1
POST
1996
1­
HOUR
RATE
OF
PROGRESS
PLAN
FOR
THE
BEAUMONT/
PORT
ARTHUR
(
BPA)
NONATTAINMENT
AREA
This
document
is
to
provide
a
technical
review
of
the
revisions
to
the
BPA
ozone
nonattainment
area
=

s
Post
1996
Rate
of
Progress
Plan.

A.
General
Requirements:

Section
182(
c)(
2)
of
the
CAA
requires
each
serious
and
above
ozone
nonattainment
area
to
submit
a
SIP
revision,
which
describes,
how
the
area
will
achieve
an
actual
volatile
organic
compound
(
VOC)
emission
reduction
from
the
baseline
emissions
of
at
least
3
percent
of
baseline
emissions
per
year
averaged
over
each
consecutive
3­
year
period
beginning
6
years
after
enactment
(
i.
e.,
November
15,
1996)
until
the
area
=

s
attainment
date.
Section
182(
c)(
2)(
C)
explains
the
conditions
under
which
reductions
of
oxides
of
nitrogen
(
NOx)
may
be
substituted
for
reductions
in
VOC
emissions.

B.
BPA
Background:

On
March
30,
2004,
EPA
issued
a
final
action
in
the
Federal
Register
reclassifying
BPA
from
moderate
1­
hour
ozone
nonattainment
to
serious.
With
this
new
classification
came
several
requirements
including
a
requirement
to
provide
a
revision
to
the
State
Implementation
plan
showing
the
182(
c)
(
2)
rate
of
progress
requirements
would
be
met
for
1999,
2002
and
2005.

The
Texas
Commission
of
Environmental
Quality
(
TCEQ)
submitted
a
rate
of
progress
plan
for
the
BPA
area
in
a
letter
dated
November
16,
2004.
This
document
is
to
review
these
revisions.

C.
Calculation
of
Target
Levels
of
Emissions
To
demonstrate
that
the
rate
of
progress
requirements
of
the
Clean
Air
Act
will
be
met,
a
State
must
calculate
the
target
level
of
emissions
for
each
milestone
year.
This
calculation
is
complicated
by
the
fact
that
the
Clean
Air
Act
does
not
allow
the
plans
to
take
credit
for
emissions
reductions
due
to
federal
motor
vehicle
and
Reid
vapor
pressure
control
programs
that
were
enacted
prior
to
1990.
Therefore,
the
reductions
from
these
Federal
programs
are
subtracted
from
the
base
line
emissions
resulting
in
A
adjusted
base
year
@

emission
levels.
Because
as
the
fleet
turns
over
from
year
to
year
the
benefits
of
these
programs
change,
the
adjusted
base
year
inventory
must
be
calculated
with
respect
to
each
milestone
year.
In
addition,
the
Clean
Air
Act
also
requires
that
reductions
that
would
accrue
from
correcting
deficiencies
in
the
State
=

s
VOC
Reasonably
Available
Control
Technology
(
RACT)
program,
so
called
RACT
fix
ups,
cannot
be
credited
and
must
be
subtracted
from
the
target
level
of
emissions.
These
constraints
result
in
a
multi­
step
process
for
calculating
the
target
level
of
emissions
in
each
of
the
milestone
years.
EPA
=

s
guidance
for
calculating
emission
target
levels
is
contained
in
the
document
A
Guidance
on
the
Post­
1996
Rate­
of­
Progress
Plan
and
Attainment
Demonstration
@

(
EPA­
452/
R­
93­
015,
January
1994).
Table
1
below
summarizes
the
calculation
of
target
levels
that
were
provided
by
2
TCEQ.
EPA
has
reviewed
the
calculations
and
agrees
that
the
target
level
calculations
have
been
performed
correctly.
As
can
be
seen
in
Table
1,
for
the
time
periods
1997­
1999,
2000­
2002,
and
2003­
2005,
TCEQ
has
substituted
NOx
reductions
for
a
portion
of
the
VOC
reductions.

