Austin/ Round Rock MSA Emissions Reduction Strategies Clean Air Action Plan Technical Report Prepared by The Capital Area Planning Council ( CAPCO) on behalf of The Austin Round Rock MSA Clean Air Coalition Austin, Texas, March 2004 A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 i Executive Summary This report supports the requirement outlined in the Austin Round Rock Metropolitan Statistical Area ( A/ RR MSA) Early Action Compact ( EAC), December 18, 2002 Memorandum of Agreement Section II A. 1 Milestones, Local Emission Reduction Strategies Selected, January 31,

2004 for the Clean Air Action Plan. It summarizes the control measures that will be in effect for the attainment demonstration.

Federal Regulations currently or expected to be in place are covered in Section Two. Existing or proposed State Regulations are covered in Section Three. These measures are described in a summary format and are addressed further in the Maintenance for Growth report.

Section Four covers the local measures that either, ( A) require state regulations or actions for implementation and enforcement or, ( B) are recommended for local regulation, agreement, or voluntary arrangement and implementation. A discussion including who is affected by the measure, what the control strategy and implementation plan is, the methodology used to calculate the emission reduction, and cost estimates for each control measure is included for the Table A measures. The amount of NOx reduced by the requested state regulations is estimated to be about 12.73 tpd and the VOC reduction about 23.64 tpd. The Table B measures are summarized and will have to be developed further by the local adopting authority. Jurisdictions may select from Table B the measures that will complete their " fair share" obligation to emission reductions. Estimation on the amount of emissions reductions from the locally instituted measures will depend on how they are implemented by each jurisdiction.

The total NOx and VOC reductions are 10.6% and 14.8% respectively of the 2007 anthropogenic emissions for the A/ RR MSA. The largest NOx reductions are coming from the Power Plants at 7.08 tpd. The largest VOC reductions come from the Degreasing Controls and Stage 1 Vapor Recovery Requirement Change at 6.38 and 4.88 tpd respectively. The Inspection and Maintenance program in Travis and Williamson County is the next greatest reduction category providing 2.89tpd NOx reduction and 3.84tpd VOC reduction. Table ES 1 provides the summary of local reduction measures explained in this document.

Emission Reduction Measure Pollutant Bastrop Caldwell Hays Travis Williamson Total NOx n/ a n/ a 0.30 2.16 0.73 3.19 VOC n/ a n/ a 0.35 2.80 1.04 4.19 NOx 0.01 0.00 0.01 0.13 0.03 0.19 VOC n/ a n/ a n/ a n/ a n/ a 0.00 NOx 0.02 0.01 0.05 0.34 0.11 0.54 VOC 0.03 0.01 0.05 0.39 0.12 0.60 NOx n/ a n/ a n/ a n/ a n/ a 0.00 VOC 0.16 0.19 0.63 2.83 1.08 4.88 NOx n/ a n/ a n/ a n/ a n/ a 0.00 VOC 0.09 0.05 0.19 1.74 0.52 2.60 NOx n/ a n/ a n/ a n/ a n/ a 0.00 VOC 0.03 0.01 0.03 0.66 0.18 0.91 NOx n/ a n/ a n/ a n/ a n/ a 0.00 VOC 0.07 0.04 0.26 5.47 0.54 6.38 NOx n/ a n/ a n/ a n/ a n/ a 0.00 VOC 0.00 0.00 0.00 0.03 0.01 0.05 NOx n/ a n/ a n/ a n/ a n/ a 0.00 VOC 0.07 0.05 0.06 0.61 0.24 1.03 NOx n/ a n/ a n/ a n/ a n/ a 0.00 VOC 0.11 0.05 0.17 1.74 0.81 2.87 NOx 0.10 0.04 0.19 1.19 0.48 2.00 VOC n/ a n/ a n/ a n/ a n/ a 0.00 NOx 2.94 0.00 0.00 4.14 0.00 7.08 VOC n/ a n/ a n/ a n/ a n/ a 0.00 NOx 0.03 0.02 0.07 0.45 0.15 0.72 VOC 0.04 0.02 0.07 0.54 0.17 0.83 NOx 3.11 0.07 0.61 8.43 1.50 13.72 VOC 0.59 0.42 1.81 16.80 4.72 24.34 NOx 12.52 5.88 17.42 69.70 22.85 128.38 VOC 8.58 17.23 13.87 93.87 31.17 164.72 NOx 24.8% 1.2% 3.5% 12.1% 6.6% 10.7% VOC 6.9% 2.4% 13.1% 17.9% 15.1% 14.8% * Note that total I/ M reductions without Hays County are estimated to be 2.89tpd of NOx and 3.84tpd of VOC Percent Reduction [%] COUNTY TERMS Power Plant Reductions GRAND TOTAL ( REDUCTIONS) [ TPD] Total Anthropogenic Emissions [ TPD] Cutback Asphalt Low Reid Vapor Pressure Gas TERP Low Emission Gas Cans Architectural/ Industrial Coatings Controls Degreasing Controls Autobody Refinishing Controls * Inspection and Maintenance ( I& M)

Idling Restrictions on Heavy Diesel Commute Emission Reduction Program Stage I Vapor Recovery Requirement Change Table 1 1. A/ RR MSA Local Measures Emission Reductions Summary The emission distributions over the counties in the MSA are depicted in Figure ES 1 for VOC reductions and Figure ES 2 for NOx reductions. Travis County will be providing most of the reductions in both VOC and NOx at 70% and 61% respectively. Williamson County will provide a 19% reduction in VOC and Bastrop County a 23% reduction in NOx. Emission Reduction Distribution VOC Travis 70% Williamson 19% Bastrop 2% Caldwell 2%

Hays 7%

Total VOC Reduced: 25.6tpd Figure 1 1. A/ RR MSA VOC Emission Reduction Distribution. This assumes I/ M or equivalent reduction program in Hays County Emission Reduction Distribution NOx Bastrop 23%

