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DCTM_
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MEMORANDUM
To:
NETAC
Technical
Advisory
Committee
From:
Greg
Yarwood
Date:
September
17,
2004
Subject:
2007
Ozone
Reductions
for
NETAC
Control
Strategies
1
and
2
In
March
2004,
NETAC
submitted
to
EPA
a
Clean
Air
Action
Plan
(
CAAP)
for
Northeast
Texas
that
demonstrated
attainment
of
the
8­
hour
ozone
standard
based
on
control
measures
that
are
currently
enforceable
(
NETAC,
2004).
The
projected
2007
8­
hour
ozone
design
values
for
the
NETAC
attainment
demonstration
are
shown
in
Table
1.

 
Note
that
the
Waskom
and
Karnack
2007
DVs
in
Table
1
are
different
from
Table
6­
5
of
the
CAAP
because
computational
errors
have
been
corrected.

Table
1.
Projected
2007
8­
hour
ozone
design
values
(
ppb)
for
the
CAAP
attainment
demonstration
scenario
(
NETAC,
2004).
Monitor
2001­
2003
DV
Modeled
RRF
Scaled
2007
DV
Longview
82
0.981
80
Tyler
81
0.954
77
Karnack
84
0.958
80
Waskom
84
0.966
81
Notes:
The
Longview
and
Tyler
monitors
have
2001­
2003
DVs.
The
Karnack
and
Waskom
monitors
have
2002­
2003
DVs.

CONTROL
STRATEGIES
At
the
request
of
TCEQ
and
EPA,
NETAC
has
modeled
two
additional
sets
of
control
strategies
that
go
beyond
the
2007
base
case
(
run
07base5)
which
constituted
NETAC's
attainment
demonstration.
The
control
strategy
runs
show
additional
reductions
in
ozone
below
the
levels
in
the
2007
base
case
run.
Since
the
2007
base
case
demonstrates
attainment
of
the
8­
hour
ozone
standard,
these
control
strategies
provide
an
additional
measure
of
safety
in
8­
hour
ozone
levels
for
Northeast
Texas.

The
control
strategies
modeled
by
NETAC
are:

 
CTL01:
Add
HRVOC
reductions
at
Longview.
Add
the
"
gas
can"
rule.
Remove
the
water
heater
NOx
rule.
Page
2
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DCTM_
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CTL02:
Add
1.5
tons/
day
of
TERP
NOx
reductions
in
the
NETAC
5
County
area
to
Control
Strategy
1.

The
elements
of
these
strategy
runs
are
explained
below.

HRVOC
Reductions
at
Longview
The
CAAP
identified
additional
local
emissions
reductions
beyond
the
measures
accounted
for
in
the
attainment
demonstration
(
07base5).
These
reductions
include
enforceable
reductions
of
highly
reactive
VOC
(
HRVOC)
emissions
from
the
Eastman
and
Huntsman
chemical
facilities
near
Longview,
Texas.
As
described
on
page
6­
11
of
the
CAAP
(
NETAC,
2004),
these
reductions
amount
to
0.86
tons/
day
at
Eastman
and
0.08
tons/
day
(
29
tons/
year)
at
Huntsman
by
the
start
of
the
2007
ozone
season.
These
reductions
will
be
enforceable
through
emissions
permits
listed
in
the
CAAP.

TERP
NOx
Reductions
TCEQ
estimates
that
the
Texas
Emissions
Reduction
Program
(
TERP)
will
result
in
a
1.5
ton/
day
reduction
in
NOx
reductions
from
off­
road
mobile
sources
in
the
NETAC
5
County
area
in
2007
(
TCEQ,
2007).

TCEQ
"
Water
Heater"
NOx
Rule
The
2007
base
case
included
reductions
in
NOx
emissions
from
industrial
water
heaters,
small
boilers
and
process
heaters
(
TAC
117.460­
469).
TCEQ
estimated
that
this
rule
would
reduce
NOx
emissions
by
0.5
tons/
day
in
the
95­
county
East/
Central
Texas
region.
Eliminating
this
rule
increased
2007
NOx
emissions
in
the
NETAC
5
county
area
by
0.05
tons/
day,
which
is
a
negligible
amount.

TCEQ
"
Gas
Can"
VOC
Rule
The
TCEQ
has
proposed
a
statewide
low
emission
"
gas
can"
rule
to
reduce
VOC
emissions
from
small
containers
used
to
store
gasoline.
The
estimated
benefits
of
this
rule
in
the
NETAC
area
are
small
because
the
VOC
emissions
inventory
is
dominated
by
biogenic
emissions
(
NETAC,
2004).

CONTROL
STRATEGY
IMPACTS
The
impacts
of
control
strategy
reductions
on
2007
8­
hour
ozone
levels
were
evaluated
using
the
ozone
model
developed
for
the
August
13­
22,
1999
episode
(
NETAC,
2004).
Page
3
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Gate
Plaza
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101
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Tel:
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899­
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C:\
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temp\
DCTM_
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doc
Control
Strategy
1
Figure
1
shows
the
decrease
in
episode
maximum
8­
hour
ozone
and
Table
2
shows
the
projected
2007
8­
hour
ozone
design
values
for
Control
Strategy
1
(
CTL01).
The
only
significant
element
of
Control
Strategy
1
is
the
HRVOC
reduction
at
the
chemical
facilities
near
Longview.
Figure
1
shows
8­
hour
ozone
decreases
near
Longview
of
up
to
~
0.4
ppb.
The
episode
maximum
8­
hour
ozone
at
the
Longview
monitor
is
reduced
by
~
0.2
ppb.
Control
Strategy
1
does
not
alter
the
2007
design
values
(
Tables
1
and
2)
in
part
because
the
2007
design
values
are
truncated
to
the
next
lowest
ppb.
The
relative
reduction
factor
(
RRF)
for
Longview
is
0.981
for
the
2007
base
case
and
0.980
for
Control
Strategy
1
(
see
Tables
1
and
2).
This
difference
amounts
to
about
a
0.1
ppb
improvement
in
the
2007
design
value
calculation
for
Longview,
which
is
too
small
to
notice
after
the
design
value
has
been
truncated
to
the
nearest
ppb
(
80
ppb
in
both
Tables
1
and
2).