Table
1:
Calculation
of
VOC
and
NOx
Target
Levels
of
Emissions
VOC
NOx
a.
1990
Emission
Inventory
329.56
313.31
b.
1990
Adjusted
Relative
to
1996
304.97
309.59
c.
15%
Reduction/
0%
NOx
45.75
0
d.
I/
M
Correction
0
0
e.
RACT
fix
ups
4.28
0
f.
1996
Target
Level
(
b­
c­
d­
e)
254.94
309.59
g.
1990
adjusted
to
1999
301.53
309.56
h.
7%
Reduction
VOC/
2%
NOx
21.1
6.19
i.
1997­
1999
fleet
turnover
correction
(
b­
g)
3.44
0.03
j.
1999
Target
level
(
f­
h­
i)
230.4
303.37
k.
1990
adjusted
to
2002
299.70
303.53
l.
0%
VOC/
9%
NOx
0.0
27.32
m.
Fleet
Correction
2000­
2002
(
g­
k)
1.83
6.03
n.
2002
Target
(
j­
l­
m)
228.57
270.02
o.
1990
adjusted
to
2005
298.15
294.87
p.
0%
VOC/
9%
NOx
0.0
26.54
q.
Fleet
Turn
Over
2003­
2005
(
k­
o)
1.55
8.66
r.
2005
Target
Level
(
n­
p­
q)
227.02
234.82
3
D.
Inputs
to
the
Target
Level
Calculation
It
is
now
necessary
to
review
the
inputs
to
the
target
level
calculations.
Examination
of
Table
1
reveals
that
the
following
information
is
necessary
to
perform
the
target
level
calculations:
The
1990
base
year
inventory,
adjusted
base
year
inventories
for
the
years
1996,
1999,
2002
and
2005
and
estimates
of
the
reductions
due
to
correction
of
deficiencies
in
the
RACT
and
I/
M
programs.
The
RACT
deficiencies
were
estimated
and
approved
as
part
of
the
15%
plan
approval
and
will
not
be
re­
evaluated
here.
We
note
that
Texas
correctly
subtracted
the
emission
reductions
due
to
RACT
fix
ups
from
the
target
level
so
no
credit
would
be
taken.
BPA
was
not
subject
to
an
I/
M
requirement
and
thus
had
no
I/
M
deficiencies.
The
1990
inventory
and
the
adjusted
base
year
inventories
have
been
changed
in
this
SIP
revision
from
the
previously
approved
inventories
and
these
changes
are
discussed
below.

Emissions
Inventory:

The
1990
Base
Year
Inventory
is
the
starting
point
for
calculating
the
reductions
necessary
to
meet
the
requirements
of
the
1990
Act.
The
1990
Base
Year
Inventory
includes
all
area,
point,
non­
road
mobile,
and
on­
road
mobile
source
emissions
in
the
3
county
BPA
ozone
nonattainment
area.
The
1990
Base
Year
Inventory
was
originally
approved
on
November
8,
1994
(
59
FR
55586).
The
State
revised
the
1990
Base
Year
Inventory
on
August
8,
1996.
These
changes
for
BPA
were
to
the
VOC
inventory
and
were
approved
February
10,
1998
(
63
FR6659)
The
new
changes
to
the
1990
Base
Year
Inventory
are
summarized
in
Table
2.

Table
2:
1990
Rate­
of­
Progress
Base
Year
Emissions
Inventory
(
tons
per
day)

Base
Year
Inventory
Source
Type
VOC
NOx
Old
New
Old
New
Point
245.35
245.54
221.01
221.01
Area
30.63
24.56
1.44
16.73
On­
road
Mobile
19.11
36.99
41.09
54.94
Non­
road
Mobile
18.44
13.47
60.72
20.63
Total
313.53
320.56
324.26
313.31
These
revisions
are
discussed
below.