Caldwell 1%

Hays 4%

Travis 61% Williamson 11%

Total NOx Reduced: 13.8tpd Figure 1 2. A/ RR MSA NOx Emission Reduction Distribution. This assumes I/ M or equivalent reduction program in Hays County TABLE OF CONTENTS Executive summary.............................................................................................................. i TABLE OF CONTENTS ................................................................................................... iv 1 Introduction...................................................................................................................... 1 1 2 Federal Reduction Strategies ............................................................................................ 2 1 Non Road Measures............................................................................................................. 2 1 2.1 REFORMULATED SURFACE COATINGS........................................................... 2 3 2.2 AUTO BODY REFINSHING .................................................................................. 2 4 2.3 TIER 2 MOTOR VEHICLE EMISSION REGULATIONS ...................................... 2 5 2.4 NATIONAL LOW EMISSION VEHICLE STANDARD......................................... 2 6 2.5 HEAVY DUTY DIESEL ENGINE RULE............................................................... 2 7 2.6 STANDARDS FOR SMALL SPARK IGNITION HANDHELD ENGINES............ 2 8 2.7 COMPRESSION IGNITION STANDARDS FOR VEHICLES AND EQUIPMENT 2 8 2.8 EMISSIONS STANDARDS FOR LARGE SPARK IGNITION ENGINES ............. 2 9 2.9 EMISSIONS STANDARDS FOR SPARK IGNITION MARINE ENGINES........... 2 9 2.10 EMISSIONS CONTROLS FOR LOCOMOTIVES ................................................ 2 10 2.11 ALCOA CONSENT DECREE............................................................................... 2 12 3 State and Regional Reduction Strategies........................................................................... 3 1 Sec. .................................................................................................................................. 3 1 Category .......................................................................................................................... 3 1 Reductions in 2007 ( tpd) .................................................................................................. 3 1 Area Source: .................................................................................................................... 3 1 On road Source: ............................................................................................................... 3 1 Non road Source: ............................................................................................................. 3 1 Point Source:.................................................................................................................... 3 1 3.1 DEGREASING UNITS............................................................................................ 3 1 3.2 GRANDFATHERED PIPELINES ........................................................................... 3 2 3.3 STAGE 1 VAPOR RECOVERY.............................................................................. 3 2 3.4 STATE LOW EMISSION DIESEL PROGRAM...................................................... 3 3 3.5 ELECTRIC GENERATING UTILITY NOX REDUCTIONS.................................. 3 4 3.6 VOLUNTARY EMISSIONS REDUCTION PERMIT ( VERP) ................................ 3 4 3.7 HB 2912 Grandfathered Requirements ..................................................................... 3 5 3.8 CEMENT KILN NOx LIMITS................................................................................. 3 5 4 Local Strategies................................................................................................................ 4 1 4.1 LOCAL STRATEGIES INTRODUCTION.............................................................. 4 1 4.2 TABLE A EMISSION REDUCTION MEASURES................................................. 4 1 4.2.1 Inspection and Maintenance ( A1)...................................................................... 4 2 4.2.2 Idling Restrictions on Heavy Duty Diesel Engines ( A2).................................. 4 11 4.2.3 Commute Emission Reduction Program ( A3).................................................. 4 14 4.2.4 Low Emission Gas Cans ( A4) ......................................................................... 4 18 4.2.5 Stage 1 Vapor Recovery Requirement Change ( A5)........................................ 4 23 4.2.6 Degreasing Controls ( A6) ............................................................................... 4 27 4.2.7 Autobody Refinishing Controls ( A7) .............................................................. 4 29 4.2.8 Cut Back Asphalt ( A8).................................................................................... 4 35 4.2.9 Low Reid Vapor Gas ( A9) .............................................................................. 4 36 4.2.10 BACT and Offsets for New or Modified Point Sources ( A10)......................... 4 40 4.2.11 Petroleum Dry Cleaning ( A11) ....................................................................... 4 40 4.2.12 Texas Emission Reduction Program ( TERP) ( A12)......................................... 4 42 4.2.13 Power Plant Reductions ( A13) ........................................................................ 4 47 4.3 TRANSPORTATION EMISSION REDUCTION MEASURES ( TERMS) ............ 4 50 4.4 TABLE B EMISSION REDUCTION MEASURES ............................................... 4 52 4.4.1 Texas Emission Reduction Program ( TERP)................................................... 4 57 4.4.2 Texas Low Emission Diesel ( TxLED) for Fleets ............................................. 4 57 4.4.3 Transportation Emission Reduction Measures ( TERMs) ................................. 4 57 4.4.4 Access Management ....................................................................................... 4 58 4.4.5 Alternative Commute Infrastructure Requirements.......................................... 4 58 4.4.6 Drive Through Facilities on Ozone Action Days............................................. 4 58 4.4.7 Expedited permitting for mixed use, transit oriented or in fill development..... 4 59 4.4.8 Use of electric or alternative fuels for airport GSE.......................................... 4 59 4.4.9 ABIA Airside incentives for GSE use reduction.............................................. 4 59 4.4.10 Integrate alternative fuels into City's aviation fleet .......................................... 4 60 4.4.11 Operate alternative fueled surface parking lot shuttle buses............................. 4 60 4.4.12 Use existing ABIA alternative fuel infrastructure for off site parking shuttle buses 4 60 4.4.13 Low VOC Striping Material............................................................................ 4 60 4.4.14 Landfill Controls............................................................................................. 4 61 4.4.15 Open Burning Restrictions .............................................................................. 4 61 4.4.16 Tree Planting .................................................................................................. 4 62 4.4.17 Extend energy efficiency requirements beyond SB5 and SB7.......................... 4 62 4.4.18 Shift the electric load profile ........................................................................... 4 62 4.4.19 Environmental dispatch of power plants.......................................................... 4 62 4.4.20 Clean Fuel Incentives...................................................................................... 4 63 4.4.21 Low Emission Vehicles .................................................................................. 4 63 4.4.22 Adopt a School Bus Program......................................................................... 4 63 4.4.23 Police Department Ticketing........................................................................... 4 63 4.4.24 EPA Smart Way Transport Program ............................................................... 4 64 4.4.25 Business Evaluation of Fleet Usage, Including Operations and Right Sizing ... 4 64 4.4.26 Parking Incentives for Alt Fuel or Low Emission vehicles .............................. 4 64 4.4.27 Commute Solutions Programs......................................................................... 4 65 4.4.28 Direct Deposit................................................................................................. 4 65 4.4.29 e Government and/ or Available Locations ...................................................... 4 65 4.4.30 Voluntary use of APUs for locomotives operating in Central Texas ................ 4 65 4.4.31 Fueling of Vehicles in Evening ....................................................................... 4 65 4.4.32 Urban Heat Island/ Cool Cities Program.......................................................... 4 66 4.4.33 Resource Conservation ................................................................................... 4 66 4.4.34 Increase investments by Central Texas electric utility providers in energy demand management programs ................................................................................................... 4 66 4.4.35 Alter production processes and fuel choices .................................................... 4 67 4.4.36 Contract provisions addressing construction related emissions on high ozone days 4 67 4.4.37 Ensure emission reduction in SEPs, BEPS and similar agreements.................. 4 68 4.4.38 Ozone Action Day Education Program............................................................ 4 68 4.4.39 Ozone Action Day Notification Program......................................................... 4 68 4.4.40 Ozone Action Day Response Program ............................................................ 4 68 4.4.41 Alternative Fuel Vehicles................................................................................ 4 68 4.4.42 Right Sizing.................................................................................................... 4 69 4.4.43 5 minute Limit on Diesel Idling ...................................................................... 4 69 4.4.44 Cleaner Diesel ................................................................................................ 4 70 4.4.45 Vehicle Maintenance ...................................................................................... 4 70 4.4.46 Vapor Recovery on Pumps.............................................................................. 4 70 4.4.47 Low VOC Asphalt .......................................................................................... 4 71 4.4.48 Low Emission Gas Cans ................................................................................. 4 71 4.4.49 Transit Oriented Development ........................................................................ 4 71 4.4.50 Shaded Parking............................................................................................... 4 72 4.4.51 Landscaping voluntary start at noon on high ozone days ( education program). 4 72 LIST OF FIGURES Figure 1. A/ RR MSA VOC Emission Reduction Distribution ................................................... iii Figure 2. A/ RR MSA NOx Emission Reduction Distribution ..................................................... iii LIST OF TABLES Table 1 1. A/ RR MSA Local Measures Emission Reductions Summary .................................... ii Table 2 1 EPA ISSUED RULES Estimated NOx Reductions ........................................................ 2 1 Table 2 2. Federal Non road NOx reductions........................................................................... 2 2 Table 2 3. Federal Non road VOC reductions .......................................................................... 2 3 Table 2 4. Architectural Coatings VOC Emission Reduction ................................................... 2 4 Table 2 5. Auto Body Refinishing VOC Emission Reduction .................................................. 2 4 Table 2 6. Federal Tier 2 NOx Reduction ................................................................................ 2 5 Table 2 7. Federal Tier 2 VOC Reduction................................................................................ 2 5 Table 2 8. Federal NLEV NOx Reduction................................................................................ 2 6 Table 2 9. Federal NLEV VOC Reduction............................................................................... 2 7 Table 2 10. Federal H D Diesel NOx Reductions..................................................................... 2 7 Table 2 11. Federal H D Diesel VOC Reductions .................................................................... 2 8 Table 2 12. Locomotive Rule NOx Emission Reduction ........................................................ 2 11 Table 2 13. Annual NOx Reductions from Anticipated Locomotive Standards....................... 2 11 Table 3 1. Summary of TCEQ Issued Rules for Reduction Strategies ...................................... 3 1 Table 3 2. NOx reductions from degreasing rule ...................................................................... 3 2 Table 3 3. Stage 1 VOC emission reduction............................................................................. 3 3 Table 3 4. Utility ( EGU) NOx Reductions .............................................................................. 3 4 Table 3 5. Cement Kiln NOx Reduction................................................................................... 3 6 Table 4 1. I& M NOx Emission Reduction .............................................................................. 4 7 Table 4 2. I& M VOC Emission Reduction............................................................................... 4 7 Table 4 3. Run and Idle Time Derivation * From TTI .......................................................... 4 13 Table 4 4. Estimation of Heavy Duty Fleet Size ^ From TTI ................................................. 4 13 Table 4 5. Idling Restrictions NOx Emission Reduction ........................................................ 4 14 Table 4 6. Commute Program NOx Emission Reduction........................................................ 4 17 Table 4 7. Commute Program VOC Emission Reduction....................................................... 4 17 Table 4 8. 2007 State Emission Reductions............................................................................ 4 21 Table 4 9. Low Emission Gas Can VOC emission reduction.................................................. 4 22 Table 4 10. Gasoline station throughput................................................................................. 4 24 Table 4 11. Stage I Rule penetration for gas stations ............................................................. 4 24 Table 4 12. Expected emission reduction from Stage I Vapor recovery control ...................... 4 24 Table 4 13. Stage I controls VOC reductions by County ........................................................ 4 25 Table 4 14. Number of Retail Gasoline Tanks and Stage I Units by County ( 2003)................ 4 25 Table 4 15. Number of Tanks Without Stage I Capability, by Throughput ............................. 4 26 Table 4 16. Annual Costs by Throughput............................................................................... 4 26 Table 4 17. Cost Effectiveness by Rule Cut Off Level ($/ Ton VOC)..................................... 4 26 Table 4 18. Cold Cleaning Degreasing VOC Emission Reduction......................................... 4 28 Table 4 19. Comparison of VOC Limits of the Federal Rule and SCAQMD......................... 4 30 Table 4 20. Comparison of Characteristics of Paint Spray Equipment for Automotive Refinishers ..................................................................................................................... 4 33 Table 4 21. Autobody Refinishing VOC Emission Reduction ............................................... 4 34 Table 4 22. Comparison of Control Options, Source: U. S. EPA, 2002. .................................. 4 34 Table 4 23. Asphalt Paving VOC Emission Reduction........................................................... 4 36 Table 4 24. Low Reid Vapor Pressure VOC Emission Reduction........................................... 4 38 Table 4 25. RVP Cost Calculations........................................................................................ 4 39 Table 4 26. TERP NOx emission reduction............................................................................ 4 46 Table 4 27. Point Source NOx emission reduction ................................................................. 4 49 Table 4 28. Point Source NOx emission reduction by County................................................ 4 49 Table 4 29. TERM Projects ........................................................................................................ 4 51 Table 4 30. TERM VOC reduction ........................................................................................ 4 51 Table 4 31. TERM NOx reduction......................................................................................... 4 52 A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 1 1 1 Introduction The Texas Commission on Environmental Quality ( TCEQ) and the Environmental Protection Agency ( EPA) are working with communities to achieve clean air as soon as possible by entering into Early Action Compacts ( EAC) to reduce ground level ozone pollution. The EAC provides the mechanism for local emission reduction measures to be considered and recommended for inclusion in the State Implementation Plan. This document provides the description for each of the local control measures under consideration. This final selection of measures is based on review and approved by local stakeholders and officials and on technical demonstration showing attainment of the 8

hour ozone standard by December 31, 2007.

