Railroad Commission show the reason for
this upward trend in NOx emissions.  Figure 1 shows that the number of
gas wells in all 5 NETAC counties has increased during the 2000-2007
period.  The increase in the number of wells with time means more gas
compressor engines are operating within the 5-county area, which is
consistent with the increasing NOx emissions noted in the 2005 emission
inventory.    Figure 2 shows natural gas production from 1998-2006. 
Note that natural gas production is increasing in some counties and
decreasing in others.  The ratio of gas production to well number varies
with time, indicating that the amount of work required to extract gas
from the ground is also changing. In counties where the ratio decreases,
we expect that compressor engines are working harder to remove natural
gas from the ground, and that this added effort causes NOx emissions to
rise above and beyond the increases due to the addition of new wells. 



Figure 1.  Number of natural gas wells for 2000-2007 for each County in
the NETAC 5-County Area.   





Figure 2.  Natural gas production (millions of cubic feet) for 1998-2006
for each County in the NETAC 5-County Area.   



To date, NETAC’s continuing pilot program has retrofitted five gas
compressor engines and demonstrated that NOx emissions can be reduced by
approximately 96% at a cost effectiveness of less than $200 per ton of
NOx reduced.  NETAC sought funding in 2005 for broader implementation of
the gas compressor retrofit program through TCEQ’s supplemental
environmental projects (SEP) program and through the TERP program.  To
date, funding has not been authorized under either program.

NETAC has continued its efforts to implement a voluntary emission
reduction program for gas compressor engines by obtaining a funding
source.  Representatives of NETAC met with TCEQ Chairman Kathleen
Hartnett White in December 2006 to explore options and develop plans for
funding.  At the recommendation of Chairman White, NETAC conducted a
forum with representatives of TCEQ, EPA, gas compressor engine operators
and NETAC Policy Committee members in March 2007.  At that forum, NETAC
representatives requested that TCEQ review NETAC’s pilot project
report to determine whether it could be used to satisfy the criteria of
TCEQ’s TERP guidelines by establishing verification of catalyst
technology on the basis of the data and analyses presented in the study.

	Following NETAC’s forum on gas compressor engines, NETAC
representatives have worked closely with Senator Kevin Eltife to develop
legislation that would provide a funding mechanism for a voluntary
emission reduction program from gas compressor engines.  The resulting
legislation, Senate Bill 2000, was approved by the Texas Legislature and
signed by the Governor, but no funding was appropriated.  However, on
June 21, 2006, TCEQ announced that it would provide funding of $4
million to implement the compressor engine retrofit program authorized
by SB 2000.

NETAC and ETCOG are working with TCEQ to implement the compressor engine
retrofit program using the $4 million in funding made available by TCEQ.
 This funding can be utilized to achieve reductions earlier than
required by TCEQ’s East Texas Combustion Rule discussed below. 
Additionally, the retrofit program applies to engines below the 240 hp
range specified in TCEQ’s rule, thus providing  controls to a broader
group of engines that covered by TCEQ’s rule.

East Texas Combustion Rule

In June 2007, the TCEQ adopted an East Texas Combustion Rule as part of
the Dallas-Fort Worth 8-Hour Ozone SIP Revision.  The rulemaking will
subject owners or operators of stationary sources of NOx in the
Dallas-Fort Worth eight-hour ozone nonattainment area, as well as in
specified counties in the northeast Texas area, to more stringent
emission control, monitoring, testing, recordkeeping, and reporting
requirements. The Rule applies to rich-burn engines with horsepower
greater than 240 hp.  The preamble to the proposed rule published in
December 2006 noted that catalyst technology is expected to be the
primary control technology for rich-burn, gas-fired engines.  The rule
applies in 33 East Texas Counties, and the compliance deadline is March
1, 2010.  An analysis performed by the TCEQ suggests that NOx reductions
from the East Texas Combustion Rule for the 5-county Tyler-Longview area
would be approximately 7 tons per day. TCEQ has stated that adopting the
rule would not preclude implementation of voluntary emission reduction
programs before the rule’s compliance date.  

Luminant Emission Reductions at Martin Lake Power Plants

	Luminant has made a commitment to reduce NOx emissions from coal-fired
power plants by 20% below 2005 annual emissions.   To implement this
commitment, Luminant has filed with TCEQ applications for the
installation of selective catalytic reduction (SCR) technology on the
three electric generating units at the Martin Lake station.  During
TCEQ’s June 13, 2007, consideration of a Luminant permit application
for a new generating unit, TCEQ commissioner Larry Soward asked for
clarification concerning the Luminant commitment.  Luminant’s legal
counsel advised Commissioner Soward and the commission that the
commitment was evidenced by the applications to install SCR controls on
the Martin Lake units and the Sandow-4 unit.  Luminant’s legal counsel
reaffirmed that these emission reductions will occur.  

