
1
Dallas/
Fort
Worth
5%
INCREMENT
OF
PROGRESS
Submittal
Technical
Support
Document
July
2006
Introduction
This
technical
support
document
(
TSD)
evaluates
the
May
13,
2005
submittal
of
revisions
to
the
Texas
State
Implementation
Plan
(
SIP)
concerning
the
Dallas/
Fort
Worth
(
DFW)
ozone
nonattainment
area.
The
revisions
include
a
5%
Increment
of
Progress
(
IOP),
a
2002
emissions
inventory,
a
2007
motor
vehicle
emissions
budget
(
MVEB),
a
federal
consent
decree
and
a
state
permit
concerning
the
Alcoa
plant
in
Rockdale,
Milam
County,
energy
efficiency
measures,
and
revisions
to
30
TAC,
Chapter
117,
Control
of
Air
Pollution
From
Nitrogen
Compounds,
concerning
stationary
reciprocating
IC
engines
operating
within
the
DFW
ozone
nonattainment
area.
The
IOP
is
an
increment
of
emissions
reduction
from
the
area's
2002
emissions
inventory
(
EI)
and
is
one
of
three
options
presented
in
EPA's
Phase
I
8­
hour
ozone
implementation
rule
(
69
FR
23951)
to
allow
areas
to
meet
their
outstanding
1­
hour
ozone
attainment
demonstration
requirements.
This
5%
IOP
SIP
revision
was
developed
in
accordance
with
section
110
and
part
D
of
the
Clean
Air
Act
and
EPA's
Guidance
on
5
Percent
Increment
of
Progress,
40
CFR
905
(
a)(
1)(
ii)(
B),
August
2004.
The
EPA
published
the
8­
hour
ozone
designations
and
the
first
phase
governing
implementation
of
the
8­
hour
ozone
rule
in
the
Federal
Register
(
FR)
on
April
30,
2004
(
69
FR
23858
and
69
FR
23951,
respectively).
DFW
was
designated
nonattainment
for
this
standard
and
comprises
nine
counties:
Collin,
Dallas,
Denton,
and
Tarrant
counties
(
these
four
constitute
the
1­
hour
ozone
nonattainment
area,
hereinafter
referred
to
as
the
four
core
counties),
and
Ellis,
Johnson,
Kaufman,
Parker
and
Rockwall
counties.
The
8­
hour
ozone
implementation
rule
revoked
the
1­
hour
ozone
standard.
At
the
time
of
designation
however,
DFW
was
still
nonattainment
area
for
the
1­
hour
and
had
two
outstanding
1­
hour
ozone
obligations:
(
1)
the
area
did
not
have
an
approved
1­
hour
ozone
attainment
demonstration;
and
(
2)
the
area
did
not
have
approved
Reasonably
Available
Control
Technology
(
RACT)
requirements
for
major
sources
of
volatile
organic
compound
(
VOC)
emissions
(
VOC
RACT).
All
other
1­
hour
requirements
were
approved;
for
a
detailed
list,
see
the
Texas
SIP
map
at
www.
epa.
gov/
earth1r6/
6pd/
air/
sip/
sip.
htm.
The
phase
I
rule
provides
that
1­
hour
ozone
nonattainment
areas
are
required
to
adopt
and
implement
"
applicable
requirements"
according
to
the
area's
classification
under
the
1­
hour
ozone
standard
(
see
40
CFR
§
51.905(
a)(
i)).
The
DFW
area
was
still
classified
as
a
serious
nonattainment
area
at
the
time
of
the
8­
hour
designation
and
the
only
outstanding
"
applicable
requirement"
for
the
DFW
area
is
the
VOC
RACT.
We
proposed
to
approve
the
VOC
RACT
for
the
DFW
1­
hour
ozone
nonattainment
area
on
November
18,
2001
(
66
FR
4756)
and
received
no
comments.
Although
we
are
not
reopening
the
comment
period
on
VOC
RACT,
we
intend
to
finalize
that
proposed
approval
in
the
same
rulemaking
that
we
finalize
this
5%
IOP
proposal.
These
actions
will
fulfill
all
outstanding
1­
hour
ozone
obligations
for
the
DFW
area.
This
TSD
presents
the
legal
and
technical
elements
of
the
DFW
5%
IOP
submittal.
It
includes
a
review
of
the
EIs,
the
motor
vehicle
emissions
budgets,
and
the
calculations
used
to
determine
the
emission
levels
required
in
2007
to
meet
the
requirements
of
the
5%
IOP
plan.
2
Legal
Authority
Under
the
Texas
Health
and
Safety
Code,
§
§
382.011,
382.012
and
382.023,
the
Texas
Commission
on
Environmental
Quality
(
TCEQ)
has
the
authority
to
control
the
quality
of
the
state's
air
and
to
issue
orders
consistent
with
the
policies
and
purposes
of
the
Texas
Clean
Air
Act,
Chapter
382
of
the
Texas
Health
and
Safety
Code.
Notice
of
hearings
for
the
proposed
SIP
revision
was
published
in
the
December
3,
2004
issue
of
the
Texas
Register
(
29
TexReg
11414).
On
April
27,
2004,
TCEQ
adopted
a
revision
to
the
SIP
concerning
the
5%
IOP
plan
for
the
DFW
ozone
nonattainment
area.
The
State
has
the
authority
to
implement
this
revision.

Technical
Review
The
EPA
guidance
for
5%
IOP
plans
requires
the
emission
reduction
be
based
on
a
2002
emissions
inventory
(
EI),
does
not
allow
credit
from
Federal
measures
or
measures
already
in
the
SIP
as
of
2002,
requires
that
the
reductions
occur
by
2007,
and
allows
use
of
Nitrogen
Oxides
(
NOx)
or
Volatile
Organic
Compounds
(
VOCs),
or
a
combination
of
both
pollutants,
to
meet
the
5%
reduction.
Nitrogen
oxides
and
VOCs
are
precursors
for
ground­
level
ozone.
The
steps
involved
in
determining
the
emissions
needed
to
meet
the
5%
reduction
are
the
establishment
of
the
2002
(
baseline)
EI,
projection
of
the
2007
EI,
and
the
calculation
of
the
5%
reduction.

1.
2002
Emissions
Inventory
The
Clean
Air
Act
Amendments
of
1990
(
the
Act)
initiated
the
requirement
that
EIs
be
prepared
for
ozone
nonattainment
areas.
Because
ozone
is
photochemically
produced
in
the
atmosphere
when
VOCs
are
mixed
with
NOx
in
the
presence
of
sunlight,
ozone
EIs
focus
on
these
precursor
pollutants.
Carbon
monoxide
(
CO)
also
aids
in
the
process.
The
EI
identifies
the
source
types
present
in
an
area,
the
amount
of
each
pollutant
emitted,
and
the
types
of
processes
and
control
devices
employed
at
each
plant
or
source
category.
The
Act
requires
the
inventories
to
be
actual
emissions.
The
EI
in
the
5%
IOP
provides
a
baseline
emission
level
for
calculating
emission
reduction
targets
and
the
control
strategy
for
achieving
the
required
emission
reductions.
The
total
inventory
of
emissions
of
VOC,
NOx,
and
CO
for
an
ozone
nonattainment
area
is
summarized
from
the
estimates
developed
for
five
general
categories
of
emission
sources:
point,
area,
onroad
mobile,
nonroad
mobile,
and
biogenic.
The
Act
also
required
Periodic
Emission
Inventories
(
PEI)
of
all
sources
every
three
years
following.
Subsequently,
EPA
promulgated
the
Consolidated
Emissions
Reporting
Rule
(
CERR,
see
67
FR
39602,
published
June
10,
2002),
which
specified
PEI
requirements
and
dates
for
the
inventories.
The
2002
inventory
was
the
next
PEI
in
the
sequence.
The
State
developed
the
2002
PEI
for
VOCs,
NOx,
and
CO
from
point,
area,
onroad
mobile,
nonroad
mobile,
and
biogenic
sources.
Annual
and
peak
ozone
season
daily
average
emissions
were
developed.
The
year
2002
was
further
designated
as
the
base
year
for
planning
Rate­
of­
Progress
(
ROP)
and
Reasonable
Further
Progress
(
RFP)
SIPs
for
the
8­
hour
ozone
standard
(
memo
on
2002
Base
Year
Emissions
Inventory
SIP
Planning:
8­
hr
Ozone,
PM
2.5
and
Regional
Haze
Programs
from
Lydia
Wegman
and
Peter
Tsirigotis
to
Regional
Air
Directors,
November
18,
2002).
As
a
result,
8­
hour
control
strategy
planning
begins
with
an
emissions
inventory
of
sources
for
2002.
The
documents
used
by
States
to
develop
inventories
and
for
EPA
to
review
inventories
are
the
CERR,
the
draft
Emissions
Inventory
Guidance
for
Implementation
of
Ozone
3
and
Particulate
Matter
National
Ambient
Air
Quality
Standards
(
NAAQS)
and
Regional
Haze
Regulations
(
EPA­
45/
R­
03­
001,
May
2003),
various
emissions
inventory
calculation
methodology
documents,
e.
g,
Emissions
Inventory
Improvement
Program
documents,
and
the
AP­
42
emission
factor
document.
Methodology
and
general
information
on
emissions
inventories
is
available
at
the
EPA's
Emissions
Inventory
website:
http//
epa.
gov/
ttn/
chief.

