 

Identification and Evaluation of

Candidate Control Measures

Final

Technical Support Document

Prepared for: 

Seth Barna

Ozone Transport Commission (OTC) 

444 North Capitol Street, NW, Suite 638

Washington, DC  20001

(202) 508-3840

Prepared by:

MACTEC Federal Programs, Inc.

560 Herndon Parkway, Suite 200

Herndon, VA 20170

(703) 471-8383

February 28, 2007

______________________	______________________

Edward Sabo							Douglas A. Toothman

Principal Scientist						Principal Engineer



(Page intentionally left blank)Table of Contents

  TOC \o "1-4" \h \z \u    HYPERLINK \l "_Toc160602554"  1.0 EXECUTIVE
SUMMARY	  PAGEREF _Toc160602554 \h  1-1  

  HYPERLINK \l "_Toc160602555"  2.0 INTRODUCTION	  PAGEREF _Toc160602555
\h  2-1  

  HYPERLINK \l "_Toc160602556"  3.0 VOC ANALYSIS METHODS	  PAGEREF
_Toc160602556 \h  3-1  

  HYPERLINK \l "_Toc160602557"  3.1	ADHESIVES, SEALANT, ADHESIVE PRIMER,
AND SEALANT PRIMER APPLICATION	  PAGEREF _Toc160602557 \h  3-1  

  HYPERLINK \l "_Toc160602558"  3.1.1	Existing Federal and State Rules	 
PAGEREF _Toc160602558 \h  3-1  

  HYPERLINK \l "_Toc160602559"  3.1.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602559 \h  3-3  

  HYPERLINK \l "_Toc160602560"  3.1.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602560 \h  3-4  

  HYPERLINK \l "_Toc160602561"  3.1.4	Cost Estimates	  PAGEREF
_Toc160602561 \h  3-4  

  HYPERLINK \l "_Toc160602562"  3.2	CUTBACK AND EMULSIFIED ASPHALT
PAVING	  PAGEREF _Toc160602562 \h  3-5  

  HYPERLINK \l "_Toc160602563"  3.2.1	Existing Federal and State Rules	 
PAGEREF _Toc160602563 \h  3-5  

  HYPERLINK \l "_Toc160602564"  3.2.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602564 \h  3-7  

  HYPERLINK \l "_Toc160602565"  3.2.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602565 \h  3-7  

  HYPERLINK \l "_Toc160602566"  3.2.4	Cost Estimates	  PAGEREF
_Toc160602566 \h  3-7  

  HYPERLINK \l "_Toc160602567"  3.3	CONSUMER PRODUCTS	  PAGEREF
_Toc160602567 \h  3-8  

  HYPERLINK \l "_Toc160602568"  3.3.1	Existing Federal and State Rules	 
PAGEREF _Toc160602568 \h  3-8  

  HYPERLINK \l "_Toc160602569"  3.3.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602569 \h  3-9  

  HYPERLINK \l "_Toc160602570"  3.3.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602570 \h  3-10  

  HYPERLINK \l "_Toc160602571"  3.3.4	Cost Estimates	  PAGEREF
_Toc160602571 \h  3-11  

  HYPERLINK \l "_Toc160602572"  3.4	PORTABLE FUEL CONTAINERS	  PAGEREF
_Toc160602572 \h  3-11  

  HYPERLINK \l "_Toc160602573"  3.4.1	Existing Federal and State Rules	 
PAGEREF _Toc160602573 \h  3-12  

  HYPERLINK \l "_Toc160602574"  3.4.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602574 \h  3-13  

  HYPERLINK \l "_Toc160602575"  3.4.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602575 \h  3-14  

  HYPERLINK \l "_Toc160602576"  3.4.4	Cost Estimates	  PAGEREF
_Toc160602576 \h  3-15  

  HYPERLINK \l "_Toc160602577"  3.5	REGIONAL FUELS	  PAGEREF
_Toc160602577 \h  3-15  

  HYPERLINK \l "_Toc160602578"  3.5.1	Existing Federal and State Rules	 
PAGEREF _Toc160602578 \h  3-16  

  HYPERLINK \l "_Toc160602579"  3.5.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602579 \h  3-16  

  HYPERLINK \l "_Toc160602580"  3.5.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602580 \h  3-16  

  HYPERLINK \l "_Toc160602581"  3.5.4	Cost Estimates	  PAGEREF
_Toc160602581 \h  3-16  

  HYPERLINK \l "_Toc160602582"  3.6	VOC EMISSION REDUCTION SUMMARY	 
PAGEREF _Toc160602582 \h  3-17  

  HYPERLINK \l "_Toc160602583"  4.0 NOx ANALYSIS METHODS	  PAGEREF
_Toc160602583 \h  4-1  

  HYPERLINK \l "_Toc160602584"  4.1	HEAVY-DUTY TRUCK DIESEL ENGINE CHIP
REFLASH	  PAGEREF _Toc160602584 \h  4-1  

  HYPERLINK \l "_Toc160602585"  4.1.1	Existing Federal and State Rules	 
PAGEREF _Toc160602585 \h  4-1  

  HYPERLINK \l "_Toc160602586"  4.1.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602586 \h  4-2  

  HYPERLINK \l "_Toc160602587"  4.1.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602587 \h  4-2  

  HYPERLINK \l "_Toc160602588"  4.1.4	Cost Estimates	  PAGEREF
_Toc160602588 \h  4-2  

  HYPERLINK \l "_Toc160602589"  4.2	REGIONAL FUELS	  PAGEREF
_Toc160602589 \h  4-3  

  HYPERLINK \l "_Toc160602590"  4.2.1	Existing Federal and State Rules	 
PAGEREF _Toc160602590 \h  4-3  

  HYPERLINK \l "_Toc160602591"  4.2.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602591 \h  4-3  

  HYPERLINK \l "_Toc160602592"  4.2.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602592 \h  4-4  

  HYPERLINK \l "_Toc160602593"  4.2.4	Cost Estimates	  PAGEREF
_Toc160602593 \h  4-4  

  HYPERLINK \l "_Toc160602594"  4.3	ASPHALT PAVEMENT PRODUCTION PLANTS	 
PAGEREF _Toc160602594 \h  4-4  

  HYPERLINK \l "_Toc160602595"  4.3.1	Existing Federal and State Rules	 
PAGEREF _Toc160602595 \h  4-4  

  HYPERLINK \l "_Toc160602596"  4.3.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602596 \h  4-4  

  HYPERLINK \l "_Toc160602597"  4.3.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602597 \h  4-6  

  HYPERLINK \l "_Toc160602598"  4.3.4	Cost Estimates	  PAGEREF
_Toc160602598 \h  4-6  

  HYPERLINK \l "_Toc160602599"  4.4	CEMENT KILNS	  PAGEREF _Toc160602599
\h  4-6  

  HYPERLINK \l "_Toc160602600"  4.4.1	Existing Federal and State Rules	 
PAGEREF _Toc160602600 \h  4-7  

  HYPERLINK \l "_Toc160602601"  4.4.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602601 \h  4-8  

  HYPERLINK \l "_Toc160602602"  4.4.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602602 \h  4-9  

  HYPERLINK \l "_Toc160602603"  4.4.4	Cost Estimates	  PAGEREF
_Toc160602603 \h  4-9  

  HYPERLINK \l "_Toc160602604"  4.5	GLASS/FIBERGLASS FURNACES	  PAGEREF
_Toc160602604 \h  4-9  

  HYPERLINK \l "_Toc160602605"  4.5.1	Existing Federal and State Rules	 
PAGEREF _Toc160602605 \h  4-9  

  HYPERLINK \l "_Toc160602606"  4.5.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602606 \h  4-10  

  HYPERLINK \l "_Toc160602607"  4.5.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602607 \h  4-11  

  HYPERLINK \l "_Toc160602608"  4.5.4	Cost Estimates	  PAGEREF
_Toc160602608 \h  4-11  

  HYPERLINK \l "_Toc160602609"  4.6	ICI BOILERS	  PAGEREF _Toc160602609
\h  4-12  

  HYPERLINK \l "_Toc160602610"  4.6.1	Existing Federal and State Rules	 
PAGEREF _Toc160602610 \h  4-12  

  HYPERLINK \l "_Toc160602611"  4.6.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602611 \h  4-13  

  HYPERLINK \l "_Toc160602612"  4.6.3	Emission Benefit Analysis Methods	
 PAGEREF _Toc160602612 \h  4-13  

  HYPERLINK \l "_Toc160602613"  4.6.4	Cost Estimates	  PAGEREF
_Toc160602613 \h  4-22  

  HYPERLINK \l "_Toc160602614"  4.7	NOx EMISSION REDUCTION SUMMARY	 
PAGEREF _Toc160602614 \h  4-22  

  HYPERLINK \l "_Toc160602615"  5.0 REFERENCES	  PAGEREF _Toc160602615
\h  5-1  

 

List of Appendices

Appendix A – Process for Identifying and Evaluating Control Measures

Appendix B – Initial List of Control Measures

Appendix C – Control Measures Summary Sheets

Appendix D – VOC Emissions by County for 2002 and 2009

Appendix E – NOx Emissions by County for 2002 and 2009

Appendix F – ICI Boiler Regulations by State

List of Figures

List of Tables	Page

1-1	VOC Emission Reduction Benefits from OTC 2006 Control Measures	1-7

1-2	NOx Emission Reduction Benefits from OTC 2006 Control Measures	1-8

List of Tables

List of Tables	Page

1-1	Summary of OTC 2006 Control Measures	1-3

1-2	Estimated Emission Reduction Benefits in 2009 by State	1-6

3-1	Summary of OTC State Rules for Cutback and Emulsified Asphalt	3-6

3-2	Status of OTC State’s Promulgation of the OTC 2001 Model Rule for 
                  Consumer Products	3-9

3-3	Consumer Products Affected by CARB’s July 2005 Rule Amendments
3-10

3-4	Status of OTC State’s Promulgation of the OTC 2001 Model Rule for 
                     Portable Fuel Containers	3-14

3-5	OTC 2006 VOC Model Rule Benefits by State for 2009: 

	Adhesives and Sealants Application	3-19

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

	Cutback and Emulsified Asphalt Paving	3-20

3-7	OTC 2006 VOC Model Rule Benefits by State for 2009: 

	Consumer Products	3-21

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

	Portable Fuel Containers – Area Sources	3-22

3-9	OTC 2006 VOC Model Rule Benefits by State for 2009: 

	Portable Fuel Containers – Nonroad Sources	3-23

3-10	OTC 2006 VOC Model Rule Benefits by State for 2009: 

	Regional Fuels	3-24

3-11	OTC 2006 VOC Model Rule Benefits by State for 2009: 

	All Five VOC Categories	3-25

4-1	OTC Resolution 06-02 Emission Guidelines for Asphalt Plants	4-5

4-2	OTC Resolution 06-02 Emission Guidelines for Cement Kilns	4-8

4-3	OTC Resolution 06-02 Emission Guidelines for Glass Furnaces	4-10

4-4	OTC Proposal for ICI Boilers	4-14

4-5	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Natural Gas-fired Boilers	4-16

4-6	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Distillate Oil-fired Boilers	4-17

4-7	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Residual Oil-fired Boilers	4-18

4-8	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Coal Wall-fired Boilers	4-19

4-9	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Coal Tangential-fired Boilers	4-20

4-10	Current State Emission Limits and Percent Reduction for OTC
Proposal

	Point Source Coal-fired Stoker Boilers	4-21

List of Tables (continued)

List of Tables	Page

4-11	OTC 2006 NOx Model Rule Benefits by State for 2009: 

	Heavy-Duty Truck Diesel Engine Chip Reflash	4-24

4-12	OTC 2006 NOx Model Rule Benefits by State for 2009: 

	Regional Fuels	4-25

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

	Asphalt Pavement Production Plants	4-26

4-14	OTC 2006 NOx Model Rule Benefits by State for 2009: 

	Cement Kilns	4-27

4-15	OTC 2006 NOx Model Rule Benefits by State for 2009: 

	Glass/Fiberglass Furnaces	4-28

4-16	OTC 2006 NOx Model Rule Benefits by State for 2009: 

	ICI Boilers – Area (minor) Sources	4-29

4-17	OTC 2006 NOx Model Rule Benefits by State for 2009: 

	ICI Boilers – Point (major) Sources	4-30

4-18	OTC 2006 NOx Model Rule Benefits by State for 2009: 

	All Seven NOx Categories	4-31

Acronyms and Abbreviations

Acronym	Description

BOTW	Beyond-on-the-Way – refers to additional emission controls that
are being considered 

CAIR	Clean Air Interstate Rule

EGAS 5.0	Economic Growth Analysis System Version 5.0

EGU	Electric Generating Unit

EPA	U.S. Environmental Protection Agency

IPM	Integrated Planning Model

MANE-VU	Mid-Atlantic/Northeast Visibility Union

MARAMA	Mid-Atlantic Regional Air Management Association

MOBILE6	U.S. EPA’s emission model for onroad sources

NESCAUM	Northeast States for Coordinated Air Use Management

NH3	Ammonia

NIF3.0	National Emission Inventory Input Format Version 3.0

NONROAD	U.S. EPA’s emission model for certain types of nonroad
equipment

NOx	Oxides of nitrogen

OTB/W	On-the-Books/On-the-Way – refers to emission control programs
already adopted and proposed emission controls that will result in
post-2002 emission reductions 

OTC	Ozone Transport Commission

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

OTC 2006 model rules	Model rules developed by the OTC in 2006

PM10-PRI	Particulate matter less than or equal to 10 microns in diameter
that includes both the filterable and condensable components of
particulate matter

PM25-PRI	Particulate matter less than or equal to 2.5 microns in
diameter that includes both the filterable and condensable components of
particulate matter

SIC	Standard Industrial Classification code

SIP	State Implementation Plan

SCC	Source Classification Code

SO2	Sulfur dioxide

VOC	Volatile organic compounds

EXECUTIVE SUMMARY

The States of the Ozone Transport Region (OTR) are faced with the
requirement to submit attainment demonstration plans for the 8-hour
ozone National Ambient Air Quality Standards (NAAQS).  To accomplish
this, most of the states will need to implement additional measures to
reduce emissions that either directly impact their nonattainment status,
or contribute to the nonattainment status in other states.  As such, the
Ozone Transport Commission (OTC) undertook an exercise to identify a
suite of additional control measures that could be used by the OTR
states in attaining their goals.

The OTC staff and member states formed several workgroups to identify
and evaluate candidate control measures.  Initially, the Workgroups
compiled and reviewed a list of approximately 1,000 candidate control
measures.  These control measures were identified through published
sources such as the U.S. Environmental Protection Agency’s (EPA’s)
Control Technique Guidelines, STAPPA/ALAPCO “Menu of Options”
documents, the AirControlNET database, emission control initiatives in
member states as well as other states including California,
state/regional consultations, and stakeholder input.  The Workgroups
developed a preliminary list of 30 candidate control measures to be
considered for more detailed analysis.  These measures were selected to
focus on the pollutants and source categories that are thought to be the
most effective in reducing ozone air quality levels in the Northeastern
and Mid-Atlantic States.  

The Workgroups discussed the candidate control measures during a series
of conference calls and workshops held periodically from the spring of
2004 through the autumn of 2006.  The Workgroups collected and evaluated
information regarding emission benefits, cost-effectiveness, and
implementation issues.  Each of the candidate control measures were
summarized in a series of “Control Measure Summary Sheets”. 
Stakeholders were provided multiple opportunities to review and comment
on the Control Measure Summary Sheets. 

Based on the analyses by the OTC Workgroups, the OTC Commissioners made
several recommendations at the June 2006 Commissioners’ meeting in
Boston (OTC 2006a-d) and at the November 2006 Commissioners’ meeting
in Richmond (OTC 2006e-g).  The Commissioners recommended that States
consider emission reductions from the following source categories: 

Consumer Products

Portable Fuel Containers

Adhesives and Sealants Application 

Diesel Engine Chip Reflash

Cutback and Emulsified Asphalt Paving

Asphalt Production Plants

Cement Kilns

Glass Furnaces

Industrial, Commercial, and Institutional (ICI) Boilers

Regional Fuels

Additionally, the Commissioners directed the OTC to evaluate control
measures for Electric Generating Units (EGUs) and high electric demand
day units (these measures will be addressed in a separate OTC report) 
Finally, the Commissioners requested that EPA pursue federal regulations
and programs designed to ensure national development and implementation
of control measures for the following categories: architectural and
maintenance coatings, consumer products, ICI boilers over 100 mmBtu/hour
heat input, portable fuel containers, municipal waste combustors,
regionally consistent and environmentally sound fuels, small offroad
engine emission regulation, and gasoline vapor recovery (OTC 2006d).

See Appendix A for a full description of the process used by the OTC to
identify and evaluate candidate control measures.  

Table 1-1 summarizes information about the control measures identified
by the OTC Commissioners at the June 2006 and November OTC meetings. 
Table 1-1 identifies the sector, the source category, and a brief
description of the control measure.  Next is a column that identifies
the recommended approach for implementing the rule, such as an OTC model
rule or updates to existing state-specific rules.  The next two columns
show the percent reduction from 2009 emission levels. The final column
provides the cost effectiveness estimate in units of dollars per ton of
pollutant removed.  

Table 1-2 summarizes the expected emission reductions by pollutant,
control measure and State.  The emission reductions listed in Table 1-2
are for 2009, and take into account only the incremental reductions from
the control measures listed in Table 1-1.  Figures 1-1 and 1-2 show the
anticipated emission reductions by state for VOC and NOx, respectively.

  Table 1-1 Summary of OTC 2006 Control Measures

Sector	Source Category	Control Measure	Implementation Method	Percent
Reduction from 2009 OTB/W Emission Levels	Cost Effectiveness 





NOx	VOC	($/ton)

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

Area	Cutback and Emulsified Asphalt Paving	Prohibits the use of cutback
asphalt during the ozone season

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

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

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

to 1,400

Area

and

Point	Asphalt Production Plants	Area/Point Sources 

  Batch Natural Gas 0.02 lb/ton or equivalent ppm

  Batch Distillate      0.09 lb/ton or equivalent ppm

  Drum Natural Gas 0.02 lb/ton or equivalent ppm

  Drum Distillate      0.04 lb/ton or equivalent ppm

   or 

   Low NOx Burners, Best Management Practices	State Rule Update	10 - 35

	---

	NOx: <500 to 1,250









Area

and

Point	Industrial/

Commercial/

Institutional (ICI)

Boilers

>250 mmBtu/hour	Option 1 – Purchase current year NOx allowances equal
to reductions needed to achieve the required emission rates

Option 2 – Phase I 2009 emission rate equal to EGUs of similar size;
Phase II 2013 emission rate equal to EGUs of similar size 	Model Rule
Boiler and State specific	---	NOx: 600 to 18,000

Area

and

Point	ICI Boilers

100-250 mmBtu/hour	NOx Strategy #1:

     Nat gas: 0.10 lb/mmBtu

     #2, #4, #6 Oil: 0.20 lb/mmBtu

     Coal: 0.08 to 0.22 lb/mmBtu, depending on

         boiler type

NOx Strategy #2:

     Reductions achievable through 

     LNB/SNCR, LNB/FGR, SCR or some

          combination of these controls 

NOx Strategy #3:

     60% reduction from uncontrolled

NOx Strategy #4:

     Purchase current year CAIR allowances	State Rule Update	Boiler and
State specific	---	NOx: 600 to 18,000

Area

and

Point	ICI Boilers

25-100 mmBtu/hour	NOx Strategy #1:

     Nat gas: 0.05 lb/mmBtu

     #2 Oil: 0.08 lb/mmBtu

     #4, #6 Oil: 0.20 lb/mmBtu

     Coal: 0.30 lb/mmBtu

NOx Strategy #2:

     50% reduction from uncontrolled

NOx Strategy #3:

     Purchase current year CAIR allowances	State Rule Update	Boiler and
State specific	---	NOx: 600 to 18,000

Area

and

Point	ICI Boilers

<25 mmBtu/hour	Annual boiler tune-up	State Rule Update	State specific
---









	Point	Glass Furnaces	Require furnace operators to meet the emission
limits in the San Joaquin Valley rule by 2009.   These limits are
achievable through implementation of “oxyfiring” technology for each
furnace at furnace rebuild.  If the operator does not rebuild the
furnace by 2009 or implement measures to meet the limits in the San
Joaquin Valley rule, the operator would be required to purchase NOx
allowances equal to the difference between actual emissions and the
limits in the San Joaquin Valley rule. Compliance with Rule 4354 will
allow manufacturers to use a mix of control options to meet the
suggested limits. Manufacturers may propose alternative compliance
methods to meet the specified limits, including emissions averaging.
State Rule or Permit	Source specific	---	NOx: 1,254 

to 2,500

Point	Cement Plants	Require existing kilns to meet a NOx emission rate
of

3.88 lbs/ton clinker for wet kiln

3.44 lbs/ton clinker for long dry kiln

2.36 lbs/ton clinker for pre-heater kiln

1.52 lbs/ton clinker for pre-calciner kiln	State Rule Update	Source
specific	---	NOx: <2,500

Onroad

Mobile	Diesel Truck Chip Reflash	Mandatory program to upgrade the
version of software in engine electronic control module (ECM), (also
known as “chip reflash) to reduce off-cycle NOx emissions.	Model Rule
10	---	NOx: 20-30

Onroad

Mobile	Regional Fuel based on Reformulated Gasoline Options	Extend RFG
requirements to counties in OTC that currently do not have RFG.
Memorandum of Understanding - OTC	State specific	State specific

	VOC: 5,200

NOx: 3,700





Table 1-2 Estimated Emission Benefits in 2009 by State

Resulting from the OTC 2006 Control Measures

	VOC Emission Reduction Benefit

(summer tpd)	NOx Emission Reduction Benefit

(summer tpd)

State	Adhesives & Sealants	Cutback\Emulsified Asphalt Paving	Consumer
Products	PFC (Area)a	PFCs (Nonroad)a	Regional Fuels	Total VOC Reduction
Diesel Engine

Chip Reflash	Regional Fuels	Asphalt Production	Cement Kilns
Glass/Fiberglassb	ICI Boilers

Area Sources	ICI Boilers

Point Sources	Total NOx Reduction

CT	4.2	4.3	0.7	0.4	0.1	0.0	9.7	3.5	0.0	0.0	0.0	0.0	2.8	2.1	8.4

DE	1.0	0.0	0.1	0.1	<0.1	0.0	1.4	0.6	0.0	0.2	0.0	0.0	1.2	0.1	2.1

DC	0.1	0.0	0.1	0.1	<0.1	0.0	0.4	0.8	0.0	0.0	0.0	0.0	0.4	0.4	1.6

ME	2.5	10.6	0.2	0.1	<0.1	9.1	22.6	1.4	0.2	0.7	0.0	0.0	1.1	2.8	6.2

MD	5.8	0.0	1.0	1.4	0.4	3.2	11.8	5.6	0.0	0.1	13.1	0.3	1.2	2.4	22.7

MAd	8.9	8.1	10.2	1.7	0.5	0.0	29.3	6.7	0.0	0.6	0.0	1.5	6.6	6.8	22.2

NH	2.3	4.4	0.3	0.2	0.1	4.3	11.5	2.0	0.2	0.0	0.0	0.0	3.4	1.9	7.5

NJ	9.2	4.7	1.4	1.0	0.3	0.0	16.7	9.7	0.0	1.0	0.0	4.9	0.0	3.4	19.0

NY	21.5	16.4	3.7	2.6	0.8	56.9	101.9	16.1	2.1	0.0	15.3	5.8	33.8	7.0	80.1

PA	21.9	8.4	2.1	1.6	0.5	58.0	92.3	12.4	2.0	0.2	14.0	24.3	12.2	9.8	73.9

RI	1.5	1.1	0.2	0.2	<0.1	0.0	3.0	0.8	0.0	0.0	0.0	0.5	2.1	0.5	3.9

VT	2.2	1.8	0.1	0.1	<0.1	7.9	12.1	0.9	0.3	0.0	0.0	0.0	0.9	0.4	2.5

No. VAc	1.0	<0.1	0.5	0.4	0.1	0.0	1.9	2.5	0.0	0.1	0.0	0.0	3.9	0.1	6.6

OTR	82.3	59.8	20.5	9.9	3.0	139.4	314.8	63.0	4.8	3.0	42.5	37.3	69.5	37.7
257.8

The table shows the estimated emission reduction that will occur in
2009; additional reductions will occur in later years as new,
less-emitting PFCs that comply with the OTC 2006 control measure
penetrate the market.

The table show the maximum emission reduction from glass/fiberglass
furnaces when the OTC 2206 control measure is fully implemented.  No all
of the reduction shown will be achieved by 2009.  

The following jurisdictions in Virginia are part of the OTR:  Arlington
County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon
County, Manassas City, Manassas Park, and Prince William County.

MA proposed rule has a January 1, 2009 effective date and includes the
VOC limits from the OTC 2001 model rule and those in the OTC 2006 model
rule.  The 2009 benefit MA shows the benefit from both sets of limits. 
For all other States, the 2009 benefit shows the change in emissions
from the OTC 2006 model rule only. 

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

Figure 1-2 NOx Emission Reduction Benefits from OTC 2006 Control
Measures in 2009

INTRODUCTION

The Ozone Transport Commission (OTC) is a multi-state organization
created under the Clean Air Act (CAA).  The OTC is responsible for
advising EPA on transport issues and for developing and implementing
regional solutions to the ground-level ozone problem in the Northeast
and Mid-Atlantic regions.  To supplement local and state-level efforts
to reduce ozone precursor emissions, which may not alone be sufficient
to attain federal standards, the OTC member states are considering
control measures appropriate for adoption by all states in the region as
part of their planning to attain and maintain the 8-hour ozone National
Ambient Air Quality Standards (NAAQS).  

The development of the control measures described in this document
parallels a prior effort.  The OTC developed a series of model rules in
2001 for the States to consider in adopting control measures to reduce
volatile organic compound (VOC) emissions and oxide of nitrogen (NOx),
which are ozone precursors, to (1) assist in the attainment of the
one-hour ozone health standard, (2) address the VOC and NOx emission
reduction shortfalls identified by EPA, and (3) implement the State
Implementation Plans (SIP) commitments to EPA.  These model rules, which
have been adopted in many OTC states, will be referred to as the “OTC
2001 model rules” in this document. 

The analysis in this report provides a description of the control
measures identified by the OTC to help states attain the 8-hour ozone
NAAQS.  It also describes the associated incremental emission reductions
and costs associated with each measure.  The control measures analyzed
in this report are those that were identified by the OTC Commissioners
at the June 2006 OTC annual meeting in Boston (OTC 2006a, OTC 2006b, OTC
2006c) and at the November 2006 OTC fall meeting in Richmond (OTC 2006d,
OTC 2006e, OTC 2006f).  These control measures will be referred to as
the “OTC 2006 control measures” in this document.  For some source
categories, the OTC has amended the OTC 2001 model rules or developed
new model rules.  These model rules will be referred to as the “OTC
2006 model rules” in this document.  

The OTC 2006 model rules for volatile organic compounds (VOC) will
reduce emissions from adhesives, sealants, adhesive primer, and sealant
primer application; cutback and emulsified asphalt paving; consumer
products; regional fuels; and portable fuel containers.  The OTC 2006
control measures for oxides of nitrogen (NOx) will reduce emissions from
asphalt production plants, cement kilns, diesel engine chip reflash,
regional fuels, electric generating units (EGUs), glass and fiberglass
furnaces, and industrial, commercial, institutional (ICI) boilers.  

Section 3 describes the methods used to estimate the emission benefits
of the VOC control measures.  For each source category, there are
subsections that describe the existing Federal and OTC State regulations
that affect the VOC emissions, summarize the major elements of the
control measures, discuss how the emission benefits were quantified, and
present information on anticipated costs and cost-effectiveness.  VOC
emissions and reductions by State and source category in 2002 and 2009
are presented at the end of Section 3.  Section 4 presents similar
information for the NOx source categories.  Section 5 presents similar
information for the SO2 source categories.  Section 6 provides a list of
references used in developing this report.

Appendix A presents a brief description of the process that the OTC
followed in identifying and evaluating candidate control measures. 
Appendix B lists the approximately 1,000 control measures that were
initially analyzed.  Appendix C contains the control measure summary
sheets that were developed during this analysis.  Appendices D, E, and F
present the emission benefits by county for VOC, NOx, and SO2
respectively.  Each appendix contains a tabulation of the 2002 base
emissions, the projected 2009/2012/2018 emissions and expected emission
reduction benefit from the additional control measures in
2009/2012/2018).  Appendix G contains a listing of State ICI boiler
regulations.

  

VOC ANALYSIS METHODS

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

ADHESIVES, SEALANT, ADHESIVE PRIMER, AND SEALANT PRIMER APPLICATION

Adhesives, sealants, adhesive primer, and sealant primer are used in
product manufacturing, packaging, construction, and installation of
metal, wood, rubber, plastic, ceramics, or fiberglass materials.  In
general, an adhesive is any material used to bond two surfaces together.
 In general, a sealant is a material with adhesive properties that is
used primarily to fill, seal, waterproof or weatherproof gaps or joints
between two surfaces.  

