May
5,
2005
MEMORANDUM
SUBJECT:
Technical
Support
Document:
Approval
of
Revisions
to
the
Texas
State
Implementation
Plan
for
Ozone
for
Northeast
Texas
and
the
Northeast
Texas
Early
Action
Compact
Area
FROM:
Carl
Young,
Environmental
Scientist
Air
Planning
Section
(
6PD­
L)

TO:
FILE
I.
BACKGROUND
The
Clean
Air
Act
requires
the
Environmental
Protection
Agency
(
EPA)
to
establish
national
ambient
air
quality
standards
(
NAAQS)
for
pollutants
that
cause
or
contribute
to
air
pollution
that
is
reasonably
anticipated
to
endanger
public
health
or
welfare.
States
have
developed
a
State
Implementation
Plan
(
SIP)
which
identify
how
these
standards
will
be
attained
and
maintained.
The
State
must
submit
revisions
to
the
SIP
to
EPA.
EPA
reviews
the
revision
and
approves
it
if
it
conforms
with
the
Clean
Air
Act.
Approval
makes
the
revisions
Federally
enforceable.
If
the
revision
does
not
conform
with
the
Clean
Air
Act
EPA
disapproves
it.
Disapproval
will
lead
to
further
revisions
by
the
State
or
development
of
a
Federal
Implementation
Plan
by
EPA.

In
1979,
EPA
promulgated
a
1­
hour
ground­
level
ozone
standard
of
0.12
parts
per
million
(
ppm).
In
1997,
EPA
promulgated
an
8­
hour
ozone
standard
of
0.08
ppm.
Ozone
concentrations
of
85
parts
per
billion
(
ppb)
or
above
exceed
the
standard
while
concentrations
84
ppb
or
below
do
not
exceed
it.

Nitrogen
oxide
and
volatile
organic
compounds
(
VOC)
emissions
can
react
with
sunlight
to
form
ground­
level
ozone.
The
control
of
emissions
of
these
ozone
precursors
can
help
attain
the
NAAQSs
for
ozone.

In
1996,
elected
officials
and
community
leaders
of
Northeast
Texas
created
Northeast
Texas
Air
Care
(
NETAC)
to
address
ozone
air
quality
concerns
in
Gregg,
Harrison,
Rusk,
Smith,
and
Upshur
Counties.
In
order
to
ensure
attainment
of
the
1­
hour
ozone
standard
EPA,
State
and
local
officials
entered
into
a
Flexible
Attainment
Region
(
FAR)
Agreement
for
Northeast
Texas
in
September
1996.
Through
the
FAR
Agreement,
commitments
to
reduce
emissions
of
4,250
tons
per
year
of
ozone
precursors
were
made
through
Agreed
Orders.
An
Agreed
Order
is
an
enforceable
agreement
between
a
regulated
entity
and
government
regulator.

EPA
did
not
extend
the
FAR
agreement
in
2001
because
of
the
history
of
1­
hour
ozone
standard
exceedances
in
the
area
under
the
FAR.
EPA
did
suggest
that
Texas
and
the
Region
develop
and
implement
an
early
SIP.
NETAC
worked
with
three
companies
in
the
Region
to
obtain
enforceable
commitments
to
make
further
voluntary
reductions
of
nitrogen
oxide
emissions.
Texas
adopted
the
Northeast
Texas
Early
SIP
in
March
2002
and
submitted
it
to
EPA
in
July
2002.