Point
Sources
Major
point
sources
for
inventory
reporting
purposes
in
nonattainment
areas
are
defined
as
industrial,
commercial,
or
institutional
sources
that
emit
actual
levels
of
criteria
pollutants
at
or
above
10
tons
per
year
(
tpy)
of
VOC,
25
tpy
of
NOx,
or
100
tpy
of
other
criteria
pollutants
(
CO,
SO
2
,
PM
10
,
PM
2.5
,
or
lead).
The
State's
EI
rule
is
contained
in
the
Texas
Administrative
Code
(
TAC)
at
30
TAC
101.10.
To
collect
emissions
and
industrial
process
operating
data
for
these
plants,
the
TCEQ
sends
an
Emission
Inventory
Questionnaire
(
EIQ)
to
each
source
identified
as
having
triggered
the
above
level
of
emissions.
The
EIQ
requests
data
for
all
emissions
generating
units
and
emission
points,
the
type
and,
for
a
representative
sample
of
sources,
the
amount
of
materials
used
in
processes
that
result
in
emissions.
The
EIQ
requests
information
on
process
equipment
descriptions,
operation
schedules,
emission
control
devices
currently
in
use,
abatement
device
control
efficiency,
and
stack
parameters
such
as
location,
height,
and
exhaust
gas
flow
rate.
This
supporting
documentation
is
provided
for
each
source
type
within
the
EI.
Data
is
reviewed
and
quality
assured
by
Texas
prior
to
being
entered
into
State
of
Texas
Air
Reporting
System
(
STARS).
The
process
for
collecting,
reviewing,
and
quality
assuring
this
data
is
thorough
and
detailed;
it
is
contained
in
the
State's
2002
EI
Guidelines,
Attachment
1
of
this
TSD.
Emissions
by
facility
within
each
of
the
nine
counties
is
listed
in
Attachment
2
of
the
TSD.
The
State
separately
accounts
for
NOx
emissions
from
the
Alcoa
facility,
as
it
lies
outside
the
DFW
nonattainment
area.
The
5%
IOP
guidance
allows
a
nonattainment
area
to
include
VOC
sources
within
100
kilometers
(
km)
and
NOx
sources
within
200
km
of
the
nonattainment
area
to
be
included
in
calculations
of
RFP
reductions.
The
Alcoa
facility
is
120
miles
from
DFW,
thus
the
NOx
emissions
are
allowed.
The
NOx
emissions
for
the
entire
facility
are
added
to
the
nine
county
total
as
required
by
the
guidance;
these
emissions
are
23.17
tons
per
day
(
tpd).
There
is
a
discrepancy
between
point
source
totals
in
the
SIP
narrative
(
Table
2.4)
and
Appendix
A
of
the
SIP
submittal.
The
SIP
narrative
shows
VOC
emissions
of
28.31
tpd
and
Appendix
A
shows
25.82
tpd;
the
narrative
shows
NOx
emissions
of
79.31
tpd
and
Appendix
A
shows
79.05
tpd.
These
are
differences
in
timing
of
extracting
data
from
the
State's
point
source
data
system
and
therefore,
are
not
significant;
the
data
in
the
SIP
narrative
are
acceptable.
The
total
point
source
inventory
for
NOx
is
79.31
tpd
and
28.31
tpd
for
VOCs;
this
inventory,
adjusted
to
include
NOx
emissions
from
Alcoa,
is
102.48
tpd
NOx
and
28.31
tpd
VOCs.
The
2002
Point
source
inventory
is
acceptable.

Area
Sources
Area
sources
have
emissions
below
the
point
source
reporting
levels
and
are
too
numerous
and/
or
too
small
to
identify
individually.
Area
sources
are
commercial,
small­
scale
industrial,
and
residential
categories
that
use
materials
or
operate
processes
generating
emissions.
Area
sources
4
are
divided
into
two
groups,
characterized
by
either
hydrocarbon
evaporative
emissions
or
fuel
combustion
emissions.
Examples
of
hydrocarbon
evaporative
emission
sources
include:
printing
operations,
industrial
coatings,
degreasing
solvents,
house
paints,
leaking
underground
storage
tanks,
and
gasoline
service
station
underground
tank
filling
and
vehicle
refueling
operations.
Fuel
combustion
emission
sources
include
stationary
source
fossil
fuel
combustion
at
residences
and
businesses,
outdoor
burning,
structural
fires,
and
wildfires.
Emissions
of
area
sources
are
estimated
as
county­
wide
totals
rather
than
individual
source
emissions.
These
emissions,
with
some
exceptions,
may
be
calculated
by
multiplication
of
an
established,
EPA
approved,
emission
factor
(
emissions
per
unit
of
activity).
Actual
activity
data
is
used
when
available.
Examples
include
gallons
of
gasoline
sold
in
a
county,
amount
of
printer
ink
used,
number
of
wildfire
acres
burned,
and
amount
of
oil
and
natural
gas
produced.
When
actual
activity
data
is
unavailable,
surrogates
are
used,
including
total
county
population
and
employment
data
by
industry
type.
Actual
activity
data
is
often
only
available
at
the
state
or
national
level
and
must
be
adapted
to
the
county
level
using
an
appropriate
surrogate.
The
EPA's
2002
National
Emission
Inventory
(
NEI)
was
the
starting
point
for
the
area
source
2002
EI.
NEI
categories
and
emissions
were
reviewed
and
subsequently
updated
with
current
methodologies
and
local
activity
data,
as
available.
Major
efforts
were
made
to
locate
appropriate
activity
data.
Specific
categories
were
updated
using
information
and
data
that
represent
2002
activities.
Several
categories
benefitted
from
contracted
work
completed
for
year
2002
or
a
prior
year.
For
some
categories,
emissions
developed
from
previous
contracts
were
estimated
or
grown
to
2002.
For
other
less
significant
categories
emissions
were
grown
from
the
1999
EI
to
2002.
The
EPA's
Economic
Growth
Analysis
System
(
EGAS)
growth
factors
were
used
to
estimate
less
significant
categories.
As
a
result,
the
2002
area
source
EI
was
compiled
from
several
sources,
including
work
from
various
contracts,
TCEQ
research,
and
the
NEI.
For
those
area
source
categories
affected
by
TCEQ
rules,
Rule
Effectiveness
factors
were
applied
to
the
uncontrolled
emissions.
These
factors
address
the
efficiency
of
the
controls
and
the
percentage
of
the
category's
population
affected
by
the
rule.
Quality
assurance
of
area
source
emissions
involves
ensuring
that
the
activity
data
used
for
each
separate
category
is
current
and
valid.
Data
such
as
population
figures,
fuel
usage,
and
material
usage
change
annually.
Sources
of
this
information
were
contacted
for
updates
as
part
of
the
inventory
development
process.
Current
EPA
documents
were
also
obtained
to
review
for
changes
in
emission
factors.
Recalculations,
and
reasonableness
and
completeness
checks
were
conducted.
The
area
source
methodology
is
available
in
Appendix
A
of
the
submittal.
A
detailed
listing
of
DFW
emissions
by
area
source
type
within
each
of
the
nine
counties
is
contained
in
Attachment
3
of
the
TSD.
The
State
submittal
shows
VOC
emissions
for
the
portable
fuel
container
(
gas
can)
rule
outside
the
DFW
area
of
4.52
tpd;
these
are
added
to
the
nine
county
total
as
required
by
the
5%
IOP
guidance.
The
total
area
source
inventory,
adjusted
to
include
emissions
from
the
gas
can
rule,
are
38.03
tpd
for
NOx
and
208.92
tpd
for
VOCs.
The
2002
area
source
inventory
is
acceptable.