Various emission reduction techniques can effectively reduce ozone precursors.

Emission reduction methods employed nationally ( e. g., automotive emission reductions),

statewide and regionally ( emission reductions from EGUs) benefit the Austin area, but more reductions are needed to ensure clean air for the region. Ozone precursors include Nitrogen Oxides ( NOx) and Volatile Organic Compounds ( VOC) from vehicles, electric utilities and other industrial, commercial and residential sources that burn fuels.

Modeling was performed to indicate the amount of reductions needed in the area. The model shows that up to 80% of ozone monitored locally has been transported from outside the area. An important characteristic of NOx emissions is that they can be transported long distances and cause problems far from the original emissions source.

Emission reductions in other nonattainment areas will not only beneficially impact the Austin area but will also provide possible solutions for local emissions sources. TCEQ is encouraged to evaluate new major sources for impact on ozone background levels and extend local strategies to a larger, regional area. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 1 2 The Austin Round Rock MSA includes the following counties, Bastrop ( population 63 thousand), Caldwell ( 35 thousand), Hays ( 109 thousand), Travis ( 851 thousand), and Williamson ( 290 thousand). The development of the emission reduction strategies for this area has proved to be an extremely challenging effort, due to the impact of emissions transport from outside of the area, the small number of local point sources, and the monitored ozone varying so closely above and below the standard. We developed a technical advisory committee and created working groups of Area Source, Point Source,

On Road, and Non Road categories. We worked with stakeholders to consider control measures that can reasonably be implemented in each area. Other factors that were considered were the geographic area to which the control measure could be applied, the implementation dates, and resource constraints of the area.

Emission reductions were calculated by applying, where applicable, rule penetration ( RP), rule effectiveness and control efficiency factors. Rule penetration represents the percentage of the source category under consideration that is affected by a certain rule.

Rule effectiveness ( RE) is a measure of the expected degree of actual compliance with the controls specified by a rule. Control efficiency represents expected emission reductions due to process change or control implementation from the source that complies with a specific rule. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 1 2 Federal Reduction Strategies The Clean Air Action Plan ( CAAP) projects emission reductions from the following federal initiatives. A discussion on these rules is presented in the following sections.

Table 2 1 EPA ISSUED RULES Estimated NOx Reductions Sec. Category Reductions in 2007 ( tpd) Area Source measures: VOC NOx 2.1 2.2   Architectural and Industrial Maintenance Coatings   Auto Body Refinishing 1.44 0.52 n/ a n/ a On Road measures: 2.3 2.4 2.5   Tier 2 Vehicle Emission Standards   National Low Emission Vehicle Program   Heavy Duty Diesel Engine Rule 5.71 1.70 0.34 16.79 3.01 11.78 Non Road measures: 2.7 2.8 2.9 210 2.11   Small Spark Ignition Handheld Engines   Emissions from Compression Ignition Engines   Emissions from Nonroad Large Spark Ignition Engines, and Recreational Engines   Recreational Marine Standards   Locomotives 9.27 n/ a 3.48 2.28 Point Source Measures: 2.12   ALCOA Consent Decree n/ a 54 Total 18.98 91.34 Non Road Measures " Nonroad" is a term that covers a diverse collection of engines, equipment, vehicles, and vessels. Sometimes referred to as " off road" or " off highway," the nonroad category includes outdoor power equipment, recreational vehicles, farm and construction machinery, lawn and garden equipment, marine vessels, locomotives, and many other applications.

The NONROAD model was run to evaluate the reductions of federal regulations relating to certain non road equipment operating in the A/ RR MSA. The method was to ( 1) run the State of Texas for a typical ozone season weekday in 2007 and then ( 2) turn off all federal regulations being implemented after the year 1999. This provided a percentage of A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 2 reductions for hydrocarbons ( VOC) and oxides of nitrogen ( NOx) which was then applied to the local inventory as shown in Table 2 2 and Table 2 3 respectively.

Due to the nature of the NONROAD model, it was not directly possible to estimate the impact of any specific EPA regulation, such as " Phase II Small Handheld Equipment."

This is because the model uses engine technology families as opposed to specific rules ( e. g., M2, TIER2 GANO4) and because with the more recent regulations, manufacturers are allowed to introduce cleaner engines on a schedule depending on horsepower,

milestone year, and corporate averaging credits. Therefore, the emissions reductions in sections 2.6 through 2.9 are shown as a total of 9.27 tpd VOC and 3.48 tpd NOx in Table 2 1. However, it is easy to grasp the general trends in categories such as residential lawn and garden equipment or recreational marine engines, which are dominated by singlescope rules. 1 Equipment Base 2007 NOx ( tpd) Federally Controlled NOx ( tpd) Net Reduction NOx ( tpd) Reduction Agricultural 2.37 2.20 0.17 7.2% Commercial 1.66 1.49 0.17 10.0% Construction 12.73 10.60 2.13 16.7% Industrial 5.40 5.00 0.40 7.4% Commercial Lawn & Garden 2.78 2.25 0.53 19.1% Residential Lawn & Garden 0.28 0.21 0.07 25.7% Recreational Vehicles 0.08 0.07 0.01 12.5% Total 25.33 21.85 3.48 13.7%

Table 2 2. Federal Non road NOx reductions 1 ERG memo Percentage Reductions Using the NONROAD Model, February 27, 2004 A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 3 Equipment Base 2007 NOx ( tpd) Federally Controlled NOx ( tpd) Net Reduction NOx ( tpd) Reduction Agricultural 0.30 0.28 0.02 7.6% Commercial 2.41 1.61 0.80 33.2% Construction 2.10 1.52 0.58 27.8% Industrial 1.41 1.20 0.21 14.9% Commercial Lawn & Garden 13.96 7.46 6.50 46.5% Residential Lawn & Garden 2.77 1.76 1.01 36.4% Pleasure Craft 0.52 0.41 0.11 21.6% Recreational Vehicles 2.79 2.75 0.04 1.3% Total 26.26 16.99 9.27 35.3% Table 2 3. Federal Non road VOC reductions 2.1 REFORMULATED SURFACE COATINGS Rule 40 CFR 59, National Volatile Organic Compound Emission Standards for Architectural Coatings, restricts the VOC content of architectural, industrial maintenance, special industrial, and highway markings surface coatings. This measure affects makers of architectural, industrial maintenance, special industrial, and highway markings surface coatings. Compliance is required by September 13, 1999, or March 10,

2000. According to the most recent EPA guidance the final rule is expected to yield a 20% reduction in VOC emissions from Architectural and Industrial Maintenance ( AIM)

coating sources. This estimate includes a control efficiency of 20%, rule penetration and effectiveness of 100%.

Reductions for AIM coatings are achievable through product reformulations, product substitution, and consumer education. Reformulations include altering the components of the coating to achieve a lower VOC content, replacing VOC solvents with water or alternative non VOC solvents, and increasing the solids content of the coating thereby reducing the volume applied. Product substitution is accomplished by replacing higher

VOC coatings with currently available lower VOC coatings. Consumer education will provide information on the relative cost of lower VOC coatings and encourage careful,

efficient use of such products. Specific VOC content limits included in the regulatory A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 4 negotiations are not yet published. Table 2 4 provides an estimate on the reductions this rule will provide the A RR MSA.