Area
Source
Emissions:
TCEQ's
improvements
in
activity
data
and
improved
emissions
factors
resulted
in
major
changes
to
the
following
area
source
categories
­
Oil
and
Gas
Production,
Industrial
Coatings,
Consumer
Products,
and
Stage
I
Gasoline
Marketing.
Texas
has
performed
4
special
studies
for
the
categories
of
Graphic
Arts,
Oil
and
Gas
Production
and
Forest
Fires
and
revised
the
inventory
accordingly.
These
revisions
are
reflected
in
the
revised
inventory.

The
updated
studies
have
resulted
in
a
substantial
increase
in
the
1990
base
year
area
source
NOx
emissions.
The
changes
in
NOx
emissions
are
mainly
due
to
the
inclusion
of
NOx
emissions
from
oil
and
gas
production
derived
from
better
activity
data
and
emission
factors
for
engines.
We
have
reviewed
the
specific
studies
and
their
protocols
and
recommend
the
changes
be
approved.

The
estimate
of
area
source
VOC
emissions
turned
out
to
smaller
based
on
the
revised
activity
data
from
the
studies.

On
Road
Emissions:
TCEQ
has
recalculated
the
1990
on­
road
mobile
emissions
using
MOBILE6,
the
EPA
=

s
required
model.
Otherwise
the
inputs
to
the
1990
on­
road
mobile
inventory
are
unchanged.
We
have
reviewed
the
inputs
to
the
model
and
its
performance
and
recommend
this
change
be
approved.

Off­
road
Emissions
Inventory:
Appendix
7
in
the
submitted
Plan
includes
various
studies
of
offroad
emissions
categories.
In
particular,
TCEQ
has
included
area­
specific
studies
of
aircraft,
locomotive,
ship
and
construction
emissions.
Using
this
area­
specific
information
and
the
latest
version
of
the
non­
road
model
has
resulted
in
a
substantial
improvement
in
the
inventory,
and
we
recommend
approval.

Adjusted
Base
Year
Inventory:

Section
182(
b)(
2)(
C)
explains
that
the
baseline
from
which
emission
reductions
are
calculated
should
be
determined
as
outlined
in
section
182(
b)(
1)(
B)
for
15%
ROP
plans.
This
requires
that
the
baseline
exclude
emission
reductions
due
to
Federal
Motor
Vehicle
Control
Programs
(
FMVCP)
promulgated
by
the
Administrator
by
January
1,
1990,
and
emission
reductions
due
to
the
regulation
of
Reid
Vapor
Pressure
promulgated
by
the
Administrator
prior
to
the
enactment
of
the
Clean
Air
Act
Amendments
of
1990.
These
measures
are
not
creditable
to
the
Rate
of
Progress
Plans.

EPA
=

s
mobile
emission
factor
model
is
used
to
calculate
this
value.
The
model
is
run
setting
the
input
flags
to
only
apply
pre­
1990
controls.
It
is
run
holding
the
vehicle
miles
traveled
constant
at
1990
levels
but
using
the
fleet
mix
projected
for
the
milestone
years.
In
this
way,
the
reductions
from
fleet
turnover
and
pre­
1990
controls
are
factored
out
of
the
baseline
calculations.
Appendix
2,
in
the
submitted
plan,
documents
these
calculations.
EPA
has
reviewed
the
calculation
of
adjusted
base
year
inventories
and
finds
them
acceptable.

E.
Evaluation
of
NOx
Rate
of
Progress:

Substitution
of
NOx
Emission
Reductions:
Clean
Air
Act
section
182(
c)(
2)(
C)
allows
States
to
substitute
reductions
in
NOx
for
the
3%/
year
reductions
in
VOC
required
by
section
182(
c)(
2)(
B)
5
if
the
reductions
in
NOx
would
result
in
reductions
in
ozone
concentrations
at
least
equivalent
to
relying
on
VOC
reductions
alone.
According
to
EPA
guidance,
(
December,
1993
NOx
Substitution
Guidance)
States
are
required
to
justify
substitution
by
illustrating
A
consistency
@

with
the
model
attainment
demonstration.
This
guidance
was
clarified
in
a
memorandum
issued
August
5,
1994,
which
set
two
criteria
for
states
that
did
not
have
completed
attainment
demonstrations
1.
The
NOx
Reasonably
Available
Control
Technology
(
RACT)
regulations
should
be
adopted
and
submitted.
EPA
will
have
to
approve
the
NOx
RACT
rules
no
later
than
the
date
of
approval
of
the
ROP
plan
featuring
the
NOx
substitution.