Onroad
Mobile
Sources
Onroad
mobile
sources
consist
of
automobiles,
trucks,
motorcycles,
and
other
motor
vehicles
traveling
on
roadways.
Combustion
related
emissions
are
estimated
for
vehicle
engine
5
exhaust;
evaporative
hydrocarbon
emissions
are
estimated
for
the
fuel
tank
and
other
evaporative
leak
sources
on
the
vehicle.
Emission
factors
were
developed
using
the
EPA's
onroad
mobile
emissions
factor
model,
MOBILE6.
Various
model
inputs
are
provided
to
reflect
local
conditions
in
each
nonattainment
area,
including
vehicle
speeds
by
roadway
type,
vehicle
registration
by
vehicle
type
and
age,
percentage
of
vehicles
in
cold
start
mode,
percentage
of
miles
traveled
by
vehicle,
type
of
vehicle
I/
M
program
in
place,
and
gasoline
vapor
pressure.
Each
of
these
parameters
will
impact
the
emission
factor
calculated
by
the
MOBILE6
model.
The
2002
onroad
inventory
was
prepared
by
the
North
Central
Texas
Council
of
Governments
(
NCTCOG)
for
the
State.
The
2002
CERR
for
the
onroad
EI
was
modeled
using
the
newest
EPA
onroad
emission
factor
model,
MOBILE6.2.
The
areas
covered
in
the
CERR
analysis
were
the
nine
DFW
nonattainment
counties,
plus
Henderson,
Hood,
and
Hunt
counties.
The
methodology
used
to
develop
the
2002
CERR
was
in
accordance
with
the
CERR
guidance
report
(
40
CFR
Part
51,
June
10,
2002).
Methodology
and
initial
estimates
of
emissions
of
VOC
and
NOx
are
provided
Appendix
B
of
the
submittal.
The
nine
nonattainment
counties
in
the
2002
CERR
were
used
to
evaluate
the
2002
EI
in
the
5%
IOP
SIP.
To
calculate
emissions,
emission
factors
were
applied
to
vehicle
activity
using
the
Texas
Mobile
Source
Emission
Software.
Vehicle
activity
was
generated
using
the
DFW
Regional
Travel
Model
and
collected
from
Roadway
Inventory
Functional
Class
Records
data.
Adjustments
were
applied
to
develop
better
regional
emissions
estimates.
Factors
such
as
nonrecurring
congestion,
calculation
of
local
street
vehicle
miles
of
travel,
seasonal
adjustments,
and
a
transportation
model
adjustment
to
better
reflect
model
estimates
to
actual
data
collected
through
the
Highway
Performance
Monitoring
System
were
applied
to
the
modeling.
Emissions
were
summarized
in
24
one­
hour
periods
and
for
a
daily
total
for
all
nine
counties.
In
March
2005,
incorrect
diesel
fraction
inputs
were
discovered
in
the
2002
onroad
mobile
inventory
in
the
5%
IOP
SIP
proposal.
The
State
and
the
NCTCOG
corrected
the
problem
and
this
SIP
revision
includes
the
updated
onroad
mobile
estimates
of
NOx
and
VOC
emissions
for
the
2002
inventory.
Appendices
B
and
C
were
included
with
the
5%
IOP
SIP
proposal
and
contain
summaries
of
the
2000
onroad
mobile
inventory
developed
by
NCTCOG
in
2004.
Appendix
K
contains
a
summary
of
the
problems
identified
with
these
onroad
mobile
inventories
and
the
MOBILE6.2
input
file
revisions.
Appendices
L
and
M
contain
the
electronic
input
and
output
summary
files
used
in
the
"
incorrect"
onroad
emission
inventories
for
2002
and
2007,
respectively.
Appendices
N
and
O
contain
the
input
and
output
files
used
to
develop
the
"
corrected"
onroad
emission
inventories
for
2002
and
2007,
respectively.
The
DFW
onroad
emissions
for
the
nine
county
area
are
detailed
in
Appendix
K
of
the
submittal.
The
total
onroad
mobile
source
inventory
is
345.44
tpd
for
NOx
and
156.34
tpd
for
VOCs.
The
2002
onroad
mobile
source
inventory
is
acceptable.

Nonroad
Mobile
Sources
Nonroad
mobile
categories
include
aircraft,
railroad
locomotives,
recreational
vehicles
and
boats,
and
a
very
broad
range
of
equipment
from
600­
horsepower
engines
in
the
construction
equipment
class
to
one­
horsepower
string
trimmers
in
the
lawn
and
garden
class.
For
all
nonroad
mobile
categories
except
aircraft,
locomotives,
and
commercial
marine
vessels,
the
EPA
NONROAD
model
is
used
to
calculate
emissions.
This
model
generates
emissions
for
over
200
6
individual
types
of
equipment
in
the
nine
classes
listed
below.
A
summary
of
the
2002
nonroad
emissions
in
the
nine
county
DFW
nonattainment
area
is
provided
in
Table
1
below.

Table
1:
DFW
Nonroad
Mobile
Emissions
Summary
for
2002
by
Nonroad
Model
Equipment
Class
CLASS
NO
x
(
tpd)
VOC
(
tpd)

Agricultural
4.23
0.60
Commercial
7.71
9.57
Construction
56.26
9.34
Industrial/
Oilfield
19.17
4.58
Lawn
and
Garden
3.23
25.36
Logging
0.08
0.05
Railway
Maintenance
0.15
0.04
Recreational
0.28
6.19
Recreational
Marine
0.45
8.06
Activity
data
in
the
NONROAD
model
used
to
calculate
emissions
include
the
equipment
count,
horsepower
ranges,
and
fuel
types.
The
model
will
produce
emissions
for
every
county
in
the
state,
using
default
activity
data
prorated
from
national
data
to
the
state
and
county
levels
using
appropriate
surrogates.
Operating
the
model
with
all
the
default
surrogates
in
place
is
acceptable,
but
EPA
encourages
states
to
update
the
model
with
local,
county­
level
data
based
on
surveys
and
other
relevant
information.
As
local,
county­
level
data
become
available
to
the
State
it
is
incorporated
into
the
NONROAD
model.
The
latest
NONROAD
model,
version
2004,
was
used
to
develop
the
DFW
2002
nonroad
EI.
Recent
surveys
and
local
data
have
improved
the
model
results.
Improvements
to
the
following
classes
include
the
major
VOC
and
NOx
nonroad
mobile
categories:
construction,
lawn
and
garden,
oilfield,
and
recreational
marine.
Commercial
and
military
aircraft
emissions
are
calculated
using
the
Federal
Aviation
Administration's
Emissions
and
Dispersion
Modeling
System
(
EDMS)
model,
which
requires
landing/
takeoff
(
LTO)
data
and
aircraft
types.
Smaller
aircraft
emissions
are
calculated
using
EPA
emission
factors
and
applicable
LTO
data.
Ground
support
equipment
(
GSE)
emissions
at
commercial
airports
were
based
on
a
recent
survey
of
equipment
in
the
DFW
area.
Commercial
aircraft
emissions
are
18.40
tpd
NOx,
and
2.88
tpd
VOC,
general
aviation
emissions
are
0.10
tpd
NOx
and
1.61
tpd
VOC,
and
GSE
emissions
are
2.67
tpd
NOx
and
0.86
tpd
VOC.
The
locomotive
EI
is
based
on
fuel
use
and
track
mileage.
Individual
railroad
lines
were
surveyed
for
actual
data;
surveys
and
discussions
are
ongoing,
to
improve
the
locomotive
EI.
Railway
emissions
are
23.51
tpd
NOx
and
0.94
tpd
VOC.
Quality
assurance
procedures
for
nonroad
mobile
source
emissions
rely
mainly
on
quality
7
of
data
used
for
each
separate
category.
Data
such
as
local
equipment
population
and
fuel
usage
change
annually
and
sources
were
contacted
during
inventory
development
for
updates.
The
EPA
NONROAD
and
EDMS
models
ensure
that
updates
to
equipment
types,
horsepower
ranges,
and
applicable
rules
are
applied.
Reasonableness
and
completeness
checks
were
also
conducted.
Details
of
the
nonroad
mobile
emissions
by
type
for
each
of
the
nine
counties
are
listed
in
Attachment
4
of
the
TSD
and
the
methodology
is
provided
in
Appendix
A
of
the
submittal.
The
total
nonroad
mobile
source
inventory
is
136.24
tpd
for
NOx
and
70.08
tpd
for
VOCs.
The
2002
nonroad
mobile
source
inventory
is
acceptable.