Table 2 4. Architectural Coatings VOC Emission Reduction 2.2 AUTO BODY REFINSHING In 40 CFR Part 59, Subpart B, National Volatile Organic Compound Emission Standards for Automobile Refinish Coatings, the EPA set forth policy on the creditable reductions to be assumed from the national rule for auto body refinishing. The provisions of the rule apply to automobile refinish coatings and coating components that are manufactured on or after January 11, 1999 for sale or distribution in the United States. These reductions,

presented in Table 2 5, represent a 37% reduction from current emissions with an assumption of 100% rule efficiency ( presuming the coating application instructions were being followed) and penetration.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

AREA SOURCES:

Autobody Shops SCCs: 2401070000,

2401001025 &

2401005000 National Volatile Organic Compound Emission Standards for Auto Body Refinishing Austin Round Rock MSA ( 5 Counties) 0.90 0.57 0.33 37.0%

Table 2 5. Auto Body Refinishing VOC Emission Reduction Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

AREA SOURCES:

Architectural Coatings SCC: 2401008000,

2401001000,

2401001001,

2401001005,

2401001006,

2401001010,

2401001011,

2401001015,

2401001020 National Volatile Organic Compound Emission Standards for Architectural Coatings Austin Round Rock MSA ( 5 Counties) 7.18 5.74 1.44 20.0% A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 5 2.3 TIER 2 MOTOR VEHICLE EMISSION REGULATIONS The U. S. EPA promulgated a rule on February 10, 2000 ( 40 CFR Parts 80, 85 and 86, Air Pollution; Tier 2 Motor Vehicle Emission Standards and Gasoline Sulphur Control Requirements; Diesel Fuel Quality Controls) requiring more stringent tailpipe emissions standards for all passenger vehicles, including sport utility vehicles ( SUVs), minivans,

vans and pick up trucks. These regulations also require lower levels of sulfur in gasoline,

which will ensure the effectiveness of low emission control technologies in vehicles and reduce harmful air pollution.

The new tailpipe and sulfur standards require passenger vehicles to be 77 to 95 percent cleaner than those built before the rule was promulgated and will reduce the sulfur content of gasoline by up to 90 percent. The new tailpipe standards are set at an average standard of 0.07 grams per mile for NOx for all classes of passenger vehicles beginning in 2004. This includes all light duty trucks, as well as the largest SUVs. Vehicles weighing less than 6000 pounds will be phased in to this standard between 2004 and 2007.

These reductions are presented in Table 2 6 for NOx and Table 2 7 for VOC. They are estimated to be a 35.7% reduction or a net 16.79 tpd of NOx and 15.3% or a net 5.71 tpd for VOC in the A/ RR MSA.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

LDGVs + LDGT NLEV II ( Tier 2) Austin Round Rock MSA ( 5 Counties) 47.01 30.23 16.79 35.7%

Table 2 6. Federal Tier 2 NOx Reduction Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

LDGVs + LDGT NLEV II ( Tier 2) Austin Round Rock MSA ( 5 Counties) 37.23 31.52 5.71 15.3%

Table 2 7. Federal Tier 2 VOC Reduction A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 6 The significant environmental benefits of this program would come at an approximate cost to consumers of less than $ 100 for cars and $ 200 for light duty trucks. EPA estimates the program will cost industry about $ 5.3 billion. In contrast, health and environmental benefits are estimated to be $ 25.2 billion.

2.4 NATIONAL LOW EMISSION VEHICLE STANDARD Under the National Low Emission Vehicle ( NLEV) program ( 40 CFR Parts 9, 85, and 86,

Control of Air Pollution From New Motor Vehicles and New Motor Vehicle Engines:

State Commitments to National Low Emission Vehicle Program), auto manufacturers have agreed to comply with tailpipe standards that are more stringent than EPA can mandate prior to model year ( MY) 2004. These federally implemented programs affect light duty vehicles and trucks.

Once manufacturers committed to the program, the standards became enforceable in the same manner that other federal motor vehicle emissions control requirements are enforceable. The program went into effect throughout the Ozone Transport Region ( OTR) in model year 1999 and will be nationwide in model year 2001. The National Low Emission Vehicle Program requires more stringent exhaust emission standards than the Federal Motor Vehicle Control Program Tier I ( or Phase I) exhaust standards.

These reductions are presented in Table 2 8 for NOx and Table 2 9 for VOC. They are estimated to be a 9.1% reduction or a net 3.01 tpd of NOx and 5.1% or a net 1.7 tpd for VOC in the A/ RR MSA.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

LDGVs + LDGT NLEV I Austin Round Rock MSA ( 5 Counties) 33.24 30.23 3.01 9.1%

Table 2 8. Federal NLEV NOx Reduction A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 7 Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

LDGVs + LDGT NLEV I Austin Round Rock MSA ( 5 Counties) 33.23 31.52 1.70 5.1%

Table 2 9. Federal NLEV VOC Reduction 2.5 HEAVY DUTY DIESEL ENGINE RULE Under the Heavy Duty Diesel Engine Rule ( 40 CFR Parts 85 and 86, Emissions Control,

Air Pollution From 2004 and Later Model Year Heavy Duty Highway Engines and Vehicles; Light Duty On Board Diagnostics Requirements, Revision; Final Rule Friday,

October 6, 2000), truck manufacturers must comply with tailpipe standards that are more stringent by 2004 for all diesel vehicles over 8,500 pounds. These federally implemented programs affect heavy duty diesel engines used in trucks. The standards are enforceable in the same manner that other federal motor vehicle emissions control requirements are enforceable. The new standards require diesel trucks to be more than 40 percent cleaner than today's models.

The second phase of the program will require cleaner diesel fuels and even cleaner engines, and will reduce air pollution from trucks and buses by another 90 percent. EPA expects to issue the final rule, to take effect in 2006 2007, for the second phase of the program by the end of 2003.

These reductions are presented in Table 2 10 for NOx and Table 2 11 for VOC. They are estimated to be a 41% reduction or a net 11.78 tpd of NOx and 30% or a net .34 tpd for VOC in the A/ RR MSA. This includes fleet turnover, which will continue to reduce emissions over time.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

HDDV 2004 HDDV standards Austin Round Rock MSA ( 5 Counties) 40.50 28.73 11.78 41.0%

Table 2 10. Federal H D Diesel NOx Reductions A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 8 Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

HDDV 2004 HDDV standards Austin Round Rock MSA ( 5 Counties) 1.48 1.14 0.34 30.0%

Table 2 11. Federal H D Diesel VOC Reductions 2.6 STANDARDS FOR SMALL SPARK IGNITION HANDHELD ENGINES The rules for small spark ignition handheld engines are codified in 40 CFR Part 90 Control of Emission from Nonroad Spark Ignition Engines at or Below 19 Kilowatts. In July 1995, EPA finalized the first federal regulations affecting small nonroad SI engines at or below 19 kilowatts ( kW), or 25 horsepower. The regulations, commonly known as " Phase 1," took effect for most new handheld and nonhandheld engines beginning in model year 1997 and expected to result in a 32 percent reduction in HC emissions from these engines. For the nonhandheld categories, Class I engines are used primarily in walk behind lawnmowers and Class II engines are used primarily in lawn and garden tractors.

For the handheld categories, Class III and IV engines are used primarily in residential equipment such as string trimmers, leaf blowers and chainsaws. Class V engines are used primarily in commercial equipment such as chainsaws.

The Phase 2 handheld engine standards will result in a 70 percent reduction in HC+ NOx emissions from these engines beyond the 32 percent reduction from the Phase 1 standards. The Phase 2 standard began with the 2002 model year. This reduction in HC+ NOx emissions will be accompanied by an overall reduction in fuel consumption.

2.7 COMPRESSION IGNITION STANDARDS FOR VEHICLES AND EQUIPMENT This rule is addressed in 63 Federal Register 56968 ( October 23, 1998) and codified in 40 CFR Part 89 Control Of Emissions From New And In use Nonroad Compression ignition Engines. Non road diesel engines, also referred to as non road compression ignition engines, dominate the large non road engine market. Examples of non road equipment A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 9 that use diesel engines include: agricultural equipment such as tractors, balers, and combines; construction equipment such as backhoes, graders, and bulldozers; general industrial equipment such as concrete/ industrial saws, crushing equipment, and scrubber/ sweepers; some lawn and garden equipment such as garden tractors, rear engine mowers, and chipper/ grinders; material handling equipment such as heavy forklifts; and utility equipment such as generators, compressors, and pumps.

On October 23, 1998, EPA adopted more stringent emission standards for NOx, VOC's and particulate matter ( PM) for now non road, compression ignition engines, to be phased in over several years beginning in model year 1999.

2.8 EMISSIONS STANDARDS FOR LARGE SPARK IGNITION ENGINES This rule is covered in 40 CFR, Subchapter U, Part 1048 Control of Emissions from New,

Large Non road Spark ignition Engines. It controls VOC and NOx emissions from several groups of previously unregulated nonroad engines, including large industrial spark ignition engines, recreational vehicles, and diesel marine engines. This applies to manufacturers or importers of new, spark ignition, nonroad engines, including anyone who manufactures, installs, owns, operates, or rebuilds any of the engines.

The new EPA requirements vary depending upon the type of engine or vehicle, taking into account environmental impacts, usage rates, the need for high performance models,

costs and other factors. The emission standards apply to all new engines sold in the United States and any imported engines manufactured after these standards begin.

Controls on the category of large industrial spark ignition engines are first required in 2004. Controls on the other engine categories are required beginning in years after 2005.