VOC emissions from this category result from evaporation of solvents
during transfer, drying, surface preparation and cleanup operations.
These solvents are the media used to solubilize the adhesive, sealant,
or primer material so that it can be applied. The solvent is also used
to completely wet the surface to provide a stronger bond.  In plastic
pipe bonding, the solvent dissolves the polyvinyl chloride pipe and
reacts with the pipe to form a bond. Solvents used to clean the surface
before bonding and to clean the application equipment after bonding also
contribute to VOC emissions.

VOC emissions in this category are primarily from industrial and
commercial operations such as wood product manufacturers, upholstery
shops, adhesives retailers and architectural trades, such as building
construction, floor covering installation and roof repair.

Existing Federal and State Rules

EPA published the consumer and commercial products rule on September 11,
1998 (40 CFR Part 59 Subpart D) under authority of Section 183(e) of the
Clean Air Act.  The Federal Part 59 Subpart C requirements for consumer
products regulate five types of “household” adhesives (aerosols,
contact, construction and panel, general purpose and structural
waterproof).  The VOC content limits for these products apply only to
“household products”, defined as “any consumer product that is
primarily designed to be used inside or outside of living quarters or
residences, including the immediate surroundings, that are occupied or
intended for occupation by individuals.”  Thus, the Part 59 rule
applies only to adhesives used in household settings and not to
adhesives used in industrial or commercial applications.  

The OTC developed a model rule for consumer and commercial products in
2001 (referred to as the “OTC 2001 model rule for consumer products”
in this document) to regulate additional consumer product categories by
requiring more stringent VOC content limits than the Federal rule.  The
OTC 2001 model rule for consumer products contains VOC limits for
adhesives and sealants.  However, with the exception of aerosol
adhesives, the definitions of these products generally exempt products
sold in larger containers.  Specifically, the OTC 2001 model rule
includes the following definitions (italics added for emphasis): 

Section 2(8) Adhesive.   "Adhesive" means any product that is used to
bond one surface to another by attachment. “Adhesive” does not
include products used on humans and animals, adhesive tape, contact
paper, wallpaper, shelf liners, or any other product with an adhesive
incorporated onto or in an inert substrate. For “Contact Adhesive,”
adhesive does not include units of product, less packaging, which
consist of more than one gallon. For “Construction, Panel, and Floor
Covering Adhesive,” and “General Purpose Adhesive”, adhesive does
not include units of product, less packaging, which weigh more than one
pound and consist of more than 16 fluid ounces. This limitation does not
apply to aerosol adhesives.

Section 2(148)  Sealant and Caulking Compound.  "Sealant and Caulking
Compound" means any product with adhesive properties that is designed to
fill, seal, waterproof, or weatherproof gaps or joints between two
surfaces. “Sealant and Caulking Compound” does not include roof
cements and roof sealants; insulating foams; removable caulking
compounds; clear/paintable/water resistant caulking compounds; floor
seam sealers; products designed exclusively for automotive uses; or
sealers that are applied as continuous coatings. “Sealant and Caulking
Compound” also does not include units of product, less packaging,
which weigh more than one pound and consist of more than 16 fluid
ounces. For the purposes of this definition only, “removable caulking
compounds” means a compound which temporarily seals windows or doors
for three to six month time intervals, and “clear/paintable/water
resistant caulking compounds” means a compound which contains no
appreciable level of opaque fillers or pigments; transmits most or all
visible light through the caulk when cured; is paintable; and is
immediately resistant to precipitation upon application. 

Thus, the same products sold in containers larger than the above
thresholds are not covered by the OTC 2001 model rule for consumer
products.

Description of the OTC 2006 Model Rule

The OTC 2006 model rule for adhesives and sealants is based on the
reasonably available control technology (RACT) and best available
retrofit control technology (BARCT) determination by the California Air
Resources Board (CARB) developed in 1998.  The OTC 2006 model rule has
the following requirements:

Regulates the application of adhesives, sealants, adhesive primers and
sealant primers by providing options for appliers to either to use a
product with a VOC content equal to or less than a specified limit or to
use add-on controls;

Limits the VOC content of aerosol adhesives to 25 percent by weight;

Requirements for cleanup solvents;

A VOC limit for surface preparation solvents;

An alternative add-on control system requirement of at least 85 percent
overall control efficiency (capture and destruction efficiency), by
weight; 

VOC containing materials must be stored or disposed of in closed
containers; 

Prohibits the sale of any adhesive, sealant, adhesive primer or sealant
primer which exceeds the VOC content limits listed in the model rule; 

Manufacturers must label containers with the maximum VOC content as
supplied, as well as the maximum VOC content on an as-applied basis when
used in accordance with the manufacturer’s recommendations regarding
thinning, reducing, or mixing with any other VOC containing material;
and

Prohibits the specification of any adhesive, primer, or sealant that
violates the provisions of the model rule.

Several adhesive and sealant applications and products are exempt from
this model rule: tire repair, assembly and manufacturing of
undersea-based weapon systems, testing and evaluation associated with
research and development, solvent welding operations for medical
devices, plaque laminating operations, products or processes subject to
other state rules, low-VOC products (less than 20 g/l), and adhesives
subject to the state rules based on the OTC 2001 consumer products model
rule.  Additionally, the model rule provides an exemption for adhesive
application operations at stationary sources that use less than 55
gallons per calendar year of noncomplying adhesives and for stationary
sources that emit not more than 200 pounds of VOCs per year from
adhesives operations.

Emission Benefit Analysis Methods

Emissions from this category are classified as both point sources and
area sources.  About 96 percent of adhesive and sealant VOC emissions in
the OTC states fall into the area source category.  The remaining four
percent of the VOC emissions are included in the point source inventory.

The emission reduction benefit estimation methodology for area sources
is based on information developed and used by CARB for their RACT/BARCT
determination in 1998.  CARB estimates that the total industrial
adhesive and sealant emissions in California to be about 45 tons per day
(tpd).  Solvent-based emissions are estimated to be about 35 tpd of VOC
and water-based adhesive and sealant emissions are about 10 tpd of VOC. 
CARB indicated that the emission reductions would be achieved mainly due
to the switch from high-VOC to low-VOC products rather than from the use
of add-on control devices.  CARB estimated that emission reductions
achieved by statewide compliance with the VOC limits in the RACT/BARCT
determination will range from approximately 29 to 35 tpd (CARB 1998, pg.
18).  These emission reductions correspond to a 64.4 to 77.8 percent
reduction from uncontrolled levels.  For OTC modeling purposes, we used
the lower end of this range (i.e., 64.4 percent reduction) to estimate
the emission benefit for area sources due to the OTC 2006 model rule.  

For point sources, we first identified those sources that were applying
adhesives and sealants (using the source classification code of
4-02-007-xx, adhesives application).  Next, we reviewed the MANEVU
inventory to determine whether sources had existing capture and control
systems.  Several sources reported capture and destruction efficiencies
in the 70 to 99 percent range.  A few sources reported capture and
destruction efficiencies of 99+ percent.  Most of the controlled sources
reported capture and destruction efficiencies in the 90-98 percent
range.  Sources with existing control systems that exceed an 85 percent
overall capture and destruction efficiency would meet the OTC 2006 model
rule provision for add-on air pollution control equipment; no additional
reductions were calculated for these sources.  For point sources without
add-on control equipment, we used the 64.4 percent reduction discussed
in the previous paragraph based on the CARB determination. 

Cost Estimates

The cost of complying with the new requirements includes the cost of
using alternative formulations of low-VOC or water-based adhesives,
sealants, adhesive primers, and sealant primers and cleanup products. 
Based on information provided by the Ventura County Air Pollution
Control District, CARB determined that the cost-effectiveness of their
adhesives rule ranges from a savings of $1,060 per ton to a cost of
$2,320 per ton of VOC reduced (CARB 1998, pg. 17).  These costs are
likely to be less in the OTR, because some of the one-time research and
reformulation costs incurred for products sold in California will not
have to be incurred again for products sold in the OTR.  CARB also
reports a cost-effectiveness of $9,000 to $110,000 per ton of VOC
reduced for the use of add-on control equipment to comply with the
requirements.

CUTBACK AND EMULSIFIED ASPHALT PAVING

Asphalt paving is used to pave, seal and repair surfaces such as roads,
parking lots, drives, walkways and airport runways.  Asphalt paving is
grouped into three general categories: hot-mix, cutback, and emulsified.
 Hot-mix asphalt is the most commonly used paving asphalt.  Hot-mix
asphalt produces minimal VOC emissions because its organic components
have high molecular weights and low vapor pressures.  Cutback asphalt is
used in tack and seal operations, in priming roadbeds for hot-mix
application and for paving operations for pavements up to several inches
thick.  In preparing cutback asphalt, asphalt cement is blended or
“cut back” with a diluent, typically from 25 to 45 percent by volume
of petroleum distillates, depending on the desired viscosity. 
Emulsified asphalt is used in most of the same applications as cutback
asphalt but is a lower emitting alternative to cutback asphalt.  Instead
of blending asphalt cement with petroleum distillates, emulsified
asphalts use a blend of asphalt cement, water and an emulsifying agent,
such as soap.  Some emulsified asphalts contain virtually no VOC
diluents; however, some emulsified asphalts may contain up to 12 percent
VOC by volume.  

Existing Federal and State Rules

The EPA published a Control Technique Guideline (CTG) for the use of
cutback asphalt in December 1977.  The CTG recommended replacing cutback
asphalt binders with emulsified asphalt during the ozone season.  In
1979, EPA added a specification for emulsified asphalt to the CTG
recommendations to limit the content of oil distillate in emulsified
asphalt to no higher than 7 percent oil distillate.  

Table 3-1 summarizes the current asphalt paving rules for the 13 OTR
states.  Most of the states in the OTR have adopted the CTG banning
cutback asphalt in the ozone season.  Some states have exemptions to
this rule, allowing the use of cutback asphalt with up to 5 percent VOC.
 For emulsified asphalt, the requirements vary greatly.  The VOC content
of emulsified asphalt is limited to 0-12 percent, depending on the State
and the type of emulsified asphalt.  Delaware completely bans the use of
emulsified asphalt that contains any VOC.  

Table 3-1 Summary of OTC State Rules for Cutback and Emulsified Asphalt

State	Cutback Asphalt	Emulsified Asphalt

CT	22a-174-20 (k): VOC content limited to 5% during June, July, August,
and September	Nothing specified

DE	Reg. No. 24, Section 34:  Ban during ozone season	Reg. No. 24,
Section 34:  Ban on use of emulsified asphalt that contains any VOC

DC	Chapter 7 Section 8-2:707(k): Ban during the months of April, May,
June, July, August, and September	Nothing specified

ME	Chapter 131: Ban during the period May 1 through September 15, with
some exceptions	Chapter 131: VOC content limited to 3-12%, depending on
the type of use

MD	COMAR 26.11.11.02:  Ban during the period April 16 through October 14
COMAR 26.11.11.02: Allowed upon approval of the Department; no VOC
content limit specified

MA	310 CMR 7.18(9): Ozone season ban on cutback asphalt with VOC content
greater than 5% by weight with exemptions including use as prime coat
Nothing Specified

NH	Env-A 1204.42: Ban during the months of June through September;
cutback with up to 5% VOC allowed upon approval of Department	Env-A
1204.42: VOC content limited to 3-12%, depending on the type of use

NJ	7:27-16.19: Ban from April 16 through October 14, with some
exemptions	7:27-16.19: VOC content limited to 8% by volume

NY	Part 211:  Ban from May 2 through October 15	Part 211: VOC content
limited to 2-12%, depending on the type of ASTM grade

PA	25 Pa. Code Section 129.64: Ban from May 1 to October 30	25 Pa. Code
Section 129.64: VOC content limited to 0-12%, depending on type

RI	Reg. No. 25: Ban from April 1 to September 30, with some exemptions
Reg No. 25: VOC content limited to 3-12%, depending on application/use

VT	5-253.15: Ban on cutback asphalt with VOC content greater than 5% by
weight, with some exemptions	5-253.15: Ban on emulsified asphalt with
VOC content greater than 5% by weight

VA	Chapter 40, Article 39: Ban during April through October	Chapter 40,
Article 39: VOC content limited to 6% by volume



Description of the OTC 2006 Model Rule

The OTC 2006 model rule for the asphalt paving control measure prohibits
the use of cutback asphalt during the ozone season and limits the use of
emulsified asphalt to that which contains not more than 0.5 mL of oil
distillate from a 200 mL sample (as determined using American Society
for Testing and Materials {ASTM} Method D244 - Test Methods for
Emulsified Asphalts) regardless of application.  This is equivalent to a
VOC content of 0.25 percent.  Exemptions may be granted under certain
circumstances upon the approval of the State commissioner.  

Emission Benefit Analysis Methods

The OTC 2006 control measure for asphalt paving calls for a complete ban
on the use of cutback asphalt during the ozone season.  As shown in
Table 3-1, current state regulations generally ban the use of cutback
asphalt during the ozone season.  However, there are exemptions from the
ban and as a result there are VOC emissions from the use of cutback
asphalt during the ozone season.   The OTC 2006 control measure
eliminates any exemptions and totally eliminates any VOC emissions from
the use of cutback asphalt during the ozone season.

The emission reductions resulting from OTC 2006 control measure for
emulsified asphalt vary by State.  The two percent VOC content limit on
emulsified asphalt depend on the baseline VOC content of emulsified
asphalt.  The control measure limits emulsified asphalt to not more than
0.5 mL of oil distillate from a 200 mL sample as determined using ASTM
Method D244.  This is equivalent to a VOC content of 0.25 percent.  The
baseline VOC content may range from 0 to 12 percent.  New Jersey used a
VOC content of 8 percent in their baseline emission calculations (based
on the 8 percent limit in their current rule).  Reducing the VOC content
to 0.25 percent in New Jersey will result in a 96.9 percent reduction. 
Delaware already bans the use of emulsified asphalt that contains any
VOC, so there is no reduction in Delaware.  Several other states used an
average VOC content of 2.5 percent when developing their emission
inventory.  Thus, reducing the average VOC content from 2.5 percent to
0.25 percent results in a 90 percent reduction in VOC emissions.  For
States that did not supply a baseline VOC content for asphalt paving, we
used the 90 percent reduction in VOC emissions from emulsified asphalt
paving during the ozone season.  

Cost Estimates

Low-VOC alternatives are currently available and no additional costs are
expected from their use. 

CONSUMER PRODUCTS

Consumer and commercial products are those items sold to retail
customers for personal, household, or automotive use, along with the
products marketed by wholesale distributors for use in commercial or
institutional settings such as beauty shops, schools and hospitals.  VOC
emissions from these products are the result of the evaporation of
propellant and organic solvents during use.  Consumer and commercial
products include hundreds of individual products, including personal
care products, household products, automotive aftermarket products,
adhesives and sealants, FIFRA-related insecticides, and other
miscellaneous products.  

Existing Federal and State Rules

EPA published the Federal consumer and commercial products rule on
September 11, 1998 (40 CFR Part 59 Subpart D) under authority of Section
183(e) of the Clean Air Act.  This rule limits the VOC content of 24
product categories representing 48 percent of the consumer and
commercial products inventory nationwide.  According to EPA, VOC
emissions from those 24 product categories were reduced by 20 percent. 
But since over half of the inventory is unaffected by the rule, the
Federal rule is estimated to yield VOC reductions of 9.95 percent of the
total consumer products inventory (Pechan 2001, pg 7).  

Since over half of the inventory is unregulated by the Federal Part 59
rule, the OTC developed a model rule for consumer and commercial
products in 2001 (referred to as the “OTC 2001 model rule for consumer
products” in this document) to be used by the OTC jurisdictions to
develop regulations for additional consumer product categories and to
specify more stringent VOC content limits than the Federal rule.  The
VOC content limits and products covered in the OTC 2001 model rule are
similar to the rules developed by CARB in the late 1990s.  The OTC 2001
model rule for consumer products provides background for OTC
jurisdictions to develop programs to regulate approximately 80 consumer
product categories and includes technologically feasible VOC content
limits.  The emission reductions for state programs based on the OTC
2001 model rule are estimated to be 14.2 percent of the total consumer
product inventory beyond the national rule reduction (Pechan 2001, pg.
8).   

Most, but not all, states in the OTR have adopted regulatory programs
based on the OTC 2001 model rule for consumer products.  Table 3-2
summarizes the adoption status for the 13 OTR jurisdictions.  

Table 3-2 Status of OTC State’s Promulgation

of the OTC 2001 Model Rule for Consumer Products.

State	Effective Date of VOC Limits	Regulatory Citation

CT a	Initiated process to adopt in 2006	R.C.S.A. section 22a-174-40 

DE	Effective January 1, 2005	Regulation Number 41

DC	Effective June 30, 2004	Regulation 719

ME	Effective May 1, 2005	Chapter 152

MD	Effective January 1, 2005	COMAR 26.11.32

MA b	In progress – proposed effective date is January, 2009	310 CMR
7.25(12)

NH	Effective January 1, 2007	Chapter Env-A 4100

NJ	Effective Janaury 1, 2005	Chapter 27, Subchapter 24

NY	Effective January 1, 2005	Chapter 3, Part 235

PA	Effective January 1, 2005	25 Pa. Code Chapter 130, Subchapter B

RI	Intend to develop in 2006	n/a

VT	Under Consideration	n/a

VA c	Effective July 1, 2005	Chapter 40, Article 50

a) Connecticut’s proposed rule includes both the VOC limits from the
OTC 2001 model rule and the new and revised VOC emissions limits and
related provisions that were adopted by the California Air Resources
Board on July 20, 2005.  These new and revised VOC limits are identical
to those in the OTC 2006 model rule.

b) Massachusett’s proposed rule includes the VOC limits from the OTC
2001 model rule and those in the OTC 2006 model rule.

c) Virginia’s rule applies only in Northern Virginia VOC Emission
Control Area (10 northern Virginia jurisdictions in the OTR)

Description of the OTC 2006 Model Rule

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

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

New Categories with VOC Limits for Regulation

Adhesive Remover

– 4 subcategories

Anti-Static Product

Electrical Cleaner

Electronic Cleaner

Fabric Refresher	Footwear or Leather Care Product

Hair Styling Producta

Graffiti Remover

Shaving Gel

Toilet/Urinal Care Product

Wood Cleaner

Previously Regulated Category with More Restrictive Limit

Contact Adhesiveb

Previously Regulated Categories with Additional Requirements

Air Fresheners 	General Purpose Degreasers

a) This product category will incorporate Hair Styling Gel and include
additional forms of hair styling products (i.e., liquid, semi-solid, and
pump spray) but does not include Hair Spray Product or Hair Mousse.

b) This product category has been separated into 2 subcategories:
General Purpose and Special Purpose

Most of these new CARB limits become effective in California by December
31, 2006.  Two of the limits, anti-static products (aerosol) and shaving
gels, have effective dates in either 2008 or 2009.  For shaving gels,
there is a VOC limit that becomes effective on December 31, 2006, with a
more stringent second tier limit that becomes effective on December 31,
2009.  The anti-static product (aerosol) limit becomes effective on
December 31, 2008.

The OTC 2006 model rule will modify the OTC 2001 model rule based on the
CARB July 20, 2005 amendments.  The OTC is not including the anti-static
aerosol products and the second tier shaving gel limit in its revisions
to the OTC 2001 model rule because of industry concerns that meeting
these limits may not be feasible.  CARB acknowledged these concerns by
requiring a technology review of these product categories in 2008 to
determine whether the limits are achievable.  

Emission Benefit Analysis Methods

The emission reduction benefit estimation methodology is based on
information developed by CARB.  CARB estimates 6.05 tons per day of VOC
reduced in California from their July 2005 amendments (CARB 2004a, pg.
8), excluding the benefits from the two products (anti-static products
and shaving gels) with compliance dates in 2008 or 2009.  This equates
to about 2,208 tons per year in California.  The population of
California as of July 1, 2005 is 36,132,147 (Census 2006).  On a per
capita basis, the emission reduction from the CARB July 2005 amendments
equals 0.122 lbs/capita.  

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

Current OTC Emission Factor	=	6.06 lbs/capita

Benefit from CARB 2005 amendments	=	0.122 lbs/capita

Percent Reduction	=

=	100%*(1 - (6.06 – 0.122)/6.06)

2.0%

Cost Estimates

CARB estimates that the cost effectiveness of VOC limits with an
effective date of December 31, 2006, to be about $4000 per ton of VOC
reduced (CARB 2004, pg. 21).  CARB further estimates that the average
increase in cost per unit to the manufacturer to be about $0.16 per
unit.  Assuming CARB’s estimates for the OTR provides a conservative
estimate, because some of the one-time research and reformulation costs
incurred for products sold in California will not have to be incurred
again for products sold in the OTR.  

PORTABLE FUEL CONTAINERS

Portable fuel containers (PFCs) are designed for transporting and
storing fuel from a retail distribution point to a point of use and the
eventual dispensing of the fuel into equipment.  Commonly referred to as
“gas cans,” these products come in a variety of shapes and sizes
with nominal capacities ranging in size from less than one gallon to
over six gallons.  Available in metal or plastic, these products are
widely used to refuel residential and commercial equipment and vehicles
when the situation or circumstances prohibits direct refueling at a
service station.  PFCs are used to refuel a broad range of small
off-road engines and other equipment (e.g., lawnmowers, chainsaws,
personal watercraft, motorcycles, etc.).  VOC emissions from PFCs are
classified by five different activities:

Transport-spillage emissions from PFCs occur when fuel escapes from PFCs
that are in transit.

Diurnal emissions result when stored fuel vapors escape to the air
through any possible openings while the container is subjected to the
daily cycle of increasing and decreasing ambient temperatures.  Diurnal
emissions depend on the closed- or open- storage condition of the PFC. 

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

Equipment refueling vapor displacement and spillage emissions result
when fuel vapor is displaced from nonroad equipment (e.g., lawnmowers,
chainsaws, personal watercraft, motorcycles, etc.) and from gasoline
spillage during refueling of the equipment with PFCs.  These VOC
emissions are already taken into account in the nonroad equipment
emission inventory by the NONROAD model. 

Diurnal evaporative emissions are the largest category.  

Existing Federal and State Rules

The OTC developed a model rule for PFCs in 2001.  The OTC 2001 model
rule was very similar to a rule adopted by CARB in 2000.  The OTC 2001
model rule provides background for OTC jurisdictions to develop
regulatory programs that require spill-proof containers to meet
performance standards that reduce VOC emissions.  The performance
standards include a requirement that all PFCs to have an automatic
shut-off feature preventing overfilling and an automatic closing feature
so the can will be sealed when it is not being used.  The performance
standards also eliminate secondary venting holes and require new
plastics to reduce vapor permeation through container walls.  There is
no requirement for owners of conventional PFCs to modify their PFCs or
to scrap them and buy new ones.  Compliance will be accomplished
primarily through attrition.  As containers wear out, are lost, damaged,
or destroyed, consumers will purchase new spill-proof containers to
replace the conventional containers.  CARB determined that the average
useful life of a PFC is five years.  The OTC chose to assume a more
conservative ten-year turnover rate, with 100 percent rule penetration
occurring 10 years after adoption of the rule.  

CARB estimated that the performance standards would reduce VOC emissions
by 75 percent.  CARB’s 2004 analysis (CARB 2004b) reevaluated the
estimate reductions due to some unforeseen issues with the new cans and
new survey information.  Based on CARB’s updated data, CARB estimated
that VOC emissions would be reduced by 65 percent from the first set of
amendments.  

CARB has also adopted a second set of amendments in two phases.  The
first phase was filed on January 13, 2006, effective February 12, 2006. 
For Phase I, CARM amended their PFC regulation to address the use of
utility jugs and kerosene containers that are sometimes used by
consumers for gasoline.  The second phase of the amendments was filed on
September 11, 2006, effective October 11, 2006.  These amendments (CARB
2006) will:

Establish a mandatory certification program and accompanying test
procedures;

Amend the existing performance standards to eliminate the automatic
shutoff performance standard effective July 1, 2007;

Amend the existing performance standards to eliminate the fill height
and flow rate performance standards;

Amend the existing PFC pressure standard;

Amend the current test methods; 

Change the permeability standard from 0.4 to 0.3 grams/gallon-day;

Establish a voluntary consumer acceptance-labeling program that allows
participating manufacturers to label their PFCs with an ARB “Star
Rating” indicating how consumers rate their products’ ease of use;
and

Combine the currently separate evaporation requirement and permeation
standard and test method into a single diurnal standard and test method.

In February 2007, EPA finalized a national regulation to reduce
hazardous air pollutant emissions from mobile sources.  Included in the
final rule are standards that would reduce PFC emissions from
evaporation, permeation, and spillage.  EPA included a performance-based
standard of 0.3 grams per gallon per day of hydrocarbons, determined
based on the emissions from the can over a diurnal test cycle specified
in the rule.  The standard applies to containers manufactured on or
after January 1, 2009.  The standards are based on the performance of
best available control technologies, such as durable permeation
barriers, automatically closing spouts, and cans that are well-sealed. 

Description of the OTC 2006 Model Rule

As shown in Table 3-4, most states in the OTR have already adopted PFC
regulations based on the OTC 2001 model rule.  The OTC 2001 model rule
for PFCs closely mirrors the 2000 version of CARB’s PFC rule.  CARB
recently amended their gas can regulation as discussed above in Section
3.4.1.  The OTC 2006 model rule closely mirrors these CARB amendments. 
The 2006 amendments are estimated to reduce VOC emissions by 18.4 tons
per day in California at full implementation in the year 2015, in
addition to the benefits from the existing regulation.  The OTC 2006
model rule will modify the OTC 2001 model rule based on the recent CARB
amendments.  

Table 3-4 Status of OTC State’s Promulgation

of the OTC 2001 Model Rule for Portable Fuel Containers

State	Date When New Containers are Required	Regulatory Citation

CT	Effective May 1, 2004	Section 22a-174-43

DE	Effective January 1, 2004	Reg. No. 41, Section 3

DC	Effective November 15, 2003	Rule 720

ME	Effective January 1, 2004	Chapter 155

MD	Effective January 1, 2003	COMAR 26.11.13.07

MAa	In progress (effective date will be January 1, 2009)	n/a

NH	Effective March 1, 2006	Env-A 4000

NJ	Effective January 1, 2005	Subchapter 24 (7:27-24.8) 

NY	Effective January 1, 2003	Part 239

PA	Effective January 1, 2003	25 Pa. Code Chapter 130, Subchapter A

RI	In progress (late 2006 target date for final rule)	n/a

VT	Under Consideration	n/a

VAb	Effective January 1, 2005	Chapter 40, Article 42

a) Massachusetts’ proposed rule will be based only on the OTC 2006
model rule; Massachessetts will not adopt the OTC 2001 model rule.

b) Virginia’s rule applies only in Northern Virginia VOC Emission
Control Area (10 northern Virginia jurisdictions in the OTR)

Emission Benefit Analysis Methods

Emissions from PFCs are accounted for in both the area and nonroad
source inventories.   The NONROAD model accounts for equipment refueling
vapor displacement and spillage emissions result when fuel vapor is
displaced from nonroad equipment (e.g., lawnmowers, chainsaws, personal
watercraft, motorcycles, etc.) and from gasoline spillage during
refueling of the equipment with PFCs.  The area source inventory
accounts for diurnal and permeation emissions associated with the fuel
present in stored PFCs and transport-spillage emissions associated with
refueling of a gas can at the gasoline pump.  Based on the OTC 2001
model rule (Pechan 2001, pg. 11) roughly 70 percent of the VOC emissions
are accounted for in the area source inventory, while the remaining 30
percent is from equipment refueling vapor displacement and spillage that
is accounted for in the nonroad inventory.  

The emission benefits have been calculated for the emissions accounted
for in both the area and nonroad source inventory.  Emissions from the
nonroad category were estimated to be 30 percent of the PFC emissions
accounted for in the area source inventory.

Also note that the OTC baseline emissions (i.e., 2002 emissions) do not
include changes to the emission estimation methodology made by CARB in
2004. CARB conducted a new survey of PFCs in 2004, which included
kerosene containers and utility jugs.  Using this survey data, CARB
adjusted their baseline emissions; a similar adjustment to the OTC
baseline inventory has not been made.  

Estimated emission reductions were based on information compiled by CARB
to support their recent amendments.  CARB estimated that PFC emissions
in 2015 will be 31.9 tpd in California with no additional controls or
amendments to the 2000 PFC rules (CARB 2005a, pg. 10).  CARB further
estimates that the 2006 amendment will reduce emission from PFCs by 18.4
tpd in 2015 in California compared to the 2000 PFC regulations (CARB
2005a, pg. 23).  Thus, at full implementation, the expected incremental
reduction is approximately 58 percent, after an estimated 65 percent
reduction from the original 2000 rule. 

The OTC calculations assume that States will adopt the rule by July 2007
(except in Massachusetts) and provide manufacturers one year from the
date of the rule to comply.  Thus, new compliant PFCs will not be on the
market until July 2008.  Assuming a 10-year turnover to compliant cans,
only 10 percent of the existing inventory of PFCs will comply with the
new requirements in the summer of 2009.  Therefore, only 10 percent of
the full emission benefit estimated by CARB will occur by 2009 – the
incremental reduction will be 5.8 percent in 2009.  

Cost Estimates

CARB estimates that the cost-effectiveness of the 2005/2006 amendments
will range from $0.40 to $0.70 per pound of VOC reduced, or $800 to
$1,400 per ton of VOC reduced (CARB 2005a, pg. 27).  Assuming CARBs
costs for the OTR provides a conservative estimate, because some of the
one-time research and reformulation costs incurred for products sold in
California will not have to be incurred again for products sold in the
OTR.