Biogenic
Emissions
Biogenic
emissions
come
from
natural
sources,
including
soils
and
vegetation.
They
can
be
significant,
so
are
included
in
attainment
plan
modeling.
They
are
not
included
in
the
IOP
plans
since
there
are
no
feasible
control
strategies
to
reduce
these
emissions.

2.
2007
Emissions
Projections
The
TCEQ
developed
2007
emission
estimates
by
multiplying
the
2002
EI
by
a
growth
factor
or
applying
the
EI
to
a
model,
depending
on
the
source
category.
Each
of
the
future
year
inventories
for
point,
area,
onroad
and
nonroad
are
detailed
below.

Point
Sources
The
2007
point
source
inventory
was
developed
by
multiplying
the
2002
base
year
EI
by
growth
factors
that
represent
industrial
expansion.
The
controls
applied
represent
NOx
and
VOC
controls
already
in
place.
Growth
was
partially
accounted
for
through
the
emissions
banked
in
the
Emissions
Banking
and
Trading
(
EBT)
database.
Emission
Reduction
Credit
(
ERC)
and
Discreet
Emission
Reduction
Credit
(
DERC)
totals
were
tallied
(
as
of
September
8,
2004).
These
banked
emissions
could
return
to
the
airshed
as
actual
emissions
in
the
future.
As
required
in
30
TAC
Chapter
101,
an
ERC
must
be
surplus
to
any
federal,
state
or
local
rule.
The
credits
in
the
bank
have
been
devalued
to
show
surplus
using
the
Chapter
117
emission
rate
limitations
(
Chapter
117
applies
to
the
control
of
air
pollution
from
nitrogen
compounds).
Additionally,
the
DERCs
are
subject
to
10%
environmental
contributions
and
the
ERCs
are
subject
to
a
New
Source
Review
(
NSR)
permitting
offset
ratio
of
1.15:
1.
A
total
of
19.07
tpd
of
NOx
and
0.44
tpd
of
VOC
were
added
to
the
2007
EI
to
account
for
banked
emissions.
This
presumes
all
emission
credits
will
be
used
within
one
year,
which
is
unlikely,
as
the
majority
of
credits
are
DERCs.
The
Electric
Reliability
Council
of
Texas
(
ERCOT)
reports
that
electricity
demand
in
Texas
will
be
75
percent
of
capacity
in
2007
(
Reference:
ERCOT,
The
Texas
Connection
report,
"
Report
on
Existing
and
Potential
Electric
System
Constraints
and
Needs
Within
the
ERCOT
Region,"
October
1,
2003).
To
project
growth
in
EGU
emissions
in
the
2007
EI,
the
State
added
75
percent
of
the
emissions
allowed
by
permit
from
EGUs
that
were
not
in
the
2002
base
case,
but
had
received
NSR
permits
prior
to
April
2004.
This
approach
is
reasonable
as
it
does
not
account
for
the
decrease
in
emissions
from
less
efficient
existing
EGUs
that
the
new
generation
will
displace.
This
also
assumes
all
newly­
permitted
EGUs
will
be
built
and
operated,
which
is
more
reasonable
than
assuming
all
new
EGUs
will
be
operating
at
100
percent
of
their
permitted
rates
while
existing
EGUs
are
operating
at
2002
levels.
In
the
nine
county
area,
allowable
8
emissions
from
newly­
permitted
EGU's
are
8.61
tpd
of
NOx
and
1.88
tpd
of
VOC.
Emissions
for
non­
electric
generating
units
(
NEGUs)
were
estimated
using
factors
derived
from
the
Texas
Industrial
Production
Index
(
TIPI).
If
TIPI
2­
digit
Standard
Industrial
Classification
(
SIC)
factors
were
unavailable,
Economic
Growth
Analysis
System
(
EGAS)
4.0
growth
factors
were
used.
TIPI
was
used
where
possible,
as
its
November
2003
data
are
the
most
recent.
The
EGAS
model
was
last
updated
in
January,
2001,
and
uses
data
and
data
models
from
the
early
1980s
to
1999.
The
Regional
Economic
Modeling,
Inc.
(
REMI)
model,
which
is
the
economic
basis
of
EGAS
4.0,
uses
economic
data
from
1969
to
1996.
The
EGAS
also
uses
historical
emissions
data
from
the
National
Emissions
Inventory
(
NEI)
ranging
from
1972
to
1992.
(
See
the
EGAS
4.0
Reference
Manual,
on
EPA's
Clearinghouse
for
Inventories
&
Emission
Factors
(
CHIEF)
web
site).
TIPI­
EGAS
is
the
combination
of
these
two
databases.
TIPI
data
from
January
1967
through
November
2003
were
used
in
a
linear
regression
analysis
to
project
emissions
from
2002
to
2007.
According
to
the
Federal
Reserve
Bank
of
Dallas,
TIPI
is
a
value­
added
index,
based
on
a
weighted
average
of
employment,
man
hours,
and
some
production
data.
The
underlying
process
to
derive
TIPI
data
is
the
same
as
the
Bureau
of
Economic
Analysis
gross­
state
product
used
in
EGAS.
The
Chapter
117
NOx
rules
affect
EGUs
and
NEGUs
in
the
DFW
area,
so
controls
were
applied
to
the
baseline
EI
to
simulate
these
rules.
The
NEGU
equipment
regulated
by
Chapter
117,
relevant
to
this
exercise,
are
industrial
boilers
larger
than
40
MMBtu/
hr
and
industrial
engines
larger
than
300
horsepower
(
hp),
placed
into
service
prior
to
1992.
Thirteen
of
these
pieces
of
equipment
remain
in
the
2002
EI.
In
the
2002
inventory,
EGUs
accounted
for
32.59
tpd
NOx
and
1.76
tpd
VOC,
while
NEGUs
contributed
46.72
tpd
NOx
and
26.54
tpd
VOC.
The
2005
emission
factor
(
EF),
e.
g.,
lb/
MMBtu
or
g/
hp­
hr,
for
a
piece
of
equipment
is
dictated
by
Chapter
117.
To
determine
reductions
for
the
remaining
equipment,
EFs
used
in
the
2002
point
source
inventory
were
compared
to
the
Chapter
117
EFs,
and
the
required
reduction
percentages,
if
necessary,
were
calculated
and
applied.
VOC
controls
were
not
applied.
The
EGUs
in
the
four
core
counties
are
subject
to
Chapter
117;
EGUs
in
the
other
5
counties
are
subject
to
the
SB7
rules,
which
reduce
NOx
emissions
from
grandfathered
EGUs.
For
EGUs
that
are
Acid
Rain
units,
the
EFs
can
be
found
in
the
third
quarter
2002
Acid
Rain
Program
Scorecard
data
on
EPA's
Clean
Air
Markets
web
page.
Each
EGU
was
assigned
a
reduction
factor
based
on
the
actual
EF
compared
to
the
Chapter
117
EF
limitation.
The
2007
point
source
inventory
is
projected
to
be
83.52
tpd
NOx
and
30.42
tpd
VOC.
The
2007
point
source
inventory
is
acceptable.

Area
Sources
The
2007
EI
for
area
sources
was
compiled
using
EGAS
growth
factors;
EGAS
contains
individual
growth
factors
for
each
category
and
forecasting
year.
This
is
the
EPA
standard
and
accepted
method
for
developing
future
year
EIs.
The
projected
2007
area
source
inventory
is
39.64
tpd
NOx
and
215.91
tpd
VOC.
The
2007
area
source
inventory
is
acceptable.

