Appendix D13

Attachment 2: Estimated Emission Reduction Calculations to Support
Additional Control Measures and Benefits Not Included in the Regional
Modeling

New Jersey is working to propose rules that will produce additional
emission reductions that were not included in the regional modeling. 
These measures include federal, regional initiatives, State initiatives,
and additional benefits not included in earlier calculations of
benefits.  The estimated additional benefits from these measures are
listed in Table D13.3 and the measures and more detailed calculations
are presented in the following section.  These additional benefits
provide further confidence that New Jersey will attain the 8-hour ozone
National Ambient Air Quality Standard (NAAQS) by 2009.

1.	Regional - New Refinery Rules

New Jersey is preparing to propose rules to reduce emissions from
refineries from fluid catalytic cracking units (FCCUs), leaks detection
and repair (LDAR), flares, and process heaters and boilers.  The largest
categories of oxides of nitrogen (NOx) emissions from refineries are
from boilers and process heaters.  Controlling boilers and process
heaters will result in approximately 40 percent (%) in NOx emissions
using Ultra-low NOx burners (ULNB) or selective catalytic reduction
(SCR).  The 2002 inventory for this category is approximately 8.2 tons
per day (tpd) and a 40 percent reduction will yield an emission benefit
of about 3.15 tpd of NOx.  In addition, controlling VOC emissions from
flares will result in the largest reduction of VOC emissions for
refineries.  The 2002 VOC emissions inventory for flares is 1.4 tpd and
installing Flare Gas Recovery (FGR) systems will result in an emission
benefit of approximately 0.78 tpd.  In total, the control measures for
refineries will result in an emission benefit of 3.28 tpd of NOx and
1.55 tpd of VOC.

New Jersey has two major point source facilities that will be subject to
the proposed rule, one in the Northern New Jersey/New York/Connecticut
nonattainment area and one in the Southern New Jersey/Philadelphia
nonattainment area.  The other refineries in the State are subject to
similar control measures as a result of Administrative Consent Orders
(ACOs).  The Table 1 below shows the proposed control measures, the 2002
actual emissions, and the estimated reduction for volatile organic
compounds (VOC) and NOx by 2009.

Table 1: Estimated Reductions from Refineries (tons per day)

Proposed Control Measure	% NOx Reduction*	NOx

2002 Emissions (tpd)

	Estimated NOx

2009 Benefits (tpd) 	% VOC Reduction*	VOC

2002 Emissions (tpd)

	Estimated VOC

2009

Benefits (tpd) 

Fluid Catalytic Cracking Unit (FCCU)	40%	4.6	-**	85%	0.37	0.31

Leak Detection & Repair (LDAR)	-	-	-	50%	1.1	0.47

Flares	36%	0.37	0.13	55%	1.4	0.78

Boilers &  Process Heaters	40%	8.2	3.15	-	-	-

Total	-	13.17	3.28	-	2.87	1.55

*Percent reductions are based on the information provided in the NJDEP
white papers referenced in this section.  The NJDEP white papers
calculated emission benefits in tons per year.  In this SIP, those
emission benefits were converted to tons per day.

**NOx reductions are expected post-2009.

2.	Regional - High Electrical Demand Day Initiative

As part of the High Electrical Demand Day (HEDD) Initiative, New Jersey
has committed to reduce NOx emissions in those electrical generating
units that primarily operate on high electrical demand days by 19.8 tons
per day by 2009.  As of June 13, 2007, New Jersey joins the following
OTC States in signing the Memorandum of Understanding regarding this
initiative: Connecticut, Delaware, Maryland, Maine, Massachusetts, New
Hampshire, New Jersey, Rhode Island, and Vermont.  A copy of the
Memorandum of Understanding can be found in Appendix C1.