2.9 EMISSIONS STANDARDS FOR SPARK IGNITION MARINE ENGINES Provided in a program update titled Reducing Air Pollution from Non Road Engines ( EPA420 F 03 011, April 2003) are plans for controlling exhaust VOC emissions from A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 10 new spark ignition ( SI) gasoline marine engines, including outboard engines, personal watercraft engines, and jet boat engines. Of nonroad sources studied by EPA, gasoline marine engines were found to be one of the largest contributors of hydrocarbon ( HC)

emissions ( 30% of the nationwide nonroad total).

EPA is imposing emission standards for 2   stroke technology, outboard and personal watercraft engines. This will involve increasingly stringent HC control over the course of a nine year phase in period beginning in model year 1998. By the end of the phase in,

each manufacturer must meet an HC and NOx emission standard that represents a 75%

reduction in HC compared to unregulated levels. These standards do not apply to any currently owned engines or boats.

2.10 EMISSIONS CONTROLS FOR LOCOMOTIVES Federal Register Vol. 63, No 73 ( April 16, 1998), 40 CFR Parts 85, 89, and 92, Emission Standards for Locomotives and Locomotive Engines, sets NOx standards for locomotive engines remanufactured and manufactured after 2001. This program includes all locomotives originally manufactured from 2002 through 2004. It also applies to the remanufacture of all engines built since 1973. Regulation of the remanufacturing process is critical because locomotives are generally remanufactured 5 to 10 times during their total service lives, which are typically 40 years or more.

Three separate sets of emissions standards have been adopted, with the applicability of the standards dependent on the date a locomotive is first manufactured. The first set of standards ( Tier 0) applies to locomotives and locomotive engines originally manufactured from 1973 through 2001, any time they are manufactured or remanufactured. The second set of standards ( Tier 1) apply to locomotives and locomotive engines originally manufactured from 2002 through 2004. These locomotives will be required to meet the Tier 1 standards at the time of manufacture and at each subsequent remanufacture. The final set of standards ( Tier 2) apply to locomotives and locomotive engines originally manufactured in 2005 and later. Electric locomotives, historic steam powered A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 11 locomotives and locomotives manufactured before 1973 do not significantly contribute to the emissions problem and, therefore, are not included in the regulation. Table 2 12 provides an estimate on the reductions this rule will provide the A RR MSA. ). A rule penetration and effectiveness of 100% and control efficiency of 43.2% is assumed.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

NONROAD MOBILE SOURCES:

Locomotives SCC: 2285002000 Federal Rule Austin Round Rock MSA ( 5 Counties) 5.28 3.00 2.28 43.2%

Table 2 12. Locomotive Rule NOx Emission Reduction The following table provides the estimated annual NOx emission reductions for years 1999 through 2010. Because it takes forty or more years for the locomotive fleet to turn over, NOx emissions will continue to decline well beyond 2010.

Calendar Year NOx 1999 0.0%

2000  7.9%

2001  15.9%

2002  23.9%

2003  32.0%

2004  40.2%

2005  41.8%

2006  42.5%

2007  43.2%

2008  43.9%

2009  44.6%

2010  45.3%

Table 2 13. Annual NOx Reductions from Anticipated Locomotive Standards These numbers are based on a draft of the proposed locomotive standards. States are permitted to take credit for them in their SIP submittals. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 12 2.11 ALCOA CONSENT DECREE On April 9, 2003, the Justice Department, and the Environmental Protection Agency announced a major Clean Air Act settlement with Alcoa Inc. that resolved violations of the Clean Air Act's New Source Review ( NSR) and Prevention of Significant Deterioration ( PSD) requirements. Under the settlement, Alcoa has committed to install pollution controls that will result in major reductions of harmful air pollutants annually and will fund several beneficial environmental projects. Within twelve ( 12) months of the issuance of the Permit Amendment ( September 2003), Alcoa shall select one of the three pollution reduction options set forth below for the Existing Sandow Units, and shall notify the TCEQ in writing as to which option Alcoa has selected for these Units:

a. the continued utilization of the Existing Sandow Units, and the installation of pollution control equipment at these Units in compliance with Paragraphs 51 through 59 of the Consent Decree (" Option A");

b. the installation of Replacement Sandow Units for the Existing Sandow Units, with the installation and operation of pollution controls as required by the State Permitting Process, in compliance with Paragraphs 60 through 67 of the Consent Decree (" Option B"); or c. the shutdown of the Existing Sandow Units, in compliance with Paragraph 68 of the Consent Decree (" Option C").

Estimated reductions for these options are 90% of NOx or about 54 tpd. The company's Rockdale facility, located northeast of Austin, Texas, is the nation's largest emitter of sulfur dioxide ( SO2) and nitrogen oxides ( NOx) from the non utility source category,

according to EPA's 1999 National Emissions Inventory that was released in October 2001. These emissions were generated for the three coal fired electric generating industrial boilers that support the smelter operations at Rockdale and are addressed in the agreement. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 2 13 A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 3 1 3 State and Regional Reduction Strategies Sec. Category Reductions in 2007 ( tpd) Area Source: VOC NOx 3.1 Degreasing Units 1.96 n/ a 3.2 HB 2914 Grand fathered Pipelines TBD TBD On road Source: 3.3 Stage 1 Vapor Recovery 3.72 n/ a Non road Source: 3.4 Low Emission Diesel TBD TBD Point Source: 3.5 SB 7 EGU NOx Reductions n/ a 10.09 3.6 SB 766 Voluntary Emissions Reduction Permit TBD TBD 3.7 HB 2912 Grandfathered Requirements TBD TBD 3.8 Cement Kiln NOx Limits n/ a 2.16 Total ( not including TBD) 9.4 12.25 Table 3 1. Summary of TCEQ Issued Rules for Reduction Strategies State and regional reduction strategies are from state implemented rules that apply to the A/ RR MSA. Rules that apply but were listed in the emission reduction strategies are Gasoline Volatility ( 30 TAC § 114.302), Non Road Large Spark Ignition Engines ( 30 TAC 114, Subchapter 1, Division 3), and Gas fired water heaters, small boilers, and process heaters ( 30 TAC 117, Subchapter D, Division 1). There is no category or direct method to calculate the rule application.

3.1 DEGREASING UNITS Under 30 TAC 106.454 Degreasing Units, anyone obtaining a state air permit for a degreasing unit is required to meet with § 115.412 and § 115.415 as of November 1st,

2001. These rules cover operating procedures, solvent use and storage, ventilation, and record keeping. Given the projected population growth, this existing rule affects our future inventory by 10.1%. ( Table 3 2). The assumptions used in the calculation were 100% rule effectiveness, 50% rule penetration and 85% control efficiency. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 3 2 Table 3 2. NOx reductions from degreasing rule 3.2 GRANDFATHERED PIPELINES The new ruling of the grandfather permitting portion of HB 2914 will be added to 30 TAC Chapter 116, Subchapters H & I. The implementation will address reciprocating internal combustion engines connected to a pipeline. It requires 50% reduction in NOx and up to 50% reduction in VOC in East Texas. It also requires up to 20% reduction in NOx and VOC in West Texas. It allows averaging of reduction between engines connected to a pipeline. The Oasis Pipeline in Caldwell County is effected by this rule.

3.3 STAGE 1 VAPOR RECOVERY 30 TAC 115, Subchapter C, Division 2 Filling of Gasoline Storage Vessels ( Stage 1) for Motor Vehicle Fuel Dispensing Facilities, was adopted on June 30, 1999. These rules apply to the BPA, El Paso, HGA, and DFW ozone nonattainment areas and in 95 counties, including the A/ RR MSA, in the eastern and central parts of Texas. These rules regulate the filling of gasoline storage tanks at gasoline stations by tank trucks. To comply with Stage I requirements, a vapor balance system is typically used to capture the vapors from the gasoline storage tanks that would otherwise be displaced to the atmosphere as these tanks are filled with gasoline. The captured vapors are routed to the gasoline tank truck, and are processed by a vapor control system when the tank truck is subsequently refilled at a gasoline terminal or gasoline bulk plant. The rules reduce VOC emissions that are precursors to ground level ozone formation, resulting in ground level ozone reductions.

The effectiveness of Stage I vapor recovery rules depend on the captured vapors being:

( 1) effectively contained within the gasoline tank truck during transit; and ( 2) controlled Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

AREA SOURCES:

Degreasing ( All Degreasing Categories) VOC degreasing controls on new sources ( permit rules) Austin Round Rock MSA ( 5 Counties) 16.32 9.38 6.94 42.5% A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 3 3 when the transport vessel is refilled at a gasoline terminal or gasoline bulk plant.

Otherwise, the emissions captured at the gasoline station will simply be emitted at a location other than the gasoline station, resulting in no reduction in VOC emissions despite the Stage I requirements. It is estimated that the A/ RR MSA will see a 27%

reduction from the 2007 baseline emissions due to this rule ( Table 3 3). ). A rule penetration of 37.5%, rule effectiveness of 80% and control efficiency of 90% was assumed.