Onroad
Mobile
Sources
The
MOBILE6.2
onroad
emissions
model
was
used
to
project
emission
factors
for
2007
and
the
DFW
travel­
demand
model
was
used
to
estimate
vehicle
miles
traveled.
The
projected
9
2007
onroad
mobile
inventory
is
206.72
tpd
NOx
and
104.14
tpd
VOC.
The
2007
onroad
mobile
inventory
is
acceptable.

Motor
Vehicle
Emissions
Budget
(
MVEB)
The
MVEB
is
the
onroad
mobile
source
limit
of
allowable
emissions
for
NOx
and
VOCs,
as
defined
in
the
SIP.
The
5%
IOP
SIP
establishes
MVEBs
for
transportation
conformity
purposes.
To
show
conformity,
areas
must
demonstrate
that
the
estimated
emissions
from
transportation
plans,
programs
and
projects
do
not
exceed
the
MVEBs.
The
MVEBs
were
calculated
by
subtracting
creditable
onroad
emission
reductions
from
the
onroad
inventory
for
2007.
The
Texas
Emissions
Reduction
Plan
(
TERP)
is
an
onroad
mobile
source
emission
reduction
strategy
for
NOx.
Credits
are
calculated
based
on
previous
projects
and
TCEQ
estimates
that
22.2
tpd
of
NOx
will
be
reduced
by
2007.
Of
this
22.2
tpd,
the
onroad
and
nonroad
allocations
are
33.1
percent
and
66.9
percent,
respectively.
The
TCEQ
conservatively
estimates
TERP
will
provide
5.4
tpd
of
onroad
mobile
NOx
emission
reductions
for
the
DFW
nonattainment
area
in
2007.
Onroad
emission
reductions
for
VOCs
were
not
identified,
as
TERP
applies
specifically
to
NOx
reductions.
We
found
the
MVEBs
(
also
termed
transportation
conformity
budgets)
"
adequate"
and
provided
our
adequacy
determination
to
the
TCEQ
on
May
16,
2005;
codified
in
70
FR
31441,
published
June
1,
2005.
Once
determined
adequate,
these
MVEBs
must
be
used
in
future
DFW
transportation
conformity
determinations.
The
DFW
MVEBs
are
shown
in
Table
2
below.

Table
2:
2007
DFW
Motor
Vehicle
Emissions
Budgets
Criteria
Used
to
Establish
the
2007
MVEB
VOC
(
tpd)
NOx
(
tpd)

2007
onroad
mobile
source
inventory,
unadjusted
104.14
206.72
TERP
credits
(
allocation
for
on­
road
mobile)
0
 
5.4
2007
MVEB
104.14
201.32
Nonroad
Mobile
Sources
The
2007
EI
for
nonroad
mobile
sources
was
developed
using
the
NONROAD
model.
This
model
produces
future
year
EIs
routinely,
and
the
most
recent
version
contains
future
estimated
activities
and
rules
that
will
affect
emissions.
Projected
LTO
data
was
used
to
develop
the
2007
aircraft
and
ground
support
EIs,
and
railroad
activity
was
estimated
using
previous
year
surveys
and
data
from
the
railroad
lines.
The
projected
2007
nonroad
mobile
source
inventory
is
120.83
tpd
NOx
and
54.58
tpd
VOC.
The
2007
nonroad
mobile
source
inventory
is
acceptable.

The
2002
emissions
summaries
for
VOC
and
NOx
are
shown
below;
they
are
not
adjusted
for
additional
emissions
outside
the
nonattainment
area.
The
2007
emissions
summaries
for
VOC
and
NOx
are
presented
in
Tables
4­
1
and
4­
2.
10
Table
3­
1:
2002
VOC
Emissions
by
County
and
Major
Category*
(
tpd)

County
Point
Area
Onroad
Mobile
Nonroad
Mobile
County
Totals
Collin
1.13
15.07
13.36
7.59
37.15
Dallas
9.26
80.87
69.65
29.33
189.11
Denton
1.00
19.07
12.45
6.63
39.15
Ellis
5.72
6.40
4.41
2.33
18.86
Johnson
0.77
6.94
4.26
1.31
13.28
Kaufman
0.75
7.42
4.28
1.64
14.09
Parker
0.70
7.40
3.70
1.16
12.96
Rockwall
0.00
1.87
1.70
1.36
4.93
Tarrant
8.98
59.38
42.53
18.73
129.62
Total
28.31
204.42
156.34
70.08
459.15
*
unadjusted
for
emissions
from
portable
fuel
containers
Table
3­
2:
2002
NOx
Emissions
by
County
and
Major
Category**
(
tpd)

County
Point
Area
Onroad
Mobile
Nonroad
Mobile
County
Totals
Collin
2.56
1.49
27.30
13.11
44.46
Dallas
15.93
14.44
140.77
46.78
217.92
Denton
0.58
11.16
27.71
10.39
49.84
Ellis
37.83
0.18
18.21
7.79
64.01
Johnson
4.01
0.23
10.64
6.41
21.29
Kaufman
0.35
0.16
12.36
2.53
15.40
Parker
2.62
1.32
11.74
1.78
17.46
Rockwall
0.00
0.10
7.40
1.14
8.64
Tarrant
15.43
8.95
89.31
46.31
160.00
Total
79.31
38.03
345.44
136.24
599.02
**
unadjusted
for
emissions
from
Alcoa
11
Table
4­
1:
2007
VOC
Emissions
by
County
and
Major
Category*
(
tpd)

County
Point
Area
Onroad
Mobile
Nonroad
Mobile
County
Totals
Collin
1.18
15.69
8.96
6.80
32.63
Dallas
9.30
84.96
47.40
21.90
163.56
Denton
1.04
20.13
8.16
5.21
34.54
Ellis
6.08
6.75
2.67
1.77
17.27
Johnson
0.79
7.31
2.35
1.02
11.47
Kaufman
2.11
8.03
2.57
1.24
13.95
Parker
0.84
7.76
2.01
0.90
11.51
Rockwall
0.05
1.95
0.99
1.97
4.96
Tarrant
9.03
63.33
29.03
13.77
115.16
Total
30.42
215.91
104.14
54.58
405.05
*
unadjusted
for
emission
reductions
from
portable
fuel
containers
Table
4­
4:
2007
NOx
Emissions
by
County
and
Major
Category**
(
tpd)

County
Point
Area
Onroad
Mobile
Nonroad
Mobile
County
Totals
Collin
3.60
1.54
17.86
11.82
34.82
Dallas
7.87
14.97
85.71
42.17
150.72
Denton
2.67
11.75
16.82
10.76
42.00
Ellis
39.43
0.18
9.80
7.07
56.48
Johnson
6.00
0.23
5.75
6.93
18.91
Kaufman
8.22
0.16
6.82
2.50
17.70
Parker
6.35
1.39
6.11
1.92
15.77
Rockwall
2.12
0.10
3.64
1.04
6.90
Tarrant
7.26
9.32
54.21
36.62
107.41
Total
83.52
39.64
206.72
120.83
450.71
**
unadjusted
for
emission
reductions
from
Alcoa
12
NOx
Control
Measures
The
TCEQ
cited
four
measures
that
will
contribute
to
NOx
reductions
in
the
DFW
5%
IOP.
These
include
the
Texas
Emissions
Reduction
Plan,
Energy
Efficiency
programs,
changes
that
result
in
emission
reductions
for
Lean­
Burn
and
Rich­
Burn
Engines
(
the
Chapter
117
SIP
revisions),
and
a
Federal
consent
decree
and
State
Permit
with
Alcoa
that
will
also
result
in
NOx
emission
reductions.
The
Chapter
117
revisions
are
evaluated
in
Attachment
5
to
this
TSD.