In order to determine the emission reductions for New Jersey, emissions
comparisons were made between an average day in June 2005, and a very
high electric demand day in July 2005 that showed a 145% increase in New
Jersey electric generator NOx emissions and five 8-hour ozone
exceedances.  Estimated emissions from the 33 HEDD combustion turbines
which operated on the high demand day without water injection were
reduced by 40%.  Forty percent reduction is what would be generally
achievable by the installation of water injection.  Emissions from the
five (5) HEDD boilers that were operating without selective
non-catalytic reduction (SNCR) were reduced by 30%.  A thirty percent
reduction is what would be generally achievable by the installation of
SNCR.  Note that this level of control provides an estimate of the
benefits; not all units will be able to meet such reductions.  For 2009,
it is expected that the generators will be submitting plans to achieve
the emission reductions to the State for case-by-case reviews. 

The difference between the emissions as originally reported and the
emissions as reduced by the above calculations is 19.8 tons for New
Jersey.  These HEDD emission reductions were estimated to be 13.8 tons
in the Northern New Jersey/New York/Connecticut nonattainment area and
6.1 tons in the Southern New Jersey/Philadelphia nonattainment area
based on the location of the HEDD units.  Emission reduction estimates
for the States that share a multi-state nonattainment area with New
Jersey are listed Table D13.3.

3.	State - New Jersey Diesel Idling Rule Changes Calculations 

Changes to Subchapter 14, Control and Prohibition of Air Pollution from
Diesel-Powered Motor Vehicles, were proposed in 2006 and adopted in May
2007.  Emission reductions will be realized through implementation of
these rule changes.  These changes included clarifying the language on
some exemptions; eliminating other exemptions, such as sun setting the
sleeper berth exemption in 2010; and other associated changes such as
enforcement, education, outreach, and legislative changes.  There are
both NOx and PM benefits for this rule.  The NOx benefits calculations
are included in this Appendix.

Methodology:

Emission benefits were estimated by starting with a published value for
the percent of heavy duty truck emissions that result from idling,
applying an assumed idling reduction percent and applying this to the
New Jersey 2009 inventory emissions for heavy duty highway trucks. 

Idling emissions from on-road (class 8) heavy duty highway trucks
represent approximately 7.8% of total emissions.

Due to the inclusion of other heavy duty trucks in Subchapter 14
(classes 3-7, in addition to class 8 mentioned above), the amount of
emissions attributable to idling was increased from 7.8% to 10%.  

Assuming that New Jersey’s actions will reduce idling by 50%, overall
emissions from heavy duty highway trucks will be reduced to 5% (50% of
10%).

This 50% reduction in idling from Class 3-8 vehicles is estimated to be
achieved from the following sources: 

Subchapter 14 rule revision (which includes eliminating / tightening
many exemptions, the phasing-in of idling alternates such as auxiliary
power units and sun setting the sleeper berth exemption in 2010),

Increased enforcement through a legislative language change (N.J.S.A.
39:3-70.2), which allows State and local police to clearly enforce this
rule,

Education and outreach,

Idling sweeps by the Compliance and Enforcement group, 

Sales of “No Idling” signs, yielding increased awareness of the
regulation

The 2009 Emissions Inventory (for all on-road diesel heavy duty
vehicles) is 111 tons per summer day NOx.  A 5 % reduction yields
approximately 6 tons per summer day decrease in NOx.  The emission
benefit was allocated as 3 tpsd NOx for the Northern New Jersey/New
York/Connecticut nonattainment area and 3 tpsd NOx for the Southern New
Jersey/Philadelphia nonattainment area based on vehicles miles traveled
for heavy duty highway trucks. 

4.	State - New Jersey Diesel Cutpoint Rule Changes 

The New Jersey Department of Environmental Protection (NJDEP) is working
toward proposing and adopting in accordance with the New Jersey
Administrative Procedures Act and the New Jersey Air Pollution Control
Act changes to establish more stringent test standards (cutpoints) for
the existing diesel inspection and maintenance (I/M) program.  The
stricter cutpoints will result in additional emission reductions of VOCs
and NOx.  Emission reduction estimates are shown in tons of pollutants
per day. 