Also
in
March
2002,
the
Texas
Commission
on
Environmental
Quality
(
TCEQ)
proposed
the
use
of
Early
Action
Compact
(
EAC)
agreements
as
an
incentive
for
early
planning
towards
achieving
the
8­
hour
ozone
standard.
The
EAC
is
a
voluntary
plan
to
meet
the
8­
hour
ozone
standard
for
an
area
that
is
approaching
or
monitoring
exceedances
of
the
standard.
The
goal
of
the
compact
is
to
reduce
ground­
level
ozone
earlier
than
the
Clean
Air
Act
requires.
On
December
20,
2002
EPA,
State
and
local
officials
entered
into
an
EAC
agreement
for
the
Northeast
Texas
area.
The
Northeast
Texas
EAC
area
includes
Gregg,
Harrison,
Rusk,
Smith,
and
Upshur
Counties.
Representatives
from
these
counties,
the
Cities
of
Gilmer,
Henderson,
Kilgore,
Longview,
Marshall,
and
Tyler,
the
East
Texas
Council
of
Governments
(
ETCOG),
TCEQ
and
EPA
signed
the
EAC.

An
EAC
gives
local
areas
flexibility
in
meeting
the
8­
hour
ozone
standard,
provided
emissions
from
local
sources
are
controlled
earlier
than
the
Clean
Air
Act
would
require.
The
EAC
requires
submitting
implementation
plans,
implementing
local
control
measures
and
making
progress
reports.
To
date,
the
Northeast
Texas
EAC
area
has
met
all
EAC
milestones.

In
April
2004,
EPA
designated
all
areas
for
the
8­
hour
ozone
standard
(
69
FR
23858).
The
Northeast
Texas
EAC
area
was
designated
as
"
attainment"
for
the
standard.

On
November
17,
2004,
TCEQ
adopted
revisions
to
the
SIP
incorporating
the
Clean
Air
Action
Plan
(
CAAP)
developed
for
the
Northeast
Texas
EAC
area
and
the
related
8­
hour
ozone
standard
attainment
demonstration.
The
CAAP
is
a
plan
to
reduce
ground­
level
ozone
concentrations
throughout
the
EAC
area
to
comply
with
the
8­
hour
ozone
standard
by
December
31,
2007,
and
maintain
the
standard
to
2012.
The
attainment
demonstration
consists
of:
°
analyses
which
estimate
whether
selected
emissions
reductions
will
result
in
ambient
concentrations
that
meet
the
8­
hour
ozone
standard,
and
°
an
identified
set
of
measures
which
will
result
in
the
required
emissions
reductions.

The
CAAP
also
included
a
number
of
additional
control
measures
that
were
not
included
in
the
modeled
attainment
demonstration.
These
measures
are
in
addition
to
any
reductions
necessary
to
demonstrate
attainment
with
the
8­
hour
ozone
standard
by
2007.
Local
control
measures
included
in
the
Northeast
Texas
EAC
SIP
submittal
are
being
implemented
to
ensure
nitrogen
oxide
and
volatile
organic
compound
(
VOC)
emission
reductions.
All
of
these
control
measures
are
being
implemented
as
called
for
in
the
EAC.
The
revisions
were
submitted
to
EPA
on
December
6,
2004.
II.
STATE
SUBMITTALS
A.
Regulatory
Background
Agreed
Orders
for
Northeast
Texas
In
September
2001,
Texas
proposed
revisions
to
the
SIP
for
control
of
ozone
air
pollution
for
the
Northeast
Texas
area.
Notices
were
published
in
newspapers
in
Austin,
Longview
and
Tyler.
A
notice
was
also
published
in
the
September
28,
2001
Texas
Register.
Texas
adopted
revisions
to
the
SIP
on
March
13,
2002
and
submitted
them
to
EPA
on
July
18,
2002.
Reductions
from
these
agreements
are
relied
upon
in
the
EAC
attainment
demonstration.

CAAP
and
Attainment
Demonstration
for
Northeast
Texas
EAC
Area
In
July
2004,
TCEQ
proposed
revisions
to
the
SIP
concerning
the
CAAP
and
8­
hour
ozone
standard
attainment
demonstration
for
the
Northeast
Texas
EAC
area.
Notices
were
published
in
newspapers
in
Longview,
San
Antonio
and
Austin.
A
notice
was
also
published
in
the
July
30,
2004
Texas
Register.
In
August
2004
a
public
hearing
was
held
in
Longview.
TCEQ
revised
the
SIP
on
November
17,
2004
and
submitted
it
to
EPA
on
December
6,
2004.