Texas
Emissions
Reduction
Plan
(
TERP)
The
TERP
was
established
by
the
77th
Texas
Legislature
with
the
enactment
of
Senate
Bill
5
(
SB
5).
While
TERP
primarily
addresses
diesel
emission
reductions,
a
small
portion
of
the
program
involves
energy
efficiency.
The
concept
of
TERP
as
an
economic
incentive
program
was
approved
into
the
Texas
SIP
on
November
14,
2001
at
66
FR
57159.
State
rules
that
govern
TCEQ's
administration
of
portions
of
the
TERP
were
approved
into
the
SIP
on
August
19,
2005,
at
70
FR
48647.
Additional
history
on
the
TERP
is
summarized
in
the
SIP
submittals.
The
State
included
TERP
as
a
NOx
reduction
measure
in
the
DFW
5%
IOP.
The
amount
of
TERP
credit
allocated
to
DFW
for
future
years
is
predicated
on
the
funding
formula
set
up
by
the
Legislature.
Full
funding
of
the
TERP
occurred
following
the
2003
Legislative
Session.
In
HB
1365,
87.5%
of
the
TERP
revenues
were
dedicated
to
the
diesel
emissions
reduction
incentive
program.
Projected
credits
are
calculated
based
on
cost
per
ton
of
previous
projects.
The
cost
cited
in
the
SIP
is
slightly
more
than
$
5,700/
ton.
Based
on
information
available
at
the
time
this
SIP
was
developed,
the
estimated
NOx
reductions
by
2007
are
22.2
tpd.

Energy
Efficiency
The
TERP
mandated
Energy
Efficiency/
Renewable
Energy
(
EE/
RE)
measures
to
help
meet
the
NAAQS.
The
78th
Legislature
further
enhanced
the
use
of
EE/
RE
programs
for
meeting
TERP
goals
by
requiring
TCEQ
to
promote
the
use
of
energy
efficiency
as
a
way
of
meeting
the
NAAQS
and
to
develop
a
method
for
calculating
emissions
reductions
for
the
SIP
from
energy
efficiency.
To
achieve
energy
savings
in
new
construction,
SB
5
mandated
statewide
adoption
of
the
International
Residential
Code
(
IRC)
and
the
International
Energy
Conservation
Code
(
IECC)
for
residential,
commercial
and
industrial
buildings,
through
new
building
code
requirements
(
Texas
Health
and
Safety
Code,
Chapter
388
­
Texas
Building
Energy
Performance
Standards),
which
are
enforced
by
local
jurisdictions.
The
emissions
reductions
relied
upon
in
this
5%
IOP
plan
occurred
in
2003
because
of
the
energy
savings
achieved
by
power
plants
and
newlyconstructed
residential
buildings.
These
NOx
reductions
have
already
been
achieved.
To
calculate
the
SIP
credit
for
these
reductions,
a
methodology
was
developed
by
the
Energy
Systems
Laboratory
of
Texas
A&
M
University,
with
assistance
from
EPA's
Office
of
Atmospheric
Programs,
the
TCEQ,
and
ERCOT.
This
methodology
is
detailed
in
Appendix
I
of
the
submittal,
with
supplemental
information
provided
in
Appendix
A
of
the
TSD.
The
methodology
considered
the
amount
of
energy
savings
within
the
nonattainment
counties
and
above
original
SIP
baseline
assumptions.
The
energy
savings
resulted
in
NOx
reductions
at
each
power
plant
within
the
ERCOT
region
and
reductions
of
natural
gas
within
each
county,
statewide.
The
ERCOT
serves
about
85%
of
Texas,
including
the
DFW
13
nonattainment
area.
The
NOx
reductions
were
calculated
based
on
electricity
and
natural
gas
savings
from
implementation
of
the
new
building
code
to
single
and
multi­
family
residences
in
2003;
the
energy
efficiency
measures
provide
electricity
savings
and
the
reductions
to
natural
gas
are
from
the
elimination
of
pilot
lights
in
furnaces.
The
projected
2007
NOx
reductions
from
these
EE
measures
are
estimated
to
be
229
tons.
On
a
peak
summer
day
in
2007,
the
actual
NOx
emission
reductions
are
calculated
be
0.72
tpd
in
the
DFW
area.
We
reviewed
EPA's
"
Guidance
on
SIP
Credits
for
Emission
Reductions
from
Electric­
Sector
Energy
Efficiency
or
Renewable
Energy
Measures,"
August,
2004,
which
requires
the
use
of
EPA's
"
Incorporating
Emerging
and
Voluntary
Measures
in
a
SIP,"
September
2004.
To
be
approved
into
the
SIP,
a
measure
reducing
emissions
from
electricity
generation
cannot
interfere
with
other
requirements
of
the
Act,
would
need
to
be
consistent
with
SIP
attainment,
maintenance
or
RFP/
ROP
requirements,
and
provide
emission
reductions
that
are
quantifiable,
surplus,
enforceable,
permanent,
and
must
not
exceed
3%
of
the
total
amount
of
emission
reductions
required
for
the
RFP.
Each
of
these
criteria
are
reviewed
below.
The
emission
reduction
measures
must
be
quantifiable
and
include
procedures
to
evaluate
and
verify
the
actual
reductions
achieved.
The
State
satisfied
this
requirement
using
several
spreadsheet
programs
that
conservatively
calculated
energy
savings
from
the
electricity
and
natural
gas
reductions
for
residential,
commercial
and
industrial
buildings.
Emission
reductions
are
considered
surplus
as
long
as
they
are
not
otherwise
relied
on
to
meet
attainment
requirements
in
air
quality
programs
related
to
the
SIP.
These
reductions
have
not
been
relied
upon
in
another
RFP/
ROP
plan
for
Texas;
they
occurred
in
2003,
are
complete
and
won't
be
allowed
to
be
credited
in
another
SIP.
Therefore,
the
reductions
are
surplus.
Had
they
not
already
been
implemented,
we
would
detail
how
these
measures
must
be
enforceable.
The
measure
is
permanent
throughout
the
term
for
which
the
credit
is
granted
unless
it
is
replaced
by
another
measure,
or
the
State
demonstrates
that
the
emission
reductions
from
the
measure
are
no
longer
needed
to
meet
applicable
requirements.
These
measures
have
been
implemented
in
residential
construction,
which
has
a
lifetime
beyond
the
term
for
which
this
credit
is
granted
(
2007)
and
are
therefore
permanent.
The
total
amount
of
NOx
emission
reductions
calculated
for
this
RFP,
as
shown
in
Table
5­
1
below,
is
27.59
tpd.
The
emissions
already
achieved
by
the
EE
measures
(
0.72
tpd)
is
2.6%
of
this
total
and
therefore
meets
the
3%
limit.
This
revision
to
the
Texas
SIP
will
contribute
to
attainment
of
the
8­
hour
ozone
NAAQS.
As
such,
EPA's
approval
of
this
revision
will
not
interfere
with
any
applicable
requirement
concerning
attainment
or
any
other
applicable
requirement
of
the
Act
and
it
meets
and
complies
with
section
110(
l)
of
the
Act.