 

Table 2: 2009 Statewide Emission Benefits from Proposed Stricter Diesel
I/M Cutpoint Program (Tons/Day)

2009 Emission Benefits from Proposed Stricter Diesel I/M Cutpoint
Program

(Tons/Day)

VOC 	                   0.45

NOx 	                   0.13



The methodology for the estimated benefits of the expected rule is
described in this section.

Estimating inventory reductions due to diesel I/M using the USEPA
MOBILE6 model directly is not possible because MOBILE6 has no diesel I/M
model representation and assumes almost no deterioration of diesel
vehicles.  The USEPA may assume additional in-use deterioration and
mal-performance corrections of diesel vehicles in their future on-road
emission model called Motor Vehicle Emission Simulator (MOVES).

The NJDEP has developed the following preliminary methodology to
estimate emission benefits for stricter diesel I/M cutpoints.  The
California Air Resources Board (CARB) has documented a series of tables
of Heavy-Duty Diesel Vehicle (HDDV) emission I/M failure rates and
pollutant specific mal-performance factors.  A mal-performance factor is
the average fraction that emissions increase for vehicles that fail
inspection.  The mal-performance factors used for the New Jersey
methodology were derived from the CARB tables of mal-performance
frequency and effects by model year and vehicle weight class.  The
factors were weighted by model year and vehicle type.  Each criteria
pollutant has its own mal-performance factor.  The preliminary New
Jersey methodology uses: CARB mal-performance factors, New Jersey
Heavy-Duty Diesel Vehicle (HDDV) vehicle miles traveled (VMT), MOBILE6
HDDV emission factors in grams per mile (GPM) for each criteria
pollutant, and the failure/repair rates from the New Jersey diesel I/M
program. 

Emission benefits for the existing I/M program are estimated as the sum
of the deterrent benefit and the repair benefit.  It is necessary to use
data collected at the beginning of the New Jersey diesel I/M program and
compare it to data collected after the initial start-up period.  The
deterrent benefit is the product of: the difference between the
pre-enforcement and post-enforcement I/M failure rates, the HDDV VMT,
the mal-performance factors, and the average MOBILE6 HDDV emission
factors.  The repair benefit is the product of: the Diesel Emissions
Inspection Center (DEIC) failure rate, the repair rate, the HDDV VMT,
the mal-performance factors, and the average MOBILE6 HDDV emission
factors.  The repair rate is estimated by adding together: the number of
vehicles repaired during the inspection, the number of vehicles that
passed a violation reinspection, and the number of vehicles that passed
a later inspection.  This sum is divided by the total number of initial
inspection failures (pre-repair fails + violation reinspections) to
obtain the repair rate.   

The next step is to estimate the emission benefits of reducing the I/M
diesel cutpoints, i.e., the “secondary implementation.”  When
opacity cutpoints are reduced, the impact (mal-performance factors) of
the secondary implementation must be adjusted from the impact of the
initial I/M program implementation to include only the lower end of the
mal-performance range (marginal emitters).  There will also be a
deterrent benefit associated with the cutpoint change that can be
initially estimated by comparing the roadside inspection data to the
annual DEIC inspection data. Vehicles that arrive for their annual
inspection tend to have necessary maintenance performed prior to
inspection.  Vehicles pulled over at roadside are more likely to be in
normal operational mode; that is, possibly in need of repairs or
maintenance.  The ratio of roadside failure rates to annual DEIC rates
can provide an estimate of the deterrent factor involved in a secondary
implementation.  The actual impact of deterrence will be measurable once
failure rates stabilize a year or two after introduction of the new
cutpoints. 

The emission benefits of the cutpoint change are estimated as the sum of
the repair benefits and the deterrent benefits.  The repair benefits are
estimated as the product of: the projected increase in the annual DEIC
failure rate, the repair rate, the secondary implementation
mal-performance factor, the HDDV VMT, and the average MOBILE6 HDDV
emission factors.  The secondary implementation mal-performance factors
were derived by adjusting the mal-performance factors by the fractional
change in cutpoints for each model year range.  The deterrent benefits
were estimated by multiplying the repair benefits by the ratio of the
roadside failure rate to annual DEIC failure rates for the cutpoint
changes.