B.
Description
of
Submittals
[
Note
to
Reader:
Unless
otherwise
specified,
references
are
to
the
December
6,
2004
State
SIP
submittal
pertaining
to
the
CAAP
and
8­
hour
Ozone
Attainment
Demonstration
for
Northeast
Texas.]

Agreed
Orders
for
Northeast
Texas
The
SIP
revision
submitted
in
July
2002
pertained
to
control
of
ozone
air
pollution
for
the
Northeast
Texas
area.
It
contained
an
emissions
summary,
photochemical
modeling
results,
a
rate
of
progress
section,
and
a
control
strategy
including
Agreed
Orders
with
three
companies
for
reduction
of
emissions
of
nitrogen
oxides.
The
three
companies
are:
°
American
Electric
Power,
(
AEP,
formerly
Southwestern
Electric
Power
Company),
°
TXU
Generation
Company
LP
(
TXU),
and
°
Eastman
Chemical
Company.

This
review
pertains
to
the
Agreed
Orders.
The
Agreed
Orders
make
enforceable
reductions
of
emissions
of
nitrogen
oxides.
The
estimated
reductions
in
nitrogen
oxide
emissions
from
the
1997
emissions
inventory
are
listed
in
Table
1.
The
data
for
AEP
and
TXU
are
from
a
March
12,
2002
memo
from
Greg
Yarwood,
ENVIRON
International
Corporation,
to
the
NETAC
Technical
Committee.
The
data
for
Texas
Eastman
Company
is
an
updated
estimate
submitted
with
the
December
2004
SIP
submittal
(
Appendix
I,
page
6­
19).
The
Agreed
Orders
are
enforceable
under
State
law
and
should
reduce
nitrogen
oxide
emissions
by
77.4
tons
per
day.
The
Agreed
Orders
will
be
Federally
enforceable
with
EPA
approval
of
this
SIP
revision.
Table
1.
Estimated
Nitrogen
Oxide
Reductions
from
Agreed
Orders
COMPANY
NITROGEN
OXIDE
REDUCTIONS
Percent
Reduction
Ton/
day
Reduction
AEP
Knox
Lee
Plant
Pirkey
Plant
Wilkes
Plant
16%
29%
44%
1.1
7.5
5.6
TXU
Martin
Lake
Plant
Monticello
Plant
42%
27%
40.7
17.8
Eastman
Chemical
Company
33%
4.7
Each
Agreed
Order
was
signed
by
a
company
on
February
26,
2002
and
by
the
Texas
Natural
Resource
Conservation
Commission
(
now
TCEQ)
on
March
13,
2002.

The
AEP
Wilkes
Plant
is
located
in
Cass
County
while
the
TXU
plants
are
located
in
Rusk
and
Titus
Counties.
While
these
Northeast
Texas
counties
are
not
in
the
Northeast
Texas
EAC
area,
emissions
from
the
plants
can
affect
ozone
levels
in
the
Northeast
Texas
EAC
area.

Emission
reductions
from
the
Agreed
Orders
are
were
included
in
the
Northeast
Texas
EAC
attainment
demonstration
for
the
8­
hour
ozone
standard.

Agreed
Order
2001­
0878­
RUL
for
AEP
American
Electric
Power
Company
owns
and
operates
three
power
plants
in
Northeast
Texas:
°
Knox
Lee
Plant
in
Gregg
County,
°
Pirkey
Plant
in
Harrison
County,
and
°
Wilkes
Plant
in
Cass
County.