REGIONAL FUELS

The Clean Air Act Amendments of 1990 required significant changes to
conventional fuels used by motor vehicles.  Beginning in 1995,
“reformulated” gasoline must be sold in certain non-attainment areas
and other states with non-attainment areas are permitted to opt-in. 
Reformulated gasoline results in lower VOC emissions than would occur
from the use of normal “baseline” gasoline.

Existing Federal and State Rules

All but two states in the OTR are participating, in whole or in part,
with the federal reformulated gasoline program.  However, nearly
one-third of the gasoline sold in the OTR is not reformulated gasoline. 
NESCAUM has estimated the following fraction of gasoline that is
reformulated by State:  

State	Current RFG Fraction	State	Current RFG Fraction

CT	100%	NJ	100%

DC	100%	NY	54%

DE	100%	PA	24%

MA	100%	RI	100%

MD	86%	NoVA	100%

ME	0%	VT	0%

NH	64%



Description of the OTC 2006 Control Measure

The Energy Policy Act of 2005 provides the opportunity for the OTR to
achieve a single clean-burning gasoline and is consistent with what OTR
states have promoted through the long debate over MTBE/ethanol/RFG. 
Approximately one-third of the gasoline currently sold in the OTR is not
reformulated.  The new authority plus the potential for emission
reductions from the amount of non-reformulated gasoline sold in the OTR
provides an opportunity for additional emission reductions in the region
as well as for a reduced number of fuels, and possibly a single fuel, to
be utilized throughout the region.  The OTC Commissioners recommended
that the OTC member states pursue a region fuel program consistent with
the Energy Act of 2005 (OTC 2006b).

Emission Benefit Analysis Methods

Emission benefits resulting from extending reformulated gasoline to all
areas of the OTR have been calculated for 2006 by NESCAUM (NESCAUM
2006a).

Cost Estimates

According to USEPA’s regulatory impact analysis for reformulated
gasoline (USEPA 1993), the cost per ton of VOC reduced for Phase I RFG
is $5,200 to $5,900.  USEPA also estimated the cost of Phase II RFG was
$600 per ton of VOC reduced – this reflects the incremental cost over
the cost of implementing Phase I of the RFG program.  

VOC EMISSION REDUCTION SUMMARY

The results of the emission benefit calculations for the OTC states are
described in this subsection.  The starting point for the quantification
of the emission reduction benefits is the MANEVU emission inventory,
Version 3 (Pechan 2006, MACTEC 2006a) and the VISTAS emission inventory,
BaseG (MACTEC 2006b), for the northern Virginia counties that are part
of the OTR.  The MANEVU and VISTAS inventories include a 2002 base year
inventory as well as projection inventories for 2009 and 2018 (MANEVU
also has projections for 2012, but VISTAS does not).  The projection
inventories account for growth in emissions based on growth indicators
such as population and economic activity.  The projection inventories
also account for “on-the-books/on-the-way” (OTB/W) emission control
regulations that have (or will) become effective between 2003 and 2008
that will achieve post-2002 emission reductions.  For example, many
States have already adopted the 2001 OTC model rules for consumer
products and portable fuel containers.  The emission reduction benefit
from the 2001 OTC model rules are already accounted for in the MANEVU
and VISTAS projection inventories.  Emission reductions from existing
regulations are already accounted for to ensure no double counting of
emission benefits occurs.  

Note that the emission reductions contained in this Section are
presented in terms of tons per summer day.  The MANEVU base and
projection emission inventories do not contain summer day emissions for
all States and source categories; the VISTAS inventory only contains
annual values.  When States provided summer day emissions in the MANEVU
inventory, these values were used directly to quantify the emission
benefit from the 2006 OTC control measure.  When summer day emissions
were missing from the MANEVU or VISTAS inventories, the summer day
emissions were calculated using the annual emissions and the seasonal
throughput data from the NIF Emission Process table.  If the seasonal
throughput data was missing, the summer day emissions were calculated
using the annual emissions and a summer season adjustment factor derived
from the monthly activity profiles contained in the SMOKE emissions
modeling system.  

Tables 3-5 to 3-10 show State summaries of the emission benefits from
the OTC 2006 VOC control measures described previously in this Section. 
For each of the source categories, the Tables show four columns: (1) the
actual 2002 summer daily emissions; (2) the summer daily emissions for
the 2009 OTB/W scenario that accounts for growth and for the emission
control regulations that have (or will) become effective between 2003
and 2008 that will achieve post-2002 emission reductions; (3) the summer
daily emissions for 2009 with the implementation of the OTC 2006 control
measures identified in this Section, and (4) the emission benefit in
2009 resulting from the OTC 2006 control measure.  Table 3-11 shows the
same information for the total of all six source categories.

The largest estimated VOC emission reductions are in the most populous
States – New York and Pennsylvania.  The emission benefits listed for
Virginia just include the Virginia counties in the northern Virginia
area that are part of the OTR.  Benefit estimates for all other States
include the entire state.  The emission benefits also assume that all
OTC members will adopt the rules as described in the previous sections. 

The requirement for a regional fuel throughout the OTR provides the
largest emission benefit, about 139.4 tons per day across the OTR.  The
adhesives and sealants application model rule provides the second
largest emission benefit in 2009 – 82.3 tons per day across the OTR. 
The incremental benefits accrued from the amendments to State’s
existing consumer products and portable fuel container model rules are
not as large, since the States already have accrued substantial benefits
from the adoption of these rules.  

Appendix D provides county-by-county summaries of the VOC emission
benefits from the OTC 2006 VOC model rules described previously in this
Section.  Appendix D also provides additional documentation regarding
the data sources and emission benefit calculations that were performed. 
These tables can be used by the States to create additional summaries,
for example, by nonattainment area.  

Table 3-5 OTC 2006 VOC Model Rule Benefits by State for 2009 

Adhesives and Sealants Application

	Adhesives/Sealants Application 

Summer VOC Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	4.8	6.6	2.4	4.2

DE	1.4	1.6	0.6	1.0

DC	0.2	0.2	0.1	0.1

ME	3.1	3.9	1.4	2.5

MD	6.9	9.1	3.3	5.8

MA	10.6	14.7	5.8	8.9

NH	2.5	3.6	1.3	2.3

NJ	14.9	15.2	6.0	9.2

NY	24.7	33.4	11.9	21.5

PA	25.5	34.0	12.2	21.8

RI	1.8	2.4	0.9	1.5

VT	2.4	3.4	1.2	2.2

NOVA	1.2	1.6	0.6	1.0

OTR	99.8	129.8	47.5	82.3



2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

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

Cutback and Emulsified Asphalt Paving

	Cutback and Emulsified Asphalt Paving

Summer VOC Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT*	4.5	4.5	0.3	4.3

DE	0.1	0.1	0.1	0.0

DC	0.0	0.0	0.0	0.0

ME	8.6	10.6	0.0	10.6

MD	0.0	0.0	0.0	0.0

MA*	8.4	8.6	0.5	8.1

NH	3.8	4.8	0.5	4.4

NJ	4.9	4.8	0.1	4.7

NY	15.4	18.3	1.8	16.4

PA	7.7	9.3	0.9	8.4

RI	1.0	1.2	0.1	1.1

VT	1.4	1.8	0.0	1.8

NOVA	<0.1	<0.1	<0.1	<0.1

OTR	55.9	64.0	4.3	59.8



2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

* CT and MA provided revised emission estimates that differ from those
in the MANEVU Version 3 inventories.

Table 3-7 OTC 2006 VOC Model Rule Benefits by State for 2009 

Consumer Products

	Consumer Products

Summer VOC Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	40.1	35.4	34.7	0.7

DE	7.3	6.7	6.5	0.1

DC	5.7	5.1	5.0	0.1

ME	10.9	9.7	9.5	0.2

MD	52.8	48.4	47.4	1.0

MA*	62.2	64.1	53.9	10.2

NH	13.7	12.6	12.4	0.3

NJ	82.9	71.9	70.5	1.4

NY	209.6	183.3	179.6	3.7

PA	119.6	104.4	102.4	2.1

RI	10.6	9.3	9.1	0.2

VT	6.1	5.6	5.5	0.1

NOVA	21.5	23.0	22.5	0.5

OTR	642.9	579.5	559.0	20.5



2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

* MA proposed rule has a January 1, 2009 effective date and includes the
VOC limits from the OTC 2001 model rule and those in the OTC 2006 model
rule.  The 2009 benefit for MA shows the benefit from both sets of
limits.  For all other States, the 2009 benefit shows the change in
emissions from the OTC 2006 model rule only.

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

Portable Fuel Containers – Area Sources

	Portable Fuel Containers 

Summer VOC Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	9.7	6.5	6.1	0.4

DE	3.0	2.1	1.9	0.1

DC	3.6	2.5	2.4	0.1

ME	3.6	2.4	2.3	0.1

MD	39.6	24.5	23.1	1.4

MA*	18.1	18.6	16.9	1.7

NH	3.6	3.0	2.8	0.2

NJ	24.4	17.7	16.7	1.0

NY	76.6	45.0	42.4	2.6

PA	47.0	27.6	26.0	1.6

RI	3.0	2.7	2.5	0.2

VT	1.7	1.5	1.5	0.1

NOVA	8.6	6.1	5.7	0.4

OTR	242.5	160.1	150.3	9.9



2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Note:  The table shows the estimated emission reduction that will occur
in 2009; additional reductions will occur in later years as new,
less-emitting PFCs that comply with the OTC 2006 control measure
penetrate the market.

* MA PFC regulation will be based on only the OTC 2006 model rule (which
updates the provisions of the OTC 2001 model rule) and will have an
effective date of January 1, 2009.  The 2009 base emissions in MA are
uncontrolled emissions.  The 2009 emission benefits represent the total
emission reductions from the MA rule.  

Table 3-9 OTC 2006 VOC Model Rule Benefits by State for 2009 

Portable Fuel Containers – Nonroad Sources

	Portable Fuel Containers 

Summer VOC Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	2.9	1.9	1.8	0.1

DE	0.9	0.6	0.6	0.0

DC	1.1	0.8	0.7	0.0

ME	1.1	0.7	0.7	0.0

MD	11.9	7.4	6.9	0.4

MA*	5.4	5.6	5.1	0.5

NH	1.1	0.9	0.8	0.1

NJ	7.3	5.3	5.0	0.3

NY	23.0	13.5	12.7	0.8

PA	14.1	8.3	7.8	0.5

RI	0.9	0.8	0.8	0.0

VT	0.5	0.5	0.4	0.0

NOVA	2.6	1.8	1.7	0.1

OTR	72.8	48.0	45.1	3.0



2002 Actual emissions estimated to be 30 percent of area source
emissions (based on Pechan 2001, pg. 11)

2009 Base Inventory emissions estimated to be 30 percent of area source
emissions, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Note:  The table shows the estimated emission reduction that will occur
in 2009; additional reductions will occur in later years as new,
less-emitting PFCs that comply with the OTC 2006 control measure
penetrate the market.

* MA PFC regulation will be based on only the OTC 2006 model rule (which
updates the provisions of the OTC 2001 model rule) and will have an
effective date of January 1, 2009.  The 2009 base emissions in MA are
uncontrolled emissions.  The 2009 emission benefits represent the total
emission reductions from the MA rule.  

Table 3-10 OTC 2006 VOC Model Rule Benefits by State for 2009 

Regional Fuels

	Regional Fuels

Summer VOC Emissions (tpd)

State	2006 Actual	2006 

Base	2006

Control	2006 Benefit

CT	87.9	87.9	87.9	0.0

DE	26.6	26.6	26.6	0.0

DC	9.1	9.1	9.1	0.0

ME	56.2	56.2	47.1	9.1

MD	158.7	158.7	155.6	3.2

MA	148.6	148.6	148.6	0.0

NH	45.3	45.3	41.0	4.3

NJ	219.6	219.6	219.6	0.0

NY	465.0	465.0	408.1	56.9

PA	363.0	363.0	305.0	58.0

RI	22.2	22.2	22.2	0.0

VT	35.9	35.9	27.9	7.9

NOVA	54.9	54.9	54.9	0.0

OTR	1693.1	1693.1	1553.7	139.4



Note: NESCAUM analysis was only completed for 2006.  Data for 2002 and
2009 are not currently available

Table 3-11 OTC 2006 VOC Model Rule Benefits by State for 2009 

All Six VOC Categories

	All Six Categories

Summer VOC Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	149.9	142.9	133.2	9.7

DE	39.3	37.7	36.3	1.4

DC	19.6	17.6	17.2	0.4

ME	83.5	83.6	60.9	22.6

MD	270.0	248.1	236.3	11.8

MA	253.3	260.1	230.8	29.3

NH	70.0	70.3	58.8	11.5

NJ	354.1	334.6	317.9	16.7

NY	814.2	758.4	656.5	101.9

PA	576.8	546.7	454.3	92.3

RI	39.5	38.6	35.6	3.0

VT	48.0	48.7	36.5	12.1

NOVA	88.8	87.4	85.4	1.9

OTR	2,807.0	2,674.6	2,359.8	314.8



2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions based on the emissions forecasted in the
MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section.  Assumes that 2009 reductions from RFG are the same as
those calculated for 2006.

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).  Assumes that 2009 reductions from RFG are the same as those
calculated for 2006.

NOx ANALYSIS METHODS

This Section describes the analysis of the 2006 OTC control measures to
reduce NOx emissions from six source categories:  diesel engine chip
reflash, regional fuels, asphalt production plants, cement kilns,
glass/fiberglass furnaces, ICI boilers.  For each of the categories,
there are separate subsections that discuss existing Federal/state
rules, summarize the requirements of the 2006 OTC control measure,
describe the methods used to quantify the emission benefit, and provide
an estimate of the anticipated costs and cost-effectiveness of the
control measure.  At the end of Section 4, we provide the estimated
emissions for 2002 and 2009 by source category and State.  Appendix E
provides county-by-county summaries of the emission reductions for each
of the categories.  

HEAVY-DUTY TRUCK DIESEL ENGINE CHIP REFLASH

In the mid-1990s, the U.S. Department of Justice (DOJ), EPA, and CARB
determined that seven major engine manufacturers had designed their 1993
through 1998 model heavy-duty diesel engines to operate with advanced
electronic engine controls that resulted in excessive NOx emissions. 
When these engines were operated in the vehicle under “real world”
conditions, the electronic calibration would change, altering the fuel
delivery characteristics and resulting in elevated NOx levels.  DOJ, EPA
and ARB developed Consent Decrees that required the manufacturers to
provide software (the “Low-NOx Rebuild Kit” or “chip reflash”)
that modifies the injection timing adjustment that caused the excess NOx
emissions.  The kits are to be installed at the time the vehicle is
brought in for a major engine rebuild/overhaul.  The rate of rebuild has
been considerably lower than what was envisioned under the Consent
Decrees; the primary reasons being that engine rebuilds occur at
considerably higher elapsed vehicle mileage than what was contemplated
when the Consent Decrees were negotiated, and there is no federal
oversight program to ensure that individual rebuilds are occurring at
the time of rebuild.  In response to this low rebuild rate, CARB has
adopted a mandatory program, not tied to the time of rebuild, but rather
to a prescribed period of time, within which owners must bring their
vehicles into the dealer to have the reflash operation performed, with
all costs borne by the engine manufacturers. (NESCAUM 2006b).

Existing Federal and State Rules

California entered into Settlement Agreements, separate from the federal
Consent Decrees, but with analogous requirements for low-NOx rebuilds. 
The slow rate of progress in California mirrored the progress
nationally.  Accordingly, California embarked upon its own program, by
rule, to accelerate and ultimately complete the rebuilds for trucks
registered in California and for out-of-state registered trucks
traveling on roadways within the state.  The ARB rule, effective March
21, 2005, mandates that rebuilds occur over a prescribed time period,
with a final rebuild compliance date of December 31, 2006.  The CARB
mandatory program faced two separate legal challenges, alleging that
CARB has breached its settlement agreement and alleging that CARB is
illegally establishing different emissions standards on “new
engines”.  The Sacramento County Superior Court ruled that the Low NOx
Software Upgrade Regulation is invalid.  CARB indicates that it will not
appeal that ruling and is suspending further enforcement of this
regulation.  

Description of the OTC 2006 Control Measure

NESCAUM developed a model rule for consideration by its member states to
implement a low-NOx rebuild program, similar California’s program. 
The regulation applies to the engine manufacturers and to owners,
lessees, and operators of heavy-duty vehicles powered by the engines
that are required to have the low-NOx rebuild.  Consistent with the
Consent Decrees, the engine manufacturers are required to provide the
rebuild kits at no cost to dealers, distributors, repair facilities,
rebuild facilities, owners, lessees, and operators, upon their request
and to reimburse their authorized dealers, distributors, repair
facilities and rebuild facilities for their labor costs.  

Emission Benefit Analysis Methods

NESCUAM estimated potential NOx emissions reductions (tons per day) if
the Northeast States were to adopt a rebuild program similar to the
California program.  These estimates are based on the ratio of Northeast
to California in-state heavy-duty vehicle registrations, and
ARB-estimated California NOx reductions of 35 TPD (NESCAUM 2006b, pg.
5).  NESCAUM also estimated potential NOx emissions reductions for the
Mid-Atlantic States by scaling the NESCAUM projections based on
population.  For the Mid-Atlantic States, the NOx benefit was calculated
based on the per capita factors of a one ton per day reduction for each
one million people (NESCAUM 2005).

Cost Estimates

The cost associated with the reflash has been estimated at $20-$30 per
vehicle, which is borne by the engine manufacturer.  There may be costs
associated with potential downtime to the trucking firms, and
record-keeping requirements on the dealer performing the reflash and the
vehicle owner.  The MRPO estimated cost effectiveness to be $1,800 to
$2,500 (depending on vehicle size) due to incremental “fuel penalty”
of 2 percent increase in fuel consumption (ENVIRON 2006).  

REGIONAL FUELS

The Clean Air Act Amendments of 1990 required significant changes to
conventional fuels used by motor vehicles.  Beginning in 1995,
“reformulated” gasoline (RFG) must be sold in certain non-attainment
areas and other states with non-attainment areas are permitted to
opt-in.  Reformulated gasoline results in lower VOC emissions than would
occur from the use of normal “baseline” gasoline.  Phase II of the
RFG program began in 2000.

Existing Federal and State Rules

All but two states in the OTR are participating, in whole or in part,
with the federal RFG program.  However, nearly one-third of the gasoline
sold in the OTR is not RFG.  NESCAUM has estimated the following
fraction of gasoline that is reformulated by State: 

State	Current RFG Fraction	State	Current RFG Fraction

CT	100%	NJ	100%

DC	100%	NY	54%

DE	100%	PA	24%

MA	100%	RI	100%

MD	86%	NoVA	100%

ME	0%	VT	0%

NH	64%





Description of the OTC 2006 Control Measure

The Energy Policy Act of 2005 provides the opportunity for the OTR to
achieve a single clean-burning gasoline and is consistent with what OTR
states have promoted through the long debate over MTBE/ethanol/RFG. 
Approximately one-third of the gasoline currently sold in the OTR is not
reformulated.  The new authority plus the potential for emission
reductions from the amount of non-reformulated gasoline sold in the OTR
provides an opportunity for additional emission reductions in the region
as well as for a reduced number of fuels, and possibly a single fuel, to
be utilized throughout the region.  The OTC Commissioners recommended
that the OTC member states pursue a region fuel program consistent with
the Energy Act of 2005 (OTC 2006b).

Emission Benefit Analysis Methods

Emission benefits resulting from extending reformulated gasoline to all
areas of the OTR have been calculated for 2006 by NESCAUM (NESCAUM
2006a).

Cost Estimates

According to USEPA’s regulatory impact analysis for reformulated
gasoline (USEPA 1993), the cost per ton of NOx reduced for Phase II RFG
is $5,200 to $3,700.  

ASPHALT PAVEMENT PRODUCTION PLANTS

Hot mix asphalt (HMA) is created by mixing and heating size-graded, high
quality aggregate (which can include reclaimed asphalt pavement) with
liquid asphalt cement.  HMA can be manufactured by batch mix, continuous
mix, parallel flow drum mix, or counterflow drum mix plants.  The dryer
operation is the main source of pollution at hot mix asphalt
manufacturing plants.  Dryer burner capacities are usually less than 100
mmBtu/hr, but may be as large as 200 mmBtu/hr.  Natural gas is the
preferred source of heat used by the industry, although oil, electricity
and combinations of fuel and electricity are used.  The reaction of
nitrogen and oxygen in the dryer creates nitrogen oxide (NOx) emissions
in the combustion zone,

Existing Federal and State Rules

Only two of the OTR states have regulations that specifically address
NOx emissions from asphalt pavement manufacturing plants.  New Hampshire
limits NOx emissions to 0.12 pound per ton of asphalt produced, or 0.429
lb per mmBtu {Chapter Env-A 1211.08 (c)} for units greater than 26
mmBTU/hour in size.  New Jersey limits NOx emissions to 200 ppmvd at
seven percent oxygen {7:27-19.9(a)}.  Asphalt plants in other OTR states
are subject to more general fuel combustion requirements or case-by-case
RACT determinations.

Description of the OTC 2006 Control Measure

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

Table 4.1 Addendum to OTC Resolution 06-02 Emission Guidelines 

for Asphalt Plants

Plant Type	Emission Rate 

(lbs NOx/ton asphalt produced)	% Reduction

Area/Point Sources 



   Batch Mix Plant – Natural Gas	0.02	35

   Batch Mix Plant – Distillate/Waste Oil	0.09	35

   Drum Mix Plant – Natural Gas	0.02	35

   Drum Mix Plant – Distillate/Waste Oil	0.04	35

or Best Management Practices





Industry leaders have identified a number of Best Management Practices
that allow for substantial reduction in plant fuel consumption and the
corresponding products of combustion including NOx.  Best management
practices include: 

Burner tune-ups: A burner tune-up may reduce NOx emissions by up to 10
percent and may also help reduce fuel consumption. In other words, there
can be a direct pay-back to the business from regular burner tune-ups.

Effective stockpile management to reduce aggregate moisture content: 
Current information indicates that effective stockpile management can
reduce aggregate moisture content by about 25 percent, corresponding to
a reduction in fuel consumption by approximately 10 - 15 percent. There
are a number of ways to reduce aggregate moisture: covering stockpiles,
paving under stockpiles, and sloping stockpiles are all ways that
prevent aggregate from retaining moisture. Best Practices are plant- and
geographic locale-specific.

Lowering mix temperature: A Technical Working Group of FHWA is currently
investigating a number of newer formulation technologies, to understand
the practicality and performance of lowering mix temperatures.
Substantial reductions in mix temperatures, on the order of 20 percent
or more, appear to be plausible. Lowering mix temperatures, by this
amount, may reduce fuel consumption, as less heat is needed to produce
the mix.

Other maintenance and operational best practices: Additional practices
can be employed throughout the plant to help optimize production and
operations. For example, regular inspection of drum mixing flites and
other measures can be taken – all in the effort to make a plant
operate more efficiently, thereby using less fuel.

Emission Benefit Analysis Methods

The emission rates and percent reductions estimates shown above for
major sources were developed the state of New York based on the use of
low-NOx burners and FGR.  For minor sources, the requirement is the use
of low-NOx burner technology.  NOx emissions can be reduced by 35 to 50
percent with low-NOx burners and FGR, and by 25 to 40 percent with
low-NOx burners alone.  For modeling purposes, a 35 percent reduction
was assumed to apply all types of asphalt plants.  

The reductions estimated for this category only include emissions
included in the MANEVU point source emission inventory.  Only emissions
from major point sources are typically included in the MANEVU point
source database.  Emissions from non-major sources are not explicitly
contained in the area source inventory.  The emissions from non-major
asphalt plants are likely lumped together in the general area source
industrial and commercial fuel use category.  Reductions from area
source emissions at asphalt production plants are included in the ICI
boiler source category.  Therefore, there is some uncertainty regarding
the actual reductions that will occur as no accurate baseline exists for
both major and minor facilities.

Cost Estimates

The anticipate costs for control are similar to those of small to
midsize boilers or process heaters.  Low NOx burners range from $500 to
$1,250 per ton and low-NOx burners in combination with FGR range from
$1,000 to $2,000 per ton.  These cost-effectiveness data were provided
by NYSDEC.  These control efficiencies and cost-effectiveness estimates
for low-NOx burners plus FGR are generally consistent EPA’s published
data for small natural gas-fired and oil-fired process heaters and
boilers (Pechan 2005).  

CEMENT KILNS

Portland cement manufacturing is an energy intensive process in which
cement is made by grinding and heating a mixture of raw materials such
as limestone, clay, sand and iron ore in a rotary kiln.  Nationwide,
about 82 percent of the industry’s energy requirement is provided by
coal.  Waste-derived fuels (such as scrap tires, used motor oils,
surplus printing inks, etc.) provide about 14 percent of the energy. 
NOx emissions are generated during fuel combustion by oxidation of
chemically-bound nitrogen in the fuel and by thermal fixation of
nitrogen in the combustion air.

There are four main types of kilns used to manufacture portlant cement:
long wet kilns, long dry kilns, dry kilns with preheaters, dry kilns
with precalciners.  Wet kilns tend to be older units and are often
located where the moisture content of feed materials from quarries tends
to be high.  

Cement kilns are located in Maine, Maryland, New York, and Pennsylvania.
 There are no cement kilns in the other OTR states. According to the
MANEVU 2002 inventory (Pechan 2006), the number of cement kilns
operating in 2002 by size and type was:

State	Number of Facilities	Number of Long Wet Kilns	Number of Long Dry
Kilns	Number of Preheater or Precalciner Kilns

Maine	1	1	0	0

Maryland	3	2	2	0

New York	3	2	1	0

Pennsylvania	10	5	11	5

Existing Federal and State Rules

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

Option 1 – for long wet kilns, meet NOx emission limit of 6.0 pounds
per ton of clinker produced; for long dry kilns, meet limit of 5.1
pounds per ton of clinker produced; and for pre-heater/pre-calciner or
pre-calciner kilns, meet limit of 2.8 pounds per ton of clinker
produced;

Option 2 – install low NOx burners on each kiln or modify each kiln to
implement mid-kiln firing.

The one kiln in Maine is a wet process cement kiln and has been licensed
to modernize by converting to the more efficient dry cement
manufacturing process.  The new kiln is subject to BACT requirements.  

Description of the OTC 2006 Control Measure

There is a wide variety of proven control technologies for reducing NOx
emissions from cement kilns.  Automated process control has been shown
to lower NOx emissions by moderate amounts.  Low-NOx burners have been
successfully used, especially in the precalciner kilns.  CemStarSM is a
process that involves adding steel slag to the kiln, offering moderate
levels of NOx reduction by reducing the required burn zone heat input. 
Mid-kiln firing of tires provides moderate reductions of NOx emissions
while reducing fuel costs and providing an additional revenue stream
from receipt of tire tipping fees.  SNCR technology has the potential to
offer significant reductions on some precalciner kilns.  SNCR is being
used in numerous cement kilns in Europe.  A recent study (EC 2001a)
indicates that there are 18 full-scale SNCR installations in Europe. 
Most SNCR installations are designed and/or operated for NOx reduction
rates of 10-50% which is sufficient to comply with current legislation
in some countries.  Two Swedish plants installed SNCR in 1996/97 and
have achieved a reduction of 80-85%. A second recent study (ERG 2005) of
cement kilns in Texas has identified a variety of NOx controls for both
wet and dry cement kilns, with reductions in the 40 to 85% range.   

The OTC Commissioners recommended that OTC member states pursue, as
necessary and appropriate, state-specific rulemakings or other
implementation methods to establish emission reduction percentages,
emission rates or technologies that are consistent with the guidelines
shown in Table 4.2 (OTC 2006b).  The guidelines were presented in terms
of both an emission rate (lbs/ton of clinker by kiln type) as well as a
percent reduction from uncontrolled levels.  

Table 4.2 OTC Resolution 06-02 Emission Guidelines for Cement Kilns

Kiln Type	Emission Rate 

(lbs NOx/ton of clinker produced)	% Reduction from Uncontrolled

Wet Kiln	3.88	60

Long Dry Kiln	3.44	60

Pre-heater Kiln	2.36	60

Pre-calciner Kiln	1.52	60

Emission Benefit Analysis Methods

To calculate the additional reductions from the OTC 2006 Control
Measure, MACTEC calculated the 2002 emission rate (lbs NOx per ton of
clinker produced) for each kiln.  The 2002 emission rate was compared to
the OTC 2006 control measure emission rate list above to calculate a
kiln-specific percent reduction.  The kiln-specific percent reduction
was then applied to the 2002 actual emissions to calculate the emissions
remaining after implementation of the control measure.

Cost Estimates

The TCEQ study (ERG 2005) estimated a cost-effectiveness of $1,400-1,600
per ton of NOx removed for an SNCR system achieving a 50 percent
reduction on modern dry preheat precalcination kilns.  The study also
estimate a cost-effectiveness of $2,200 per ton of NOx removed for SNCR
systems achieving a 35 percent reduction on wet kilns.  The most recent
EPA report (EC/R 2000) shows data for two SNCR technologies, biosolids
injection and NOXOUT®.  These technologies showed average emission
reductions of 50 and 40 percent, respectively.  The cost effectiveness
was estimated to be $1,000-2,500/ton depending on the size of the kiln. 
Costs and the cost effectiveness for a specific unit will vary depending
on the kiln type, characteristics of the raw material and fuel,
uncontrolled emission rate, and other source-specific factors.  