The following is a summary of the equations used for the New Jersey
methodology.

Estimation of the Emission Benefits for the Current Diesel I/M Program

Diesel I/M Benefits = Diesel I/M Repair Benefit (DRB) + Diesel I/M
Initial Deterrent Benefit (DDB) 

Diesel I/M Repair Benefit (DRB) Estimation:

DRB  =  Failure Rate *  Repair Rate * NJ Average Daily HDDV VMT  *  NJ
HDDV Average Emission Factor From Mobile 6  *  Mal-performance Factor

Failure Rate = DEIC initial fail rates within a calendar year. (CY 2002)

Repair Rate = (RV + V1 + RIP) / IVF	

	where:

	RV = number of repaired vehicles (pre-repair fail/post-repair pass
during the initial inspection)

V1 = number of violation reinspections (pre-repair pass only)

RIP = number of reinspection passes (initially failed vehicles, tracked
to a post-repair pass on a later inspection)

IVF = number of Initial Inspection Vehicle Fails (Pre repair fails +
Violation reinspections*)

	*Pre-repair pass only – A portion of violations came in repaired
prior to inspection, but after the violation.

The data used to derive the fail and repair rates is from the DEIC
periodic inspection database.

The Mal-performance Factor is the average fraction that emissions
increase for vehicles that fail inspection.  The mal-performance factors
used for the New Jersey interim methodology were derived from the CARB
tables of mal-performance frequency and effects by model year and
vehicle weight class.  The factors were weighted by model year and
vehicle type.  Each criteria pollutant has its own mal-performance
factor.

Diesel I/M Initial Deterrent Benefit (DDB) Estimation:

DDB = FRD * DRB                                  

where:

FRD = Failure Rate Differential (ERF1 – ERF2)

ERF1 = pre-enforcement fail rate (actual tested vehicles)

ERF2 = post-enforcement fail rate (actual tested vehicles)

These fail rates are for roadside inspection data, pre and post
enforcement of the I/M program.  Pre-enforcement roadside failure rates
are based on roadside team data from April 1996 to January 1998.

Estimation of Emission Benefits for the Proposed Cutpoint Change

Cutpoint Change Benefit = Repair Benefits Due to Cutpoint Change +
Deterrent Benefits Due to Cutpoint Change

Both the repair and deterrent benefits can be expressed as a HDDV
mileage rate that when multiplied by the NJ HDDV Average Emission Factor
from MOBILE6 results in annual emission benefits.  These mileage rates
are called “Secondary repair mileage” and “Secondary deterrent
mileage” so that:

Cutpoint Change Benefit = (Secondary Repair Mileage + Secondary
Deterrent Mileage) * NJ HDDV Average Emission Factor from MOBILE6

Secondary Repair Mileage = Projected Annual Inspection Failure Rate
Increase * Repair Rate * Secondary Implementation Mal-performance Factor
* NJ Average Daily HDDV VMT

Projected Annual Inspection Failure Rate and Repair Rate are calculated
using data from the DEIC periodic inspection database.  The fail rates
due to the cutpoint changes are based on an analysis of the opacity
data.

Secondary Implementation Mal-performance Factor = Weighted Fleet
Fraction by Model Year Range * Fraction of Opacity Change *
Mal-performance Factor

Fraction of Opacity Change = (Old Cutpoint – New Cutpoint) / Old
Cutpoint

Weighted Fleet Fraction by Model Year Range = Fraction of Fleet summed
from beginning to end of cutpoint range.

Secondary deterrent mileage = Secondary repair mileage * (Ratio of
Annual Inspection failure rate due to the cutpoint changes to Roadside
Failure rate due to the cutpoint change)

5.	State - Municipal Waste Combustors

The NJDEP is considering proposing a NOx standard in the range of 100 to
150 ppm for municipal solid waste combustors (MSW), based upon the
ability of selective non-catalytic reduction (SNCR) to reduce emissions
more than are now being achieved.  New Jersey has five resource recovery
facilities located in the following counties:  Essex, Union, Warren
(Northern New Jersey/New York/Connecticut nonattainment area), Camden,
and Gloucester (Southern New Jersey/Philadelphia nonattainment area). 
There are 13 municipal waste combustors (MWC) at these five facilities. 
The NJDEP anticipates that a NOx emission reduction of greater than 100
tons per year (67 tpy for May 1, 2009 through Dec 31, 2009) or 0.27 tons
per day may be possible with this measure. 