The
Agreed
Order
calls
for
the
company
to
implement
several
projects
to
reduce
nitrogen
oxide
emissions.
It
specifies
30
day
rolling
average
nitrogen
oxide
emission
rates
to
be
achieved
at
Knox
Lee
Plant
Unit
number
5,
Wilkes
Plant
Unit
numbers
2
and
3,
and
the
Pirkey
Plant.
"
Thirty
day
rolling
average"
means
an
average,
calculated
for
each
day
that
fuel
is
combusted
in
a
unit,
of
all
the
hourly
emissions
data
for
the
preceding
30
days
that
fuel
was
combusted
in
the
unit.
A
nitrogen
oxide
emission
rate
of
0.18
pounds
per
million
British
Thermal
Units
(
lb/
mmBtu)
will
be
achieved
at
Knox
Lee
Plant
Unit
number
5.
Wilkes
Plant
Unit
numbers
2
and
3
will
each
achieve
a
nitrogen
oxide
emission
rate
of
0.17
lb/
mmBtu.
The
Pirkey
Plant
will
achieve
a
nitrogen
oxide
emission
rate
of
0.22
lb/
mmBtu.
As
an
alternative
to
achieving
the
reductions
at
the
Knox
Lee
and
Wilkes
plants,
AEP
is
allowed
to
achieve
equivalent
reductions
at
the
Pirkey
plant,
in
excess
of
the
30
day
rolling
average
nitrogen
oxide
emission
rate
of
0.22
lb/
mmBtu.
As
an
alternative
to
completing
any
of
the
projects
to
achieve
the
nitrogen
oxide
emission
reductions
AEP
may
propose
to
the
State
alternative
projects
that
would
achieve
equivalent
emissions
reductions.
Additionally,
as
an
alternative
to
achieving
the
nitrogen
oxide
emission
reductions
at
the
Wilkes
and
Knox
Lee
plants,
AEP
may
propose
to
the
State
alternative
projects
that
would
achieve
equivalent
emissions
reductions
at
the
Pirkey
Plant.
TCEQ
will
evaluate
alternative
projects
under
30
TAC
115,
Subchapter
J
(
§
§
115.901­
115.916).
This
process
requires
public
notification
of
proposals
and
was
approved
by
EPA
on
May
22,
1997
(
62
FR
27964).

Agreed
Order
2001­
0879­
RUL
for
TXU
TXU
owns
and
operates
two
power
plants
in
Northeast
Texas:
°
Martin
Lake
Steam
Electric
Station
in
Rusk
County,
and
°
Monticello
Steam
Electric
Station
in
Titus
County.

The
Agreed
Order
calls
for
the
company
to
operate
low
nitrogen
oxide
technology
on
the
three
primary
generating
units
at
each
plant
in
order
to
reduce
nitrogen
oxide
emissions.
It
specifies
that
operation
of
the
three
primary
generating
units
at
each
plant
will
achieve
a
30
day
rolling
average
nitrogen
oxide
emission
rate
of
0.2
lb/
mmBtu.

As
an
alternative
to
operating
the
low
nitrogen
oxide
technology
and
achieving
the
nitrogen
oxide
emission
reductions
on
the
three
primary
generating
units
at
each
plant
the
company
may
to
propose
to
the
State
alternative
projects
that
would
achieve
equivalent
emissions
reductions.
TCEQ
will
evaluate
alternative
projects
under
30
TAC
115,
Subchapter
J
(
§
§
115.901­
115.916).
This
process
requires
public
notification
of
proposals
and
was
approved
by
EPA
on
May
22,
1997
(
62
FR
27964).

Agreed
Order
2001­
0880­
RUL
for
Eastman
Chemical
Company
Eastman
Chemical
Company
owns
and
operates
a
chemical
and
plastics
manufacturing
plant
in
Longview,
Harrison
County.
The
Agreed
Order
calls
for
the
company
to
reduce
nitrogen
oxide
emissions
at
the
plant.
It
specifies
that
the
company
will:
°
shut
down
one
cooling
tower
engine,
°
commit
one
older
natural
gas
fired
engine
to
serve
only
in
a
back­
up
service
capacity,
restrict
its
operation
to
2,190
hours
annually
and
track
its
operating
time,
°
shut
down
five
older
natural
gas
fired
engines,
°
shut
down
ten
gas
reformer
furnaces,
and
°
shut
down
two
synthesis
gas
heaters.