2.
At
least
one
of
the
two
following
conditions
should
be
met:
(
a)
modeling
of
at
least
one
episode
should
have
been
completed
with
photochemical
grid
modeling
which
shows
that
NOx
reductions
are
useful
in
reducing
ozone
concentrations;
or
(
b)
a
regional
modeling
analysis
supporting
use
of
NOx
controls
to
reduce
ozone
within
the
area
under
consideration
for
use
of
NOx
substitution
should
be
available.

Texas
has
submitted
revised
NOx
RACT
rules
for
the
Beaumont/
Port
Arthur
area
for
the
new
classification.
The
RACT
rules
for
the
previous
classification
were
evaluated
in
a
separate
TSD
and
Federal
register
notice
to
determine
if
they
meet
the
Clean
Air
Act
Requirement
for
RACT.
They
were
approved
on
September
1,
2000
(
65
FR
53172).

Texas
has
provided
modeling
on
several
occasions
indicating
that
NOx
reductions
would
be
beneficial
in
reducing
ozone
levels,
and
EPA
approved
such
an
attainment
demonstration
on
May
15,
2001
(
66
FR
26914).
Most
recently,
Texas
submitted
in
a
letter
dated
October
15,
2005
an
attainment
demonstration
for
the
8­
hour
standard
with
modeling
indicating
NOx
reductions
would
be
necessary
for
the
BPA
area
to
attain
the
standard.

NOx
Reductions:

Table
3
summarizes
the
level
of
NOx
emissions
expected
in
each
year.

Table
3:
Actual
and
Projected
NOx
Emissions
(
tons/
day)
Category\
Year
1990
1999
2002
2005
Point
221.01
131.84
110.23
109.30
Area
16.73
10.86
7.09
6.40
On­
Road
54.94
57.17
49.56
33.97
Off­
Road
20.63
25.34
26.77
27.43
Total
313.31
225.21
193.65
177.1
Target
NA
303.37
270.02
234.82
Table
3
indicates
that
emissions
in
1999,
2002
and
2005
will
be
well
below
the
target
level
of
emissions
for
NOx.
Each
of
the
projections
is
discussed
below.
6
Point
Source
NOx:
Texas
used
actual
reported
emissions
adjusted
for
rule
effectiveness
to
estimate
point
source
emissions
for
1999
and
2002.
For
2005,
only
minimal
additional
emission
reductions
were
projected
by
TCEQ.
In
actuality,
the
attainment
demonstration
called
for
2/
3
of
the
point
source
reductions
to
occur
by
2003
and
an
additional
1/
3
of
the
emission
reductions
to
occur
by
2005
so
additional
emission
reductions
beyond
the
levels
reported
in
2002
are
expected.
The
amount
of
these
additional
reductions
is
difficult
to
predict
because
some
of
the
reduction
in
2002
could
have
been
from
early
reductions
with
the
2003
and
2005
rules.

One
difficulty
in
the
use
of
reported
inventories
to
demonstrate
compliance
with
the
target
levels
calculated
from
the
1990
inventory
is
over
time
emissions
estimation
techniques
change.
Thus,
an
"
apples
to
oranges"
comparison
can
occur
because
the
emissions
in
the
milestone
years
are
being
calculated
differently
than
emissions
were
calculated
in
the
1990
inventory.
Particularly,
for
NOx
sources,
the
early
90'
s
was
a
time
period
when
many
sources
moved
from
engineering
estimates
to
measurements
with
continuous
monitors.
These
emission
estimates
based
on
CEMS
are
more
accurate
but
they
also
tend
to
be
lower
then
the
reported
emissions
based
on
emission
factor
data.
A
straight
comparison
of
emissions
between
1990
and
1996
might
indicate
a
reduction
had
occurred
when
in
reality
only
method
for
estimation
had
changed.