Table 3: Estimated Reductions from Municipal Waster Combustors

Municipal Solid Waste Plant	Air Flow Rates in Actual Cubic Feet per
Minute (ACFM) 	Air Flow Rates in Dry Standard Cubic Feet per Minute 
(DSCFM) 	Pounds per hour using 100 ppm NOx limit	Pounds per hour using
130 ppm NOx limit	Pounds per hour using 150 ppm NOx limit

Essex	 237,900 	60867	44	57	65

Essex	 220,000 	56287	40	52	60

Essex	 229,000 	58590	42	55	63

Average ACFM	 228,967 	58581



	Camden	   97,409 	24922	18	23	27

Camden	   99,064 	25346	18	24	27

Camden	 101,495 	25967	19	24	28

Average ACFM	   99,323 	25412



	Union	 128,029 	32756	23	30	35

Union	 131,191 	33565	24	31	36

Union	 130,767 	33457	24	31	36

Average ACFM	 129,996 	33259





	0	0	0	0

Warren	   50,005 	12794	9	12	14

Warren	   55,702 	14251	10	13	15

Average ACFM	   52,854 	13523





	0	0



Gloucester	   62,820 	16072	12	15	17

Gloucester	   72,130 	18454	13	17	20

Average ACFM	   67,475 	17263











Total pounds per hour =	296	385	444







	Total tons per year = 

	1296	1685	1944















Assumption: 15% oxygen in the stack and 300 degrees F stack temperature







	Actual 2002 NOx in tons per year = 	1,803	Expected reductions = 	507
118









Permitted NOx = 	3,541







The calculations of the estimated emission reductions, using the 130 ppm
NOx limit as an example:  

Estimate emissions from each municipal solid waste plant in pounds per
hour.

Convert pounds per hour to tons per year: 

(lbs/hr)(8760 hours/year)/2000 lbs/ton = tons/year

(385 lbs/hr)(8760 hours/year)/2000 lbs/ton = 1685 tons/year 

Calculate estimated emission reductions:

	Expected reductions in emissions from MSW plants in tons/year = 

 	(Actual 2002 NOx emissions from MSW plants in tons/year) – (Emission
emissions from the MSW plants in tons/year)

 = (1803 tons/year) – (1685 tons/year) 

= 118 tons/year

The NJDEP estimated these benefits based upon permitted airflow rates at
each facility.  These emissions are higher than the actual emissions
reported by the facility because, in general, the facilities operate at
air flow rates below the permitted level.  Also, the NJDEP anticipates
that the facilities will decrease their emissions due to optimizing
their existing NOx control systems (i.e., either injecting more ammonia
or adding more nozzles).  The NJDEP also expects that Camden County
Resource Recovery facility will need to install a new NOx control to
comply with the proposed rules.  Therefore, the NJDEP expects that the
estimated benefits will be even greater than those calculated.

6.	State - Petroleum Storage Tanks

New Jersey is working on proposing control measures for storage tanks
which concentrates on the following storage operations; external
floating roof tanks with slotted guide poles, degassing and interior
tank cleaning operations, floating roof landing losses, and gasoline
external floating roof tanks without domes.  These storage operations do
not have any VOC emission controls.  The controls that will achieve
reductions by 2009 include the external floating roof tanks with slotted
guide poles and degassing and interior tank cleaning operations. 
Anticipated emission reductions from controls for floating roof landing
losses and gasoline external floating roof tanks without domes are not
included in this SIP revision as they will occur post-2009 as the tanks
are taken out of service.  The control measures and benefits under
consideration for 2009 are summarized in Table 4.  For 2009, the total
reductions are 2.25 tons per day (tpd) during the ozone season, and 464
tons per year (tpy), and they will come from the cleaning/degassing
provisions of the rule (1.74 tpd) and the deck fitting retrofits for
external floating roof tanks (0.51 tpd).  