In
order
to
re­
start
any
facility
that
was
shut
down,
the
company
must
propose
to
the
State
one
or
more
alternative
projects
that
would
achieve
equivalent
emissions
reductions.
TCEQ
will
evaluate
alternative
projects
under
30
TAC
115,
Subchapter
J
(
§
§
115.901­
115.916).
This
process
requires
public
notification
of
proposals
and
was
approved
by
EPA
on
May
22,
1997
(
62
FR
27964).
CAAP
and
Attainment
Demonstration
for
Northeast
Texas
EAC
Area
The
SIP
revision
submitted
in
December
2004
incorporated
the
CAAP
and
8­
hour
ozone
standard
attainment
demonstration
for
the
Northeast
Texas
EAC
area.
The
revisions
were
based
on
the
CAAP
and
attainment
demonstration
submitted
to
TCEQ
by
the
area
in
March
2004,
under
its
EAC.
The
attainment
demonstration
includes:
°
analyses
which
estimate
whether
selected
emissions
reductions
will
result
in
ambient
concentrations
that
meet
the
8­
hour
ozone
standard
in
the
Northeast
Texas
EAC
area,
and
°
an
identified
set
of
measures
which
will
result
in
the
required
emissions
reductions.

The
attainment
demonstration
was
supported
by
results
of
photochemical
modeling
and
technical
documentation.
It
shows
that
the
8­
hour
ozone
standard
should
continue
to
be
attained
by
2007
and
maintained
through
2012.
A
Technical
Support
Document
for
the
Modeling
is
attached
(
Attachment
1
of
this
TSD).

The
model
used
is
the
Comprehensive
Air
Quality
Model
with
Extensions
(
CAMx).
The
projected
2007
8­
hour
ozone
design
value
for
Northeast
Texas
is
81
ppb
which
demonstrated
attainment
(
page
3­
5).
The
design
value
is
used
to
determine
whether
an
area
is
attaining
the
ozone
standard.
The
model
took
into
account
expected
growth
and
measures
to
reduce
air
pollution.
These
measures
include
locally
developed
control
strategies,
Texas
SIP
control
strategies,
and
EPA
requirements
such
as
cleaner
vehicles
and
fuels.
The
locally
developed
control
strategies
used
for
the
attainment
demonstration
modeling
are:
°
Agreed
Orders
for
AEP,
TXU,
and
Eastman
Chemical
Company
(
Appendix
A,
page
6­
3),
and
°
enhanced
leak
detection
and
repair
programs
(
LDAR)
for
Eastman
Chemical
and
Huntsman
Chemical
to
control
volatile
organic
compound
emissions
(
page
3­
4).

As
discussed
above,
the
Agreed
Orders
were
adopted
in
2002.
The
LDAR
programs
for
Eastman
Chemical
and
Huntsman
Chemical
are
control
measures
that
were
included
in
the
EAC
SIP
submittal.
These
measures
ensure
nitrogen
oxide
and
VOC
emission
reductions.