GLASS/FIBERGLASS FURNACES

The manufacturing process requires raw materials, such as sand,
limestone, soda ash, and cullet (scrap and recycled glass), be fed into
a furnace where a temperature is maintained in the 2,700°F to 3,100°F
range.  The raw materials then chemically react creating a molten
material, glass.  The reaction of nitrogen and oxygen in the furnace
creates NOx emissions.  

The main product types are flat glass, container glass, pressed and
blown glass, and fiberglass.  In the OTR, the preponderance of glass
manufacturing plants is in Pennsylvania.  New York and New Jersey also
have several plants.  Massachusetts, Maryland, and Rhode Island each
have one glass manufacturing plant.

Existing Federal and State Rules

Only Massachusetts and New Jersey have specific regulatory limits for
NOx emissions from glass melting furnaces.  Massachusetts has a 5.3
pound per ton of glass removed limit for container glass melting
furnaces having a maximum production of 15 tons of glass per day or
greater.  New Jersey has a 5.5 pound per ton of glass limit for
commercial container glass manufacturing furnaces and an 11 pound per
ton of glass for specialty container glass manufacturing furnaces.  New
Jersey also required borosilicate recipe glass manufacturing furnaces to
achieve at least a 30 percent reduction from 1990 baseline levels by
1994.  The regulations for other states with glass furnaces (Maryland,
New York, Pennsylvania, and Rhode Island) do not contain specific
emission limitation requirements, but rather require RACT emission
controls as determined on a case-by-case basis.

Description of the OTC 2006 Control Measure

Several alternative control technologies are available to glass
manufacturing facilities to limit NOx emissions (MACTEC 2005).  These
options include combustion modifications (low NOx burners, oxy-fuel
firing, oxygen-enriched air staging), process modifications (fuel
switching, batch preheat, electric boost), and post combustion
modifications (fuel reburn, SNCR, SCR).  Oxyfiring is the most effective
NOx emission reduction technique and is best implemented with a complete
furnace rebuild.  This strategy not only reduces NOx emissions by as
much as 85 percent, but reduces energy consumption, increases production
rates by 10-15 percent, and improves glass quality by reducing defects. 
Oxyfiring is demonstrated technology and has penetrated into all
segments of the glass industry.

The OTC Commissioners recommended that OTC member states pursue, as
necessary and appropriate, state-specific rulemakings or other
implementation methods to establish emission reduction percentages,
emission rates or technologies that are consistent with the guidelines
shown in Table 4.3 (OTC 2006g).  The guidelines were presented in terms
of both an emission rate (lbs/ton of glass produced) as well as a
percent reduction from uncontrolled levels for the different types of
glass manufactured.

Table 4.3 Addendum to OTC Resolution 06-02 Guidelines for Glass Furnaces

Type of Glass	Emission Rate 

(lbs NOx/ton of glass pulled)

Block 24-hr Ave.	Emission Rate 

(lbs NOx/ton of glass pulled)

Rolling 30-day Ave.

Container Glass	4.0 	n/a

Flat Glass	9.2 	7.0 

Pressed/blown Glass	4.0 	n/a

Fiberglass	4.0 	n/a

Note: Compliance date is 2009.  NOx allowances may be surrendered in
lieu of meeting the emission rate based on a percentage of the excess
emissions at the facility, at the discretion of the State.

Emission Benefit Analysis Methods

The NOx emission reduction benefit calculation varied by State depending
upon the availability of data:

New Jersey DEP evaluated the existing controls at each facility.  NJDEP
identified furnaces that have closed, indicated whether the facility
requested banking of emissions, and specified whether the emissions from
the closed furnace should remain in the projection year inventory. 
NJDEP also identified furnace-specific projected emission rates based on
the use of oxyfuel technology.

Pennsylvania DEP provided 2002 throughput (tons of glass pulled) and
emission rate data (lbs NOx/ton of glass pulled).  The 2002 emission
rate was compared to the OTC 2006 control measure emission rate list
above to calculate a furnace-specific percent reduction.  The
furnace-specific percent reduction was then applied to the 2002 actual
emissions to calculate the emissions remaining after implementation of
the control measure.  If a furnace had an emission rate below the OTCC
2006 control measure emission rate, then no incremental reduction was
calculated.  PADEP also identified several furnaces that have shut down
– emissions from these furnaces were set to zero in the projection
year inventory.  

For all other States with glass furnaces (MA, MD, NY, and RI), furnace
specific data were not available.  The NOx emission reduction benefit
was calculated by applying an 85 percent reduction for oxyfiring
technology to the projected 2009 base inventory.  This approach does not
take into account existing controls at the facilities.

Cost Estimates

A recent study by the European Commission (EC 2001b) reports a 75 to 85
percent reduction in NOx based on oxyfiring technology, resulting in
emission rates of 1.25 to 4.1 pounds of NOx per ton of glass produced. 
The cost effectiveness was determined to be $1,254 to $2,542 depending
on the size of the furnace.  EPA’s Alternative Control Techniques
Document (USEPA 1994) estimated an 85 percent reduction in NOx emissions
for oxyfiring with a cost-effectiveness of $2,150 to $5,300.  

Other technologies may be used to meet the limits in Table 4.3.  The
costs associated with meeting those limits are source-specific and
depend on the existing controls in place and the emission rates being
achieved.  Site-specific factors greatly influence the actual achievable
performance level and control costs at a particular facility.  

ICI BOILERS 

Industrial/commercial/institutional (ICI) boilers combust fuel to
produce heat and process steam for a variety of applications. 
Industrial boilers are routinely found in applications the chemical,
metals, paper, petroleum, food production and other industries. 
Commercial and institutional boilers are normally used to produce steam
and heat water for space heating in office buildings, hotels, apartment
buildings, hospitals, universities, and similar facilities.  Industrial
boilers are generally smaller than boilers in the electric power
industry, and typically have a heat input in the 10-250 mmBtu/hr range;
however, industrial boilers can be as large as 1,000 mmBtu/hr or as
small as 0.5 mmBtu/hour.  Most commercial and institutional boilers
generally have a heat input less than 100 mmBtu/hour.  It is estimated
that 80 percent of the commercial/institutional population is smaller
than 15 mmBtu/hour.  The ICI boiler population is highly diverse –
encompassing a variety of fuel types, boiler designs, capacity
utilizations and pollution control systems – that result in
variability in emission rates and control options.  

For emission inventory purposes, emissions from ICI boilers are included
in both the point and area source emission inventories.  Generally, the
point source emission inventory includes all ICI boilers at major
facilities.  The point source inventory lists individual boilers, along
with their size and associated emissions.  The area source inventory
generally includes emissions for ICI boilers located at non-major
facilities.  It does not provide emissions by the size of boiler, as is
done in the point source inventory.  Area sources emissions are
calculated based on the fuel use not accounted for in the point source
inventory.  This is done by taking the total fuel consumption for the
state (by fuel type and category), as published by the U.S. Department
of Energy, and subtracting out the fuel usage reported in the point
source inventory.  Emissions are then calculated on a county-by-county
basis using the amount of fuel not accounted for in the point source
inventory and average emission factors for each fuel type.  

Existing Federal and State Rules

ICI boilers are subject to a variety of Clean Air Act programs. 
Emission limits for a specific source may have been derived from NSPS,
NSR, NOx SIP Call, State RACT rules, case-by-case RACT determinations,
or MACT requirements.  Thus, the specific emission limits and control
requirements for a given ICI boiler vary and depend on fuel type, boiler
age, boiler size, boiler design, and geographic location.  

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

OTC 2001 Model Rule ICI Boiler Thresholds and Limits

Applicability Threshhold	Emission Rate Limit	Percent NOx Reduction

5-50 mmBtu/hr	None	Tune-up Only

50-100 mmBtu/hr	Gas-fired:  0.10 lbs/mmBtu

Oil-fired:   0.30 lbs/mmBtu

Coal-fired: 0.30 lbs/mmBtu	50%

100-250 mmBtu/hr	Gas-fired:  0.10 lbs/mmBtu

Oil-fired:   0.20 lbs/mmBtu

Coal-fired: 0.20 lbs/mmBtu	50%

>250 mmBtu/hr*	Gas-fired:  0.17 lbs/mmBtu

Oil-fired:   0.17 lbs/mmBtu

Coal-fired: 0.17 lbs/mmBtu	50%

* Only for boilers not subject to USEPA’s NOx SIP Call

Implementation of the OTC 2001 model rule limits varied by State –
some OTC states adopted these limits while others did not.  MACTEC
researched current State regulations affecting ICI boilers and
summarized the rules in Appendix F.  The specific requirements for each
state were organized into a common format to efficiently include the
State-by-State differences by fuel type and boiler size.  This
organization oversimplifies the source categories and size limitations
that differ from State-to-State.  This simplification was necessary to
match the rules to the organization of the emission data bases (i.e.,
Source Classification Codes) being used in the analysis.

Description of the OTC 2006 Control Measure

The OTC Commissioners recommended that OTC member states pursue as
necessary and appropriate state-specific rulemakings or other
implementation methods to establish emission reduction percentages,
emission rates or technologies for ICI boilers (OTC 2006b).  These
guidelines have undergone revision based on a more refined analyses.
Table 4.4 provides the current OTC proposal for ICI boilers.

Emission Benefit Analysis Methods

The emission reduction benefits resulting from the OTC ICI boiler
control measure were calculated differently for point and area sources. 
For point sources, the emission reductions were estimated by comparing
the emission limits in the existing (2006) state regulations with the
limits contained in the OTC ICI boiler proposal.  

Table 4.4 Addendum to OTC Resolution 06-02 Guidelines for ICI Boilers

ICI Boiler Size

(mmBtu/hr)

	Control Strategy/

Compliance Option	NOx Control Measure

5-25

Annual Boiler Tune-Up

25-100	Option #1	Natural Gas:           0.05 lb NOx/mmBtu

#2 Fuel Oil:            0.08 lb NOx/mmBtu

#4 or #6 Fuel Oil:   0.20 lb NOx/mmBtu

Coal:                       0.30 lb NOx/mmBtu**

	Option #2	50% reduction in NOx emissions from uncontrolled baseline

	Option #3	Purchase current year CAIR NOx allowances equal to reducted
needed to acheiv the required emission rates

100-250	Option #1	Natural Gas:            0.10 lb NOx/mmBtu

#2 Fuel Oil:             0.20 lb NOx/mmBtu

#4 or #6 Fuel Oil:    0.20 lb NOx/mmBtu

Coal:

     Wall-fired           0.14 lb NOx/mm Btu

     Tangential           0.12 lb NOx/mm Btu

     Stoker                  0.22 lb NOx/mm Btu

     Fluidized Bed      0.08 lb NOx/mm Btu

	Option #2	LNB/SNCR, LNB/FGR, SCR, or some combination of these controls
in conjunction with Low NOx Burner technology

	Option #3	60% reduction in NOx emissions from uncontrolled baseline

	Option #4	Purchase current year CAIR NOx allowances equal to reducted
needed to acheiv the required emission rates

>250	Option #1	Purchase current year CAIR NOx allowances equal to
reducted needed to acheiv the required emission rates

	Option #2	Phase I – 2009

Emission rate equal to EGUs of similar size

Phase II – 2012

Emission rate equal to EGUs of similar size



Tables 4-5 through 4-10 shows the current state emission limits by size
range and fuel type, and the percentage reduction from the OTC proposed
limits to the current state requirement.  In cases where a state did not
have a specific limit for a given size range, then the more general
percent reduction from uncontrolled values in Table 4-4 was used.  The
fuel types/boiler types shown in Tables 4-5 through 4-10 were matched to
SCCs in the point source inventory.  MACTEC used the SCC and design
capacity (mmBtu/hour) from the MANEVU and VISTAS emission inventories to
apply the appropriate state specific reduction factor to estimate the
emission reduction benefit.   

The emission limits shown in Tables 4-5 through 4-10 generally apply
only to ICI boilers located at major sources (i.e. point sources).  ICI
boilers located at minor sources (i.e., area sources) are generally not
subject to the emissions limits.  In general, emissions from area source
ICI boilers are uncontrolled (except possibly for an annual tune-up
requirement).  The one exception is New Jersey: beginning on March 7,
2007, N.J.A.C. 27.27-19.2 requires any ICI boiler of at least 5 mmBtu/hr
heat input to comply with applicable NOx emission limits whether or not
it is located at a major NOx facility.  

To calculate the reductions from area source ICI boilers, MACTEC applied
the general percent reduction from uncontrolled values in Table 4-4 to
the area source inventory (i.e., 10 percent reduction for annual
tune-ups for boilers < 25 mmBtu/hr, and a 50 percent reduction for
boilers between 25 and 100 mmBtu/hr).  

The area source inventory does not provide information on the boiler
size.  To estimate the boiler size distribution in the area source
inventory, we first assumed that there were no boilers > 100 mmBtu/hr in
the area source inventory.  Next, we used boiler capacity data from the
USDOE’s Oak Ridge National Laboratory (EEA 2005) to estimate the
percentage of boiler capacity in the < 25 mm Btu/hr and 25-100 mm Btu/hr
categories.  Third, we assumed that emissions were proportional to
boiler capacity.  Finally, we calculated the weighted average percent
reduction for area source ICI boilers based on the capacity in each size
range and the percent reduction by size range discussed in the previous
paragraph.  For industrial boilers, the weighted average reduction was
34.5 percent; for commercial/institutional boilers, the weighted average
reduction was 28.1 percent.

Table 4.5 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Natural Gas-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold 

mmBtu/hour Heat Input

Applicability Threshold 

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.10	0.05	0.05	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	50.0	75.0	75.0	10.0

DE	0.10	0.10	LNB	NL	NL

0.0	0.0	0.0	0.0	0.0

DC	0.20	0.20	NL	NL	NL

40.0	50.0	50.0	50.0	10.0

ME	0.20	NL	NL	NL	NL

40.0	60.0	50.0	50.0	10.0

MD	0.20	0.20	0.20	0.20	0.20

40.0	50.0	75.0	75.0	10.0

MA	0.20	0.20	0.10	NL	NL

40.0	50.0	50.0	50.0	10.0

NH	0.10	0.10	0.10	NL	NL

0.0	0.0	50.0	50.0	10.0

NJ	0.10	0.10	0.10	NL	NL

0.0	0.0	50.0	50.0	10.0

NY	0.20	0.20	0.10	NL	NL

40.0	50.0	50.0	50.0	10.0

PA	Source Specific NOx RACT 

29.4	50.0	50.0	50.0	10.0

SE PA	0.17	0.10	Source Specific RACT

29.4	0.0	50.0	50.0	10.0

RI	0.10	0.10	0.10	NL	NL

0.0	0.0	50.0	50.0	10.0

VT	0.20	NL	NL	NL	NL

40.0	60.0	50.0	50.0	10.0

NOVA	0.2	0.2	0.2	0.2	0.2	 	40.0	50.0	75.0	75.0	10.0



NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.6 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Distillate Oil-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold 

mmBtu/hour Heat Input

Applicability Threshold 

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.20	0.08	0.08	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	0.0	60.0	60.0	10.0

DE	0.10	0.10	LNB	NL	NL

0.0	0.0	0.0	0.0	0.0

DC	0.30	0.30	0.30	NL	NL

60.0	33.3	73.3	50.0	10.0

ME	0.20	0.30	0.30	NL	NL

40.0	33.3	73.3	50.0	10.0

MD	0.25	0.25	0.25	0.25	0.25

52.0	20.0	68.0	68.0	10.0

MA	0.25	0.30	0.12	NL	NL

52.0	33.3	33.3	50.0	10.0

NH	0.30	0.30	0.12	NL	NL

60.0	33.3	33.3	50.0	10.0

NJ	0.20	0.20	0.12	NL	NL

40.0	0.0	33.3	50.0	10.0

NY	0.25	0.30	0.12	NL	NL

52.0	33.3	33.3	50.0	10.0

PA	Source Specific NOx RACT 

29.4	33.3	33.3	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	0.0	33.3	50.0	10.0

RI	0.12	0.12	0.12	NL	NL

0.0	0.0	33.3	50.0	10.0

VT	0.30	NL	NL	NL	NL

60.0	60.0	50.0	50.0	10.0

NOVA	0.25	0.25	0.25	0.25	0.25	 	52.0	20.0	68.0	68.0	10.0



NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.7 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Residual Oil-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold 

mmBtu/hour Heat Input

Applicability Threshold 

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.20	0.20	0.20	NL

CT	0.25	0.25	0.25	0.25	0.25

52.0	20.0	20.0	20.0	10.0

DE	0.10	0.10	LNB	NL	NL

0.0	0.0	0.0	0.0	0.0

DC	0.30	0.30	0.30	NL	NL

60.0	33.3	33.3	50.0	10.0

ME	0.20	0.30	0.30	NL	NL

40.0	33.3	33.3	50.0	10.0

MD	0.25	0.25	0.25	0.25	0.25

52.0	20.0	20.0	20.0	10.0

MA	0.25	0.30	0.30	NL	NL

52.0	33.3	33.3	50.0	10.0

NH	0.30	0.30	0.30	NL	NL

60.0	33.3	33.3	50.0	10.0

NJ	0.20	0.20	0.30	NL	NL

40.0	0.0	33.3	50.0	10.0

NY	0.25	0.30	0.30	NL	NL

52.0	33.3	33.3	50.0	10.0

PA	Source Specific NOx RACT 

29.4	33.3	33.3	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	0.0	50.0	50.0	10.0

RI	LNB/FGR	LNB/FGR	LNB/FGR	NL	NL

0.0	0.0	0.0	50.0	10.0

VT	0.30	NL	NL	NL	NL

60.0	60.0	50.0	50.0	10.0

NOVA	0.25	0.25	0.25	0.25	0.25	 	52.0	20.0	20.0	20.0	10.0



NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.8 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Coal Wall-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold 

mmBtu/hour Heat Input

Applicability Threshold 

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.14	0.30	0.30	NL

CT	0.38	0.38	0.38	0.38	0.38

68.4	63.2	21.1	21.1	10.0

DE	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

DC	0.43	0.43	NL	NL	NL

72.1	67.4	50.0	50.0	10.0

ME	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

MD	0.38	0.65	0.38	0.38	0.38

68.4	78.5	21.1	21.1	10.0

MA	0.45	0.45	NL	NL	NL

73.3	68.9	50.0	50.0	10.0

NH	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NJ	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NY	0.45	0.5	NL	NL	NL

73.3	72.0	50.0	50.0	10.0

PA	Source Specific NOx RACT 

29.4	72.0	50.0	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	30.0	50.0	50.0	10.0

RI	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

VT	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NOVA	0.38	0.38	0.38	0.38	0.38	 	68.4	63.2	21.1	21.1	10.0



n/a indicates that there are no coal-fired ICI boilers in the state.

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.9 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Coal Tangential-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold 

mmBtu/hour Heat Input

Applicability Threshold 

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.12	0.30	0.30	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	40.0	0.0	0.0	10.0

DE	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

DC	0.43	0.43	NL	NL	NL

72.1	72.1	50.0	50.0	10.0

ME	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

MD	0.38	0.65	0.38	0.38	0.38

68.4	81.5	21.1	21.1	10.0

MA	0.38	0.38	NL	NL	NL

68.4	68.4	50.0	50.0	10.0

NH	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NJ	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NY	0.42	0.5	NL	NL	NL

71.4	76.0	50.0	50.0	10.0

PA	Source Specific NOx RACT 

29.4	76.0	50.0	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	40.0	50.0	50.0	10.0

RI	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

VT	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NOVA	0.38	0.38	0.38	0.38	0.38	 	68.4	68.4	21.1	21.1	10.0



n/a indicates that there are no coal-fired boilers in the state.

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.10 Current State Emission Limits and Percent Reduction
Estimated from Adoption of OTC ICI Boiler Proposal

Point Source Coal-Fired Stoker Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold 

mmBtu/hour Heat Input

Applicability Threshold 

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.22	0.30	0.30	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	0.0	0.0	0.0	10.0

DE	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

DC	0.43	0.43	NL	NL	NL

72.1	48.8	50.0	50.0	10.0

ME	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

MD	0.38	0.65	0.38	0.38	0.38

68.4	66.2	21.1	21.1	10.0

MA	0.33	0.33	NL	NL	NL

63.6	33.3	50.0	50.0	10.0

NH	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NJ	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NY	0.3	0.3	NL	NL	NL

60.0	26.7	50.0	50.0	10.0

PA	Source Specific NOx RACT 

29.4	26.7	50.0	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	0.0	50.0	50.0	10.0

RI	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

VT	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NOVA	0.4	0.4	0.4	0.4	0.4	 	70.0	45.0	25.0	25.0	10.0



n/a indicates that there are no coal-fired boilers in the state.

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Cost Estimates

The OTC recently completed an analysis of ICI boiler NOx control cost
estimates (Bodnarik 2006) using detailed information on direct capital
equipment costs, direct installation costs, indirect capital costs, and
direct and indirect operating costs.  The analysis examined five types
of NOx control technologies – low-NOx burners (LNB), ultra low-NOx
burners (ULNB), LNB plus flue gas recirculation (LNB+FGR), LNB plus
selective non-catalytic reduction (LNB+SNCR), and selective catalytic
reduction (SCR).  The analysis also considered various fuel types –
coal, residual oil, distillate oil, and natural gas.  The cost
effectiveness varies by fuel type, boiler size, current regulatory
requirements, current control technology, and boiler firing type.  The
annual cost-effectiveness was found as low as $600 per ton and as high
as $18,000 per ton. In general, for most scenarios the cost
effectiveness was estimated to be less than $5,000 per ton of NOx
removed.

NOx EMISSION REDUCTION SUMMARY

The results of the emission benefit calculations for the OTC states are
described in this subsection.  The starting point for the quantification
of the emission reduction benefits is the MANEVU emission inventory,
Version 3 (Pechan 2006, MACTEC 2006a) and the VISTAS emission inventory,
BaseG (MACTEC 2006b), for the northern Virginia counties that are part
of the OTR.  The MANEVU and VISTAS inventories include a 2002 base year
inventory as well as projection inventories for 2009 and 2018 (MANEVU
also has projections for 2012, but VISTAS does not).  The projection
inventories account for growth in emissions based on growth indicators
such as population and economic activity.  The projection inventories
also account for “on-the-books/on-the-way” (OTB/W) emission control
regulations that have (or will) become effective between 2003 and 2008
that will achieve post-2002 emission reductions.  Emission reductions
from existing regulations are already accounted for to ensure no double
counting of emission benefits occurs.  

Note that the emission reductions contained in this Section are
presented in terms of tons per summer day.  The MANEVU base and
projection emission inventories do not contain summer day emissions for
all States and source categories; the VISTAS inventory only contains
annual values.  When States provided summer day emissions in the MANEVU
inventory, these values were used directly to quantify the emission
benefit from the 2006 OTC control measure.  When summer day emissions
were missing from the MANEVU or VISTAS inventories, the summer day
emissions were calculated using the annual emissions and the seasonal
throughput data from the NIF Emission Process table.  If the seasonal
throughput data was missing, the summer day emissions were calculated
using the annual emissions and a summer season adjustment factor derived
from the monthly activity profiles contained in the SMOKE emissions
modeling system.  

Tables 4-11 to 4-17 show State summaries of the emission benefits from
the OTC 2006 NOx control measures described previously in this Section. 
For each of the seven source categories, the Tables show four emission
numbers: (1) the actual 2002 summer daily emissions; (2) the summer
daily emissions for the 2009 OTB/W scenario that accounts for growth and
for the emission control regulations that have (or will) become
effective between 2003 and 2008 that will achieve post-2002 emission
reductions; (3) the summer daily emissions for 2009 with the
implementation of the OTC 2006 control measures identified in this
Section, and (4) the emission benefit in 2009 resulting from the OTC
2006 control measure.  Table 4-18 shows the same information for the
total of all seven source categories.

The largest estimated NOx emission reductions are in the more
industrialized States – New York and Pennsylvania – which have most
of the cement kilns and glass furnaces in the OTR.  These two states
also have a large population of ICI boilers.  The emission benefits
listed for Virginia just include the Virginia counties in the northern
Virginia area that are part of the OTR.  Benefit estimates for all other
States include the entire state.  The emission benefits also assume that
all OTC members will adopt the rules as described in the previous
sections. 

Appendix E provides county-by-county summaries of the NOx emission
benefits from the OTC 2006 NOx control measures described previously in
this Section.  Appendix E also provides additional documentation
regarding the data sources and emission benefit calculations that were
performed.  These tables can be used by the States to create additional
summaries, for example, by nonattainment area.  

Table 4-11 OTC 2006 NOx Model Rule Benefits by State for 2009 

Heavy-Duty Truck Diesel Engine Chip Reflash

	Heavy-Duty Truck Diesel Engine Chip Reflash 

Summer NOx Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	66.7	n/a	n/a	3.5

DE	21.8	n/a	n/a	0.6

DC	8.1	n/a	n/a	0.8

ME	82.8	n/a	n/a	1.4

MD	105.0	n/a	n/a	5.6

MA	152.7	n/a	n/a	6.7

NH	30.5	n/a	n/a	2.0

NJ	133.5	n/a	n/a	9.7

NY	177.6	n/a	n/a	16.1

PA	437.1	n/a	n/a	12.4

RI	8.3	n/a	n/a	0.8

VT	13.7	n/a	n/a	0.9

NOVA	16.6	n/a	n/a	2.5

OTR	1254.5	0.0	0.0	63.0



n/a – not available due to lack of 2009 emissions data for on-road
vehicles in NIF format.

Table 4-12 OTC 2006 NOx Model Rule Benefits by State for 2009 

Regional Fuels

	Regional Fuels

Summer NOx Emissions (tpd)

State	2006 Actual	2006 

Base	2006

Control	2006 Benefit

CT	81.3	81.3	81.3	0.0

DE	24.8	24.8	24.8	0.0

DC	8.4	8.4	8.4	0.0

ME	44.1	44.1	43.8	0.2

MD	144.0	144.0	144.0	0.0

MA	137.4	137.4	137.4	0.0

NH	38.4	38.4	38.2	0.2

NJ	204.2	204.2	204.2	0.0

NY	381.3	381.3	379.1	2.1

PA	284.8	284.8	282.9	2.0

RI	20.5	20.5	20.5	0.0

VT	26.3	26.3	26.0	0.3

NOVA	50.8	50.8	50.8	0.0

OTR	1446.2	1446.2	1441.4	4.8



NESCAUM analysis was only completed for 2006.  Data for 2002 and 2009
are not currently available

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

Asphalt Pavement Production Plants

	Asphalt Pavement Production Plants

Summer NOx Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	0.0	0.0	0.0	0.0

DE	0.6	0.6	0.4	0.2

DC	0.0	0.0	0.0	0.0

ME	1.7	2.0	1.3	0.7

MD	0.2	0.2	0.1	0.1

MA	1.1	1.8	1.2	0.6

NH	0.0	0.0	0.0	0.0

NJ	1.3	2.8	1.8	1.0

NY	0.0	0.1	0.0	0.0

PA	0.6	0.7	0.5	0.2

RI	0.1	0.1	0.1	0.0

VT	0.0	0.0	0.0	0.0

NOVA	0.3	0.3	0.2	0.1

OTR	5.9	8.6	5.6	3.0



2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are the emissions forecasted in the MANEVU
2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G inventory,
and account for growth and any emission reductions associated with
on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Table 4-14 OTC 2006 NOx Model Rule Benefits by State for 2009 

Cement Kilns

	Cement Kilns

Summer NOx Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	0.0	0.0	0.0	0.0

DE	0.0	0.0	0.0	0.0

DC	0.0	0.0	0.0	0.0

ME	4.7	4.7	4.7	0.0

MD	17.2	17.2	4.1	13.1

MA	0.0	0.0	0.0	0.0

NH	0.0	0.0	0.0	0.0

NJ	0.0	0.0	0.0	0.0

NY	35.1	35.1	19.8	15.3

PA	44.7	44.7	30.7	14.0

RI	0.0	0.0	0.0	0.0

VT	0.0	0.0	0.0	0.0

NOVA	0.0	0.0	0.0	0.0

OTR	101.9	101.9	59.4	42.5



2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are the emissions forecasted to be the
same as in 2002 (i.e., no growth was assumed). 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Table 4-15 OTC 2006 NOx Model Rule Benefits by State for 2009 

Glass/Fiberglass Furnaces

	Glass/Fiberglass Furnace

Summer NOx Emissions (tpd)

State	2002 Actual	2009 

Base	Maximum

Control	MaximumBenefit

CT	0.0	0.0	0.0	0.0

DE	0.0	0.0	0.0	0.0

DC	0.0	0.0	0.0	0.0

ME	0.0	0.0	0.0	0.0

MD	0.3	0.3	0.1	0.3

MA	1.4	1.8	0.3	1.5

NH	0.0	0.0	0.0	0.0

NJ	7.7	7.1	2.2	4.9

NY	6.1	6.8	1.0	5.8

PA	36.3	44.3	20.0	24.3

RI	0.7	0.5	0.1	0.5

VT	0.0	0.0	0.0	0.0

NOVA	0.0	0.0	0.0	0.0

OTR	52.5	60.9	23.6	37.3



2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are the emissions forecasted in the MANEVU
2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G inventory,
and account for growth and any emission reductions associated with
on-the-books/on-the-way controls measures. 