Table 3 3. Stage 1 VOC emission reduction 3.4 STATE LOW EMISSION DIESEL PROGRAM This strategy implements a state LED fuel program ( 30 TAC 114.313 designated alternative limit) requiring fuel producers and importers, beginning April, 2005 to ensure that all diesel fuel used in 110 East Texas counties, including the A/ RR MSA, for both on road and non road use does not exceed 500 ppm sulfur, contains less than 10.0% by volume of aromatic hydrocarbons, and has a minimum cetane number of 48. Alternative diesel fuel formulations that achieve equivalent emission reductions may also be used.

The state LED fuel program also requires that, beginning June 1, 2006, the sulfur content be reduced to 15 ppm sulfur in both on road and non road diesel fuel in 110 East Texas counties. The fuel required by the state LED fuel program will have a lower aromatic hydrocarbon content and a higher cetane number in each gallon of diesel than required by current federal regulations for on road diesel. Due to a provision in the rule allowing refiners to receive credit for alternate emission reductions, some benefits of NOx reductions may not be realized during the final two years of this plan. Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%)

AREA SOURCES:

Stage I Refueling SCC: 2501060053 Stage I VRS on 125k Gas Stations Austin Round Rock MSA ( 5 Counties) 13.79 10.07 3.72 27.0% A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 3 4 3.5 ELECTRIC GENERATING UTILITY NOX REDUCTIONS Senate Bill 7, enacted by the 76th Legislature, restructured electric utility service in Texas. Owners of grandfathered facilities that generate electric energy for compensation were required to apply for an electric generating facility ( EGF) permit from the commission by September 1, 2000. The legislation provided that initial issuance of these permits allow for notice and comment hearing proceedings, not contested case evidentiary hearings. The legislation does not allow for amendments to EGF permits.

Renewal of these permits requires notice, comment, and opportunity for a contested case hearing. Table 3 4 shows the expected NOx reductions due to this measure. ). A rule penetration and effectiveness of 100% and control efficiency of 50% is assumed.

Table 3 4. Utility ( EGU) NOx Reductions 3.6 VOLUNTARY EMISSIONS REDUCTION PERMIT ( VERP)

The Voluntary Emission Reduction Permit ( VERP) program is found under 30 TAC 116 Subchapter H, Division 4. In 1999, the 76th Texas State Legislature used the CARE Committee's recommendation as the basis for Senate Bill 766 ( SB 766), which directed the TCEQ to develop rules containing incentives for the voluntary permitting of grandfathered facilities. The TCEQ adopted rules to implement the VERP program on December 16, 1999. The owners and operators of a number of grandfathered facilities took advantage of the incentives offered by the VERP program and submitted VERP applications for their grandfathered facilities. Additionally, the owners and operators of other grandfathered facilities submitted permit by rule registrations and other new source review permit applications to permit their grandfathered facilities. The deadline to apply for a VERP was August 31, 2001. Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%) Point Sources ( EGUs): ID#: BC0015L, BC0082T, BC0083R, HK0108C, TH0004D, TH0006W, TH0104V, Senate Bill 7 NOx reduction Austin Round Rock MSA ( 5 Counties) 31.11 21.02 10.09 32.4% A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 3 5 3.7 HB 2912 Grandfathered Requirements The mandatory permitting requirements of HB 2912 are the culmination of legislative efforts, beginning in 1997, to permit or otherwise authorize all grandfathered facilities.

House Bill 2912 created four new types of permits for grandfathered facilities: existing facility permits, small business stationary source permits, EGF permits, and pipeline facilities permits. House Bill 2912 also mandated the dates by which grandfathered facilities must apply for a permit and have controls operational or submit a shutdown notice. Grandfathered facilities that are addressed by an application for a VERP are not required to comply with the provisions of HB 2912 for grandfathered facilities. However,

grandfathered facilities that withdraw their VERP applications and elect to submit a permit application for an authorization under HB 2912 will forfeit those incentives,

including eligibility for amnesty from enforcement. This rule will be under 30 TAC 116 Subchapter H Permits for Grandfathered Facilities, Divisions 2 and 3.

3.8 CEMENT KILN NOx LIMITS 30 TAC 117 Subchapter B, Division 4 Cement Kilns, applies to each portland cement kiln in Bexar, Comal, Ellis, Hays, and McLennan Counties except as specified in § 117.265 and § 117.283 ( relating to Emission Specifications; and Source Cap). It establishes emission limits on the basis of pounds of NOx per ton of clinker produced for cement kilns placed into service before December 31, 1999. These limits are based on the NOx emissions averaged over each 30 consecutive day period, and vary depending on the type of cement kiln. For each preheater precalciner or precalciner kiln in Hays County, 2.8 lbs/ ton of clinker produced is specified in Role 117.283. It is expected a 27% reduction in NOx will be seen where this rule is applicable.

The reduction from Texas Lehigh Cement, as incorporated in TCEQ permit no. 3611D,

will go from 7.2 tpd of NOx to 5.04 tpd for a total of 2.16 tpd reduction or 30%. This is given in Table 3 5. The 2007 emission was adjusted using a growth factor to the final value 5.24 tpd. All non EGU were grown using growth factors from the EGAS model A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 3 6 ( by TCEQ). A rule penetration and effectiveness of 100% and control efficiency of 30%

is assumed.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net Reduction ( tpd) Percent Reduction (%) Point Sources ( TX LEHIGH C.): HK0108C NOx reduction Austin Round Rock MSA ( 5 Counties) 7.20 5.04 2.16 30.0%

Table 3 5. Cement Kiln NOx Reduction A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 1 4 Local Strategies 4.1 LOCAL STRATEGIES INTRODUCTION The June 2003 EAC milestone identified and described potential local emission reduction strategies. The milestone report, and subsequent revisions, organizes the measures into two tables. The measures in Table A apply to all or most jurisdictions in the A/ RR MSA.

They will require state regulation. The Table B measures are self selected by the jurisdictions with each choosing at least three for implementation. These are in addition to continuing O3 Flex commitments. Jurisdictions may choose to enhance an existing O3 Flex measure. Included in this section is a Transportation Emission Reduction Measure ( TERM) that will be implemented by various local jurisdictions through an agreement with the Capital Area Metropolitan Planning Organization ( CAMPO).

4.2 TABLE A EMISSION REDUCTION MEASURES NOx Reductions ( tpd) VOC Reductions ( tpd) A1 Inspection and Maintenance ( I& M) 3.19 4.19 A2 Idling Restrictions on Heavy Diesel 0.19 0.00 A3 Commute Emission Reduction Program 0.27 0.30 A4 Stage I Vapor Recovery Requirement Change 0.00 4.88 A5 Low Emission Gas Cans 0.00 1.97 A6 Degreasing Controls 0.00 6.38 A7 Autobody Refinishing Controls 0.00 0.05 A8 Cutback Asphalt 0.00 1.03 A9 Low Reid Vapor Pressure Gas 0.00 2.87 A10 BACT and Offsets for New or Modified Point Sources TBD TBD A11 Petroleum Dry Cleaning 0.00 1.06 A12 Texas Emission Reduction Program ( TERP) 2.00 0.00 A13 Power Plant Reductions 7.08 0.00 Total ( Does not include TBD) 12.73 23.64 Emission Reduction Measures ( State Regulations)

Table A. Recommended Measures requiring State Regulations of Actions. Note: The I& M program assumes participation from Hays County. Without Hays Co participation reductions are 2.89tpd and 3.84tpd of NOx and VOC respectively. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 2 This section describes each of the control measures appearing in Table A. Each control measure is described and emission reduction calculations are presented in the remainder of this chapter. Actual implementation dates and regulation names were supplied by the state. Actual emission reductions may vary slightly from the estimates appearing in this chapter since these estimates are based on EPA guidance, and not necessarily actual data from the in situ emission control measures. CAPCO contracted with ERG, Inc. to provide technical support in quantifying emissions and evaluating regulatory and other implementation issues.

Table A measures require state regulations or actions for implementation and enforcement. They will be implemented no later than December 31, 2005. ( Power plant reductions and TERP will begin phasing in no later than December 31, 2005.) The semiannual review reports will track and document Table A measures.

4.2.1 Inspection and Maintenance ( A1)

SOURCE TYPE AFFECTED Program participants are owners of 2 to 24 year old gasoline vehicles, safety inspection station owners and operators, vehicle repair facilities, TCEQ, DPS and counties that choose to administer ( or contract with another entity to administer) a LIRAP program.

The program does not apply to motorcycles or slow moving vehicles, as defined by Section 547.001, Transportation Code. Test on resale is required for all vehicles from non I/ M program counties that are sold and registered in the I/ M program counties. Per state statute, vehicles belonging to students at public universities, but registered in non

I/ M program counties, must participate to receive campus parking privileges.