A
September
17,
2004
memorandum
from
Greg
Yarwood,
Environ,
to
the
NETAC
Technical
Advisory
Committee,
discusses
the
modeling
that
was
done
for
Northeast
Texas
(
Attachment
2
of
this
TSD).
Table
1
of
the
memo
corrects
previous
computational
errors
and
shows
the
results
of
modeling
that
included
the
Agreed
Orders
but
did
not
include
the
emission
reductions
from
the
LDAR
programs
for
Eastman
Chemical
and
Huntsman
Chemical.
The
design
value
predicted
by
the
model
is
81
ppb.
Table
2
of
the
memo
identifies
the
results
of
additional
modeling
that
took
into
consideration:
°
the
emission
reductions
from
the
LDAR
programs
°
the
Texas
regulation
on
portable
fuel
containers,
and
°
delay
of
a
Texas
regulation
on
nitrogen
oxide
emissions
from
industrial
water
heaters,
small
boilers
and
process
heaters.
Again,
the
design
value
predicted
by
the
model
is
81
ppb.
Table
3
of
the
memo
identifies
the
results
of
modeling
that
included
the
above
items
and
added
an
additional
1.5
tons
per
day
of
nitrogen
oxide
emission
reductions
from
the
Texas
Emissions
Reduction
Plan
(
TERP)
in
the
area.
The
design
value
predicted
by
the
model
remained
81
ppb.
The
modeling
supports
the
predictions
of
the
8­
hour
ozone
standard
attainment
demonstration
for
the
Northeast
Texas
area.

As
discussed
above
Eastman
Chemical
Company
owns
and
operates
a
chemical
and
plastics
manufacturing
plant
in
Longview,
Harrison
County.
Huntsman
Chemical
owns
a
polypropylene
plant
that
is
co­
located
with
the
Eastman
Chemical
facility.
The
LDAR
program
for
Eastman
Chemical
is
enforceable
under
Texas
Voluntary
Emissions
Reduction
Permits
47007,
48588,
and
48590.
Estimated
highly
reactive
VOC
emission
reductions
are
0.63
tons
per
day
for
these
permits.
The
LDAR
program
for
Huntsman
Chemical
is
enforceable
under
Texas
Flexible
Plantwide
Applicability
Limit
Permit
18105.
Estimated
highly
reactive
VOC
emission
reductions
0.08
tons
per
day
for
Huntsman
Chemical.
(
Note:
The
estimated
reductions
for
Huntsman
Chemical
were
incorrectly
listed
as
29
tons
per
day
rather
than
29
tons
per
year
on
page
5­
2
of
the
SIP
submittal).
Eastman
Chemical
also
agreed
to
early
implementation
of
an
additional
LDAR
program
required
by
a
Federal
Maximum
Achievable
Control
Technology
regulation,
(
40
CFR
63,
subpart
UU),
before
July
1,
2005,
which
would
provide
an
additional
0.23
tons
per
day
highly
reactive
VOC
emission
reduction
(
Appendix
A,
page
6­
11).
The
LDAR
program
control
measures
are
enforceable
through
TCEQ
air
permit
conditions.
Copies
of
these
permits
may
be
obtained
from
TCEQ.

The
estimated
benefits
from
the
Texas
portable
fuel
container
rule
are
small
because
the
VOC
emissions
inventory
is
dominated
by
biogenic
emissions.
Texas
assumed
zero
benefit
from
the
rule
in
the
modeling
(
Gerry
Wolfe,
TCEQ,
personal
communication).

Texas
delayed
implementation
of
a
state
regulation
on
nitrogen
oxide
emissions
from
industrial
water
heaters,
small
boilers
and
process
heaters
(
December
17,
2005
Texas
Register).
It
is
estimated
that
the
delay
would
increase
2007
nitrogen
oxide
emissions
by
0.05
tons
per
day
in
the
EAC
area
(
attachment
2
of
this
TSD).

TERP
is
a
set
of
incentive
programs
aimed
at
improving
air
quality
in
Texas.
TERP
provides
funding
to
offset
the
incremental
costs
of
projects
associated
with
reducing
nitrogen
oxide
emissions
from
high­
emitting
internal
combustion
engines.
Projects
in
the
Northeast
Texas
EAC
area
are
eliglible
for
TERP
funding.
TCEQ
has
allocated
funding
for
up
to
1.5
tons
per
day
of
nitrogen
oxide
reductions
in
the
Northeast
Texas
EAC
area
by
2007
(
page
5­
3).
Texas
noted
that
TERP
reductions
were
not
being
relied
upon
for
the
North
East
Texas
attainment
demonstration
(
page
3­
4).