Maximum Control Inventory emissions are the emissions remaining after
full implementation of the beyond-on-the-way control measures described
in this Section.  Not all of the anticipated reductions from the
glass/fiberglass OTC 2006 control measure will be achieved by 2009. 
This column shows the emissions remaining after full implementation of
the measure, which may not occur until 2012 or 2018.

Maximum Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the base emissions and the maximum control
emissions).

Note:  The table shows the maximum emission reduction from
glass/fiberglass furnaces when the OTC 2006 control measure is fully
implemented.  Not all of the reduction shown will be achieved by 2009.  

Table 4-16 OTC 2006 NOx Model Rule Benefits by State for 2009 

ICI Boilers – Area (Minor) Source

	ICI Boilers – Area (Minor) Sources

Summer NOx Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	8.9	9.4	6.5	2.8

DE	3.4	3.5	2.3	1.2

DC	1.3	1.6	1.1	0.4

ME	5.0	5.3	4.2	1.1

MD	3.5	4.0	2.9	1.2

MA	24.4	25.8	19.1	6.6

NH	21.3	24.2	20.8	3.4

NJ	20.5	15.6	15.6	0.0

NY	105.2	112.2	78.4	33.8

PA	38.0	39.8	27.6	12.2

RI	6.6	7.3	5.3	2.1

VT	2.3	2.9	1.9	0.9

NOVA	11.8	11.9	8.1	3.9

OTR	252.0	263.4	193.9	69.5



2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are the emissions forecasted in the MANEVU
2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G inventory,
and account for growth and any emission reductions associated with
on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Table 4-17 OTC 2006 NOx Model Rule Benefits by State for 2009 

ICI Boilers – Point (Major) Source

	ICI Boilers – Point (Major) Sources

Summer NOx Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	5.8	5.6	3.5	2.1

DE	7.7	7.3	7.3	0.0

DC	1.0	1.1	0.8	0.4

ME	10.2	12.8	10.1	2.8

MD	14.2	11.2	8.8	2.4

MA	13.8	15.4	8.7	6.8

NH	3.9	4.8	2.9	1.9

NJ	12.9	10.8	7.4	3.4

NY	31.4	30.8	23.8	7.0

PA	33.4	36.5	26.7	9.8

RI	4.2	4.9	4.3	0.5

VT	0.7	0.9	0.5	0.4

NOVA	0.2	0.2	0.0	0.1

OTR	139.3	142.3	104.6	37.7



2002 Actual emissions come from the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are the emissions forecasted in the MANEVU
2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G inventory,
and account for growth and any emission reductions associated with
on-the-books/on-the-way controls measures. 

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section. 

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Table 4-18 OTC 2006 NOx Model Rule Benefits by State for 2009 

All Seven NOx Categories

	All Seven NOx Categories

Summer NOx Emissions (tpd)

State	2002 Actual	2009 

Base	2009

Control	2009 Benefit

CT	162.7	n/a	n/a	8.4

DE	58.2	n/a	n/a	2.1

DC	18.8	n/a	n/a	1.6

ME	148.5	n/a	n/a	6.2

MD	284.4	n/a	n/a	22.7

MA	330.8	n/a	n/a	22.2

NH	94.1	n/a	n/a	7.5

NJ	380.0	n/a	n/a	19.0

NY	736.8	n/a	n/a	80.1

PA	874.9	n/a	n/a	74.9

RI	40.5	n/a	n/a	3.9

VT	42.9	n/a	n/a	2.5

NOVA	79.6	n/a	n/a	6.6

OTR	3252.3	n/a	n/a	257.8



n/a – not available due to lack of 2009 emissions data for on-road
vehicles in NIF format.

REFERENCES

Bodnarik 2006: Bodnarik, Andrew M., New Hampshire Department of
Environmental Services, “ICI Boiler NOx Control Cost Estimates from
OTC Methodology”, presented at the OTC Control Strategy/SAS Committee
Meeting, November 2, 2006.

CARB 1998: California Air Resources Board, “Determination of
Reasonably Available Control Technology and Best Available Retrofit
Control Technology for Adhesives and Sealants”, December, 1998.

CARB 1999: California Air Resources Board, “Initial Statement of
Reasons for Proposed Rule Making Public Hearing to Consider the Adoption
of Portable Fuel Container Spillage Control Regulations”, August 6,
1999.

CARB 2004a: California Air Resources Board, “Initial Statement of
Reasons for Proposed Amendments to the California Aerosol Coating
Products, Antiperspirants and Deodorants, and Consumer Products
Regulations, Test Method 310, and Airborne Toxic Control Measure for
Para-dichlorobenzene Solid Air Fresheners and Toilet/Urinal Care
Products Volume I: Executive Summary”, June 24, 2004.

CARB 2004b: California Air Resources Board, Letter from William V.
Loscutoff to Stakeholders, June 7, 2004.

CARB 2005a: California Air Resources  Board, “Staff Report: Initial
Statement of Reasons for Proposed Amendments to the Portable Fuel
Container Regulations”, July 29, 2005.

CARB 2005b: California Air Resources Board, “Final Statement of
Reasons: Public Hearing to Consider Amendments to the Regulations for
Portable Fuel Containers”, October 2005.

CARB 2006: California Air Resources Board, “Final Statement of
Reasons: Public Hearing to Consider Amendments to the Regulations for
Portable Fuel Containers”, July 2006.

Census 2006: U.S. Census Bureau, web site   HYPERLINK
"http://www.census.gov/popest/counties/tables/" 
www.census.gov/popest/counties/tables/  containing county population
files for 2005.  

EC 2001a.  European Commission, “Integrated Pollution Prevention and
Control (IPPC) Reference Document on Best Available Techniques in the
Cement and Lime Manufacturing Industries”, December 2001.  

EC 2001b.  European Commission, “Integrated Pollution Prevention and
Control (IPPC) Bureau Reference Document on Best Available Techniques in
the Glass Manufacturing Industry”, December 2001.

EC/R 2000.  EC/R Incorporated, “NOx Control Technologies for the
Cement Industry – Final Report”, prepared for the U.S. Environmental
Protection Agency, September 19, 2000.  

EEA 2005:  Energy and Environmental Analysis, Inc. “Characterization
of the U.S. Industrial/Commercial Boiler Population”, prepared for Oak
Ridge National Laboratory, May 2005.

ENVIRON 2006:  ENVIRON International Corporation, “Evaluation of
Candidate Mobile Source Control Measures”, prepared for Lake Michigan
Air Directors Consortium, January 5, 2006.

ERG 2005. Eastern Research Group, Inc., “Assessment of NOx Emissions
Reduction Strategies for Cement Kilns – Ellis County’, prepared for
the Texas Commission on Environmental Quality, December 19, 2005.

MACTEC 2005:  MACTEC Federal Programs, Inc., “Interim White Paper -
Midwest RPO Candidate Control Measures: Glass Manufacturing”, prepared
for Lake Michigan air Directors Consortium, December 2005.  

MACTEC 2006a:  MACTEC Federal Programs, Inc., “Draft Final Technical
Support Document: Development of Emission Projections for 2009, 2012,
and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU
Region”, prepared for Mid-Atlantic Regional Air Management
Association, December 7, 2006.

MACTEC 2006b:  MACTEC Federal Programs, Inc., “Draft Documentation for
the 2002, 2009, and 2018 Emission Inventories for VISTAS”, prepared
for Visibility Improvement State and Tribal Association of the
Southeast, under development.

NESCAUM 2005a: The Clean Air Association of the Northeast States, email
from Arthur Marin NESCAUM to Chris Recchia OTC, December 7, 2005.

NESCAUM 2005b: The Clean Air Association of the Northeast States, “Low
Sulfur Heating Oil in the Northeast States: An Overview of Benefits,
Costs and Implementation Issues,” December 2005.

NESCAUM 2006a: The Clean Air Association of the Northeast States, email
from Arthur Marin NESCAUM to Seth Barna OTC, February 2006.

NESCAUM 2006b: The Clean Air Association of the Northeast States, “Low
NOx Software Upgrade for Heavy-Duty Trucks: Draft Model Rule Staff
Report, February 20, 2006.

OTC 2006a: Ozone Transport Commission, “Memorandum of Understanding
Among the States of the Ozone Transport Commission on a Regional
Strategy Concerning the Integrated Control of Ozone Precursors from
Various Sources”, June 7, 2006.

OTC 2006b: Ozone Transport Commission, “Resolution 06-02 of the Ozone
Transport Commission Concerning Coordination and Implementation of
Regional Ozone Control Strategies for Certain Source Categories”, June
7, 2006.

OTC 2006c: Ozone Transport Commission, “Statement of the Ozone
Transport Commission Concerning Multi-Pollutant Emission Control of
Electric Generating Units”, June 7, 2006.

OTC 2006d: Ozone Transport Commission, “Resolution 06-03 of the Ozone
Transport Commission Concerning Federal Guidance and Rulemaking for
Nationally-Relevant Ozone Control Measures”, June 7, 2006.

OTC 2006e: Ozone Transport Commission, “Modified Charge of the Ozone
Transport Commission to the Stationary Area Source Committee Regarding
Electric Generating Units”, November 15, 2006.

OTC 2006f: Ozone Transport Commission, “Statement of the Ozone
Transport Commission Concerning Regional and State Measures to Address
Emissions from Mobile Sources”, November 15, 2006.

OTC 2006g: Ozone Transport Commission, “Addendum to Resolution 06-02
of the Ozone Transport Commission Concerning Coordination and
Implementation of Regional Ozone Control Strategies for Various
Sources”, November 15, 2006.

Pechan 2001:  E.H. Pechan & Associates, Inc., “Control Measure
Development Support Analysis of Ozone Transport Commission Model
Rules”, prepared for Ozone Transport Commission, March 31, 2001.

Pechan 2005:  E.H. Pechan & Associates, Inc., “AirControlNET Version
4.1 Documentation Report”, prepared for the U.S. Environmental
Protection Agency, September, 2005.

Pechan 2006:  E.H. Pechan & Associates, Inc., “Documentation for 2002
Emission Inventory, Version 3”, prepared for Mid-Atlantic Regional Air
Management Association, April 2006.

USEPA 1993.  U.S. Environmental Protection Agency, “Final Regulatory
Impact Analysis for Reformulated Gasoline”, EPA-420/R-93-017, December
1993.

USEPA 1994.  U.S. Environmental Protection Agency, “Alternative
Control Techniques Document – NOx Emissions from Glass
Manufacturing”, EPA-453/R-94-037, June 1994.

Appendix A – Process for Identifying and Evaluating Control Measures

Background

The States of the Ozone Transport Region (OTR) are faced with the
requirement to demonstrate attainment with the 8-hour ozone NAAQS 8-hour
ozone National Ambient Air Quality Standards (NAAQS) by June 15, 2008. 
To accomplish this, most of the states will need to implement additional
measures to reduce emissions that either directly impact their
nonattainment status, or contribute to the nonattainment status in other
states.  In addition, the States are conducting attainment planning work
to support development of PM2.5 and regional haze State Implementation
Plans (SIPs).  As such, the Ozone Transport Commission (OTC) undertook
an exercise to identify a suite of additional control measures that
could be used by the OTR states in attaining their goals.

In March 2005, the Ozone Transport Commission (OTC) established the
Control Strategies Committee as an ad-hoc committee to assist with
coordination of the attainment planning work.  The Control Strategies
Committee works with three other OTC committees.  The Stationary and
Area Source (SAS) Committee evaluates control measures for specific
stationary source sectors or issues.  The Mobile Source Committee
examines control measures for on-road and non-road mobile sources.  And
the Modeling Committee develops and implements a strategic plan for
SIP-quality modeling runs to support attainments demonstrations.

The SAS Committee is comprised of various workgroups that evaluate
control measures for specific sectors or issues.  These workgroups
included:

Control Measures Workgroup focuses on stationary area sources;

Reasonably Available Control Technology (RACT) workgroup focuses on
major point sources;

Multi-Pollutant Workgroup focuses on electric generating units (EGUs);

High Electric Demand Day (HEDD) examines EGU peaking units; and

Industrial, Commercial, and Institutional (ICI) Boiler Workgroup focuses
on control technologies for different fuels and boiler size ranges. 

The OTC also issued a contract to MACTEC to help the SAS Committee
identify and evaluate candidate control measures as well as to quantify
expected emission reductions for each control measure.  

Workgroup Activities

Initially, the Workgroups compiled and reviewed a list of approximately
1,000 candidate control measures.  These control measures were
identified through published sources such as the U.S. Environmental
Protection Agency’s (EPA’s) Control Technique Guidelines,
STAPPA/ALAPCO “Menu of Options” documents, the AirControlNET
database, emission control initiatives in member states as well as other
states including California, state/regional consultations, and
stakeholder input.  Appendix B provides the initial list of control
measures that were evaluated.  

Based on the review of the 1,000 candidate control measures, the
Workgroups developed a short list of measures to be considered for more
detailed analysis.  These measures were selected to focus on the
pollutants and source categories that are thought to be the most
effective in reducing ozone air quality levels in the Northeastern and
Mid-Atlantic States.  The Workgroups reviewed information on current
emission levels, controls already in place, expected emission reductions
from the control measures, when the emission reductions would occur,
preliminary cost and cost-effectiveness data, and other implementation
issues.  Each of the candidate control measures on the short list were
summarized in a series of “Control Measure Summary Sheets”.  The
Control Measure Summary Sheets are contained in Appendix C.  The
Workgroups discussed the candidate control measures during a series of
conference calls and workshops to further refine the emission reduction
estimates, the cost data, and any implementation issues.  The Workgroups
also discussed comments from stakeholders.  The Workgroups prioritized
the control measures and made preliminary recommendations regarding
which measures to move forward on.

OTC Commissioners’ Recommendations

Based on the analyses by the OTC Workgroups, the OTC Commissioners made
several recommendations at the Commissioner’s meeting in Boston June
2006 and November 2006.  The Commissioners recommended that States
consider emission reductions from the following source categories: 

Consumer Products

Portable Fuel Containers

Adhesives and Sealants Application 

Diesel Engine Chip Reflash

Cutback and Emulsified Asphalt Paving

Asphalt Production Plants

Cement Kilns

Glass Furnaces

Industrial, Commercial, and Institutional (ICI) Boilers

Regional Fuels

Electric Generating Units (EGUs)

Additionally, the Commissioners requested that EPA pursue federal
regulations and programs designed to ensure national development and
implementation of control measures for the following categories:
architectural and maintenance coatings, consumer products, ICI boilers
over 100 mmBtu/hour heat input, portable fuel containers, municipal
waste combustors, regionally consistent and environmentally sound fuels,
small offroad engine emission regulation, and gasoline vapor recovery. 
The various recommendations by the OTC Commissioners made from 2004 to
2006 are summarized in Table A-1.  

Stakeholder Input

Stakeholders were provided multiple opportunities to review and comment
on the Control Measure Summary Sheets.  Table A-2 lists the public
meetings that were held as an opportunity for stakeholders to review and
respond to the Control Measure Summary Sheets and Commissioner’s
recommendations.  Stakeholders provided written comments, as listed in
Table A-3.  In addition to submitting written comments, the Workgroups
conducted teleconferences with specific stakeholder groups to allow
stakeholders to vocalize their concerns directly to state staff and to
discuss the control options.  These stakeholder conference calls and
meeting are listed in Table A-4.  The OTC staff and state Workgroups
carefully considered the verbal and written comments received during
this process.  

Table A-1: OTC Formal Actions, 2004-2006

Date	Action/Synopsis

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

Nov. 10, 2004	Charge to Stationary and Area Sources Committee Regarding
Multi-Pollutant Emission Control for Electrical Generating Units and
Large Industrial Sources  Directs the SAS Committee to develop an
implementation strategy for to implement the OTC’s multi—pollutant
position, recommend methods for allocating NOx and SO2 caps, assess
methods to advance the OTC’s Multi0Pollutant position beyond the OTR,
develop a program implementation structure, and present a Memorandum of
Understanding for consideration by the Commission.

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

Nov. 10, 2004	Statement on OTC Modeling  Directs the Modeling Committee
to coordinate inventories and modeling needed for ozone, regional haze,
and PM; seek input for air directors and OTC committees on regional
strategies for modeling; continue to use CALGRID as a screening tool;
and continue to explore application of emerging tools.

June 8, 2005	Resolution of the States of the Ozone Transport Commission
Regarding Development of a Regional Strategy for the Integrated Control
of Ozone Precursors and Other Pollutants of Concern from Electrical
Generating Units (EGUs) and Other Large Sources  Resolves that member
States: develop a regional Multi-Pollutant program to assist in
attaining and maintaining the 8-hour ozone NAAQS; seek to gain support
from other states for a broader inter-regional strategy; develop an
emissions budget and region-wide trading program; explore all feasible
options to utilize the CAIR framework; and develop implementation
mechanisms including a Memorandum of Understanding among the states.

Nov. 3, 2005	Statement of the Ozone Transport Commission With Regard to
Advancement of Potential Regional Control Measures for Emission
Reduction from Appropriate Sources and State Attain Planning Purposes 
Directs the staff of the OTC to continue investigation and modeling work
associated with all potential regional control measures.

Feb. 23, 2006	Action Items Directs OTC staff to continue efforts on the
following issues:  Letter to EPA on Small Engines, Consumer Products,
Architectural/Industrial Maintenance Coatings (AIM), Chip Reflash,
Diesel Emissions Reductions, Modeling Efforts.

June 7, 2006	Memorandum of Understanding Among the States of the Ozone
Transport Commission on a Regional Strategy Concerning the Integrated
Control of Ozone Precursors from Various Sources  Commits OTC States to
continue to work with interested stakeholders and pursue state-specific
rulemakings as needed and appropriate regarding the following sectors to
reduce emission of ozone precursors: Consumer Products, Portable Fuel
Containers, Adhesives and Sealants, and Diesel Engine Chip Reflash.

June 7, 2006	Statement of the Ozone Transport Commission Concerning
Multi-Pollutant Emission Control of Electric Generating Units  Directs
OTC staff and its workgroups to continue to formulate a program beyond
CAIR to address emissions from this sector and to evaluate and recommend
options to address emissions associated with high electrical demand days
during the ozone season.

June 7 2006	Resolution 06-02 of the Ozone Transport Commission
Concerning Coordination and Implementation of Regional Ozone Control
Strategies for Certain Source Categories  Resolves that OTC States
continue to work with interested stakeholders and pursue state-specific
rulemakings as needed to establish emission reduction percentages,
emission rates or technologies as appropriate for the following source
categories: asphalt paving (cutback and emulsified), asphalt plants,
cement kilns, regional fuels, glass furnaces, and ICI boilers. 

June 7, 2006	Resolution 06-03 of the Ozone Transport Commission
Concerning Federal Guidance and Rulemaking for Nationally-Relevant Ozone
Control Measures  Resolves that OTC States request that EPA pursue
federal regulations and programs for national implementation of control
measures comparable to the levels the OTC has adopted; these areas
include AIM Coatings, Consumer Products, ICI Boilers over 100 MMBTU,
Portable Fuel Containers, Municipal Waste Combustors, Regional Fuels,
Small Engine Emission Regulation, and Gasoline Vapor Recovery.

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

Nov. 15, 2006	Statement of the Ozone Transport Commission Concerning
Regional and State Measures to Address Emissions from Mobile Sources 
Supports the aggressive implementation of a suite of controls through
the OTC Clean Corridor Initiative including: diesel retrofits, the
Smartways program, California Low Emission Vehicle programs, anti-idling
programs, low-NOx diesel alternatives, transportation demand management
to reduce the growth in VMT, and voluntary action and outreach programs.
 

Nov. 15, 2006	Addendum to Resolution 06-02 of the Ozone Transport
Commission Concerning Coordination and Implementation of Regional Ozone
Control Strategies for Various Sources  Resolves that OTC States
continue to pursue state-specific rulemakings as needed to establish
emission reduction percentages, emission rates or technologies as
appropriate for the following source categories: asphalt plants, glass
furnaces, and ICI boilers.

OTC formal actions can be found on the OTC website at the following
address:

  HYPERLINK "http://www.otcair.org/document.asp?fview=Formal" 
http://www.otcair.org/document.asp?fview=Formal  

Table A-2: OTC Control Measures Public Meetings, 2004-2006

Date	Meeting	Location

June 8-9, 2004	OTC/MANE-VU Annual Meeting	Red Bank, NJ

Nov. 9-10, 2004	OTC Fall Meeting	Annapolis, MD

Apr. 21-22, 2005	OTC Stationary and Area Source/Mobile Source Committee
Meeting	Linthicum, MD

June 7-8, 2005	OTC Annual Meeting	Burlington, VT

Oct. 5, 2005	OTC Control Strategy Committee Meeting	Linthicum, MD

Nov. 2-3, 2005	OTC Fall Meeting	Newark, DE

Jan. 24, 2006	OTC Control Strategy Committee Meeting	Linthicum, MD

Feb. 22-23, 2006	OTC Special Meeting	Washington, DC

Apr. 5-6, 2006	OTC Control Strategy Committee Meeting	Linthicum, MD

June 6-7, 2006	OTC Annual Meeting	Boston, MA

July 28, 2006	OTC/RTO/ISO Meeting	Herndon, VA

Sep. 18, 2006	OTC High Energy Demand Day Workgroup Meeting	Herndon, VA

Sep. 19, 2006	OTC Stationary and Area Source Committee Meeting	Herndon,
VA

Nov. 2, 2006	OTC Control Strategies and Stationary and Area Source
Committee Meeting	Linthicum, MD

Nov. 15, 2006	OTC Fall Meeting	Richmond, VA

Dec. 5-6, 2006	OTC High Energy Demand Day Workgroup Meeting	Hartford, CT

Meeting agendas and presentations can be found on the OTC website at the
following address:

  HYPERLINK "http://www.otcair.org/document.asp?fview=meeting" 
http://www.otcair.org/document.asp?fview=meeting   

Table A-4: Stakeholder Comments on OTC Control Strategies

Stakeholder	Source Category

  HYPERLINK ""  Adhesive and Sealant Council 	Adhesives and Sealants

National Paint & Coatings Association (  HYPERLINK ""  NPCA) 	Adhesives
and Sealants

  HYPERLINK ""  Ameron International 	AIM Coatings

  HYPERLINK ""  McCormick Paints 	AIM Coatings

  HYPERLINK ""  National Paint and Coatings Association (NPCA) 	AIM
Coatings

  HYPERLINK ""  Painting and Decorating Contractors of America (PDCA) 
AIM Coatings

  HYPERLINK ""  PROSOCO, Inc. 	AIM Coatings

  HYPERLINK ""  RUDD Company Inc. 	AIM Coatings

  HYPERLINK ""  TEX COTE 	AIM Coatings

  HYPERLINK ""  The Master Painters Institute (MPI) 	AIM Coatings

  HYPERLINK ""  The Society for Protective Coatings (SSPC) 	AIM Coatings

  HYPERLINK ""  Wank Adams Slavin and Associates, LLC (WASA) 	AIM
Coatings

  HYPERLINK ""  NAPA Asphalt Production 	Asphalt Production

  HYPERLINK ""  MATRIX Systems Auto Refinishing 	Auto Refinishing

  HYPERLINK ""  Portland Cement Association (PCA)  	Cement Kilns

  HYPERLINK ""  St Lawrence Cement 	Cement Kilns

  HYPERLINK ""  Consumer Specialty Products Association (CSPA) 	Consumer
Products

  HYPERLINK ""  Cosmetic, Toiletry and Fragrance Association (CTFA) 
Consumer Products

  HYPERLINK ""  National Paint & Coatings Association (NPCA) 	Consumer
Products

  HYPERLINK ""  Clean Air Task Force 	Diesel Retrofits

Center for Energy and Economic Development, Inc. (  HYPERLINK ""  CEED) 
EGUs

  HYPERLINK ""  Chesapeake Bay Foundation 	EGUs

  HYPERLINK ""  Clean Air Task Force 	EGUs

  HYPERLINK ""  Conectiv Energy 	EGUs

  HYPERLINK ""  Dominion 	EGUs

  HYPERLINK ""  Exelon 	EGUs

International Brotherhood of Electrical Workers , United Mine Workers of
America, Center for Energy & Economic Development, Inc., Pennsylvania
Coal Association	EGUs

  HYPERLINK ""  NRG 	EGUs

  HYPERLINK ""  PPL Services 	EGUs

  HYPERLINK ""  The Clean Energy Group 	EGUs

  HYPERLINK ""  National Lime Association (NLA) 	Lime Kilns

  HYPERLINK ""  Debra Jacobson, Prof. Lecturer in Energy Law 	NOx
Sources

  HYPERLINK ""  Flexible Packaging Association (FPA)s 	Printing/Graphic
Arts

  HYPERLINK ""  Graphic Arts Coalition Flexography Air Regulations 
Printing – Flexography

  HYPERLINK ""  Graphic Arts Coalition Printing & Graphic Arts 
Printing/Graphic Arts

  HYPERLINK ""  Graphic Arts Coalition Screen Litho Air Regulations 
Printing – Lithography

Stakeholder comments can be found on the OTC website at the following
address:

  HYPERLINK
"http://www.otcair.org/projects_details.asp?FID=95&fview=stationary" 
http://www.otcair.org/projects_details.asp?FID=95&fview=stationary  

Table A-4: OTC Conference Calls and Meetings with Stakeholders, 2006

Source Category	Date(s)	Industry Lead

Adhesives and Sealants	Aug. 30, 2006	Adhesives Council

Asphalt Paving	Mar. 30, 2006

Sep. 21, 2006

Sep. 28, 2006

Oct. 13, 2006	National Asphalt Paving Association (meeting)

National Asphalt Paving Association

Asphalt Emulation Manufacturers Association 

Asphalt Emulation Manufacturers Association

Asphalt Production	Oct. 25, 2006	National Asphalt Paving Association
(meeting)

Consumer Products	Mar. 24, 2006

June 22, 2006

June 22, 2006

Aug. 29, 2006	Consumer Specialty Products Association

American Solvents Council (meeting)

Consumer Specialty Products Association

Consumer Specialty Products Association

Glass Manufacturers	July 5, 2006

Aug. 16, 2006

Sep. 14, 2006

Oct. 19, 2006	North American Insulation Manufacturers Assoc.

North American Insulation Manufacturers Assoc.

Glass Association of North America

Glass Association of North America

ICI Boilers	Mar. 14, 2006

Mar. 24, 2006

July 18, 2006

Aug. 1, 2006	Council of Industrial Boiler Owners

Institute of Clean Air Companies

Council of Industrial Boiler Owners (meeting)

Council of Industrial Boiler Owners (conference)



Appendix B – Initial List of Control Measures

The comprehensive list of control measures can be found at:

  HYPERLINK "http://www.otcair.org"  http://www.otcair.org  

Appendix C – Control Measure Worksheets

This Appendix contains the Control Measure Summary Worksheets for the
following source categories:

Manufacture and Use of Adhesives and Sealants 

Architectural and Industrial Maintenance Coatings

Asphalt Paving (Emulsified and Cutback)

Asphalt Production Plants

Automotive Refinish Coatings

Cement Kilns

Chip Reflash (Heavy Duty Diesel Engines)

Consumer Products

Glass and Fiberglass Furnaces

Industrial, Commercial, Institutional Boilers

Industrial Surface Coatings – Fabric Printing, Coating, and Dyeing

Industrial Surface Coatings – Large Appliances

Industrial Surface Coatings – Metal Cans

Industrial Surface Coatings – Metal Coils

Industrial Surface Coatings – Metal Furniture

Industrial Surface Coatings – Miscellaneous Metal Parts

Industrial Surface Coatings – Paper and Web Coating

Industrial Surface Coatings – Plastics Parts

Industrial Surface Coatings – Wood Building Products

Industrial Surface Coatings – All Categories

Lime Kilns

Municipal Waste Combustors

Printing and Graphic Arts

Portable Fuel Containers

Reformulated Gasoline

CONTROL MEASURE SUMMARY

Manufacture and Use of Adhesives and Sealants 

(SCC- 2440020000)

Control Measure Summary

The provisions of this model rule limit emissions of volatile organic
compounds (VOCs) from adhesives, sealants and primers.  The model rule
achieves VOC reductions through two basic components: sale and
manufacture restrictions that limit the VOC content of specified
adhesives, sealants and primers sold in the state; and use restrictions
that apply primarily to commercial/industrial applications.  By reducing
the availability of higher VOC content adhesives and sealants within the
state, the sales prohibition is also intended to address adhesive and
sealant usage at area sources.  Emissions from residential use of
regulated products are addressed through the sales restrictions and
simple use provisions.  

A reasonably available control technology determination prepared by the
California Air Resources Board (CARB) in 1998 forms the basis of this
model rule.  In the years 1998-2001, the provisions of the CARB
determination were adopted in regulatory form in various air pollution
control districts in California including the Bay Area, South Coast,
Ventura County, Sacramento Metropolitan and San Joaquin Valley.

Costs and Emissions Reductions

2002 existing measure:  No existing limitations for this category

Candidate measure:  Approximately 75% of VOC emissions originate from
solvent-based adhesives and sealants, the remaining 25% of VOC in this
category are due to water-based materials. VOC content limits have been
enacted by various APCD in California from 1998 to 2001.