This
issue
was
studied
in
the10/
27/
1999
SIP
revision.
In
Appendix
H
of
that
earlier
SIP,
TCEQ
documented
the
results
of
a
survey
that
indicated
that
some
19%
of
the
reductions
between
1990
and
1996
were
due
to
calculation
changes.
The
remaining
changes
were
the
result
of
the
installation
of
control
devices,
process
changes,
and
the
net
change
due
to
shut
downs
and
start­
ups.
Backcasting
the
survey
results
now
to
adjust
the
1990
inventory
indicates
the
revised
1990
inventory
we
are
addressing
in
this
notice
might
be
about
13
tons
per
day
higher
than
if
it
had
been
calculated
on
the
same
basis
as
previously
approved
1990
base
year
inventories.
A
lower
1990
base
year
inventory
would
result
in
lower
target
levels
in
each
milestone
year.
Each
target
level,
however,
would
be
no
more
than
13
tons
per
day
lower
than
the
target
levels
shown
in
Table
3.
Since,
as
shown
in
table
3,
the
emissions
for
each
of
the
milestone
years
are
far
more
than
13
tons
per
day
under
the
target
level
emission,
possible
paper
reductions
in
emissions
inventories
due
to
emissions
calculation
changes
should
not
impact
the
approvability
of
the
rate
of
progress
plan.

Texas
documents
the
control
measures
that
have
been
adopted
to
reduce
NOx
emissions
on
Sheet
13
of
Appendix
1
of
the
SIP.
The
controls
include
the
institution
of
NOx
RACT
controls
in
1999,
Lean
Burn
Engine
Controls
in
2001,
Phase
I
of
the
attainment
controls
in
2003(
first
1/
3
of
the
controls)
and
phase
II
of
the
attainment
controls
in
2005.
All
of
these
control
measure
have
been
approved
in
separate
federal
register
actions.
Also,
in
the
early
1990'
s
there
were
some
process
shut
downs
that
resulted
in
lower
emissions.

Texas
has
not
projected
additional
reductions
due
to
the
last
phase
of
NOx
controls
that
occurred
in
2005
because
additional
reductions
were
not
needed
to
demonstrate
ROP.
EPA
believes
additional
reductions
will
occur
during
the
time
period
2002­
2005
because
of
the
NOx
reductions
being
put
in
place
as
part
of
the
BPA
attainment
demonstration.
Through
2002,
only
a
25%
reduction
had
occurred
from
the
1996
level
shown
in
the
Appendix.
The
attainment
7
demonstration
projected
a
40%
reduction
in
point
source
emissions
from
1997
levels
so
EPA
believes
that
2005
should
be
10­
20
tons
per
day
lower
than
projected
in
the
ROP
plan.

Area
Source
NOx:
Table
3
shows
area
source
NOx
emissions
decreasing
from
16.73
to
6.40
tons
per
day.
These
reductions
result
primarily
from
decreases
in
emissions
from
the
oil
and
gas
category.
These
decreases
result
from
decreasing
crude
production
in
the
area.
EPA
has
reviewed
the
methodology
and
additional
information
supporting
the
decreases
in
emissions
from
oil
and
gas
production
shown
in
the
Plan
and
finds
it
acceptable.

On
Road
NOx:
The
calculation
of
on­
road
emissions
is
documented
in
Appendix
2
of
the
Plan.
EPA
has
reviewed
the
information
and
believes
the
emission
estimations
are
approvable.
The
reductions
in
emissions
reflect
fleet
turnover
and
the
introduction
of
new
cars
and
trucks
into
the
fleet.
The
reductions
calculated
using
the
latest
transportation
network
estimates
and
MOBILE6
have
been
able
to
more
than
offset
the
increasing
vehicle
miles
traveled
in
the
BPA
area.