Alcoa
­
Milam
County
EPA's
guidance
on
the
5%
IOP
plan
provides
examples
of
wind
rose
data
and
existing
modeling
data
as
information
that
could
be
used
to
demonstrate
the
impact
of
emissions
on
nonattainment
areas.
Alcoa
is
located
almost
due
south
of
the
DFW
area.
Texas
has
provided
wind
rose
and
back
trajectory
data
for
days
with
high
8­
hour
ozone
concentrations
and
confirmed
that
on
many
of
those
days,
winds
are
from
the
south.
Alcoa
is
one
the
largest
sources
of
NOx
in
the
State.
Texas
provided
data
from
an
aircraft
flight
showing
that
a
plume
from
the
Alcoa
14
facility
could
have
a
30
part
per
billion
(
ppb)
impact
(
above
background)
some
25­
30
miles
from
the
plant.
The
impact
on
DFW,
approximately
120
miles
north,
is
expected
to
be
smaller
but
significant;
emission
reductions
at
Alcoa
could
benefit
DFW
air
quality
and
should
be
creditable.
On
April
9,
2003,
a
Federal
Consent
Decree
was
signed
with
Alcoa,
which
required
the
facility
to
reduce
NOx
emissions
from
3
boilers
located
at
its
Milam
County
facility.
These
boilers
are
fired
by
locally
mined
lignite
coal
and
provide
power
to
the
company's
aluminum
smelting
operations.
At
a
distance
of
120
miles,
the
facility
is
within
the
200
km
radius
for
NOx,
but
outside
the
100
km
radius
for
VOC
emissions.
These
emission
reductions
are
also
required
to
be
permanent,
enforceable,
quantifiable
and
surplus.
Per
the
consent
decree,
the
reductions
must
be
permanent.
The
consent
decree
remains
in
place
until
either
the
existing
boilers
achieve
and
maintain
certain
emission
limitations
for
24
months,
the
replacement
boilers
achieve
and
maintain
certain
emission
limitations
for
24
months,
or
the
existing
boilers
have
been
permanently
shut
down.
Additionally,
the
consent
decree
terminates
only
after
all
of
the
requirements
of
the
consent
decree,
including
those
mentioned
above,
are
incorporated
into
Alcoa's
Title
V
operating
permit
for
the
Rockdale
facility
(
see
Consent
Decree
within
Appendix
D
of
the
submittal,
Section
XX
­
Termination).
The
emission
reductions
must
be
legally
and
practically
enforceable.
The
terms
of
the
consent
decree
are
legally
enforceable
by
EPA.
Texas
has
issued
Permit
No.
48437
to
Alcoa
that
incorporates
the
terms
of
the
consent
decree,
so
the
reductions
are
also
enforceable
by
TCEQ.
The
emission
reductions
are
practically
enforceable
because
the
consent
decree
requires
the
company
to
install,
operate
and
maintain
continuous
emissions
monitors
(
CEMs).
The
NOx
CEMs
must
be
certified
and
operated
in
compliance
with
40
CFR
Part
75
and
the
protocol
submitted
must
be
approved
by
EPA.
The
consent
decree
and
State
Permit
contain
emission
limits
upon
which
to
quantify
the
emission
reductions.
The
consent
decree
requires
three
boilers
to
be
in
compliance
or
shutdown
by
June
15,
2007.
Texas
chose
to
include
emission
reductions
for
just
one
of
the
boilers.
Texas
calculated
3.9
tpd
of
emission
reductions
would
occur
by
June
15,
2007.
EPA
has
reviewed
the
emissions
inventory
for
2002
and
the
emission
limits
in
the
consent
decree,
and
agree
that
3.9
tpd
of
emission
reductions
will
occur.
The
5%
IOP
rule
requires
that
emission
reductions
be
surplus
or
in
addition
to
measures
in
the
SIP
at
the
time
of
the
effective
date
of
the
designation
and
in
addition
to
national
or
regional
measures.
For
Alcoa,
the
reductions
must
be
surplus
to
the
State's
Regional
Ozone
plan
which
required
a
30%
reduction
in
emissions,
and
the
reductions
must
be
surplus
to
the
State's
New
Source
Review
(
NSR)
Program,
which
is
also
part
of
the
SIP.
On
April
19,
2000,
Texas
and
Alcoa
entered
into
an
agreed
order
that
was
later
submitted
to
EPA
and
approved
as
a
revision
to
the
SIP.
This
order
required
Alcoa
to
reduce
emissions
from
1998
levels
by
30%
and
required
the
reductions
be
in
place
by
December
31,
2002.
Texas
accounted
for
the
reductions
from
the
agreed
order
in
the
2002
inventory.
A
comparison
of
the
reported
emissions
to
the
emission
limits
in
the
agreed
order
indicates
that
all
3
boilers
were
in
compliance
with
the
terms
of
the
order
during
2002.
Emission
reductions
from
the
2000
agreed
order
were
included
in
the
2002
baseline
and
the
2003
reductions
are
surplus.
The
concern
regarding
whether
or
not
the
2003
reductions
are
surplus
to
the
State's
NSR
SIP
arises
because
the
2003
consent
decree
resulted,
in
part,
from
allegations
that
the
company
15
had
modified
the
facility
without
obtaining
the
NSR
permit.
If
reductions
obtained
by
correcting
a
violation
of
an
approved
rule
meet
the
terms
of
the
IOP
rule,
the
reductions
must
come
from
new
measures
not
already
in
the
SIP.
The
NSR
rules
are
not
new,
thus
reductions
from
complying
with
the
NSR
rules
should
not
be
creditable.
Alcoa
however,
agreed
to
go
beyond
requirements
that
would
have
been
in
place
had
the
facility
obtained
a
permit
when
the
alleged
violations
occurred.
Per
EPA,
modifications
made
in
the
1980'
s
should
have
been
permitted
and
subject
to
new
source
performance
standards.
The
limit
for
a
facility
burning
lignite
coal
would
have
been
0.6
lbs/
million
Btu.
The
permit
submitted
with
the
previous
Alcoa
NOx
reduction
(
30%
reduction
SIP)
indicated
the
facility
would
be
down
to
0.8
lbs/
million
Btu
by
2002.
If
the
company
was
operating
at
0.8
lbs/
million
Btu
in
2002,
the
difference
between
0.8
and
0.6
lbs/
million
Btu
would
not
be
creditable.
This
is
a
conservative
assumption
since
Alcoa
probably
operated
below
0.8
lbs/
million
Btu
in
2002.
With
this
assumption
and
recognizing
that
Alcoa
must
reduce
the
operating
rate
to
0.1
lbs/
million
Btu:
(.
6­
.1
lbs/
mmbtu)/(
0.8­.
1
lbs/
mmbtu)*
100
=
71;
71%
of
the
reductions
reported
by
Texas
would
be
available
for
credit.
Texas
reported
3.9
tpd,
thus
71%
or
2.8
tpd
are
creditable.
The
Alcoa
federal
consent
decree
strengthens
the
SIP
as
it
requires
the
affected
sources
to
reduce
their
NOx
emissions
beyond
the
level
of
compliance
otherwise
required
by
law
and
to
incorporate
those
requirements
into
a
Title
V
operating
permit.
This
revision
to
the
Texas
SIP
will
contribute
to
attainment
of
the
8­
hour
ozone
NAAQS.
As
such,
EPA's
approval
of
this
revision
will
not
interfere
with
any
applicable
requirement
concerning
attainment
or
any
other
applicable
requirement
of
the
Act
and
it
meets
and
complies
with
section
110(
l)
of
the
Act.

VOC
Control
Measures
The
TCEQ
included
three
measures
that
will
contribute
to
VOC
reductions:
the
Statewide
Portable
Fuel
Container
Rule,
and
revisions
to
expand
Surface
Coating
Operations
and
Stage
I
Vapor
Recovery
from
the
four
core
counties
to
all
nine
nonattainment
counties.

Statewide
Portable
Fuel
Container
Rule
TCEQ
adopted
regulations
for
portable
fuel
containers
sold
in
Texas
and
EPA
approved
the
rules,
published
in
the
Federal
Register
(
FR)
on
February
10,
2005
(
70
FR
7041).
The
regulations
will
lower
VOC
emissions
in
Texas
from
portable
fuel
containers
that
spill
or
leak.
TCEQ
projected
2.79
tpd
of
emissions
reductions
in
the
DFW
9
county
area
and
0.63
tpd
of
emissions
reductions
within
100
km
of
the
DFW
area,
a
total
of
3.42
tpd
of
VOC
emission
reductions
for
the
DFW
area.
TCEQ
used
methodology
developed
by
the
California
Air
Control
Board
to
project
the
emission
reductions.
See
70
FR
7041
and
the
associated
TSD
for
additional
information;
the
SIP
narrative
and
Appendix
H
of
the
submittal
also
provide
detail.

Surface
Coating
Operations
Various
rules
for
surface
coating
operations
are
in
effect
for
the
four
core
counties,
to
meet
1­
hour
ozone
nonattainment
requirements.
The
State
adopted
a
rule
extending
these
requirements
to
all
nine
nonattainment
counties.
In
a
separate
action,
EPA
approved
SIP
revisions
made
to
30
TAC
Chapter
117,
extending
the
rules
for
surface
coating
operations
to
the
five
new
nonattainment
counties
(
71
FR
3009,
published
January
19,
2006).
This
rule
will
reduce
16
VOC
emissions
by
0.3
tpd;
see
Attachment
6
to
this
TSD
for
details.

Stage
I
Vapor
Recovery
Rules
are
in
effect
for
Stage
I
vapor
recovery
during
gasoline
unloading
operations
in
the
four
core
counties,
with
an
exemption
for
facilities
with
a
throughput
equal
to
or
less
than
10,000
gallons
per
month
(
gpm).
Texas
adopted
a
rule
to
extend
the
Stage
I
requirements,
with
the
10,000
gpm
exemption,
to
all
nine
nonattainment
counties.
In
a
separate
action,
EPA
approved
SIP
revisions
made
to
30
TAC
Chapter
117,
extending
Stage
I
vapor
recovery,
(
71
FR
3009,
published
January
19,
2006).
This
rule
will
reduce
VOC
emissions
by
2.09
tpd;
see
Attachment
7
to
this
TSD
for
details.