On July 17, 2007, the NETAC Policy Committee adopted a resolution urging
TXU (now Luminant), Kohlberg Kravis Roberts, and Texas Pacific Group to
cooperate with NETAC and TCEQ in making its proposed emission reductions
legally enforceable. NETAC’s co-chairs met with Luminant in 2007 to
discuss plans for additional controls at the Martin Lake units. 
Luminant has promised to provide NETAC additional information during the
first quarter of 2008.

NETAC’s 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 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 emphasized 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.  

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 second half of 2007, the NETAC Technical Advisory Committee
held meetings on June 28 and October 30, and will meet again on December
19.   The NETAC Policy Committee met on July 17 and October 30.  

During the June 28 and October 30 meetings, the Technical Committee
discussed: (a) the status of EPA’s proposed revisions to the ozone
NAAQS; (b) progress on funding NETAC’s gas compressor pilot project to
demonstrate engine retrofits that reduce NOx emissions in Northeast
Texas; (c) the impact of fires on high ozone days at the Longview
monitor during May-June, 2005; (d) measurements of VOCs at the Longview
CAMS 19 during 2005-2006 and 2007; (e) the 2007 ozone season and current
attainment status; (f) high ozone events during 2007; (g) ozone modeling
of May-June 2005; (h) compressor testing for NETAC's Pilot Project; and
(i) the status of future reduction strategies in Northeast Texas (gas
compressor engine rule, SB2000, and Luminant's reductions at Martin
Lake).

During the July 17 and October 30 meetings, the Policy committee
discussed: (a) the status of EPA’s proposed revisions to the ozone
NAAQS; (b) funding for the gas compressor engine retrofits program; (c)
transportation conformity; (d) New Source Review in nonattainment areas;
(e) criteria for maintaining policy committee membership; (f) TCEQ
rulemaking to implement HB 3732 on advanced clean energy projects; (g)
the 2007 ozone season and current attainment status; (h) EPA's review of
the ozone standard and TCEQ's comments; (i) the status of future
reduction strategies in Northeast Texas (gas compressor engine rule,
SB2000, and Luminant's reductions at Martin Lake).  The Policy Committee
also (j) approved a resolution concerning TXU emission reduction plans
at Martin Lake and (k) presented a Clean Air Achievement award to
Senator Kevin Eltife.

Public Outreach

NETAC is actively engaged in public education and outreach activities
concerning ozone air quality issues.  The public outreach committee
organized an ozone season awareness kickoff event for April 26, 2007.  
The purpose of the “kickoff event” was to raise public awareness of
ozone air quality issues and encourage public support for programs
designed to minimize ozone formation.

NETAC Public Education/Outreach activities for 2007 have consisted of
the following:

Hosting the NETAC website (www.netac.org).  The website is regularly
updated with meeting dates, associated agendas and enclosures for
Committee meetings.  The public can also find minutes of past meetings,
various air quality reports, and a directory of all participants in
NETAC. 

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. 

The Annual Ozone Season Awareness Event was held in Tyler at the Rose
Garden Center on April 26, 2007.  Speakers at the event included
Theresa Pella, Air Quality Planning Section Manager, TCEQ, who discussed
air quality issues affecting East Texas.  Other speakers included Jim
Mathews, NETAC Legal Counsel, who gave the NETAC Progress Report for
2007 and Steve Dayton, TERP Grant Contract Development Team Leader,
TCEQ, who discussed the status of TERP activities in Northeast Texas.

NETAC also sponsored a series of public service announcements (PSAs)
that ran on several local radio stations from May through September
2007.  A series of five different PSAs sought to educate the public
about what they can do at both work and home during the ozone season to
reduce their impact on air quality readings. 

The NETAC Public Education/Outreach Committee approved the purchase of
book covers for school districts in the five county region for the
2007-2008 school year.  The book covers have an informational theme as
well as including information on where to learn more about air quality.
 This is one of the most well received activities as ETCOG receives
numerous thank you letters from students and school administrations.

The NETAC Public Education/Outreach Committee approved the purchase of
additional signage for the inside of transit buses operated by ETCOG
Rural Transit.  The signage promotes the air quality benefits of public
transit and the alternative-fueled buses operated by these transit
providers.