Emissions reductions: VOC content limits for the solvent-based materials
can result in 64.4% reduction in total emissions from this category.
(CARB RACT/BARCT for Adhesives/ Sealants, Dec 1998)

Control costs:  Costs for control by reformulation are estimated by the
CARB at less than $2500 / ton (1999$).  Many manufacturers have either
reformulated solvent-based products to reduce the VOC content or have
developed low-VOC water-based latex and acrylic products, or
polyurethane or silicone products in response to the adoption of similar
regulations in California.  Thus, the actual costs in the OTC region are
anticipated to be lower.  

Estimated costs for add-on controls carbon and thermal oxidizers ranged
from $10,000 to $100,000 per ton.  

Timing of implementation: 01/01/09

Implementation area:  Region-wide	Annual VOC

2002 Emissions: 35,489 tpy

2009 Emissions: 46,241 tpy

2009 Reduction: 29,438 tpy

2009 Remaining: 16,803 tpy

Summer VOC

2002 Emissions:  99.8 tpd

2009 Emissions: 129.8 tpd

2009 Reduction:  82.3 tpd

2009 Remaining:  47.5 tpd





Interaction with other OTC Model Rules

The products regulated in this model rule do not overlap with the
products regulated by either the architectural and industrial
maintenance (AIM) or consumer product rules.  A “coating,” as
contemplated in the AIM rule, is a “material applied onto or
impregnated into a substrate for protective, decorative or functional
purposes.”  Because the coating is applied only to one substrate, it
is clearly distinguished from adhesives and sealants, which are defined
in both the consumer product and adhesive rules by application to two
surfaces; in the case of adhesives, the two surfaces are directly bonded
while in the case of sealants, a gap between two surfaces is filled.  

The overlap between the consumer product and adhesive rules is addressed
mainly by an exemption in the adhesive rule for adhesives and sealers
subject to the state’s consumer products regulation.

Reference:

California Air Resources Board.  Determination of Reasonably Available
Control Technology and Best Available Retrofit Technology for Adhesives
and Sealants.  December 1998.  Page 18 provides the emission reduction
estimates for California: the ARB emission inventory estimates 45 tons
per day pre-rule; reductions will range from approximately 29 to 35 tons
per day.  We used the low end of this range to calculate the percent
reduction of 64.4% (i.e. 29 tpd/45 tpd).  Page 17 provides the
cost-effectiveness information:  the cost of complying with the
determination reflects the cost of using alternative formulations of
low-VOC or water-based adhesives, sealants, and cleanup products. 
Ventura County APCD staff determined that the cost-effectiveness of
their adhesives rule ranges from a savings of $0.53 per pound to a cost
of $1.16 per pound of VOC reduced ($1,060 to 2,320). The use of add-on
control equipment to comply was $4.50 to $55.00 per pound ($9,000 to
$110,000).





CONTROL MEASURE SUMMARY FOR    

AIM Coatings

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

2001 existing measure:  Federal AIM rules 40CFR Part 59 

Emission Reductions:  20% reduction from uncontrolled levels

Control Cost:  $228 per ton 

Timing of Implementation:  Compliance required by September 1999

Implementation Area:  Nationwide	VOC (with Part 59 limits)

2002 OTR total:    124,173



2009 On-the-Way Measure:  OTC Model Rule based on a model rule adopted
by the California Air Resources Board (CARB) in June, 2000 for 33 air
control districts. 

Emission Reductions:  31% beyond Federal AIM rule 

Control Cost:  $6,400 per ton 	VOC (After OTC Model Rule)

2009 Reduction:    -25,150

2009 Remaining:    99,023

Candidate measure: Follow CARB 2007 Rulemaking.  Modify rule as
appropriate when complete (in time for 2009) Participate actively in
CARB process.  Conduct survey in 2006 for 2005 sales data. 

Emission Reductions :  6% emissions reduction

For modeling purposes we split the difference between SCAQMD and OTC
model rule. But we go 75% of the way toward SCAQMD on the top four sales
products, and set a 250 g/l VOC limit for Industrial Maintenance
coatings. The reductions are calculated using the “reg neg”
spreadsheet.

Control Cost:  Cost of OTC Survey (revise with cost data from the future
CARB SCM when available in 2007)  SCAQMD estimated the overall
cost-effectiveness for their 1999 Amendments to $13,317 per ton.  For
Dec. 5 2003 amendments to Rule 1113, SCAQMD estimated the
cost-effectiveness to be in the range of $4,229 to $11,405 per ton

Timing of Implementation: 01/01/09

Implementation Area:  Throughout OTR and MRPO	VOC (After CARB 2007 Rule)

2009 Reduction:    -5,941

2009 Remaining:   93,082



REFERENCES:

2002 Existing Measure (Federal Part 59 Rules):

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation
Report, September 2005.  Pages III-1347 and III-1348 shows the 20%
reduction for the Federal Part 59 rule at a cost of $228 per ton
(1990$). 

2009 On-the-Books Measure (OTC Model Rule):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001. 
Table II-6 shows 31% reduction (OTC Model Rule beyond Federal rule). 
Page 15 presents cost of $6,400 per ton based on CARB’s 2000 Staff
Report for the Suggested Control Measure for Architectural Coatings. 

Candidate Measure (CARB 2007 Suggested Control Measure):

CARB is in the process of updating the 2000 Suggested Control Measure
(SCM) for Architectural Coatings this year.  They will be using 2004
survey data as an important resource to update the SCM, but will not
begin the formal SCM update process until the survey is completed. They
anticipate bringing the SCM update to our Board in mid to late 2007.

CARB is developing an analysis of costs for implementing an updated
it’s Suggested Control Measure.  Results of the analysis will not be
available until 2007.  

Cost information for the South Coast Phase rules were obtained from: 

South Coast Air Quality Management District.  Final Staff Report for
Proposed Amended Rule 1113 – Architectural Coatings.  December 5,
2003.  “estimated the cost-effectiveness to be in the range of $4,229
to $11,405 per ton of VOC reduced. The low end of the range was
determined based on the retail cost of compliant coatings reported by
coating manufacturers surveyed by staff. The upper end of the range was
derived by estimating the increased cost at the retail level due to the
increase in cost of raw materials, reformulation, testing and packaging
a new product prior to commercialization.”  The Dec. 2003 amendments
lowered the VOC limit for the following specialty coating categories:
clear wood finishes including varnishes and sanding sealers, roof
coatings, stains, and waterproofing sealers including concrete and
masonry sealers.  

South Coast Air Quality Management District.  Appendix F Addendum to
Staff Report, Final Socioeconomic Impact Assessment, Proposed Amendments
to Rule 1113.  May 1999.  The May 1999 amendments to Rule 1113 lower VOC
limits for the coating categories of industrial maintenance; non-flats;
primers, sealers, and undercoaters; quick-dry enamels; quick-dry
primers, sealers, and undercoaters; roof coatings; floor coatings, rust
preventative coatings, stains, and waterproofing wood sealers.  The
overall cost-effectiveness of the proposed amendments, (total
costs/total emission reductions) over the years 2002-2015, is estimated
to be $13,317 per ton.   





CONTROL MEASURE SUMMARY FOR EMULSIFIED AND CUTBACK ASPHALT PAVING    

Control Measure Summary: OTC Regional Ban on Cutback Asphalt in Ozone
Season, with lower VOC/Solvent Contents for Emulsified Asphalt. 	VOC
Emissions in 

Ozone Transport Region

2002 existing measures:  

1. Cutback asphalt: The OTC states typically ban the use of cutback
asphalt during the ozone season.  States do provide various exemptions
to the ban, most notably  allowances may be made for cutbacks which
contain less than 5% VOC.  

2. Emulsified asphalt:  Ten of the OTC states regulate emulsified
asphalt by providing allowable VOC content limits for the various
applications.  Three of the states do not address emulsified asphalts in
their regulation.

Control Cost:  According to the 1977 CTG (EPA-450/2-77-037), which
formed the basis for the existing regulations, the use of emulsified
asphalts (no VOC) presented a cost savings. 

Timing of Implementation: All regulations implemented in 1990s or
earlier under the 1-hour ozone standard.

Implementation Area:  OTC 1-hour ozone non-attainment areas.	

Annual VOC 

2002 cutback:    9,154 tpy

2002 emulsified:  10,379 tpy

2002 total:  19,533 tpy

Summer VOC

2002 cutback:  17.5 tpd

2002 emulsified:  38.5 tpd

2002 total:        56.0 tpd



Candidate measure: For cutback asphalt paving

Measure ID: BOTW09-AP-Cutback

Place a complete prohibition on the use of cutback asphalt during the
ozone season.

Emission Reductions: to be achieved from using lower VOC content
emulsified asphalt products or working outside the ozone season. 

Control Cost:  Negligible.

Timing of Implementation:  01/01/09

Implementation Area: All OTC 8-hour ozone non-attainment counties or
individual state-wide.	

Summer VOC

2009 OTB:  19.9 tpd

2009 Reduction:  19.9 tpd

2009 Remaining:   0.0 tpd



Candidate measure: For emulsified asphalt paving

Measure ID: BOTW09-AP-Emulsified

Proposes to limit ozone season use of emulsified asphalt to that which
contains not more than 0.5 ml of oil distillate from the 200 mL sample
using the ASTM D244 test method regardless of application (which is
0.25% VOC by volume)

Emission Reductions: to be achieved from using lower VOC content
emulsified asphalt products or working outside the ozone season.  

Control Cost:  Negligible

Timing of Implementation:  01/01/09

Implementation Area: All OTC 8-hour ozone non-attainment counties or
individual state-wide.	

Summer VOC

2009 OTB:  44.2 tpd

2009 Reduction:   39.9 tpd

2009 Remaining:  4.3 tpd

d



Control Measure Recommendation:  

States implement most stringent measure possible to achieve VOC
reductions by 2009 from OTB projections in OTC states, with out
disrupting state and county paving operations.



Brief Rationale for Recommended Strategy: 

(1) Delaware already implements and complies with the most stringent
proposed control strategy.  

(2) The control strategy is supported by the 1977 Control Techniques
Document EPA-450/2-77-037.

CONTROL MEASURE SUMMARY FOR 

Asphalt Production Plants 

Control Measure Summary: NOx emission reductions can be obtained through
installation of low NOx burners and flue gas recirculation.  SO2 can be
reduced by reducing the sulfur in fuel limits for distillate oil to 500
ppm.	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  No existing limitations for this specific
category have been identified.

	2002 NOx Base:

2002 SO2 Base:	827

847

Candidate Measure:  

Emission Reductions: NOx can be reduced between 35% to 50% with low NOx
burners and flue gas recirculation (FGR).  SO2 can be reduced 25% to 75%
by reducing the sulfur in fuel limits for distillate oil to 500 ppm.

The MANEVU data for this category is incomplete.  Only major point
sources are typically included in the point source database.  Non-major
source emissions are likely lumped into the area source inventory with
other industrial/commercial boilers/heaters.  The point source data
projects only 800+ tons per year (TPY) of both NOx and SO2 actual
emissions in 2002 for the entire region.  New York actual emissions are
over 600 TPY of NOx and 400 TPY of SO2.  Therefore, it is unknown what
the actual reductions will produce as no accurate baseline exists for
both major and minor facilities.

Control Cost:  Costs for control are similar to those of small to
midsize boilers or process heaters.  Low NOx burners range from $500 to
$1250 per ton.  While Low NOx burners in combination with FGR range from
$1000 to $2000 per ton.

Projected cost increase from lowing sulfur in distillate oil is
approximately 2 to 3 cents per gallon.

Timing of Implementation: Similar to the NOx RACT procedures of 1994. 
Require a NOx compliance plan by the spring of 2008 with full
implementation and compliance within one year (01/01/09).

 

Unknown for sulfur-in-fuel reductions.

 

Implementation Area:  Region-wide

	NOx

2009 Base:

2009 Reduction:

2009 Remaining:

SO2  

2009 Base:

2009 Reduction:

2009 Remaining:

	

1,276

-549

727

1,266

-950

316



Recommended Strategy: States should support rules that encourage a
combination of Best Management Practices, Low NOx Burners and FGR in
asphalt production plants to achieve a 20-35% reduction in NOx emissions
form a 2002 base, and encourage the use of low-sulfur oil.  

Area source emissions from asphalt plants are not included in this
summary.



REFERENCES:

Note: The reductions estimated for this category only include emissions
from point sources.  Area source emissions from fuel combustion at
asphalt production plants are not explicitly contained in the area
source emissions.  These emissions are likely lumped together in the
general area source industrial and commercial fuel use category. 
Reductions from area source emissions at asphalt production plants are
included in the ICI boiler source category.





Candidate Measure (Low NOx Burners plus FGR; low sulfur fuel oil):

The emission reduction estimates and cost-effectiveness data were
provided by NYSDEC.  These control efficiencies and cost-effectiveness
estimates for Low NOx Burners plus FGR are generally consisten with the
data presented in E.H. Pechan & Associates, Inc., AirControlNET Version
4.1: Documentation Report, September 2005.  Information in this report
for small oil-fired process heaters and ICI boilers provide similar
levels of control and cost-effectiveness.



Candidate Measure (Best Management Practices)

Best Practices to Reduce Fuel Consumption and/or Lower Air Emissions:
HMA industry leaders have identified a number of Best Practices that, if
implemented, allow for substantial reduction in plant fuel consumption
and the corresponding products of combustion including NOx. In today’s
business environment, there is significant incentive to reduce fuel
usage.  For this reason, implementing best practices to reduce fuel
consumption and NOx emissions, forms the basis of a sustainable
strategy.

Effective stockpile management to reduce aggregate moisture content:
Current information indicates that effective stockpile management can
reduce aggregate moisture content by about 25 percent, corresponding to
a reduction in fuel consumption by approximately 10 - 15 percent. There
are a number of ways to reduce aggregate moisture: covering stockpiles,
paving under stockpiles, and sloping stockpiles are all ways that
prevent aggregate from retaining moisture. Best Practices are plant- and
geographic locale-specific.

Burner tune-ups: As identified in OTC Resolution 06-02 and companion
control measures summaries, a burner tune-up may reduce NOx emissions by
up to 10 percent. From a contractor’s perspective, this also is
helpful in reducing fuel consumption. In other words, there can be a
direct pay-back to the business from regular burner tune-ups.

Lowering mix temperature: A Technical Working Group of FHWA is currently
investigating a number of newer formulation technologies, to understand
the practicality and performance of lowering mix temperatures.
Substantial reductions in mix temperatures, on the order of 20 percent
or more, appear to be plausible. Lowering mix temperatures, by this
amount, may reduce fuel consumption, as less heat is needed to produce
the mix.

Other maintenance and operational best practices: Additional practices
can be employed throughout the plant to help optimize production and
operations. For example, regular inspection of drum mixing flites and
other measures can be taken – all in the effort to make a plant
operate more efficiently, thereby using less fuel.







Plant Type	Emission Rate 

(lbs NOx/ton asphalt produced)	% Reduction

Area/Point Sources (State emissions option)



   Batch Mix Plant – Natural Gas	0.02	35

   Batch Mix Plant – Distillate/Waste Oil	0.09	35

   Drum Mix Plant – Natural Gas	0.02	35

   Drum Mix Plant – Distillate/Waste Oil	0.04	35

Area/Point Sources (State technology option)



   Batch/Drum Mix Plant – Natural Gas	Low-NOx Burner Technology 

and/or Best Management Practices

   Batch/Drum Mix Plant – Distillate/Waste Oil	Low-NOx Burner
Technology 

and/or Best Management Practices



CONTROL MEASURE SUMMARY FOR 

Auto Refinish Coatings – Area Source

Control Measure Summary: Limiting the concentration of solvents in Auto
Refinishing Coatings in order to reduce VOC emissions. Encourage the use
of high transfer-efficiency painting methods (e.g., high volume low
pressure spray guns), and controls on emissions from equipment (e.g.,
spray gun) cleaning, housekeeping activities (e.g., use of sealed
containers for clean-up rags), and operator training.	Emissions
(tons/year) in Ozone Transport Region

2002 existing measure:  Federal Auto Body Refinishing rules 40CFR Part
59 Subpart B

Emission Reductions:  37% reduction from Part 59 (from Pechan OTC Model
Rule Report) due to Part 59 VOC content limits

Control Cost:  $118 per ton for Part 59 rules 

Timing of Implementation:  Part 59 compliance required by January 1999

Implementation Area:  Part 59 – Nationwide;	VOC Uncontrolled:

2002 Reduction:

2002 Base:	

50,759

-18,781

31,978

OTB Control Measure:  OTC Model Rule for Mobile Equipment Repair and
Refinishing

Emission Reductions:  38% reduction from 2002 Levels in those States
that adopted OTC model Rule (per Pechan March 31, 2001 OTC Model Rule
Report)

Control Cost:  $1,534 per ton of VOC

Timing of Implementation: Assuming 2007 effective date of rule, emission
reductions are achieved 01/01/09.

Implementation Area: All counties in the OTR.

	VOC:

2009 Reduction:

2009 Remaining:	

-10,468

21,510

Candidate measure:  CARB October 20, 2005 SCM Staff Report – Lowers
VOC limits, combines coatings categories, simplifies recording.

Emission Reductions: CARB estimates a 65% reduction in VOC emissions
from a 2002 baseline; the OTC model rule is very similar to the CARB
2002 baseline, so a similar reduction would be expected in the OTR.

Control Cost:  $2,860 per ton

Timing of Implementation: Assuming 2007 effective date of rule, emission
reductions are achieved in beginning 01/01/09.

Implementation Area: All counties in the OTR.

	VOC:

2009 Reduction:

2009 Remaining:	

-13,981

7,529



REFERENCES:

2002 Existing Measure (Federal Part 59 Rules):

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation
Report, September 2005.  Pages III-1364 shows the Federal Part 59 rule
at a cost of $118 per ton (1990$) and a reduction of 37 percent from
uncontrolled levels. 

2009 On-the-Books Measure (OTC Model Rule):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001. 
Table II-6 shows 37% reduction for Federal Part 59 rule and 38% (OTC
Model Rule beyond Federal rule).  Page 17 presents cost of $1,534 per
ton based on estimates used for PA Rule 129.75.

Candidate Measure (CARB 2005 Suggested Control Measure):

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

The OTC Model Rule coating categories and VOC limits are:

OTC Model Rule

Limit

Coating Type

Grams per Liter

Pounds per gallon

Automotive pretreatment primer

780

6.5

Automotive primer-surfacer	

575

4.8

Automotive primer-sealer

550

4.6

Automotive topcoat:	

single stage-topcoat

600

5.0

2 stage basecoat/clearcoat

600

5.0

3 or 4-stage basecoat/clearcoat

625

5.2

Automotive Multi-colored Topcoat	

680

5.7

Automotive specialty

840

7.0





CONTROL MEASURE SUMMARY FOR 

Cement Kilns

Control Measure Summary:	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  NSR; PSD; State RACT.  

 	 NOx

2002 Base:	

31,960

On the Books:  NOx SIP Call

Measure ID: NOx SIP Call 

Emission Reductions:  The SIP Call requirements were estimated by EPA to
result in NOx reductions of approximately 25 percent from the cement
industry.

Control Cost:  $2,000 per ton  

Timing of Implementation:  2004

Implementation Area:  OTR 	NOx

2009 Base:

2009 Reduction:

2009 Remaining:

	

31,960

-7,990

23,970

Candidate measure:  Use of proven control technologies (such as SNCR) or
other methods to meet recommended emission limits.

Emission Reductions:  source specific, varies from 0-63% based upon 2002
base rates.

Control Cost:  less than 2,500 per ton

Timing of Implementation:  01/01/09

Implementation Area:  OTR	                   NOx

2009 Base:

Candidate Reduction:

2009 Remaining:	

31,960

-13,231

18,279



Policy Recommendation:  It is recommended that a program be developed
reduces NOx emissions from existing cement kilns by requiring existing
kilns to meet a NOx emission rate of

3.88 lbs/ton clinker for wet kiln

3.44 lbs/ton clinker for long dry kiln

2.36 lbs/ton clinker for pre-heater kiln

1.52 lbs/ton clinker for pre-calciner kiln.  

Trading between facilities would not be permitted, but averaging at a
facility would be permissible.     

Brief Rationale for Recommended Strategy:  This limit is consistent with
the emission reduction capabilities of SNCR.  There are 18 full-scale
SNCR installations in Europe.  

REFERENCES

EC/R Incorporated.  NOx Control Technologies for the Cement Industry –
Final Report. September 19, 2000.  This report for EPA shows data for
two SNCR technologies, biosolids injection and NOXOUT®. These
technologies showed average emission reductions of 50 and 40 percent,
respectively.  For biosolids injection, “Cost effectiveness for this
kiln is based on the annualized costs of ($320,000/year), the emission
reduction achieved at that facility (emissions decreased from 2.4 lb/ton
of clinker to 1.2 lb/ton of clinker), a kiln capacity of 215 tons/hr,
and an annual operation of 8,000 hr/yr. Cost effectiveness is a credit
of ($310/ton) for installing biosolids injection on this kiln” due to
tipping fee for using biosolids (dewatered sewage sludge)  For NOXOUT®,
“40 percent NOX reduction based on the available test data. Cost
effectiveness for the two kilns, using urea as the reagent, is based on
an uncontrolled emission rate of 3.8 lb NOX/ton of clinker, kiln
capacities of 92 and 130 tons/hr respectively, annual operation of 8,000
hr/yr, and a NOX control efficiency of 40%. Cost effectiveness is
$1,000/ton for the smaller kiln and $2,500/ton for the larger kiln.”

European Commission.  Integrated Pollution Prevention and Control (IPPC)
Reference Document on Best Available Techniques in the Cement and Lime
Manufacturing Industries.  December 2001.  These report indicates that
there are 18 full-scale SNCR installation in Europe.  Most SNCR
installations are designed and/or operated for NOx reduction rates of
10-50% which is sufficient to comply with current legislation in some
countries.  Two Swedish plants installed SNCR in 1996/97 and have
achieved a reduction of 80-85% at both kilns.



Emission Rates:

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

Kiln Type	Heat Input Requirement 

(mmBtu/ton of clinker)	Average NOx Uncontrolled Emission Rate 

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

(lb/ton of clinker)

Wet 	6.0	9.7	3.6 to 19.5

Long Dry	4.5	8.6	6.1 to 10.5

Preheater	3.8	5.9	2.5 to 11.7

Precalciner	3.8	3.8	0.9 to 7.0



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

Kiln Type	Percent Reduction from Uncontrolled	Low-End NOx Controlled
Emission Rate 

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

(lb/ton of clinker)	High-End NOx Controlled Emission Rate 

(lb/ton of clinker)

Wet 	60	1.44	3.88	7.80

Long Dry	60	2.44	3.44	4.20

Preheater	60	1.00	2.36	4.68

Precalciner	60	0.36	1.52	2.80



The State/workgroup lead recommended the use of the the average NOx
Controlled emission rates in the above table (expressed as lb/ton of
clinker). 

CONTROL MEASURE SUMMARY FOR 

Chip Reflash

Control Measure Summary: Upgrade the version of software in engine
electronic control module (ECM) aka “Chip Reflash”. Software
reprograms the vehicle's computer and reduces off-cycle NOx emissions.
The installation process typically takes between one-half to one hour.
Emissions Reductions (tons/day) 

2002 existing measure:  

No existing measure in the OTR other than the EPA program resulting from
the consent decrees on 7 heavy duty engine manufacturers.  The results
of the EPA program thus far are significantly lower than the level
originally projected by the Agency (less than 10% implementation). CARB
implemented a voluntary program that did not achieve its expected
results, so the Board’s backstop mandatory program was triggered. The
CARB mandatory program is facing two separate legal challenges, alleging
that CARB has breached its settlement agreement and alleging that CARB
is illegally establishing different emissions standards on “new
engines”.



Candidate measure:  

Measure ID: Model rule for Mandatory Chip Reflash Program in the OTR

Emission Reductions:  NOx reduction (TPD) from in-state registered
vehicles

Control Cost:  Moderate – manufacturers must provide the rebuild kits
free to any truck operator who requests it.  The cost associated with
the reflash has been estimated at $20-$30 per vehicle, which is borne by
the engine manufacturer.  There may be costs associated with potential
downtime to the trucking firms, and record-

keeping requirements on the dealer performing the reflash and the
vehicle owner. For the MRPO, ENVIRON estimated cost effectiveness to be
“$1,800 to $2,500 (depending on vehicle size) due to incremental
“fuel penalty” of 2% increase in fuel consumption).  However, in
reality, no fuel penalty has been documented on vehicles that have
already been reflashed.

Timing of Implementation: The kits are currently available, so once the
states adopt the rule, retrofits can begin according to the schedule. 

Implementation Area: All OTR and MRPO states (NOx reductions 109 TPD)	

LADCO

Northeast

states

Mid-Atlantic

States

Total OTR

	

46 TPD

41 TPD

22 TPD

63 TPD

Policy Recommendation of State/Workgroup Lead:  Expand scope of the
model rule for the Northeast states to the entire OTR and MWRPO 



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





CONTROL MEASURE SUMMARY FOR 

Consumer Products

Control Measure Summary: Consumer Products

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

2002 Existing Measure: The Federal Consumer Products Rule Part 59 

Emission Reductions:  20 % reduction of the categories being regulated
or 9.95 % reduction of the entire consumer products inventory (about 40
% of products were included in rule).

Control Cost:  $237 per ton of VOC reduced

Timing of Implementation: 12/98

Implementation Area: Nationwide 	2002 Annual

Uncontrolled:

Reduction:

Remaining:

2002 Summer

Uncontrolled:

Reduction:

Remaining:	

258,537 tpy

25,724 tpy

232,813 tpy

713.9 tpd

71.0 tpd

642.9 tpd

2009 On-the-Books Measure: Adopt the 2001 OTC Model Rule for Consumer
Products in all OTC states (this model rule was based on a series of
five CARB consumer products rules).

Emission Reductions:  14.2 % beyond federal rule or a total of 21 % from
the uncontrolled state. 

Control Cost: $800 per ton VOC reduced 

Timing of Implementation:  1/1/05 effective date of VOC limits (though
some states were later and some have yet to adopt)

Implementation Area: OTR	2009 Annual

Reduction:

Remaining:

2009 Summer

Reduction:

Remaining:	

22,916 tpy

209,897 tpy

63.4 tpd

579.5 tpd

Candidate Measure #1: Adopt the CARB amendments to their consumer
products rule, adopted 7/20/05, with the exception of the 12/31/09
shaving gel, and 12/31/08 anti-static aerosol VOC limits.  This rule
sets new VOC limits for 11 categories, revises the existing VOC limit
for 1 category and includes some additional requirements.  See more
detailed limits below.

Emission Reductions:  CARB estimates their rule will achieve a 6.3
ton/day reduction of VOC in California, which is equivalent to about
11.3 tons per day in the OTR or a 2% reduction beyond the on-the-books
measure.  

Control Cost: $4,800 per ton of VOC reduced 

Timing of Implementation: 01/01/09 

Implementation Area OTR	2009 Annual

Reduction:

Remaining:

2009 Summer

Reduction:

Remaining:	

7,453 tpy

202,444 tpy

20.6 tpd

558.9 tpd 

Candidate Measure #2:  Follow and adopt as appropriate CARB ‘s next
round of amendments  to their consumer products rule, to be developed
and proposed by approximately late 2006/early 2007 with limits effective
in 2010.  

Emission Reductions: The CONS-2 amendments are estimated by CARB to
achieve VOC reductions of about 20-35 tpd in California by 2010 which is
equivalent to about 36-63 tpd in the OTR (The mid-point of this range
was used in the calculations, 49.5 tpd).

Control Cost:  Unknown at present; 

Timing of Implementation: 01/01/10 

Implementation Area OTR	VOC not modeled:

2009 Annual

Reduction:

Remaining:

2009 Summer

Reduction:

Remaining:	

Not Available





Summary of Candidate Measure #1:  The proposed VOC limits based on
CARB’s 7/20/05 amendments are as follows:





Summary of Candidate Measure #1:  The proposed VOC limits based on
CARB’s 7/20/05 amendments are as follows:



PRODUCT CATEGORY

CARB VOC CONTENT LIMIT %

OTC PROPOSED CONTENT LIMIT%

CARB EFFECTIVE DATE

OTC

PROPOSED EFFECTIVE DATE

Adhesive, Contact – General purpose *

55

55

12/31/2006

1/1/2009

                                  Special Purpose*

80

80

12/31/2006

1/1/2009

Adhesive Remover - Floor or Wall covering

5

5

12/31/2006

1/1/2009

                                  Gasket or Thread Locking

50

50

12/31/2006

1/1/2009

                                  General Purpose

20

20

12/31/2006

1/1/2009

                                   Specialty

70

70

12/31/2006

1/1/2009

Anti-static - non-aerosol

11

11

12/31/2006

1/1/2009

Electrical Cleaner

45

45

12/31/2006

1/1/2009

Electronic Cleaner

75

75

12/31/2006

1/1/2009

Fabric refresher – aerosol

15

15

12/31/2006

1/1/2009

                      non-aerosol

6

6

12/31/2006

1/1/2009

Footware or Leather Care  - aerosol

75

75

12/31/2006

1/1/2009

                                              Solid

55

55

12/31/2006

1/1/2009

                                      all other forms

15

15

12/31/2006

1/1/2009

Graffiti Remover –aerosol

50

50

12/31/2006

1/1/2009

                       non-aerosol

30

30

12/31/2006

1/1/2009

Hair Styling Products – aerosol & pump sprays

6

6

12/31/2006

1/1/2009

                               all other forms

2

2

12/31/2006

1/1/2009

Shaving Gel

7

7

12/31/2006

1/1/2009

Toilet/Urinal Care – aerosol

10

10

12/31/2006

1/1/2009

                         non-aerosol

3

3

12/31/2006

1/1/2009

Wood Cleaner – aerosol

17

17

12/31/2006

1/1/2009

                   non-aerosol

4

4

12/31/2006

1/1/2009

* Change to an existing category





References:

2002 Existing Measure (Federal Part 59 Rules):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001.

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation
Report, September 2005.  Pages III-1377 shows the Federal Part 59 rule
at a cost of $237 per ton (1990$). 