CONTROL STRATEGY The I/ M program requires all subject gasoline vehicles 2 to 24 years old registered and primarily operated in the I/ M program counties ( Hays, Travis and Williamson) to undergo an annual emissions inspection test in conjunction with the annual safety inspection. Emissions inspection tests are conducted at all safety inspection stations. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 3 The entire vehicle safety and emissions inspection should be completed in about 20 minutes from the time the vehicle is driven into the inspection bay. If a vehicle fails the emissions inspection test, the items of failure will be indicated on the Vehicle Inspection Report. The vehicle should be repaired and returned to the same inspection station with 15 days for a free re test. A passing emission inspection test ( or test waiver) is required in order to renew vehicle registration or to receive a safety inspection sticker.

IMPLEMENTATION The I/ M program was evaluated to be applied in Travis, Hays and Williamson Counties.

As of the plan submittal date ( 3/ 31/ 04) the City of San Marcos had voted not to participate in the I/ M program, thus eliminating Hays County form program applicability.

The I/ M Program counties exercise the flexibility offered to EAC areas in Senate Bill 1159 and request that TCEQ adopt a rule including the MSA's I/ M Program in the state program. Periodic program evaluations will determine if any revisions or modifications are needed. The plan must be implemented no later than December 31, 2005.

The OBDII testing program will be used to test 1996 model year and newer vehicles. All 1996 and newer vehicles less than 14,000 pounds ( passenger cars, pickup trucks, sport utility vehicles) are equipped with OBD systems. The OBD system monitors emission performance components to ensure that the vehicle runs as cleanly as possible. The system also assists repair technicians in diagnosing and fixing emission related problems.

If a problem is detected, the OBD system illuminates a " Check Engine" or " Service Engine Soon" warning lamp on the vehicle instrument panel to alert the driver. The system will store information about the detected malfunction so that a repair technician can accurately find and fix the problem.

Model year 1996 and newer vehicles are required to meet EPA specifications for collection and transfer of emissions control data during each driving cycle. The Diagnostic Link Connector ( DLC) cable on the emissions test analyzer is hooked up to the DLC located in the vehicle. When the vehicle's OBD system has checked the emissions control systems and detected a problem with the vehicle, this information is A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 4 stored in the vehicle's on board computer. The OBD test transmits this data to the analyzer and the vehicle will fail the inspection. The inspection report will indicate which emissions control systems were checked and display the description of the fault codes retrieved from the vehicle.

The Two Speed Idle testing program will be used to test 1995 model year and older vehicles. The TSI test uses a tailpipe probe exhaust gas analyzer to measure VOC and CO while the vehicle is idling at a low and a high rate.

The I/ M program includes a high emitter program to identify vehicles that are significantly exceeding federal vehicle emission standards. On road remote sensing equipment will be used to identify high emitting vehicles in the three I/ M program counties or those commuting from contiguous counties. The van installed on road testing equipment is strategically placed to capture auto emissions from single lane traffic in an acceleration mode. Vehicles identified as high emitters must be tested using the ageappropriate OBDII or TSI test within 30 days of notification and be repaired, if necessary. A passing test result ( or test waiver) will be needed to renew vehicle registration.

The following waivers and extensions will be available to all qualifying vehicle owners through the Texas Department of Public Safety ( DPS):

Individual Vehicle Waiver   In order to address unusual cases where a vehicle cannot meet emissions standards, an Individual Vehicle Waiver may be issued to a vehicle owner whose vehicle has failed its initial emissions inspection and reinspection and in which at least $ 600 in emissions related repairs have been performed by a registered repair facility.

Low Mileage Waiver   A Low Mileage Waiver may be issued to a vehicle owner whose vehicle has failed both its initial emissions inspection and the reinspection and in which at least $ 100 in emissions related repairs have been A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 5 performed. The vehicle should have been driven less than 5,000 miles in the previous inspection cycle and anticipate being driven fewer than 5,000 miles before the next required safety inspection.

Parts Availability Time Extension   A Parts Availability Extension may be issued for 30, 60 or 90 days to a vehicle owner whose vehicle fails the initial emission inspection and needs time to locate necessary vehicle emissions control parts.

Low Income Time Extension A Low Income Time Extension may be issued to a vehicle owner whose vehicle has failed its initial inspection and re inspection, and the applicant's adjusted gross income is at or below the federal poverty level.

Counties that implement a vehicle emissions inspection program may elect to implement the Low Income Repair Assistance, Retrofit, and Accelerated Vehicle Retirement Program ( LIRAP). Vehicle owners whose vehicles fail the emissions inspection and who meet eligibility requirements may receive assistance through this program. The assistance can pay for emissions related repairs or be used toward a replacement vehicle if they choose to retire the vehicle. Note that in case of the vehicle replacement additional emission reductions may be expected when newer vehicles are purchased but are not quantified. The assistance program is funded through a portion of the emissions inspection fee. The program is administered through a grant contract between TCEQ and each participating county. Only 5% of the grant contract funds may be used for the administrative costs of the program. Assistance is limited to no more than $ 600 for repairs or $ 1,000 toward replacement of the vehicle.

In order to be eligible for LIRAP, the vehicle owner's total family income must be less than or equal to twice the amount of the Federal Poverty Guidelines for designated family units. ( At this writing, $ 24,240 for a family of two and $ 36,800 for a family of four). A vehicle is eligible for repair assistance if it failed the emissions inspection within 30 days of application, is currently registered, and has been registered in the program area for the two years preceding application, and it passes the safety inspection portion of the test. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 6 Repairs must be performed at a DPS recognized repair facility. Vehicle retirement eligibility requirements are the same as for vehicle repairs, except the vehicle must have passed a safety inspection within 15 months of the application.

ESTIMATED EMISSION REDUCTION MOBILE6.2 was used to estimate NOx and VOC emission rates for vehicles operating in each of the 3 counties, for a typical ozone season weekday in 2007. Emission rates were then combined with VMT values to estimate emissions in tons per day, for the uncontrolled base case, the standard state program, and the alternative control options listed above.

ERG obtained link level activity data for Travis, Williamson, and Hays Counties from the Texas Transportation Institute ( TTI). These link files included hourly speed and VMT estimates by vehicle type, for each link in the area, for the September 2007 modeling episode. MOBILE6 input file data were obtained from CAMPO. The CAMPO data included county level registration distributions and diesel sales fractions ( from 2002 TxDOT data), and ambient temperatures and humidity levels obtained from the TCEQ.

The MOBILE6.2 hourly emission factor outputs were combined by roadway and vehicle type with the link level activity data to estimate total 24 hour mass emissions for the region. Different control scenarios were specified corresponding to each of the cases listed above. The MOBILE6.2 input files and VMT link files are available from ERG.

The I/ M program is expected to reduce NOx emissions by 3.19 tons per day and VOC emissions by 4.19 tons per day ( Table 4 1 and Table 4 2). The I/ M program will also reduce toxic emissions, some of which are known carcinogens. It will encourage proper vehicle maintenance, which may result in fuel savings for some vehicle owners. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 7 Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net NOx Reduction ( tpd) Percent Reduction (%) ONROAD MOBILE: All Light Duty vehicles & Heavy Duty Gasoline Vehicles ( LDV, HDGV) Inspection and Maintenance ( I& M) Hays, Travis Williamson 31.12 27.93 3.19 10.3%

Table 4 1. I& M NOx Emission Reduction Note: The I& M program assumes participation from Hays County. Without Hays Co participation reductions are 2.89tpd of NOx.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net VOC Reduction ( tpd) Percent Reduction (%) ONROAD MOBILE: All Light Duty vehicles & Heavy Duty Gasoline Vehicles ( LDV, HDGV) Inspection and Maintenance ( I& M) Hays, Travis Williamson 30.33 26.14 4.19 13.8%

Table 4 2. I& M VOC Emission Reduction Note: The I& M program assumes participation from Hays County. Without Hays Co participation reductions are 3.84tpd of VOC.

ESTIMATED COST ERG developed bottom up estimates for test fees using their in house I/ M fee calculator.

The fee calculator develops a cash flow to calculate the fee required to assure a fair return on capital and operations costs over a 10 year program operations period. The calculator is dynamic, accounting for growth in the overall fleet, as well as changing proportions of OBD and ASM/ TSI populations. ( E. G., OBD populations increase with time, while pre

OBD fleets decrease, allowing for partial liquidation of under utilized ASM/ TSI equipment over time.) The key parameters used in the different testing scenarios are listed below. Note that all estimates are incremental to the time and effort associated with safety tests. Ultimately, the test fees are determined by TCEQ.