Non­
road
Mobile
NOx:
Non­
road
emissions
are
represented
in
the
following
table
4
copied
from
Appendix
1
of
the
Plan.

Table
4:
Non­
Road
Inventory
with
Controls
(
NOx
tons/
day)

Year
1990
1999
2002
2005
Aircraft
0.03
0.04
0.04
0.04
GSE
0.00
0.00
0.00
0.00
Commercial
Marine
9.16
11.12
12.64
13.59
Locomotive
1.80
3.50
3.64
3.82
NONROAD
Model
Categories
9.64
10.68
10.45
9.98
Total
20.63
25.34
26.77
27.34
The
emissions
estimates
in
Table
4
were
calculated
using
methods
documented
in
Appendix
7
of
the
SIP.
Texas
has
used
survey
data
studies
to
improve
upon
the
default
values
in
the
model
for
these
inventory
estimates.
We
have
reviewed
the
information
and
recommend
approval
of
the
non­
road
emissions
estimates.

The
non­
road
model
provides
estimates
of
emissions
from
all
non­
road
categories
except
ships,
trains
and
locomotives.
It
provides
estimates
of
emissions
based
on
the
impact
of
tightening
federal
standards
for
construction
equipment,
mobile
industrial
equipment
such
as
fork
lifts,
recreational
boats,
lawn
and
garden
equipment
and
other
categories
while
taking
into
account
any
growth
in
activity
levels
The
above
estimates
overestimate
the
expected
controlled
2005
emissions
because
they
do
not
8
take
into
account
expected
emission
reductions
that
will
achieved
through
the
Texas
Emission
Reduction
Plan
program
which
provides
grant
money
to
owners
and
operators
of
diesel
equipment
to
use
cleaner
engines
or
add
retrofit
devices
to
clean
the
exhaust.

Summary
of
NOx
ROP:
EPA
believes
that
Texas
has
used
acceptable
methods
to
estimate
the
actual
emissions
and
target
level
emissions
for
the
NOx
ROP
plan
and
demonstrate
that
the
ROP
emission
reductions
milestones
will
be
met.

F.
Evaluation
of
VOC
ROP
VOC
Emissions:
Table
5
documents
that
VOC
emissions
for
1999,
2002
and
2005
are
less
than
the
respective
target
levels.

Table
5:
Actual
and
projected
VOC
inventories
(
tons/
day)

Category\
Year
1990
1999
2002
2005
Point
245.54
84.73
59.12
59.31
Area
24.56
31.48
37.32
36.69
On­
Road
36.99
20.52
17.21
12.59
Off­
Road
13.47
13.29
12.57
10.96
Total
320.56
150.02
126.22
119.55
Target
NA
230.40
228.57
227.02
Point
Source
VOC:
As
with
NOx,
TCEQ
used
the
actual
reported
rule
effectiveness
adjusted
inventories
for
1999
and
2002
to
determine
the
VOC
emissions
in
each
of
these
years.
For
2005,
no
further
reductions
were
projected.
See
sheet
13
of
Appendix
1.
Substantial
emission
reductions
have
occurred
between
1990
and
2002.
The
reductions
are
the
result
of
measures
that
were
included
in
the
previously
approved
15%
plan
through
1996
and
federal
MACT
standards
that
resulted
in
reductions
in
VOCs.
There
is
a
long
list
of
emission
reduction
measures
that
have
been
included
in
the
plan.
The
decrease
in
emissions
as
reported
in
the
2002
inventory
is
evidence
that
these
reductions
have
occurred.