Additional
Measures
to
Reduce
Nitrogen
Oxide
and
VOC
Emissions
The
CAAP
incorporated
into
the
Northeast
Texas
EAC
SIP
submittal
also
includes
a
number
of
additional
local
control
measures
that
were
not
included
in
the
modeled
attainment
demonstration.
These
measures
are
in
addition
to
any
reductions
necessary
to
demonstrate
attainment
with
the
8­
hour
ozone
standard
by
2007.
The
additional
local
control
measures
are
being
implemented
as
called
for
in
the
EAC
to
ensure
nitrogen
oxide
and
VOC
emission
reductions.

The
additional
local
control
measures
include:
°
implementation
of
the
Texas
Emissions
Reduction
Plan
(
TERP)
in
the
area,
°
use
of
18
lower
emitting
propane
light
heavy­
duty
vans
purchased
in
2003
and
2004
for
the
area,
°
public
awareness
programs,
and
°
energy
efficiency
programs
for
Longview,
Marshall
and
Tyler
(
pages
5­
2
to
5­
4).

As
discussed
above
TERP
is
a
set
of
incentive
programs
aimed
at
improving
air
quality
in
Texas.
TCEQ
reported
that
two
projects
in
the
Northeast
Texas
EAC
area
had
been
recommended
for
funding
(
Texas
Emissions
Reduction
Plan,
Biennial
Report
to
the
Texas
Legislature,
December
2004,
www.
tceq.
state.
tx.
us/
assets/
public/
comm_
exec/
pubs/
sfr/
079_
04.
pdf
).
Estimated
nitrogen
oxide
emission
reductions
from
these
projects
are
0.11
tons
per
day.
The
selected
projects
are
listed
in
Table
2.

Table
2.
Projects
in
Northeast
Texas
selected
for
funding
under
TERP
Applicant
Ton/
day
Nitrogen
Oxide
Reduction
Project
Sabine
Mining
Company
0.0556
Replace
older
Bull
Dozer
and
Excavator
New
Waskom
Gas
0.0426
On­
site
Electrification
for
Stationary
Compressor
Pumps
Total
0.11
NETAC
promotes
the
TERP
grants
program
on
its
website
www.
netac.
org.
The
TERP
application
deadline
for
2005
was
January
21,
2005.
Additional
projects
to
reduce
nitrogen
oxide
emissions
in
Northeast
Texas
may
be
funded.

In
2003
and
2004
18
new
lower
emitting
propane
light
heavy­
duty
vans
were
purchased
for
the
ETCOG
Rural
Transportation
Program.
It
is
estimated
that
operation
of
the
eighteen
vans
will
provide
total
emissions
reductions
of
0.4
tons
per
year
of
VOC
and
2.0
tons
per
year
of
nitrogen
oxides.

ETCOG
runs
a
public
education
and
ozone
awareness
program
for
the
EAC
area.
The
purpose
of
the
program
is
to
encourage
practices
that
reduce
emissions
that
lead
to
ozone
formation.
The
program
includes:
°
a
communications
network
to
communicate
ozone
action
day
forecasts;
°
a
NETAC
website
(
www.
netac.
org),
°
production
and
distribution
of
public
service
announcements,
°
school
programs
and
teacher
training
workshops,
°
distribution
of
public
information
and
educational
materials,
and
°
an
annual
Ozone
Season
Kick­
off
meeting
for
Northeast
Texas.

The
Cities
of
Longview,
Marshall
and
Tyler
are
implementing
energy
efficiency
programs.
These
programs
can
reduce
the
demand
for
electricity
and
thus
reduce
emissions
from
electric
generating
power
plants.

Tyler
is
implementing
energy
efficiency
programs
that
involve:
°
building
lighting,
°
high
volume
air
conditioning
and
controls
upgrades,
°
traffic
light
upgrades,
°
park
lighting
upgrades,
and
°
wastewater
plant
motor
and
controls.