Technical Activities

NETAC technical activities during 2005 and 2006 were focused on ambient
air monitoring.  During 2007, there has been a shift in emphasis from
monitoring to emission inventory development and ozone modeling and with
the goal of understanding the causes of episodes of elevated ozone
concentrations at the Longview monitor and developing a plan for
maintaining attainment through 2012.  NETAC carried out the following
technical activities in the second half of 2007 to support the EAC and
CAAP:

Air Monitoring

For several years, NETAC has collected canister VOC samples at CAMS 19
to augment the TCEQ’s monitoring activities at Longview.  VOC samples
collected at CAMS 19 in August-September, 2006 were analyzed to identify
what categories of VOCs were present and their potential to form ozone. 
Light alkanes (with less than 8 carbon atoms) consistent with
composition of natural gas were the most frequently detected VOCs at
Longview.  They were present in all samples, and the individual VOC
species were well-correlated, suggesting a common source such as oil and
gas production. VOC species associated with oil and gas production have
a low tendency to form ozone, but they were a constant presence at CAMS
19, and their concentrations were large enough that they could make a
significant contribution to ozone formation.  The ozone forming
potential of biogenic emissions as well as the contribution of highly
reactive anthropogenic volatile organic compounds was determined, but
limitations on the spatial and temporal sampling in this data set make
it likely that their contributions were underestimated.

NETAC continued to continue to collect VOC data in 2007.  During the
months of August and September, 2007, near-continuous VOC monitoring was
performed at CAMS 19 using a new technology.  VOCs were analyzed using
photo-acoustic spectroscopy (PAS) every 5-10 minutes, 24 hours a day,
providing a nearly continuous record of non-methane hydrocarbon
concentrations speciated to several broad classes.

NETAC conducted an aircraft study in August and September of 2006 to
obtain data on ozone contributions from local sources in Northeast Texas
and from ozone transport.  This is the third NETAC aircraft study; the
first was performed in August/September 2003 and the second in
August/September, 2005.  In 2006, the aircraft was operated by Baylor
University and collected data for ozone, nitrogen oxides (NOx), total
reactive nitrogen (NOy), sulfur dioxide (SO2), carbon monoxide (CO),
formaldehyde (HCHO), light scattering by haze, total olefins, and
meteorological parameters.  Successful flights were completed on seven
days from August 9 to November 3, 2006.  The aircraft observed ozone
production from sources in Northeast Texas including chemical plants,
power plants, forest fires, and urban areas.  The aircraft measured
ozone transport into Northeast Texas across the border with Louisiana. 
One flight was focused on characterizing emissions from the Eastman
Complex.   During this flight, the aircraft investigated the spatial
variations of highly reactive volatile organic compounds and NOx in the
immediate vicinity of the facility and in a plume extending downwind of
it.

NETAC operated a radar profiler at Longview CAMS19 from September, 2006
to September, 2007 to collect upper air data on wind speed and
direction.  The profiler was put in place as part of the TexAQS II
field study, and NETAC extended the deployment through the 2007 ozone
season.  The data were incorporated into conceptual models of high
ozone days that occurred in 2007.  The data have been archived so that
they would be available for future analysis and modeling studies.

Evaluating Emissions Growth

In 2007, NETAC focused on further refinement of the 2005 emission
inventory for Northeast Texas and began work on the development of a
2012 future year emission inventory.  High priority was placed on
improving the inventory of NOx emissions from compressor engines
associated with natural gas production. NETAC is developing an emission
inventory for 2012 focused on Northeast Texas that incorporates growth
projections and the effects of planned controls.  Several activities
were undertaken to inform those projections of growth and controls. 
During the first half of 2007, NETAC analyzed natural gas well and
production data from the Texas Railroad Commission with the aim of
understanding trends in NOx emissions associated with gas compressor
engines (See Figures 1 and 2).  NETAC also cataloged potential emission
reductions through 2012 that will be effected through the TERP program. 
The impact of future emissions reductions under the CAIR and BART
programs was assessed.  

Because power plants are a major source of NOx in Northeast Texas, it is
important to incorporate into the 2012 inventory the effects of new
power plants as well as new controls in existing plants.  The TCEQ has
received permit applications to construct several new coal-fired
electrical generating units (EGUs) in eastern Texas to meet future
energy demand in the state.  During the first half of 2007,
representatives of NETAC met with the firms that acquired the former TXU
(now known as Luminant): Kolberg, Kravitz, Roberts & Co. and Texas
Pacific Group.  These prospective owners were seeking input on emission
reduction plans in light of announced decisions to cancel construction
of 8 of Luminant’s 11 proposed new coal-fired electric generating
units in Texas.  NETAC representatives urged the prospective owners to
proceed with implementation of previously announced plans to implement
selective catalytic reduction (SCR) controls on the 3 existing units at
Martin Lake.  Luminant filed permit applications with TCEQ to authorize
implementation of SCR controls on the three existing units at Martin
Lake.