As
with
the
NOx
point
source
reductions,
the
survey
document
in
the
1999
SIP
revision
is
instructive
as
to
whether
some
of
the
reductions
shown
in
the
inventory
are
just
the
result
of
changes
in
emissions
estimation
techniques.
From
the
survey,
it
appears
that
36%
of
the
change
between
1990
and
1996
was
the
result
of
calculation
methodology
changes.
The
remaining
reductions
are
the
result
of
control
programs,
and
changes
in
unit
activity.
So
the
1990
inventory
is
probably
overestimated
when
calculated
on
the
same
basis
as
the
later
year
inventories
by
about
45
tons
per
day.
If
the
1990
inventory
were
reduced
by
45
tons
per
day,
then
the
target
levels
for
each
of
the
milestone
years
would
then
be
reduced
by
no
more
than
45
tons
per
day.
As
can
be
9
seen
in
Table
5,
such
lower
VOC
reduction
targets
could
still
be
met.

Another
concern
is
the
accuracy
of
the
VOC
inventory.
Several
recent
studies
of
ambient
data
taken
from
aircraft
have
indicated
that
VOC
emissions
from
industrial
sources
­
particularly
highly
reactive
VOC
emissions
­
are
underreported
in
the
Houston
Galveston
area
even
though
industry
sources
are
using
EPA
methods
for
emissions
estimation.
It
is
likely
since
many
of
the
same
types
of
sources
are
present
in
the
BPA
area
that
are
present
in
the
Houston/
Galveston
area
and
the
same
emission
estimation
techniques
are
used
in
both
areas
that
some
degree
of
underestimation
has
also
occurred
in
the
BPA
area.

It
is
not
possible
to
determine
to
what
degree
emissions
are
underestimated.
Though
assumptions
could
be
made
about
the
degree
of
underestimation
in
more
recent
years
based
on
the
limited
amount
of
ambient
data
available,
it
is
not
possible
to
determine
to
what
degree
emissions
were
under
estimated
in
1990.
EPA
believes
therefore
that
the
best
can
be
done
at
this
point
is
to
use
comparable
approaches
to
estimating
emissions
between
1990
and
the
milestone
years
so
that
the
relative
reductions
in
emissions
over
the
years
can
be
estimated.
To
that
end,
the
survey
data
discussed
above
has
proved
very
useful
in
factoring
out
reductions
that
are
due
to
calculation
method
changes.

For
future
revisions
to
the
SIP,
we
expect
that
some
of
the
problems
in
the
emissions
estimation
will
be
mitigated.
Texas
now
requires
that
fugitive
emissions
be
calculated
using
correlation
equations.
This
is
the
most
sophisticated
method
of
estimating
fugitive
emissions
short
of
bagging
each
potential
leaking
component.
Texas
also
requires
companies
that
have
monitoring
programs
for
their
cooling
towers
to
use
the
monitoring
data
to
estimate
emissions
instead
of
using
the
"
controlled"
EPA
emission
factors.
If
they
do
not
have
monitoring
data
they
must
use
the
uncontrolled
factor.
This
approach
will
encourage
sources
to
monitor
the
cooling
water
inlets
to
establish
their
actual
emissions.
Texas
has
initiated
a
stakeholder
process
to
investigate
further
improvements
to
the
inventory.

Area
Source
VOC:
Area
source
emission
reductions
are
summarized
on
Sheet
12
of
Appendix
1
of
the
SIP.
The
estimates
shown
in
Table
5
are
the
uncontrolled
estimates.
In
other
words,
TCEQ
has
demonstrated
that
BPA
is
meeting
its
ROP
targets
without
taking
credit
for
any
area
source
reductions.
In
fact,
there
have
been
a
number
of
controls
to
this
category,
including
stage
II
controls
on
gas
stations
and
national
controls
on
consumer
products
and
architectural
coatings.
Texas
has
credited
these
controls
to
the
contingency
plan.
The
amount
of
reductions
is
documented
in
Table
4­
3
of
the
SIP.

On
Road
VOC:
The
calculation
of
on­
road
emissions
is
documented
in
appendix
2
of
the
SIP.
EPA
has
reviewed
the
information
and
believes
the
emission
estimations
are
approvable.
The
reductions
in
emissions
reflect
fleet
turnover
and
the
introduction
of
new
cars
and
trucks
into
the
fleet.