2009 On-the-Books Measure (OTC Model Rule):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001. 
Table II-6 shows 14.2% reduction (OTC Model Rule beyond Federal rule). 
Page 8 presents cost of $800 per ton based on CARB’s Sept. 1999
Initial Statement of Reasons for Proposed Amendments to the California
Consumer Products Regulation.

Candidate Measure #1 (CARB 2005 and 2006/2007 Amendments):

California Air Resources Board.  Initial Statement of Reasons for
Proposed Amendments, Volume 1: Executive Summary.  June 24, 2004.  Table
2 of the Executive Summary shows that the CONS-1 amendments will achieve
reductions of about 6.8 tons per day state wide (6.3 tons per day
without the 12/31/09 Shaving gel, and 12/31/08 anti-static aerosol
regs..  Page 21 states the cost of CONS-1 will be $2.40 per pound
($4,800 per ton).  Since OTC’s model rule is very similar to the
CARB’s rule, and emissions are proportional to population, CARB’s
6.3 ton per day reduction was prorated to the OTC region based on the
ratio of OTR 2002 population (63 million) to CA 2002 population (35
million) yielding approximately 11.3 tons per day in the OTR (4,139 tons
per year).

Page 4 states that the estimated reductions from CONS-2 (not yet
proposed) will achieve 20-35 tons per day statewide by 2010.  Since
OTC’s model rule is very similar to the CARB’s rule, and emissions
are proportional to population, the mid-point of CARB’s 20-35 ton per
day reduction (i.e., 27.5 tons per day) was prorated to the OTC region
based on the ratio of OTR 2002 population (63 million) to CA 2002
population (35 million) yielding approximately 49.5 tons per day in the
OTR (18,068 tons per year).





CONTROL MEASURE SUMMARY FOR 

Glass/Fiberglass Furnaces

Control Measure Summary:	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  NSR; PSD; State RACT.  

	 NOx

2002 Base:	

18,840

Candidate measure:  Use of oxyfiring or other methods to meet
recommended emission limits.

Emission Reductions:  source specific, varies from 0-85% depending upon
2002 base rates.

Control Cost:  $ 924 to 2,232 per ton  

Timing of Implementation:  01/01/09

Implementation Area:  OTR 	NOx

2009 projected:

Reduction at full implementation:

Remaining after full implementation:

	

21,893

-13,474

8,419



Control Measure Recommendation:  Develop a control strategy that
requires implementation of an “oxyfiring” program for each furnace
at the next furnace rebuild.  Alternatively, states may allow
manufacturers to propose compliance methods based on California’s San
Joaquin Valley Rule 4354 which allows a mix of control options to meet
specified emission limits.  Prior to furnace rebuild, owners/operators
may be allowed, by the state, to meet emissions limits by purchasing a
state specified number of NOx allowances. Continuous emission monitoring
systems would be used to determine emissions.  This Measure should be
modeled at 85% reduction.



Brief Rationale for Recommended Strategy:  Oxyfiring is best
implemented, and provides the most effective NOx emission reductions,
with a complete furnace rebuild.  This strategy not only reduces NOx
emissions by as much as 85 percent, but reduces energy consumption,
increases production rates by 10-15%, and improves glass quality by
reducing defects.  Oxyfiring is demonstrated technology and has
penetrated into all segments of the glass industry.

REFERENCES

European Commission, Integrated Pollution Prevention and Control (IPPC)
Bureau.  Reference Document on Best Available Techniques in the Glass
Manufacturing Industry.  December 2001.  This document reports 75 to 85%
reduction in NOx and emission rates of 1.25 to 4.1 lbs NOx/ton.  The
cost effectiveness was determined to be $1,254 to $2,542 depending on
the size of the furnace.

U.S. EPA Alternative Control Techniques Document – NOx Emissions from
Glass Manufacturing, EPA-453/R-94-037, June 1994.  Oxyfiring reduction
of 85%, cost-effectiveness of $2,150 to $5,300.



Emission rates based on San Joaquin Valley Rule 4354 

Type of Furnace	Block 24-hour Average	Rolling 30-day average

   Container Glass	4.0 pounds of NOx per ton of glass pulled	4.0 pounds
of NOx per ton of glass pulled

   Fiberglass	4.0 pounds of NOx per ton of glass pulled	4.0 pounds of
NOx per ton of glass pulled

   Flat Glass	9.2 pounds of NOx per ton of glass pulled	7.0 pounds of
NOx per ton of glass pulled



CONTROL MEASURE SUMMARY FOR 

Industrial, Commercial, Institutional (ICI) Boilers – Jointly
processed with MANE-VU

Addendum to OTC Resolution 06-02 Guidelines for ICI Boilers

ICI Boiler Size

(mmBtu/hr)

	Control Strategy/

Compliance Option	NOx Control Measure

5-25

Annual Boiler Tune-Up

25-100	Option #1	Natural Gas:           0.05 lb NOx/mmBtu

#2 Fuel Oil:            0.08 lb NOx/mmBtu

#4 or #6 Fuel Oil:   0.20 lb NOx/mmBtu

Coal:                       0.30 lb NOx/mmBtu**

	Option #2	50% reduction in NOx emissions from uncontrolled baseline

	Option #3	Purchase current year CAIR NOx allowances equal to reducted
needed to acheiv the required emission rates

100-250	Option #1	Natural Gas:            0.10 lb NOx/mmBtu

#2 Fuel Oil:             0.20 lb NOx/mmBtu

#4 or #6 Fuel Oil:    0.20 lb NOx/mmBtu

Coal:

     Wall-fired           0.14 lb NOx/mm Btu

     Tangential           0.12 lb NOx/mm Btu

     Stoker                  0.22 lb NOx/mm Btu

     Fluidized Bed      0.08 lb NOx/mm Btu

	Option #2	LNB/SNCR, LNB/FGR, SCR, or some combination of these controls
in conjunction with Low NOx Burner technology

	Option #3	60% reduction in NOx emissions from uncontrolled baseline

	Option #4	Purchase current year CAIR NOx allowances equal to reducted
needed to acheiv the required emission rates

>250	Option #1	Purchase current year CAIR NOx allowances equal to
reducted needed to acheiv the required emission rates

	Option #2	Phase I – 2009

Emission rate equal to EGUs of similar size

Phase II – 2012

Emission rate equal to EGUs of similar size



CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Fabric Printing

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Fabric Printing, Coating and Dyeing - 2002 existing measures: 

    NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties  

      EPA CTG RACT limit: 2.9 lbs VOC/gal coating [0.35 kg/liter] (minus
H2O & exempt solvents)

       Applicability:  Sources 3 lbs/hour, 15 lb/day or 10 tons/year
uncontrolled emissions

       OTC state RACT limits: MD, NJ, NH = 2.9 lbs/gal coating

           MA = 4.8 lbs VOC/gal of solids applied  (equivalent to 2.9
lbs/gal coating)	VOC

Actual 2002:	(not available)

Fabric Printing, Coating and Dyeing - 2009 On-the-Books measures: 

   MACT Std. - Subpart OOOO (68 FR 32172, 5/29/03)

      EPA MACT limits existing sources:

                Coating and printing operations -   0.12 kg HAP/liter
solids

                Dyeing and finishing operations  -   0.016 kg HAP/liter
solids

                    Dyeing operations only             -   0.016 kg
HAP/liter solids

                    Finishing operations only        -    0.0003 kg
HAP/liter solids

Emission Reductions:  

     Nationwide – 60% HAP reduction from 1997 baseline

      MACT Organic HAP control efficiency option: 97% for existing
sources

           MACT Estimated VOC reduction 60% (Pechan Table)

Control Cost:  

    Nationwide –$14.5 million/yr for 4,100 tons/yr = $3,537/ton

Timing of Implementation: Compliance Date (existing) May 29, 2006 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Fabric Printing, Coating and Dyeing 

Candidate measure 1:  Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: Permanent Total Enclosure

      Emission Reductions: Estimated VOC reduction 95-97% 

        (Air Control Net 3.0 Table)

Control Cost:  $1,459-$1,565/ton

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties

	                       VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	

(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper



CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Large Appliances

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Large Appliances - 2002 existing measures:  

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties; 

       EPA CTG RACT limit: 2.8 lbs VOC/gal coating [0.34 kg/liter] 

                                                 (minus H2O & exempt
solvents)	VOC

Actual 2002:	

(not available)

Large Appliances - 2009 On-the-Books measures:  

   MACT Std. – Subpart NNNN (67 FR 48254, 7/23/02)

        EPA MACT limits existing sources: 0.13 kg HAP/liter solids

Emission Reductions:  

     Nationwide – 45% HAP reduction from 1995 baseline

    MACT Organic HAP control efficiency option: xx% for existing sources

           Estimated VOC reduction: 0% (Pechan Table)  - 60%??

Control Cost:  

    Nationwide – $1.63 million/yr for 1,190 tons/yr = $1,370/ton

Timing of Implementation: Compliance Date (existing) July 23, 2005

 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Large Appliances 

Candidate measure 1:  Adopt More Stringent RACT regulations (e.g., ICAC
letter 2/16/2001); lower applicability thresholds, extend geographic
coverage

Measure ID: 

   ICAC Option 1 -  Nationwide – 80% HAP reduction from 1995 baseline
( Additional 250 tons/per HAP)

   ICAC Option 2 -  Nationwide – 98% HAP reduction from 1995 baseline
( Additional 1,190 tons/per HAP)

Emission Reductions:  

Control Cost:  

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation of: Final recommendation not made as of June,
2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper



CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Metal Cans

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Metal Can - 2002 existing measures:  

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties;

    EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

         Sheet basecoat & over varnish                               2.8
 [0.34 kg/l]

         2 and 3-piece can interior & 2-piece can              4.2 
[0.50 kg/l]

         3-piece can side-seam spray                                  
5.5  [0.66 kg/l]

         End sealing compound                                           
3.7  [0.44 kg/l]

       Applicability:  10 tons/year uncontrolled emissions

       OTC state RACT limits: MD, NJ, NH same limits as CTG;  

             MA (4.5,  9.8, 21.8, 7.7 lbs/gallon of solids applied)	VOC 

Actual 2002:	

(not available)

Metal Can - 2009 On-the-Books measures:  

   MACT Std. – Subpart KKKK (68 FR 64432 , 11/13/03) 

    EPA MACT limits existing sources:

         Sheet coating                                                 
0.03 kg HAP/l solids

         Body Coating

                2-piece beverage cans                             0.07
kg HAP/l solids

                2-piece food cans                                    
0.06 kg HAP/l solids

                1-piece aerosol cans                                0.12
kg HAP/l solids           

         3-piece can assembly

                Inside Spray                                           
0.29 kg HAP/l solids

                Aseptic side seam strips on food cans      1.94 kg HAP/l
solids

                Nonaseptic side seam strips on food cans  0.79 kg HAP/l
solids

                Side seam strips on non-food cans             1.18 kg
HAP/l solids

                Side seam strips on aerosol cans                1.46 kg
HAP/l solids

         End sealing compound

                Aseptic end seal compounds                       1.94 kg
HAP/l solids                                                            

         Nonaseptic end seal compounds                 0.00 kg HAP/l
solids

         Repair spray coatings                                  2.06 kg
HAP/l solids

         Emission Reductions:  

     Nationwide – 70% HAP reduction from 1997 baseline

    MACT Organic HAP control efficiency option: xx% for existing sources

    Estimated VOC reduction 70% (Pechan Table)

Control Cost:  

    Nationwide – $58.7 million/yr for 6,800 tons/yr = $8,632/ton

Timing of Implementation: Compliance Date (existing) Nov. 13, 2006

 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	

(not available)



Metal Can (Continued)

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: Permanent Total Enclosure 

      Emission Reductions:  Estimated VOC reduction 95% 

                                         (Air Control Net 3.0 Table)

Control Cost: $7,947/ton 

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties.	       
               VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper





CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Metal Coils

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Metal Coil - 2002 existing measures:  

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties;

       EPA CTG RACT limit: 2.6 lbs VOC/gal coating [0.31 kg/liter]

                                                 (minus H2O & exempt
solvents)

       Applicability:  Sources 10 tons/year uncontrolled emissions

       OTC state RACT limits:  NH - same limits as CTG	VOC

Actual 2002:	(not available)

Metal Coil – 2009 On-the-Books measures:  

   MACT Std. – Subpart SSSS (67 FR 39794 , 6/10/02)        

       EPA MACT limits existing sources: 0.046 kg HAP/liter solids

Emission Reductions:  

    Nationwide – 53% HAP reduction from current levels?

    MACT Organic HAP control efficiency option: xx% for existing sources

         Estimated VOC reduction 53% (Pechan Table)

Control Cost:  

    Nationwide – $7.6 million/yr for 1,316 tons/yr = $5,775/ton

Timing of Implementation: Compliance Date (existing) June 10, 2005

 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Metal Coil 

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: 

Emission Reductions:  

Control Cost:  

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties.

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper





CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Metal Furniture

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Metal Furniture - 2002 existing measures:

      NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

       EPA CTG RACT limit: 3.0 lbs VOC/gal coating [0.36 kg/liter]

                                                 (minus H2O & exempt
solvents)

       Applicability:  Sources 10 tons/year uncontrolled emissions

       OTC state RACT limits:  NH - same limits as CTG	VOC

Actual 2002:	(not available)

Metal Furniture – 2009 On-the-Books measures:  

   MACT Std. – Subpart RRRR (67 FR 28606 , 5/23/03)

       EPA MACT limits existing sources: 0.10 kg HAP/liter solids

Emission Reductions:  

           Nationwide – 73% HAP reduction from 1997/1998 baseline

    MACT Organic HAP control efficiency option: xx% for existing sources

          Estimated VOC reduction 0% (Pechan Table)

Control Cost:  

          Nationwide – $14.8 million/yr for 16,300 tons/yr = $908/ton

Timing of Implementation: Compliance Date (existing) May 23, 2006

 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Metal Furniture 

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: Permanent Total Enclosure

      Emission Reductions:  Estimated VOC reduction 95% 

                                         (Air Control Net 3.0 Table)

Control Cost:  $20,115/ton

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

 

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties.

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper





CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Miscellaneous Metal Parts

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Miscellaneous Metal Parts - 2002 existing measures:  

  NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

  EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

         Clear or transparent top coat                                  
 4.3 [0.52 kg/l]

         Air dries Coatings                                             
         3.5 [0.42 kg/l]

         Coating used in extreme environmental conditions 3.5 [0.42
kg/l]                        

         All other coatings                                             
          3.0 [0.35 kg/l]

       Applicability:  10 tons/year uncontrolled emissions

       OTC state RACT limits: NH same limits as CTG	VOC

   Actual 2002:	

(not available)

Miscellaneous Metal Parts – 2009 On-the Books measures:  

  MACT Std. – Subpart MMMM (69 FR 130 , 1/2/04)

     EPA MACT limits existing sources:

         General use  Coating                                       0.31
kg HAP/l solids

         High Performance Coating                             3.30 kg
HAP/l solids

         Rubber-to-Metal Coating                                4.50 kg
HAP/l solids                    

         Extreme Performance Fluoropolymer          1.5   kg HAP/l
solids                                              

Emission Reductions:  

    Nationwide – 48% HAP reduction from 1997 baseline

          MACT Organic HAP control efficiency option: xx% for existing
sources 

   Estimated VOC reduction 0% (Pechan Table)

Control Cost:  

          Nationwide – $57.3 million/yr for 26,000 tons/yr = $2204/ton

Timing of Implementation: Compliance Date (existing) Jan. 2, 2007

 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	

(not available)

Miscellaneous Metal Parts 

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: 

Emission Reductions:  

Control Cost:  

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010 

Implementation Area: 

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper





CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Paper and Other Web

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Paper & Other Web - 2002 existing measures:  

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

        EPA CTG RACT limit: 2.9 lbs VOC/gal coating [0.35 kg/liter]

                                                 (minus H2O & exempt
solvents)

       Applicability:  Sources 3 lbs/hour, 15 lb/day or 10 tons/year

                                 uncontrolled emissions

       OTC state RACT limits: MD, NJ, NH = 2.9 lbs/gal coating

           MA = 4.8 lbs VOC/gal of solids (equivalent to 2.9 lbs/gal
coating)	VOC

Actual 2002:

	Paper & Other Web – 2009 On-the-Books measures:  

  MACT Std. – Subpart JJJJ (67 FR 72330 , 12/4/02)

      EPA MACT limits existing sources: 0.2 kg organic HAP/kg coating
solids

Emission Reductions:  

    Nationwide – 80% HAP reduction from current levels??

          MACT Organic HAP control efficiency option: 95% for existing
sources 

          Estimated VOC reduction 80% (Pechan Table)

Control Cost:  

    Nationwide – $64 million/yr for 34,500 tons/yr = $1,855/ton

Timing of Implementation: Compliance Date (existing) Dec. 5, 2005

 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Paper & Other Web 

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: 

Emission Reductions:  

Control Cost:  

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

 

Implementation Area: 

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper





CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Plastic Parts

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Plastic Parts - 2002 existing measures:  

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

  EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

                                                                 Auto
Interior          Auto Exterior

   High Bake Prime                                 3.8 [0.46 kg/l]      
               --

   High Bake Prime - Flexible                          --               
      5.0 [0.60 kg/l]

   High Bake Prime – Nonflexible                   --                 
    4.5 [0.54 kg/l]

   High Bake Color                                  4.1 [0.49 kg/l]     
     4.6 [0.55 kg/l]

   Low Bake Prime                                  3.5 [0.42 kg/l]      
    5.5 [0.66 kg/l]          

   Low Bake Color                                   3.5 [0.42 kg/l]     
     5.6  red or black

   Low Bake Color                                             --        
            4.5 all others

       Applicability:  NH - 50 tons/year uncontrolled emissions

       OTC state RACT limits: NH - same limits as CTG	VOC

Actual 2002:	

(not available)

Plastic Parts - 2009 On-the Books measures:  

  MACT Std. – Subpart PPPP (69 FR 20968 , 4/19/04)

   EPA MACT limits existing sources:

       General Use Coating                            -   0.16 kg HAP/kg
coating solids

       Automotive Lamp Coating                  -   0.45 kg HAP/kg
coating solids

       Thermoplastic Olefins                         -   0.26 kg HAP/kg
coating solids

       New Assembled On-Road Vehicles    -   1.34 kg HAP/kg coating
solids

Emission Reductions:  

    Nationwide – 80% HAP reduction from 1997 baseline

          Estimated VOC reduction 0% (Pechan Table)

Control Cost:  

    Nationwide – $10.9 million/yr for 7,560 tons/yr = $1,442/ton

Timing of Implementation: Compliance Date (existing) April 19, 2007 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	

(not available)

Plastic Parts 

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: 

      Emission Reductions:  

Control Cost:  

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010 

Implementation Area: 	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper



CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings Wood Building Products

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Wood Building Products - 2002 existing measures:  

  NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

  EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

	VOC

Actual 2002:

	 (not available)

Wood Building Products - 2009 On-the-Books measures:  

  MACT Std. – Subpart QQQQ (68 FR 31746 , 5/28/03)

    EPA MACT limits existing sources:

                                   -                        kg HAP/liter
of solids (lb HAP/gal solids)

      Doors, Windows & Misc.                         0.231              
      (1.93)

      Flooring                                                     0.093
                    (0.78)

      Interior Wall Paneling & Tileboard       0.183                    
(1.53)

      Other Interior Panels                               0.020         
           (0.17)

      Exterior Siding & Primed Door Skins   0.007                     
(0.06)

Emission Reductions:  

    Nationwide – 63% HAP reduction from 1997 baseline

          MACT Organic HAP control efficiency option: xx% for existing
sources

          Estimated VOC reduction 63% (Pechan Table)

Control Cost:  

    Nationwide –$22.5 million/yr for 4,900 tons/yr = $4,592/ton

Timing of Implementation: Compliance Date (existing) May 28, 2006

 

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Wood Building Products 

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: 

Emission Reductions:  

Control Cost:  

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: 

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation of State/Workgroup Lead: Final recommendation not
made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper





CONTROL MEASURE SUMMARY FOR 

Industrial Surface Coatings All Categories

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Industrial Surface Coatings Category Total - 2002 existing measures:

    NSPS: PSD/NSR; State RACT rules in 1-hour non-attainment counties
Total VOC

Point &Area

Actual 2002:	164,445

Industrial Surface Coatings Category Total - 2009 On-the-Books measures:
 

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

                            Subpart NNNN (67 FR 48254, 7/23/02) 

                            Subpart KKKK (68 FR 64432 , 11/13/03) 

                            Subpart SSSS (67 FR 39794 , 6/10/02) 

                            Subpart RRRR (67 FR 28606 , 5/23/03)

                            Subpart MMMM (69 FR 130 , 1/2/04) 

                            Subpart JJJJ (67 FR 72330 , 12/4/02)

                            Subpart PPPP (69 FR 20968 , 4/19/04)

                            Subpart QQQQ (68 FR 31746 , 5/28/03)

Emission Reductions:  

    OTC Regional – x,xxx from 2002 baseline

Control Cost:  

   OTC Regional –$ xx.x million/yr for x,xxx tons/yr = $4,592/ton

Timing of Implementation: Compliance Dates (existing) 5/29/06;

                                                                        
 (existing) 7/23/05;           

                                                                        
 (existing) 11/13/06;

                                                                        
 (existing) 6/10/05;

                                                                        
 (existing) 5/23/06;

                                                                        
 (existing) 1/2/07;

                                                                        
 (existing) 12/5/05;

                                                                        
 (existing) 4/19/07;

                                                                        
 (existing) 5/28/06                                   

Implementation Area:  Ozone Transport Region	Total VOC

Point & Area

Actual 2002:

OTB 2009:

Reduction from OTB:

MANE-VU

2002 Point*

MANE-VU

2002 Area* 

(Ed Sabo’s

        e-mail 

      01/06/06)	

164,445

-175,983

 -11,448

  24,931

139,512

From 10/04/05 draft emission inventory

Industrial Surface Coatings Category Total  

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: 

      Emission Reductions:  

Control Cost:  

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010 

Implementation Area: 	                      VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	

(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper





Background Information

Industrial surface coatings are used during the manufacture of a wide
variety of products including: fabrics, paper, large appliances, metal
cans, metal coils, metal furniture, metal parts, plastic parts, and wood
building materials.  Surface coating is the process by which paints,
inks, varnishes, adhesives or other decorative or functional coatings
are applied to a substrate (e.g., fabric, metal, wood, or plastic) to
protect or decorate the substrate.  Industrial surface coatings can be
applied by brushing, rolling, spraying, dipping, flow coating,
electro-coating, or combinations and variations of these methods.  The
process used to coat a particular product is dependent on the
composition of the coating, the substrate to which the coating is
applied and the intended end use of the final product.  After a coating
is applied, it is dried or cured either by conventional curing through
the use of thermal drying ovens, or through the use of radiation. 
During conventional curing, heat from thermal ovens is used to evaporate
the solvents and/or water trapped in the coating and release them into
the atmosphere.  Two types of radiation curing processes currently in
use are ultraviolet (UV) curing and electron beam (EB) curing.

Emissions are released by the evaporation of the solvents used in the
coatings and the evaporation of any additional solvents used to dilute
(thin) the coating prior to application and for cleaning the coating
equipment after use.  Emissions from surface preparation and coating
applications are a function of the VOC content of product used. 
Emissions are also a function of the type of coating process used
(rolling, dipping, spraying, etc.) and the transfer efficiency of the
process.  Transfer efficiency is the percentage of the coating solids
that are applied (e.g., sprayed) which actually adhere to the surface
being coated.  Emissions from cleaning vary with the type of cleanup and
the housekeeping practices used.

Industrial surface coating is estimated to account for approximately
164,000 tons per year of VOC emissions in the Mid-Atlantic/Northeast
Visibility Union (MANE-VU) region in 2002 from both point and area
sources.  It is important to consider two aspects regarding the accuracy
of this emissions estimate when assessing this category for additional
controls:

The MANE-VU VOC emissions inventory for the industrial surface coating
category includes emissions from both point and area sources.  While the
2002 VOC emissions inventory for the MANE-VU region indicates that VOC
emission from area sources in this category are substantial, the area
source part of the emissions inventory is highly uncertain and may be
substantially overestimated.  The method used to estimate area source
VOC emissions relies heavily on employee emission factors and employment
data.  These emission factors are based on data collected by EPA in the
1980s and may not accurately portray the types of coatings, the type of
coating equipment, or the type of control technology currently in use.

 

At least nine types of industrial surface coating point sources are
already controlled due to state specific VOC RACT regulations or will
soon be controlled prior to 2009 as a result of the recently promulgated
Maximum Achievable Control Technology (MACT) standards.  Since the MACT
standards were  designed to control air toxic emissions and not
necessarily VOC emissions the  effectiveness of the MACT standards for
controlling VOC emissions will vary with the industrial surface coating
subcategory (e.g., metal cans, wood building products, etc.) and the
type of  coating equipment and the type of solvents used in that
subcategory.

Regulatory History

	Industrial surface coating processes are currently subject to multiple
state and federal regulations pursuant to Titles I and III of the Clean
Air Act.  Title I imposes Standards of Performance for New Stationary
Sources (NSPS) on new and modified large stationary sources.  In the
early 1990s, EPA promulgated NSPSs for various types of industrial
surface coating operations.  These regulations applied to surface
coating operations that were constructed or modified after effective
dates specified in each NSPS.  In general, surface coating operations
constructed or modified after 1980 are subject to NSPS requirements. 
The NSPS generally established VOC emission rate limits that could be
complied with using either compliant coatings or add-on capture and
control equipment.  For certain source categories the NSPS also set
transfer efficiency requirements.

	New and modified large stationary sources that increase their emissions
can also be subject to the New Source Review (NSR) requirements of Title
I.  NSR requires a control technology review for large new plants and
for modifications at existing plants that result in a significant
increase in emissions, subjecting these sources to Best Available
Control Technology (BACT) in attainment areas and Lowest Achievable
Emission Rate (LAER) in nonattainment areas.  BACT and LAER control
requirements are updated over time to reflect improvements in control
equipment and are reviewed on a case-by-case basis during state
permitting process.

	Criteria pollutants, which include VOCs, nitrogen oxides (NOx), sulfur
dioxide (SO2), fine particulate matter (PMfine), carbon monoxide (CO)
and lead (Pb), are also regulated by the State Implementation Plans
(SIPs) required by Title I.  SIPs set forth the states’ strategies for
achieving reductions of criteria pollutants for which the state is
currently out of attainment.  SIPs must include requirements that all
major stationary sources located in nonattainment areas must install
reasonably available control technology (RACT).  RACT levels must be
basedon the level of emissions reduction that can be reasonably achieved
at a reasonable cost.  The U.S. EPA has issued a series of Control
Technology Guidelines (CTGs) and Alternative Control Technologies (ACT)
documents to assist states in defining RACT for a number of industrial
surface coating categories.  For categories not covered by a CTG or ACT
document, state regulations require that a case-by-case RACT
determination be made.  Most of the EPA’s CTGs and ACT documents for
the industrial surface coating category were developed prior to 1990. 
While specific RACT requirements will vary from state to state, some OTC
states have already adopted RACT regulations that are more stringent
than the CTG/ACT requirements.

Policy Recommendation

   As can be noted from the background information, the regulatory
history, and the information contained in summary tables, the industrial
surface coatings category includes at least nine different major source
types and multiple processes for each source type with regulations and
emissions limits that vary not only by major source type, but also by
individual process and individual product.  In addition, the industrial
surface coatings category is already subject to a variety of regulations
(NSPS; PSD/NSR, state RACT, MACT, state specific rules on hazardous air
pollutants) that were adopted to achieve different goals.  Some
regulations (e.g., RACT) were designed to reduce VOC emissions.  Other
regulations (e.g., MACT) were designed to reduce emissions of hazardous
air pollutants but have the side benefit of reducing VOC emissions as
well.

   

    Analysis of the potential benefits and costs of adopting additional
VOC control measures, Beyond On-The-Way (BOTW) measures) is further
complicated by the following:

Uncertainty as to the accuracy of the current (2002) MANE-VU VOC
emissions inventory for the industrial surface coatings category;

Difference in current VOC RACT limits among the OTC states;

Difference in the estimates of the potential VOC reductions from MACT
standards; and

Difference in the source size and geographic area covered by a specific
regulation.

   The most recent version of the (2002) MANE-VU VOC emissions inventory
for the MANE-VU region estimates total VOC emissions from the industrial
surface coatings category to be 164, 445 tons (24,931 tons of VOC from
point sources and 139,512 tons from area sources).   Further
investigation into the amount of VOC emissions from area sources will
most likely reveal that these VOC emissions are substantially
overestimated due in part to the emission factors and employment data
used and in part to the cutpoints used by various states for
distinguishing a point source from an area source.  