Table 4: Estimated 2009 VOC Benefits from Petroleum Storage Tank Control
Measures

Control Measure	Estimated 2009 Benefit 

(tons per day)

External floating roof tanks with slotted guidepole sleeves & covers
0.51

Tank degassing & cleaning	1.74

TOTAL	2.25



Slotted guidepole sleeves and covers would be required for tanks storing
VOC and/or refinery products with a vapor pressure of less than 11.0
psia on external floating roof tanks which amounts to about 118 tanks
for New Jersey.  The base inventory for 2002 is 0.52 tpd (189 tpy). 
Calculating growth and control from this measure would reduce this
category to 0.01 tpd (2 tpy) for 2009 with a 99% reduction in VOC from
controlling 50% of the 236 external floating roof tanks in New Jersey. 
The emission reductions of approximately 0.51 tpd were allocated to each
nonattainment area based on the ratio of storage tanks located in New
Jersey in the Northern New Jersey/New York/Connecticut area (80%) and in
the Southern New Jersey/Philadelphia nonattainment area (20%).

The control measure that New Jersey is considering for tank degassing
and interior tank cleaning will have an approximate efficiency of 95%. 
New Jersey has approximately 1000 floating roof tanks that store VOC
and/or refinery products with a vapor pressure less than 11.0 psia. 
This control measure is based on the number of tanks cleaned during the
ozone season once every 10 years (or 100 tanks per year).  The base
inventory for 2002 is 292 tpy (calculated over 159 days, because the
requirements only apply during ozone season).  Calculating growth and
control from this measure would reduce this category to 0.094 tpd (15
tpy) with a 95% reduction in VOC for 2009 (calculated for 159 days,
because requirements only apply during ozone season).  Estimated
emission reductions of 1.74 tpd were allocated to each nonattainment
area based on the ratio of storage tanks located in New Jersey in the
Northern New Jersey/New York/Connecticut area (80%) and in the Southern
New Jersey/Philadelphia nonattainment area (20%).

NOx Rule (2005)

The 2005 NOx rule was included in the modeling, but additional emission
reductions were estimated in addition to those estimated for the
modeling.  Estimated emission reductions from the New Jersey 2005
amendments to Subchapter 19 “Additional NOx controls” were
calculated in 2001 by E.H. Pechan.  However, as discussed in the New
Jersey rule proposal dated September 20, 2004, additional reductions
were estimated from annual tune-ups for boilers.  The benefits of the
NOx RACT rule (2005) included in the regional modeling were 7 tpsd
(point and area sources) (see Appendix E); the benefits included in the
New Jersey 2005 rule proposal were 13.3 tpsd.  The additional emission
reductions, for point sources, are approximately 4.7 tpsd; these
additional emission reductions were allocated to each nonattainment area
based on location such that 3.1 tpsd of benefits are in the Northern New
Jersey/New York/Connecticut area (66%) and 1.6 tpsd are in the Southern
New Jersey/Philadelphia nonattainment area (34%). 

8.	Portable Fuel Container Rules

New Jersey’s existing Portable Fuel Container rule, which was one of
the six OTC 1-hour ozone shortfall measures discussed in Chapter 4, and
the anticipated amendments to that rule discussed as a BOTW measure in
Chapter 4, were included in the 2009 BOTW modeling.  However, additional
emission reductions are anticipated beyond those estimated for the
modeling.  