Non­
Road
Mobile
VOC:
Table
6
delineates
the
estimated
emissions
of
VOCs
from
non­
road
mobile
sources.
10
Table
6:
Non­
Road
Inventory
with
Controls
(
VOC
tons/
day)

Year
1990
2002
2005
2007
Aircraft
0.06
0.07
0.07
0.07
GSE
0.0
0.0
0.0
0.0
Commercial
Marine
0.27
0.33
0.37
0.41
Locomotive
0.07
0.14
0.15
0.15
NONROAD
Model
Categories
13.07
14.46
15.14
15.87
Total
13.47
15.00
15.74
16.51
The
reports
listed
in
Appendix
7
of
the
SIP
document
these
emission
levels.
EPA
has
reviewed
the
information
and
recommends
approval.

G.
ROP
Motor
Vehicle
Emissions
Budget
The
Rate
of
Progress
budgets
are
contained
in
Table
7.
These
budgets
come
directly
from
the
onroad
mobile
source
emission
projections
shown
in
Tables
3
and
5.
These
tables
show
that
these
budgets
are
consistent
with
meeting
the
ROP
goals.
In
accordance
with
40
CFR
93.118(
e)(
4),
the
availability
of
these
budgets
for
review
by
the
public
was
posted
on
EPA's
adequacy
website
on
December
7,
2004
for
a
period
of
greater
than
30
days.
No
comments
were
received
during
this
time.
We
recommend
that
these
MVEB
=

s
be
proposed
for
approval.

Table
7:
SIP
ROP
Motor
Vehicle
Emissions
Budgets
(
Tons
per
day)

Year
NOx
VOC
1999
57.17
20.52
2002
49.56
17.21
2005
33.97
12.59
H.
Summary
and
Recommendation:
TCEQ
has
used
acceptable
techniques
to
show
that
emissions
in
1999
and
2002
were
well
below
the
target
level
for
those
years
and
that
emissions
in
2005
will
be
below
the
rate
of
progress
target
level.
Therefore
we
recommend
approval
of
the
Beaumont/
Port
Arthur
Rate
of
Progress
Plan.
In
addition,
TCEQ
has
adopted
motor
vehicle
emissions
budgets
based
on
the
Rate
of
Progress
Plan
that
should
also
be
approved.

I.
Contingency
Measures:
The
Clean
Air
Act
requires
that
States
have
Contingency
Measures
11
that
will
be
implemented
if
an
area
fails
to
meet
a
milestone
or
misses
its
attainment
date.
EPA
has
interpreted
this
requirement
to
mean
that
the
State
should
identify
specific
measures
that
will
achieve
an
additional
3%
reduction
in
emissions
with
no
further
action
by
the
State.
In
this
case,
Texas
has
clearly
demonstrated
that
the
1999
and
2002
ROP
milestones
have
been
met
and
therefore
no
contingency
measures
are
required
to
be
implemented
for
failure
to
meet
those
ROP
milestones.
Further,
TCEQ
has
shown
that
in
2005,
emission
reductions
will
be
much
more
than
the
3%
emission
reduction
required
for
2002­
2005
(
see
Table
3
and
Table
5).
These
surplus
emission
reductions
can
be
creditable
as
a
contingency
for
meeting
the
2005
ROP
milestone.
TCEQ
has
also
shown
in
the
SIP
that
in
the
year
following
2005,
i.
e.,
2006
that
more
than
a
3%
reduction
will
occur
(
See
Table
4­
6
of
the
SIP).
For
the
above
reasons,
EPA
believes
that
TCEQ
has
sufficient
ROP
contingency
measures
to
insure
the
BPA
area
remains
on
track
to
meet
its
Rate
of
Progress
goals
through
2005.

On
May
26,
2005
at
70
FR
30592,
EPA
issued
a
rule
that
defines
the
one­
hour
"
applicable
requirements"
the
BPA
area
is
still
required
to
meet.
One­
hour
ROP
contingency
measures
are
not
an
"
applicable
requirement."
Therefore,
it
is
recommended
that
no
action
be
taken
on
the
ROP
contingency
plan.