Figure
1.
Decrease
in
episode
maximum
8­
hour
ozone
due
to
Control
Strategy
1
(
CTL01).
Page
4
Golden
Gate
Plaza
$
101
Rowland
Way
$
Novato,
California
94945­
5010
USA
Tel:
(
415)
899­
0700
$
Fax:
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415)
899­
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C:\
dmautop\
temp\
DCTM_
ARP.
doc
Table
2.
Projected
2007
8­
hour
ozone
design
values
(
ppb)
for
Control
Strategy
1
(
CTL01).
Monitor
2001­
2003
DV
Modeled
RRF
Scaled
2007
DV
Longview
82
0.980
80
Tyler
81
0.954
77
Karnack
84
0.958
80
Waskom
84
0.966
81
Control
Strategy
2
Figure
2
shows
the
decrease
in
episode
maximum
8­
hour
ozone
and
Table
3
shows
the
projected
2007
8­
hour
ozone
design
values
for
Control
Strategy
2
(
CTL02).
The
significant
elements
of
Control
Strategy
2
are
the
TERP
NOx
reductions
for
off­
road
mobile
sources
and
the
HRVOC
reductions
at
the
chemical
facilities
near
Longview.
Figure
2
shows
8­
hour
ozone
decreases
throughout
the
NETAC
area
with
the
largest
decrease
of
~
0.6
ppb
near
Tyler.
Control
Strategy
2
does
not
alter
the
2007
design
values
in
part
because
the
2007
design
values
are
truncated
to
the
next
lowest
ppb.
Comparing
the
relative
reduction
factors
(
RRFs)
in
Tables
1
and
2
shows
improvement
in
the
2007
design
value
calculations
of
~
0.2
ppb
for
Tyler
and
Longview,
which
are
too
small
to
notice
after
the
design
values
have
been
truncated
to
the
nearest
ppb.

Figure
2.
Decrease
in
episode
maximum
8­
hour
ozone
due
to
Control
Strategy
2
(
CTL02).
Page
5
Golden
Gate
Plaza
$
101
Rowland
Way
$
Novato,
California
94945­
5010
USA
Tel:
(
415)
899­
0700
$
Fax:
(
415)
899­
0707
C:\
dmautop\
temp\
DCTM_
ARP.
doc
Table
3.
Projected
2007
8­
hour
ozone
design
values
(
ppb)
for
Control
Strategy
2
(
CTL02).
Monitor
2001­
2003
DV
Modeled
RRF
Scaled
2007
DV
Longview
82
0.979
80
Tyler
81
0.951
77
Karnack
84
0.958
80
Waskom
84
0.965
81
TERP
NOx
Reduction
The
impact
of
the
1.5
ton/
day
TERP
NOx
reduction
for
off­
road
mobile
sources
is
the
difference
between
Control
Strategies
2
and
1,
shown
in
Figure
3.
The
TERP
NOx
reduction
results
in
8­
hour
ozone
decreases
throughout
the
NETAC
area
with
the
largest
reductions
near
Tyler.
This
is
because
Tyler
is
the
largest
urban
area
and
therefore
has
the
highest
concentration
of
off­
road
NOx
emissions
in
the
NETAC
area.

Figure
3.
Decrease
in
episode
maximum
8­
hour
ozone
due
to
the
TERP
NOx
reduction
for
off­
road
mobile
sources
(
Control
Strategy
2
minus
Control
Strategy
1).
Page
6
Golden
Gate
Plaza
$
101
Rowland
Way
$
Novato,
California
94945­
5010
USA
Tel:
(
415)
899­
0700
$
Fax:
(
415)
899­
0707
C:\
dmautop\
temp\
DCTM_
ARP.
doc
Conclusions
 
HRVOC
reductions
at
the
Eastman
and
Huntsman
chemical
facilities
near
Longview
result
in
8­
hour
ozone
decreases
of
up
to
~
0.4
ppb
in
the
vicinity
of
these
sources.

 
The
TERP
NOx
reduction
for
off­
road
mobile
sources
results
in
8­
hour
ozone
decreases
throughout
the
NETAC
area
of
up
to
~
0.6
ppb
near
Tyler.

 
The
ozone
benefits
of
the
HRVOC
and
TERP
NOx
strategies
are
too
small
to
see
in
the
projected
2007
design
values
because
the
design
values
are
truncated
to
the
next
lowest
ppb.

References
NETAC
(
2004).
"
Clean
Air
Action
Plan
for
Northeast
Texas."
Report
prepared
for
the
East
Texas
Council
of
Governments
by
the
Northeast
Texas
Air
Care
Technical
Committee.
March
31,
2004.

TCEQ
(
2004).
"
New
NETAC
2007
ozone
simulation."
Memo
from
Gerry
Wolfe
(
TCEQ)
to
Greg
Yarwood,
September
4,
2004.