   

   A quick sampling of the current VOC RACT limits in the OTC states
reveals differences not only in the limits for existing sources (lbs.
VOC per gallon of coating  minus water and exempt solvents), but also in
the size of source to which these limits apply.

   Several complications arise when trying to calculate the potential
VOC reductions from a particular MACT standard including the following:

 

Not all toxics regulated under the MACT are VOCs;

MACT standards are expressed as kg HAP/liter of solids or lbs.
HAP/gallon of solids not lbs. VOC/gallon of coating minus water and
exempt solvent so the MACT limit applies to all HAPs not just VOCs; and

The specific types of processes and coatings regulated under the MACT
standards are different than the types of processes and coatings
regulated under the RACT standards. 

These complications have lead to widely varying estimates of the
potential additional VOC reductions from the application of a particular
MACT requirement (from 0% to as much as 80% VOC reduction nationwide).

   RACT standards and MACT standards apply to sources located in
different geographic areas throughout the Ozone Transport Region.  For
some OTC states RACT standards apply only to sources located in 1-hour
ozone nonattainment counties while in other OTC states RACT standards
apply statewide.  MACT standards are applicable nationwide and only to
major HAP sources (10 tons/year of individual HAP or 25 tons/year of
combined HAPs).

Given all of these uncertainties the following options are available:

OTC states that currently have higher VOC RACT limits than the EPA
CTG/ACT VOC RACT limits can adopt more stringent RACT regulations;

OTC states can extend the geographic coverage for RACT limits to
statewide;

OTC states can lower the RACT applicability thresholds

OTC states can adopt more stringent control requirements for specific
industrial surface coating categories (e.g., permanent total enclosures
for metal can coating processes).

Policy recommendations:

1) Due to uncertainty in current MANE-VU VOC emissions inventory for
this category, develop an improved, state specific VOC emissions
inventory for point and area sources for each subcategory of industrial
surface coatings before requiring additional controls beyond MACT.

CONTROL MEASURE SUMMARY FOR 

Lime Kilns

Control Measure Summary: Good combustion practices and kiln operation
for Lime Kilns.  These kilns are used for the calcination of limestone. 
Lime kilns are also often associated with paper mills.	Emissions
(tons/year) in Ozone Transport Region

2002 existing measure:  NSR; PSD; State RACT.  

Emission Reductions:  

Control Cost:  

Timing of Implementation:   

Implementation Area:  OTR 	 NOx

  Uncontrolled:

2002 Reduction:

2002 Base:	

4,649

      0

 4,649

Candidate measure:  Good combustion practices and kiln operation

Emission Reductions: Under Evaluation

Control Cost:  less than $2,000 per ton

Timing of Implementation:  01/01/09

Implementation Area:  OTR	                   NOx

2009 Base including growth:

2009 Reduction:

2009 Remaining:	

 

5,228

TBD



Policy Recommendation: Final recommendation not made as of June, 2006.  



Recommended Strategy:  See additional discussion in briefing paper



REFERENCES:

European Commission, Integrated Pollution Prevention and Control (IPPC)
Bureau.  Reference Document on Best Available Techniques in the Cement
and Lime Manufacturing Industries.  December 2001. “The direct
transfer of low-NOx burner technology from cement kilns to lime kilns is
not straightforward. In cement kilns, flame temperatures are higher and
low-NOx burners have been developed for reducing high initial levels of
‘thermal NOx’. In most lime kilns the levels of NOx are lower and
the ‘thermal NOx’ is probably less important.”

Northeast States for Coordinated Air Use Management.  Assessment of
Control Technology Options for BART-Eligible Sources: Steam Electric
Boilers, Industrial Boilers, Cement Plants, and Paper and Pulp
Facilities.  March 2005.  “Due to the design of the lime kiln, SNCRs
and SCRs are not viable NOx reduction techniques.  Installing low-NOx
burners is also not a practical NOx reduction technique according to a
BACT analysis conducted on a new lime kiln in 1997…combustion
modification such as decreasing excess air is the best way to reduce NOx
emissions”.  



CONTROL MEASURE SUMMARY FOR

Municipal Waste Combustiors 

(Only NOx reductions are evaluated under this strategy)

Control Measure Summary	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  Federal performance standards and emissions
guidelines for large MWCs (40 CFR 60 Subparts Cb and Eb).  No control
technology is mandated to meet the emissions limitations.  EPA approved
state trading programs for NOx compliance are allowed as is
facility-wide averaging for NOx compliance.

Emission Reductions:  19,000 Mg NOx/yr nationally (increment over 1991
40 CFR 60 Subpart Ca standards).

Control Cost:  $7.2 per Mg municipal solid waste combusted.

Timing of Implementation: Compliance required December 19, 2000.

Implementation Area:  Nationwide.	 NOx  

2002 Base:	26,139

	SO2:

2002 Base	3,865

	VOC:

2002 Base	473

Implement Federal Rules:

Measure ID: 

Emission Reductions:  Varies per state depending on the number of MWC
units, incinerator technology and chosen emissions limitations.  In
Connecticut, this measure resulted in NOx emissions reductions of 1.6
tons/summer day and 592 tons/year.

Control Cost:  $0 to approximately $1,500/MMBtu/hr depending on whether
SNCR was installed in response to the federal emissions guidelines and
whether SNCR is feasible.  

Timing of Implementation:  Assuming timely adoption of state rule
amendments, compliance with emissions limitations could be required by
May 1, 2009.

Implementation Area:  Maine, Maryland, Massachusetts, New Hampshire, New
Jersey, New York and Pennsylvania report operating MWC units (assuming
state NOx emissions limitations are at the level of the federal
emissions guidelines).  

	NOx

2009 Reduction:

2009 Remaining:	

-3,610

22,529

	SO2	***

	

VOC	

***

Policy Recommendation of State/Workgroup Lead:  

Individual states with operating MWCs should evaluate the possible
reduction of state NOx emissions limitations to produce creditable
emissions reductions.  At the regional level, this strategy should not
be emphasized as it is state-specific in nature (depending on the MWC
population, current control level and current state standards); does not
require regional implementation to maximize its effectiveness; emissions
from MWCs are a minor portion of the regional inventory given MACT-based
standards required under Section 129 of the Clean Air Act; and EPA has
proposed more stringent NOx emission limits for MWCs that states will be
required to adopt and implement as of April 2009.



Recommended Strategy:  

MWCs are subject to stringent MACT emissions standards, including
standards for NOx, under Section 129 of the Clean Air Act.  To comply
with these MACT standards, many MWC owners and operators installed
control technologies, including SNCR, to comply with the federal
deadline of December 19, 2000.  Many MWCs may be operated to reduce
emissions to a level below the current federal standards.  For example,
Connecticut includes a state NOx emission reduction credit (ERC) trading
program in its MWC rule.  Recognizing that the "excess emissions"
produced in Connecticut's MWC NOx ERC trading program could yield
creditable emissions reductions if the required NOx emissions limits
were reduced, in October 2000, the Department amended the state MWC rule
to require the MWC owners and operators to meet more stringent NOx
emissions limits as of May 1, 2003.  The resulting emissions reductions
of 1.62 tons of NOx per summer day (248 tons per ozone season) were used
for compliance with the "shortfall" emission reduction obligation needed
for EPA approval of the attainment demonstration for the 1-hour ozone
national ambient air quality standard.  

Other states in the OTC region have operating MWC units that now comply
with MACT-based state emissions limitations.  Many MWC units now operate
with SNCR to control NOx emissions.  For MWC units that do not now have
SNCR, SNCR is likely a feasible RACT measure capable of reducing NOx
emissions below the state limits.  Thus, the reduction of the state MWC
NOx limits may produce creditable NOx emissions reductions. 
Furthermore, since MWCs are not subject to the Clean Air Interstate Rule
(CAIR) and may not participate in a CAIR NOx trading program, reduction
of state MWC NOx emissions limitations could be considered an equity
measure that places MWC owners in a position similar to the owners of
large electric generating units subject to CAIR.  However, the amount of
creditable emissions reductions a state may obtain from this strategy is
limited given EPA's December 19, 2005 proposal of reduced emissions
limitations for MWCs.





BACKGROUND INFORMATION

In December 1995, EPA adopted new source performance standards (NSPS)
(40 CFR 60 subpart Eb) and emission guidelines (subpart Cb) for MWC
units with a combustion capacity greater than 250 tons per day.  Both
the NSPS and emission guidelines require compliance with emission
limitations for nine pollutants including NOx that reflect the
performance of maximum achievable control technology (MACT).  The
emission guidelines required compliance by December 2000 for all
existing MWCs, while the NSPS apply to new MWCs.  On December 19, 2005,
EPA proposed revisions to the emissions guidelines to reflect the levels
of performance achieved due to the installation of control equipment (70
FR 75348).  This proposal includes reduced NOx emissions limitations
that states will be required to adopt and implement by April 2009, if
the proposal is finalized.  Selective non-catalytic reduction (SNCR) is
considered MACT for NOx under both the 1995 guidelines and the 2005
proposal.  

Connecticut's MWC regulation, section 22a-174-38 of the Regulations of
Connecticut State Agencies (R.C.S.A.) (Attachment A), was adopted in
June 1999 with NOx emissions limits equivalent to the federal emissions
guidelines (Phase I NOx limits).  Owners and operators of the state's 15
MWC units were required to comply with the emissions limits no later
than December 19, 2000.  R.C.S.A. section 22a-174-38 was amended in
October 2000 to include more stringent NOx emissions limits (Phase II
NOx limits), for which compliance was required no later than May 1,
2003.  The following NOx emissions reductions, relative to emissions
levels under the Phase I NOx limits, are attributed to the Phase II NOx
limits in Connecticut:

592 tons per year;

248 tons per ozone season; and 

1.62 tons per day during the ozone season.  

EPA's December 19, 2005 proposal to update the 1995 emissions standards
will substantially reduce the ability of other states to achieve the
same level of emissions reductions that Connecticut achieved by
implementing this measure in 2003.  

Add-on NOx Control

The number of NOx-reduction technologies for MWCs are limited as these
units use a heterogeneous, wet fuel; are less thermally efficient than
fossil fuel-fired boilers of comparable heat input; and require larger
amounts of excess air and less densely-packed heat recovery systems. 
Low-NOx burners, fuel switching and load curtailment are not possible
control options.  

The only generally applicable and feasible add-on control technology for
reducing NOx emissions from MWCs is SNCR.  SNCR is a chemical process
for removing NOx from flue gas.  In the SNCR process, a reagent,
typically liquid urea or anhydrous gaseous ammonia is injected within a
boiler or in ducts in a region where the temperature is between 900 and
1100 degrees Celsius.  The reaction converts NOx to nitrogen gas and
water vapor.  SNCR performance depends on factors specific to each type
of combustion equipment, including flue gas temperature, residence time
for the reagent and flue gas, amount of reagent injected, reagent
distribution, uncontrolled NOx level and carbon monoxide and oxygen
concentrations.  

Some disadvantages arise from the use of SNCR including:  the high
operating temperatures required; ineffectiveness at high temperatures
with low concentrations of NOx; the need to accommodate enough residence
time to complete the chemical reaction at high temperatures; and
undesirable excess ammonia and urea emissions ("ammonia slip") that
arise from an incomplete chemical reaction (Thermal Energy
International, 2000).  

All of Connecticut's large MWC units are equipped with SNCR, including
nine mass burn/waterwall units and three refuse-derived fuel units.  Two
tire-fired units subject to the state MWC rule also operate with SNCR. 
Similarly, all of New Jersey's large MWC units are equipped with SCR to
meet NOx emissions limitations based on the federal emissions
guidelines.

Cost

The capital cost of installing SNCR on a MWC unit is approximately
$1,500 MMBtu/hr (see, e.g., Institute of Clean Air Companies, 2000). 
Most of the cost of using SNCR is in operating expenses (Institute of
Clean Air Companies, 2000), which EPA estimates as falling between 680
and 1,200 $/MMBtu (1993 dollars).  Thus, SNCR is well suited for
seasonal control in that it may provide significant reductions in NOx
emissions but incurs little cost when the system is not in use.  EPA has
assigned an ozone season cost effectiveness to SNCR operated on MWC
units of $2,140 per ton of NOx reduced (1990 dollars)(EPA, 1999, Table
16). 

Emissions reductions

In Connecticut, MWC facility owners report emissions reductions of 25 to
50% from the operation of SNCR; a typical reduction of 35-40% could be
assumed from the installation and operation of SNCR/ammonia injection to
MWC units of similar size and type.  Other combustors of varying
technologies and capacities but with similar baseline NOx emissions have
reported reductions ranging from 35 - 75% from the operation of
urea-based SNCR (Appendix 1, Institute of Clean Air Companies, 2000). 
EPA assigns a typical 45% emission reduction to the effectiveness of
SNCR at MWCs (EPA, 1999, Table 16).  

REFERENCES

Institute of Clean Air Companies.  May 2000.  Selective Non-Catalytic
Reduction (SNCR) for Controlling NOx Emissions. 
http://www.fueltechnv.com/pdf/TPP-534.pdf

Thermal Energy International Inc.  2000.  Thermal THERMALONOx
Competitive Advantages.    HYPERLINK
"http://www.thermalenergy.com/solutions/solutions.html" 
http://www.thermalenergy.com/solutions/solutions.html 

U.S. Environmental Protection Agency.  November 1999.  Nitrogen Oxides
(NOx), Why and How They are Controlled.  Clean Air Technology Center: 
EPA 456/F-99-006R.  

U.S. Environmental Protection Agency.  April 2005.  Corrected Response
to Significant Public Comments on the Proposed Clean Air Interstate
Rule.  Comment of IWSA.  

U.S. Environmental Protection Agency.  December 19, 2005.  Standards of
Performance for New Stationary Sources and Emission Guidelines for
Existing Sources:  Large Municipal Waste Combustors; Proposed Rule.  70
FR 75348.  

CONTROL MEASURE SUMMARY FOR 

Printing and Graphic Arts

Control Measure Summary:  This category includes categories of both heat
set and non-heat set operations.  It includes lithographic, gravure,
flexographic and screen printing.  It includes both point sources and
area sources.

	Emissions (tons/year) in Ozone Transport Region

2002 existing measures: RACT, BACT, NSPS

   	VOC Point 

Actual 2002

VOC Area

Actual 2002:

	

5,501

31,738



2009 On-the-Books measures:    MACT Std. - Subpart KK

      Publication rotogravure – limit organic HAP emissions to no more
than 8% of volatile matter used each month.  Either reformulation or 92%
capture and control efficiency.  Product and packaging rotogravure and
wide-web flexo – limit organic HAP emissions to no more than 5% of
volatile matter used each month.  Either reformulation or 95% capture
and control efficiency.

       Emission Reductions:  

     Control Cost:  

Timing of Implementation: Compliance Date (existing) December 5, 2005 

Implementation Area:  Nationwide	VOC Point

Actual 2002:

2009 Reduction: 

2009 Remaining:

VOC Point

Actual 2002:

2009 Reduction: 

2009 Remaining:	

5,501

-121

5,380

31,738

-0

31,738

Candidate measure:  Adopt the requirements of SCAQMD rule 1130 and
1130.1

      Emission Reductions:  Under evaluation

Control Cost:  Under evaluation

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010 

Implementation Area: OTR

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	Under review

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

Implementation Area: OTR	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	Under review

Candidate measure: Adopt September 2006 CTGs.  In September 2006, EPA
determined that control technique guideline (CTG) documents will be
substantially as effective as national regulations in reducing VOC
emissions in ozone nonattainment areas from the following Group II
product categories: lithographic printing materials, letterpress
printing materials, and flexible packaging printing materials 

Implementation Area: OTR

Under Review

Policy Recommendation: Final recommendation not made as of June, 2006.  



Brief Rationale for Recommended Strategy:  



CONTROL MEASURE SUMMARY FOR 

Portable Fuel Containers

Control Measure Summary: Portable Fuel Containers

This control measure establishes design and manufacturing specifications
for portable fuel containers (PFCs) based on the California Air
Resources Board (CARB) rules.  PFCs are used to refuel residential and
commercial equipment and vehicles.  PFCs are used to refuel a broad
range of small off-road engines and other equipment (e.g., lawnmowers,
chainsaws, personal watercraft, motorcycles, etc.).	VOC Emissions 

in Ozone Transport Region

2002 Existing Measure: None 	2002 Annual:

2002 Summer:	99,919 tpy

315.3 tpd

2009 On-the-Books Measure: Adopt the OTC Model Rule for PFCs, which is
based on the 2000 CARB rule for PFCs.

Emission Reductions:  Based on a CE=65%, RE=100%, RP=based on the number
of years the rule has been in place based on the assumed 10-yr turnover
of the sale of the cans, and Total control = 65% when fully implemented
after 10 years.  

Control Cost:  $581 per ton 

Timing of Implementation: State specific with a 10% per year turnover,
full reductions are achieved after 10 years.  CARB, and the EPA, have
estimated a 5 year turnover for the cans, but the OTC used a more
conservative 10 year turnover in calculating emission reductions.

Implementation Area: OTR 	Annual:

2009 Reduction:

2009 Remaining:

Summer:

2009 Reduction:

2009 Remaining:	

33,055 tpy

66,864 tpy

107.1 tpd

208.2 tpd

2009 On-the-Way Measure:  Proposed Federal HAP Mobile Source Reg (Feb
28, 2006) Rule –   This rule proposes to regulate PFCs similar to
CARBs 2006 rule amendments and will regulate permeability to 0.3 grams
of HC per gallon per day (2001 OTC Model Rule has 0.4 grams per gallon
per day).  It does not contain CARBs amendments regarding kerosene
containers and utility jugs.

Emission Reductions:  EPA estimates about a 9% reduction nationwide in
2009 and a 61% reduction when fully implemented after 5 years.  

Control Cost:  $180 per ton without fuel savings; over the long term,
fuel savings outweigh costs.

Timing of Implementation:  Jan.1, 2009 effective date of rule and 20%
per year turnover, full reductions are achieved after 5 years, in 2014.

Implementation Area: Nationwide	Annual:

2009 Reduction:

2009 Remaining:

Summer:

2009 Reduction:

2009 Remaining:	

negligible

66,864 tpy

negligible

208.2 tpd



Candidate measure: Adopt the CARB 2006 amendments broadening PFC
definition to include kerosene containers and utility jugs, increasing
the permeability requirement from 0.3 grams of hydrocarbons per gallon
per day to 0.4 grams of hydrocarbons per gallon per day, and other
changes needed to make the OTC Model Rule consistent with CARB

Emission Reductions: CARB estimates their amendments are expected to
reduce ROG emissions by 58% after full penetration into the marketplace,
assumed to be 5 years. 

Control Cost: CARB estimate is $800 to $1,400 per ton reduced

Timing of Implementation: State specific with a 10% per year turnover,
full reductions are achieved after 10 years

Implementation Area: OTR

	Annual:

2009 Base:

2009 Reduction:

2009 Remaining:

Summer:

2009 Base:

2009 Reduction:

2009 Remaining:	

66,864 tpy

4,152 tpy

62,712 tpy

208.2 tpd

12.8 tpd

195.4 tpd 

Summary of Candidate Measure:

The California Air Resources Board (CARB) 2000 PFC regulation
establishes design and manufacturing specifications for PFCs.  PFC
emissions are calculated by accounting for emissions from five different
components related to gas container use: permeation, diurnal,
transport-spillage, refueling spillage and refueling vapor displacement
emissions.  The permeation, diurnal emissions (associated with storage)
and transport-spillage emissions are included in the area source
inventory.  The equipment refueling spillage and refueling vapor
displacement emissions are calculated from the non-road model and are
included in the non-road inventory.  After four years of implementation
and a comprehensive assessment of the program, CARB staff  identified
some problems with the rule related to consumer acceptance and reducing
anticipated emission reductions.  Their 2006 amendments address these
issues, as well as expanding on the regulation to increase emission
reductions.  The amendments include the following:

Eliminate the requirement for an auto shutoff.

Eliminate fuel flow rate and fill level standards.

Eliminate one opening standard.

Reduce pressure standard from 10 psig to 5 psig.

Establish a certification program for PFCs.

Expand the definition of a PFC to include utility jugs and kerosene
containers.  CARB staff determined that consumers were using these
containers for gasoline.

Change permeability standard from 0.4 grams ROG /gallon-day to 0.3
grams/gallon-day.

Combine the evaporation and permeation standards into a new diurnal
standard to simplify certification and compliance testing. 

Adopt new PFC test procedures.   

Include a voluntary Consumer Acceptance Program to support and encourage
user-friendly PFC designs (i.e., allowing the use of the ARB Star Rating
system to clearly identify superior designs as determined by users).

While ARB staff does not expect these changes to affect the cost of
gasoline cans, the price of kerosene cans could rise to as much as $8.50
per container once the regulations are implemented.  CARB also estimates
the cost-effectiveness to be between $0.40 to $0.70 per pound.



Recommended Strategy:  CARB, through their comprehensive history of
research and multiple product surveys, have the best technical data
available to create rules to regulate portable fuel containers.  Most
portable fuel container manufacturers market their products nationally,
therefore many will be selling the new products nationally after they
have produced cans than conform with the CARB rules.  The CARB rule
contains some revisions to their original rule to ease consumer
acceptance of the cans, for states that have adopted the original OTC
model rule.  In addition the CARB rule amendments regulate kerosene cans
and utility jugs, which the Federal rule proposal does not.  



References:

2009 On-the-Books Measure (OTC Model Rule):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001. 
Much of the analysis in this report was based on CARB’s analysis for
CARB’s original 1999 PFC rule , which estimated a 75% reduction that
would be fully achieved after 5 years (CARB’s assumed life cycle for
PFCs).  The OTC used a more conservative 10-year turnover rate in its
analysis.  Table II-5 of the Pechan report shows the cost of compliance
to be $581/ton.

2009 On-the-Way Measure (Proposed 2/28/06 Federal Rule):

U.S. EPA Office of Transportation and Air Quality.  Estimating Emissions
Associated with Portable Fuel Containers (PFCs), Draft Report,
EPA420-D-06-003, February 2006.  

U.S. EPA Office of Transportation and Air Quality.  Draft Regulatory
Impact Analysis: Control of Hazardous Air Pollutants from Mobile
Sources, EPA420-D-06-004, February 2006.  

Candidate Measure (CARB 2006 Amendments):

California Air Resources Board.  Final Statement of Reasons for
Rulemaking, Including Summary of Comments and Agency Response: PUBLIC
HEARING TO CONSIDER AMENDMENTS TO THE PORTABLE FUEL CONTAINER
REGULATIONS.  September 15, 2005.  

California Air Resources Board.  Initial Statement of Reasons for
Proposed Amendments to  the Portable Fuel Container Regulations.  July
29, 2005.  Table 5.1 shows the cost-effectiveness of the proposed
amendments to be $0.40 to $0.70 per pound ($800 to $1,400 per ton)







CONTROL MEASURE SUMMARY FOR 

Regional Fuel

Control Measure Summary: The OTR proposes a common fuel standard for the
OTR states that does not require MTBE or Ethanol, but exhibits
Environmentally Beneficial Combustion Properties.	NOx Emissions
(tons/summer day) in OTR

2002 existing measure:  Federal program in the CAA requiring RFG in
certain non-attainment areas and allowing other states with
non-attainment areas to opt-in.  All but two states in the OTR are
participating, in whole or in part, with the federal program, however
nearly 1/3 of the gasoline sold in the OTR is not RFG. 



Candidate measure:  

Measure ID: OTR-wide Regional Fuel

Emission Reductions:  

Control Cost:  unknown at this time

Timing of Implementation:  

Implementation Area: All states in the OTR	

NOx

VOC	

~ 4.8 tpsd

~ 139.4 tpsd

 



Policy Recommendation:  Continue to examine the potential for a regional
fuel, keeping in mind that some states like PA may have
statutory/legislative constraints.





Brief Rationale for Recommended Strategy:  The Energy Policy Act of 2005
provides the opportunity for the OTR to achieve a single clean-burning
gasoline without MTBE, as it also eliminates the oxygen content
requirement for RFG.  The authority provided in Energy Act is consistent
with what states promoted through the long debate over MTBE/ethanol/RFG.
 Approximately one-third of the gasoline currently sold in the OTR is
not RFG; most is conventional gasoline.  The new authority plus the
potential for emission reductions from the amount of non-RFG sold in the
OTR provides an opportunity for additional emission reductions in the
region as well as for a reduced number of fuels, and possibly a single
fuel, to be utilized throughout the region.











 

Appendix D – VOC Emissions by County for 2002 and 2009

Table D-1  Adhesives and Sealants VOC Area Source Emission Summary for
2002 and 2009 by County

Table D-2 Adhesives and Sealants VOC Point Source Emission Summary for
2002 and 2009 by County

Table D-3 Cutback and Emulsified Asphalt Paving VOC Area Source Emission
Summary for 2002 and 2009 by County

Table D-4 Consumer Products VOC Area Source Emission Summary for 2002
and 2009 by County

Table D-5 Portable Fuel Containers VOC Area Source Emission Summary for
2002 and 2009 by County

Table D-6 Portable Fuel Containers VOC Nonroad Source Emission Summary
for 2002 and 2009 by State

Table D-7 Reformulated Gasoline Emission Summary by State

Due to their large size, these tables are being transmitted
electronically in the spreadsheet named Appendix_D_VOC_2009.xls.  There
are separate tabs for each of the tables listed above.  

Appendix E – NOx Emissions by County for 2002 and 2009

Table E-1  Reformulated Gasoline Emission Summary by State

Table E-2 Chip Reflash Emission Summary by State

Table E-3 Asphalt Production Plant NOx Emission Summary for 2002 and
2009 by County

Table E-4 Cement Kiln NOx Emission Summary for 2002 and 2009 by County

Table E-5 Glass and Fiberglass Furnace NOx Emission Summary for 2002 and
2009 by County

Table E-6 ICI Boiler NOx Area Source Emission Summary for 2002 and 2009
by State

Table E-7 ICI Boiler NOx Point Source Emission Summary for 2002 and 2009
by State

Due to their large size, these tables are being transmitted
electronically in the spreadsheet named Appendix_E_NOx_2009.xls.  There
are separate tabs for each of the tables listed above.  

Appendix F – State ICI Boiler Regulations

Due to their large size, these tables are being transmitted
electronically in the spreadsheet named Appendix F State ICI Regs.xls. 
There are separate tabs for each state.  In the final report, these
tables will be provided in electronic format  

 	Assumes 100% rule effectiveness, which is reasonable given that the
MWCs are operated with continuous emissions monitoring.

 	The use of SCR to control NOx emissions from MWCs in North American is
limited to very few units (see, e.g.,   HYPERLINK
"http://www.region.peel.on.ca/pw/waste/facilities/algonquin-power.htm" 
http://www.region.peel.on.ca/pw/waste/facilities/algonquin-power.htm )
because the nature of municipal solid waste requires huge SCR reactor
sizes and significant actions to prevent catalyst poisoning.  These
factors, combined with the relatively small size of most MWCs, makes the
use of SCR prohibitively expensive (EPA 2005, comment by IWSA). 

 	Connecticut also has three mass burn refractory units that are
classified as small MWCs and do not use SNCR.  

 	For comparison, EPA places the capital cost of SNCR between 1,600 and
3,300 $/MMBtu (1993 dollars).  In 2002, the 3-unit facility (140
MMBTU/hr per unit) owned by the Connecticut Resources Recovery Authority
in Bridgeport, Connecticut installed SNCR on all three units at a
capital cost of $2.1 million.

 PAGE   

	

TSD for 2006 OTC Control Measure Evaluation	February 28, 2007

	Page  PAGE   vi 

	MACTEC Federal Programs, Inc.

TSD for 2006 OTC Control Measure Evaluation	February 28, 2007

Section 1 – Executive Summary	Page  PAGE   1-8 

TSD for 2006 OTC Control Meaure Evaluation	February 28, 2007

Section 2 – Introduction	Page  PAGE   2-2 

TSD for 2006 OTC Control Measure Evaluation	February 28, 2007

Section 3 – VOC Analysis Methods	Page   PAGE  3-25 

TSD for 2006 OTC Control Measures	February 28, 2007

Section 4 – NOx Analysis Methods	Page   PAGE  4-31 

TSD for 2006 OTC Control Measures	February 28, 2007

Section 5 – References	Page   PAGE  5-3 

TSD for OTC Control Measure Evaluation	February 28, 2007

Appendix A –Process for Identifying and Evaluating Control Measures
Page A-  PAGE  8 

TSD for OTC Control Measure Evaluation	February 28, 2007

Appendix B – Initial List of Control Measures	Page B-  PAGE  1 

TSD for 2006 OTC Control Measure Evaluation	February 28, 2007

Appendix C – Control Measure Worksheets	Page C-  PAGE  43 

TSD for OTC Control Measure Evaluation	February 28, 2007

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


TSD for 2006 OTC Control Measure Evaluation	February 28, 2007

Appendix E – NOx Emissions by County for 2002 and 2009	Page E-  PAGE 
1 

TSD for 2006 OTC Control Measure Evaluation	February 28, 2007

Appendix F – State ICI Boiler Regulations 	Page G-  PAGE  1 