NETAC previously modeled the impact of 11 proposed new EGUs and
Luminant’s offset strategy.  The modeling data indicate that
installation of SCR on the 3 existing Martin Lake units would reduce the
2007 design value at Longview by approximately 1.4 ppb.  NETAC will
continue to closely follow Luminant’s plans for Martin Lake and other
power plants.

Ozone Modeling

In 2006, NETAC completed seasonal ozone modeling for June to September
of 2002 and May to September of 2005.  NETAC’s 2005 seasonal ozone
model is being refined to develop a SIP-quality episodic/seasonal ozone
model. This model will be used to understand the reasons for recent
ozone trends in Northeast Texas through an examination of the influences
of regional transport, local sources and meteorological variability on
Northeast Texas ozone levels. The emission inventory updates described
above will be integrated into the model, and their impact will be
assessed.  The episodic/seasonal modeling will be evaluated against
monitoring data.  Future year modeling of 2012 will be performed using
the emission inventory described above.  The impact of new emissions
sources and controls in Northeast Texas will be evaluated.  The role of
regional transport will be examined over time to determine whether
trends in ozone transport are improving, and how transport and
meteorology would be expected to influence ozone levels in Northeast
Texas in the future.  The model will also be used to evaluate the
impacts on Northeast Texas of potential new regional emission sources
and the potential benefits of regional emission reduction strategies. 
The model will guide any steps that may be taken to maintain compliance
with 8-hour ozone standard.   

In the second half of 2007, a 4-km resolution meteorological database
for the ozone model was completed and evaluated against observed weather
data.  Ozone modeling of the May-June 2005 period was performed and the
model was evaluated against TCEQ monitoring data. The model was found to
simulate measured surface ozone with good accuracy.  During November of
2007, TCEQ made available a revised emission inventory for 2005.  The
incorporation of this inventory into the ozone model was initiated
during the second half of 2007, as well the addition of hourly
continuous emissions monitoring data for large NOx sources in the
region, an updated, high resolution biogenic emission inventory, and a
new, state-of-the-science chemical mechanism.  

Attachment 1

NETAC Policy Committee 

Gregg County

Judge Bill Stoudt, Co-Chair

Harrison County

Judge Richard Anderson

Rusk County

Judge Sandra Hodges

Smith County

Judge Joel Baker

Upshur County

Judge Dean Fowler

City of Gilmer

Jeff Ellington

City of Henderson

Mayor Buzz Fullen

City of Kilgore

Jeff Howell

City of Longview

Mayor Jay Dean

Councilman John Bolster

City of Marshall

Mayor Ed Smith

Janet Cook

City of Tyler

Mayor Joey Seeber, Co-Chair

Greg Morgan

Longview Economic Development Corp. (LEDCO)

John Stroud

Marshall Economic Development Corp. (MEDCO)

Cliff Todd

Tyler Economic Development Corporation (TEDCO)

Tom Mullins

WE CAN

Ms. Tammy Campbell

AEP/SWEPCO

Keith Honey

Delek Refining

No current representative

Eastman Chemical Company

Darrell Rachels

Luminant

David Duncan

Attachment 2

NETAC Technical Advisory Committee

City of Longview

Robert Ray, Assistant City Attorney

Karen Owen, Longview MPO

City of Marshall

Janet Cook

City of Tyler

Greg Morgan

Angela Choy

EPA

Carrie Page

Erik Sndyer

TCEQ

Keith Mars

Doug Boyer

Charles Murray

NETAC General Counsel, 

Jim Mathews, Mathews and Freeland

TxDOT

Dale Spitz

AEP/SWEPCO

Kelly Spencer

Kimberly Hughes

N. N. Dharmarajan

Bruce Moore

CenterPoint Energy

Laura Guthrie

Lynette James

Delek Refining-Oil & Gas Company

No current Representative

Eastman Chemical Company

Sharon Wellman

Huntsman Chemical Company

Dennis Leahy

Luminant

David Duncan

Dick Robertson

Rick Hanning

Caddo Lake Institute, Inc.

Rick Lowerre, Lowere & Frederick

Environmental Defense Fund 

Mr. Ramon Alvarez, Ph.D.

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

Rick Hanning, Luminant

Kathy Bell, TCEQ-Region 5 Air Program

Leigh Ann Brunson, TCEQ-Austin

Kelly Spencer, AEP/SWEPCO

Scott McCloud, AEP/SWEPCO

 PAGE   

	  PAGE  1 