3.
Calculation
of
the
5%
IOP
Table
5­
1
itemizes
and
sums
the
NOx
and
VOC
reductions
creditable
toward
the
5%
IOP.
Table
5­
2
shows
the
variables
used
to
calculate
the
adjusted
2002
EI,
from
which
the
5%
of
NOx
and
VOC
reductions
will
be
subtracted.
Table
5­
3
shows
the
variables
used
to
calculate
the
adjusted
2007
EI,
which
cannot
exceed
95%
of
the
adjusted
2002
EI
to
meet
the
5%
reduction.

Table
5­
1:
Calculation
of
Control
Strategy
Reductions
SOURCE
OF
REDUCTIONS
NOx
(
tpd)
VOC
(
tpd)

Existing
measures
TERP
22.2
Portable
fuel
containers
(
9
county
area)
2.79
Portable
fuel
containers
(
within
100
km
radius)
0.63
Surface
coating
(
expand
to
5
new
counties)
0.3
Lower
Stage
I
exemption
throughput
to
10,000
gpm
(
expand
to
5
new
counties)
2.09
Subtotal
22.2
5.81
Proposed
measures
Alcoa
(
within
200
km
radius)
2.8
Energy
Efficiency
0.72
IC
engines
(
9
county
area)
1.87
Subtotal
5.39
Total
identified
reductions
27.59
5.81
17
Table
5­
2:
Calculation
of
2002
Adjusted
Baseline
Emissions
Inventory
Variables
to
calculate
adjusted
EI
VOC
(
tpd)
NOx
(
tpd)

2002
baseline
EI
459.15
599.02
Alcoa
(
within
200
km
radius)
+
23.20
Portable
fuel
containers
(
within
100
km
radius)
+
4.52
Adjusted
2002
baseline
EI
463.67
622.22
The
VOC
control
strategy
reductions
provide
5.81
tpd,
which
is
1.25%
of
the
adjusted
2002
baseline.
The
NOx
reductions
provide
27.59
tpd,
which
is
4.43%
of
the
adjusted
2002
baseline.
Per
the
5%
guidance,
the
sum
of
the
percentage
of
the
VOC
reductions
planned
and
the
percentage
of
the
NOx
reductions
planned
must
equal
5%.
In
this
case,
the
sum
of
1.25%
+
4.43%
=
5.68%.

Table
5­
3:
Calculation
of
2007
Emission
Levels,
Adjusted
to
Meet
5%
Target
Variables
to
calculate
adjusted
EI
VOC
(
tpd)
NOx
(
tpd)

2007
inventory
405.05
450.71
Reductions
proposed
to
meet
5%
­
5.81
­
27.59
2007
EI,
adjusted
to
5%
target
levels
399.24
423.12
Per
EPA's
5%
IOP
guidance,
states
should
ensure
that
the
projected
2007
EI
is
at
least
5%
less
than
the
2002
EI,
whether
one
or
both
of
NOx
and
VOCs
are
used.
When
5%
is
subtracted
from
each
of
the
adjusted
2002
inventories,
the
emissions
for
VOCs
are
440.49
tpd
and
emissions
for
NOx
are
591.11
tpd.
The
2007
target
emission
inventories
are
lower
(
shown
in
Table
5­
4)
and
therefore
meet
the
5%
guidance.

Table
5­
4:
DFW
Reductions
from
2002
to
2007
Pollutant
Adjusted
2002
EI
2002
EI,
minus
5%
Adjusted
2007
EI
VOC
(
tpd)
463.67
440.49
399.24
NOx
(
tpd)
622.22
591.11
423.12
The
VOC
reductions
in
this
rulemaking
include
58.60
tpd
in
reduced
growth
and
5.81
tpd
from
new
measures.
The
NOx
reductions
include
171.51
tpd
in
reduced
growth
and
27.59
tpd
from
new
measures.
This
SIP
revision
demonstrates
that
the
DFW
nonattainment
area
has
met
the
5%
increment
of
emission
reduction
requirement.
18
EPA
Conclusion
and
Recommendation
This
SIP
revision
was
submitted
by
the
state
to
satisfy
obligations
for
the
1­
hour
ozone
attainment
demonstration
for
the
DFW
ozone
nonattainment
area.
The
State's
submittals
for
the
DFW
5%
IOP
show
emission
reductions
from
the
area's
2002
EI
to
the
2007
EI
greater
than
5%.
EPA
has
determined
that
the
VOC
and
NOx
reductions
submitted
for
new
measures
are
acceptable
for
all
sources
but
Alcoa.
After
adjusting
the
Alcoa
NOx
reductions
downward,
the
area
still
has
sufficient
emission
reductions
to
meet
the
5%
requirement.
The
emission
reduction
measures
credited
toward
the
5%
IOP
are
quantified,
permanent,
surplus,
and,
if
approved
by
EPA,
will
be
federally
enforceable
SIP
revisions.
We
have
also
reviewed
the
2002
EI
and
the
2007
MVEB
and
determined
that
they
are
consistent
with
the
requirements
of
the
Act
and
EPA's
regulations,
guidance
and
policy.
Therefore,
EPA
recommends
to
approve
this
submittal
as
a
Proposed
Federal
Register
notice.
Although
we
are
not
reopening
the
comment
period
on
RACT,
we
intend
to
finalize
our
proposed
approval
that
RACT
is
in
place
for
all
major
sources
of
VOCs
in
the
DFW
1­
hour
nonattainment
area
in
the
final
rulemaking
for
this
proposal.
These
revisions
fulfill
the
outstanding
attainment
demonstration
obligation
for
the
1­
hour
ozone
standard
in
the
DFW
nonattainment
area
and
the
outstanding
obligation
to
adopt
and
implement
all
applicable
requirements
under
the
1­
hour
ozone
standard.
We
propose
to
approve
these
rules
under
section
110
and
part
D
of
the
Act
and
EPA's
regulations.

Technical
Support
Material
Submitted
by
the
State
The
State
submitted
the
following
materials
as
technical
support
for
the
5%
IOP
plan:
1.
Notices
and
Proposal:
List
of
dates
and
publications
where
the
notice
of
public
hearing
was
printed
for
public
review;
list
of
officials
and
agencies
receiving
the
notice
of
public
hearings;
copy
of
the
notice
printed
in
the
Austin
American­
Statesman
on
November
22,
2004;
copy
of
the
notice
printed
in
the
Texas
Register
on
December
3,
2004;
and
the
proposed
Revisions
to
the
State
Implementation
Plan
for
the
Control
of
Ozone
Air
Pollution,
5
Percent
Increment
of
Progress
Demonstration,
Dallas/
Fort
Worth
Ozone
Nonattainment
Area,
8­
Hour
Ozone
Standard,
dated
November
17,
2004.
2.
Testimony:
Written
testimony
received
on
the
proposed
revisions;
oral
testimony
received
at
the
public
hearings
­
Arlington,
Texas
on
January
3,
2005
and
Austin,
Texas
on
January
4,
2005;
and
registration
forms
with
notice
of
intent
to
testify
at
the
hearing,
for
both
public
hearings.
3.
Evaluation:
interoffice
memorandum
to
the
TCEQ
commissioners
discussing
the
revisions
to
the
SIP
concerning
the
DFW
5%
IOP
plan;
and
response
to
comments
received
on
the
proposed
SIP
revision.
4.
Recommendation:
Revisions
to
the
SIP
for
the
Control
of
Ozone
Air
Pollution,
5
Percent
Increment
of
Progress
Demonstration,
Dallas/
Fort
Worth
Ozone
Nonattainment
Area,
8­
Hour
Ozone
Standard,
Adopted
April
27,
2005;
and
certified
copy
of
the
order
adopting
the
revision
to
the
SIP,
issued
May
9,
2005.
5.
CD­
ROM
with
Appendices
A
­
O
for
the
SIP
revision
and
5%
IOP
plan,
prepared
by
the
TCEQ,
dated
June
29,
2005.