Emissions from Portable Fuel Containers come from both area and non-road
sources.  However, for New Jersey, only the estimated area source
emission reductions for the 2005 Portable Fuel Container rule and the
anticipated BOTW PFC rule amendments were included in the 2009 BOTW
modeling.  For further details regarding the 2005 Portable Fuel
Container rule calculations and additional details regarding the
anticipated BOTW Portable Fuel Container amendment calculations see
Appendix E.  The NJDEP has calculated the following additional
reductions for the non-road sector:

approximately 2.1 tpsd of VOC in 2009 for the 2005 PFC rule, and;

approximately 0.3 tpd per summer day of VOC in 2009 for the anticipated
BOTW PFC amendments.  

The emissions were allocated to each nonattainment area based on the New
Jersey nonattainment area ratios calculated for the 2005 PFC rule; this
equates to approximately 1.7 tons per summer day VOC in the Northern New
Jersey/New York/Connecticut nonattainment area and 0.7 tons per summer
day in the Southern New Jersey/Philadelphia nonattainment area.

9.	ICI Boiler Rule

The BOTW ICI boiler rule, discussed in detail in Chapter 4, was included
in the 2009 BOTW modeling.  However, additional emission reductions are
anticipated beyond the 0.1 tpd that was estimated for the modeling. 
Estimated emission reductions from the anticipated ICI boiler rule were
calculated as discussed in Appendix E.  Based on these calculations, New
Jersey estimates an additional 2 tpd NOx reductions beyond those
included in the 2009 BOTW modeling – 1.4 tpd in the Northern New
Jersey/New York/Connecticut nonattainment area and 0.6 tpd in the
Southern New Jersey/Philadelphia nonattainment area.  The emission
benefits were allocated to each nonattainment area based on the percent
of point source emissions in each nonattainment area.  

 Ahmed, S.  SCS004C – Fluid Catalytic Cracking Unit (FCCU) in a
Petroleum Refinery.  New Jersey Department of Environmental Protection,
Stationary Combustion Sources Workgroup, April 11, 2007.

 Ahmed, S.  SCS004D – Equipment Leaks at Petroleum Refinery.  New
Jersey Department of Environmental Protection, Stationary Combustion
Sources Workgroup, February 22, 2007.

 Ahmed, S.  SCS004B – Flares in a Petroleum Refinery.  New Jersey
Department of Environmental Protection, Stationary Combustion Sources
Workgroup, February 22, 2007.

 Ahmed, S.  SCS004A – Process Heaters & Boilers in a Petroleum
Refinery.  New Jersey Department of Environmental Protection, Stationary
Combustion Sources Workgroup, February 22, 2007.

 Percent emission reductions vary by pollutant and depend upon percent
of flare gas recovered using a Flare Gas Recovery (FGR) system.

 Percent emission reductions vary by pollutant and depend upon percent
of flare gas recovered using a Flare Gas Recovery (FGR) system.

 Memorandum of Understanding Among the States of the Ozone Transport
Commission Concerning the Incorporation of High Electrical Demand Day
Emission Reduction Strategies into Ozone Attainment State Implementation
Planning, March 2, 2007. 

 http://www.otcair.org/

 NESCAUM.  Final Report: Heavy-Duty Engine Emissions in the Northeast,
May 1997. 

 NESCAUM.  Final Report: Heavy-Duty Engine Emissions in the Northeast,
May 1997. 

 http://www.arb.ca.gov/msei/on-road/downloads/tsd/HDT_Emissions_New.pdf

 E.H. Pechan.  Control Measure Development Support Analysis of Ozone
Transport Commission Model Rules.  Prepared for the Ozone Transport
Commission by E.H. Pechan & Associates, Springfield, VA,
01.02.001/9408.000, March 31, 2001.

 New Jersey Register 36 N.J.R. 4228(a); September 20, 2004.

  MACTEC.  OTC Identification and Evaluation of Candidate Control
Measures, Final Technical Support Document.  Prepared for the Ozone
Transport Commission by MACTEC Federal Programs, Inc., Herdon, VA,
February 28, 2007.

 MACTEC.  Development of Emission Projections for 2009, 2012, and 2018
for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region, Final
Technical Support Document.  Prepared for Mid-Atlantic Regional Air
Management Association (MARAMA) by MACTEC Federal Programs, Inc.,
February 28, 2007.

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