As
part
of
its
energy
efficiency
planning
Longview
has
made
improvements
in:
°
lighting,
°
high
volume
air
conditioning
systems,
°
swimming
pool
operations,
and
°
public
safety
communications
equipment.

Marshall
is
initiating
an
energy
efficiency
plan
with
assistance
from
Texas
A&
M
University.

In
compliance
with
the
next
EAC
milestone,
the
control
measures
listed
in
this
section
are
scheduled
to
be
implemented
on
or
before
December
31,
2005.

Maintenance
for
Growth
Per
the
EAC
protocol,
an
emissions
inventory
was
developed
for
the
year
2012.
The
2012
inventory
show
that
anthropogenic
emissions
of
both
nitrogen
oxides
and
VOCs
decrease
from
2007
to
2012,
as
the
result
of
locally
implemented
control
measures
and
Federal
emissions
control
programs
for
vehicles
(
page
2­
4).
This
decrease
in
emissions
is
additional
evidence
that
the
Northeast
Texas
EAC
area
will
maintain
the
8­
hour
ozone
standard
through
2012.

C.
Completeness
of
Submittals
The
submissions
from
Texas
included:
°
letter
of
submission,
°
evidence
that
the
State
adopted
the
revision,
°
a
copy
of
the
revision,
°
evidence
that
the
State
followed
necessary
requirements
in
making
the
revision,
°
evidence
that
Public
Notice
was
given
of
the
proposed
change,
°
certification
that
public
hearings
were
held
,
°
compilation
of
public
comments
and
the
State's
response,
°
identification
of
all
regulated
pollutants,
°
identification
of
the
locations
of
affected
sources,
and
°
information
on
how
compliance
will
be
determined.

III.
CONCLUSIONS
&
RECOMMENDATIONS
The
revisions
being
reviewed
strengthen
the
Texas
Ozone
SIP
for
Northeast
Texas.
The
Agreed
Orders
require
reductions
of
emissions
of
nitrogen
oxide
from
the
facilities
of
three
companies.
The
attainment
demonstration
submitted
indicates
that
the
8­
hour
ozone
standard
will
continue
to
be
attained
in
2007
and
through
2012.
The
CAAP
adopted
into
the
SIP
included:

°
two
local
control
measures
to
reduce
VOC
emissions
for
two
Longview,
Texas
facilities,
and
°
a
number
of
additional
local
control
measures
that
were
not
included
in
the
modeled
attainment
demonstration.
These
measures
will
reduce
VOC
and
nitrogen
oxide
emissions
and
ensure
that
the
area
remains
in
attainment
for
the
8­
hour
ozone
standard.

We
have
determined
that
the
two
local
control
measures
to
reduce
VOC
emissions
at
the
Longview
facilities,
which
were
included
in
the
attainment
demonstration,
are
enforceable
against
the
sources
via
state
air
permits,
and
are
surplus
and
permanent
emission
reductions.
These
control
measures
are
consistent
with
the
EAC
protocol
requirements.
We
have
also
reviewed
the
additional
control
measures
in
the
CAAP,
which
were
not
included
in
the
attainment
demonstration,
and
determined
that
the
projected
emission
reductions
will
strengthen
the
SIP.
We
have
reviewed
the
CAAP
and
the
attainment
demonstration
and
determined
that
they
are
consistent
with
the
requirements
of
the
CAA,
EPAs
policy,
and
the
EAC
protocol.
It
is
recommended
that
these
revisions
to
the
Texas
Ozone
SIP
concerning
Northeast
Texas
be
approved.
Approval
of
the
three
Agreed
Orders
will
make
them
federally
enforceable.
Attachments
Attachment
1.
Technical
Support
Document
for
Modeling
Attachment
2.
September
17,
2004
Memorandum
from
Greg
Yarwood,
Environ,
to
the
NETAC
Technical
Advisory
Committee