Baseline cost assumptions:

  3,120 hrs of operation/ station per year   Inspector $/ hr  $ 12 ( OBD/ TSI), $ 12 ( ASM), all @ 30% loading   Test time  20 minutes for ASM, 15 minutes for TSI, 10 minutes for OBD   Bay space lease cost  $ 32/ sf/ yr ( only applied when test lane is in use  assumes alternate revenue generating activities will occur in that area when not testing) A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 8   Wholesale capital cost  $ 31,000 ASM, $ 12,000 TSI, $ 8,000 OBD ( Combined OBD/ TSI system  $ 14,000)

  ASM installation  $ 4,000 ( in ground)

  Annual interest rate for equipment financing  12.5%

  Warranty  $ 2,700 per yr ASM, $ 2,000 TSI   Utilities  $ 1,200 / yr ASM, $ 100 TSI   Span gases  $ 384 / yr ASM, $ 250 TSI   Zero gases  $ 0.45 per TEST ASM and TSI   Computer link  $ 1.00 per test   Program Administration and Enforcement  $ 2.50 per vehicle ($ 2.00 to DPS High Emitter Program, $ 0.50 for TCEQ audits/ enforcement)

  Discount Rate  6%

  Inflation Rate  4%

  Equipment depreciation  10%

  Real wage rate increase  2%

  Corporate Income Tax rate  34%

Using these input parameters ERG estimated the following test fees, assuming 1 free retest is allowed after repairs. Any costs associated with Low Income Repair Assistance Program ( LIRAP) subsidies are not included in these estimates.

  OBD Only  $ 11.972   TSI Only  $ 14.52   ASM Only  $ 25.91   OBD + TSI  $ 16.69 Note that these independent estimates are quite close to the official state fees of $ 27.00 for ASM, and $ 14.00 for TSI ( in El Paso), but substantially different than the $ 21.00 fee for OBD ( without LIRAP).

Repairs Repair costs for the different type of test failures were based on results from a number of I/ M programs across the country. ERG took a rough mid point value from the available data to estimate costs for each test type. For OBD, the state of Wisconsin reported repair costs at $ 227 per OBD failure for 2003, while the TCEQ reported an average of $ 397.

Both Oregon and California reported approximately $ 300 per OBD repair, which was 2 OBD fees also account for TSI testing of the ~ 2.5% of 1996 and older vehicles that cannot be tested using OBD equipment, due to instrument non communication and/ or a not ready sensor status  these vehicles receive a TSI test instead. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 9 used in the ERG estimates. Repair costs for loaded transient test failures ( including IM240, IM147, and ASM) ranged from ~$ 200 in Arizona to $ 440 in Texas. TSI repairs were based on 2003 California data. Average repair costs by test type are summarized below.

  OBD  $ 300   TSI  $ 135   ASM  $ 300 ERG assumed repairs would only have a one year lifetime, so these figures correspond directly to annual program costs. 3 Inconvenience Costs ERG estimated the amount of extra time needed to comply with program requirements,

considering travel time to and from the test facility, likely wait times before the test,

actual test time, and time required to obtain needed repairs and subsequent retests. While test time is available from several I/ M programs, estimates for the other categories are not available and had to be estimated by ERG staff. 4 ERG assumed that OBD and TSI stations would be relatively numerous and easily accessed by Austin area motorists. For example, in order to meet anticipated demand and to keep wait times down during peak periods ( lunch and after work), ERG's I/ M fee calculator estimates that 125 stations offering OBD and TSI testing will be needed in the three county area in 2007. Therefore ERG assumed 20 minutes of additional travel time to and from these stations. The expected high number of stations should also keep wait times low, assumed to be five minutes on average for TSI and OBD.

3 Although repair lifetime is unknown, this assumption is consistent with the state requirement for annual testing. 4 Wait times are often also tracked by I/ M station operators, but these times are highly dependent on the number of stations, specific locations, and other local factors, and therefore could not be used with confidence for the yet to be designed Austin program. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 10 Given the higher cost of entry associated with ASM testing, ERG assumed fewer stations would be available to serve the pre OBD population than under TSI. Accordingly, ERG assumed 30 minutes of travel time and 10 minutes of wait time on average for ASM testing.

ERG used data from TCEQ's I/ M database to estimate average test times for the three options  20 minutes for ASM, 15 minutes for TSI, 10 and minutes for OBD.

The time required for repair is likely to vary according to test type. Since many TSI failures simply require air/ fuel adjustments and related tune ups, which are relatively quick, ERG assumed an average of 2 hours for these repairs. However, vehicles failing OBD or ASM for high NOx emissions may often require new catalysts or other complex repairs. Therefore ERG assumed 3 hours on average for OBD and ASM repairs.

ERG calculated the total motorist time required for program compliance for each of these options using the above assumptions, as well as estimates of total vehicle tests ( from local registration records) and failure rates obtained from TCEQ. Given the uncertainty in the value of this time, ERG did not monetize inconvenience costs. 5 The emissions test fee ( set by TCEQ) is expected to be no more than $ 20 in Travis and Williamson Counties. The safety inspection fee is $ 12.50, so the combined inspection cost is not expected to exceed $ 32.50. Testing equipment costs ( estimated at $ 15,000 per station) are recouped through fee. The equipment includes the Two Speed Idle ( TSI), the On Board Diagnostic ( OBD) analyzer testing system, gas cap tester and 2 D Bar Code scanner.

REFERENCES U. S. Environmental Protection Agency, " Inspection/ Maintenance Program Requirements," Final Rule, 57 Federal Register 52950 ( November 5, 1992).

5 A very conservative calculation could use the existing minimum wage rate for the opportunity cost of leisure time ($ 5.15/ hr). Under these assumptions program cost effectiveness values increase by a modest amount  ~$ 3,000 to $ 5,000 per ton of NOx + VOC. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 11 U. S. Environmental Protection Agency, " I/ M Costs, Benefits, and Impacts Analysis," Draft, February 1992. ERG, Inc., Technical Support Documentation: Emission Control Strategy Evaluation for the Austin/ San Marcos ( A/ SM) MSA EAC Clean Air Action Plan ( CAAP), January 26, 2004 4.2.2 Idling Restrictions on Heavy Duty Diesel Engines ( A2)

SOURCE TYPE AFFECTED Owners and operators of heavy duty diesel vehicles, MSA county and municipality law enforcement agencies or designees are affected by this measure.

CONTROL STRATEGY This measure restricts engine idling of vehicles with a gross vehicle weight rating of more than 14,000 pounds to five consecutive minutes. Exemptions are allowed for vehicles with a gross vehicle weight rating of 14,000 pounds or less; that are forced to remain motionless because of traffic conditions over which the operator has no control;

are being used as an emergency or law enforcement vehicle; when the engine operation is providing power for a mechanical operation other than propulsion; when engine operation is providing power for multiple passenger heating or air conditioning while occupied by passengers; when the engine is being operated for maintenance or diagnostic purposes, or when the engine is being operated solely to defrost a windshield.

Alternative methods of providing power to the vehicle are currently available. Truck stop electrification allows the vehicle operator to access electricity as a power source. Small generators, which emit less and are commercially available, can be used as auxiliary power sources.

IMPLEMENTATION This measure will apply throughout the MSA. To implement this measure, the MSA requests TCEQ adopt the measure through rulemaking applicable in the MSA and authorize MSA county and municipality law enforcement agencies, or other county and municipality entities, to enforce the measure. The plan must be implemented no later A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 12 than December 31, 2005. In the event TCEQ designates program responsibility to a local entity, the TCEQ and EPA will make every reasonable effort to provide adequate funding for program administration.

ESTIMATED EMISSION REDUCTION ERG used a methodology previously developed for the TNRCC ( now TCEQ) to estimate NOx emission reductions from such a rule in the Houston area. 6 Following this methodology, to calculate fleet idle emissions for Heavy duty diesel vehicles ( HDDV) and heavy duty gasoline vehicles ( HDGV) in the five county Austin area it was necessary to first obtain the number of vehicles in each county, as well as to estimate the average vehicle idle time for each county. Average vehicle idle time was estimated by using a SAS program that read in mileage accumulation rates ( MAR), by age, from the MOBILE6.2 default values. For both HDDV and HDGV vehicles, an average MAR was calculated using data from each of the eight applicable MOBILE6.2 vehicle types. The program also read in registration distribution data for each county from TxDOT records, and weighted the distribution using county VMT data obtained from TTI.

For each county, average MARs were ratioed by the registration data and summed to obtain an annual mileage accumulation rate by vehicle age, which in turned was used to calculate average VMT per day. Using the average VMT per day and the average speed ( also read in from the TTI data), the average run time per vehicle was deduced. The average idle time was assumed to be 25% of the average run time for diesels, and 23%

for gas vehicles, based on heavy duty engine certification cycles ( see ERG Memo to TNRCC). Finally the number of vehicles in each county was obtained by dividing the total fleet VMT ( obtained from TTI data) by the average VMT per day calculated above.

6 ERG Memo to Hazel Barbour, Texas Natural Resource Conservation Commission Re: Determination of NOx Benefits from Proposed Idle Shut Off Rule, February 2001. Estimates were included in the latest HGA SIP revision. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 13 Idle emission factors ( g/ mi) were then obtained from MOBILE6.2 output. 7 An average idle speed of 3.1 mph ( per model defaults) was used to convert the idle emission factor to g/ hr. This value, along with the number of vehicles in each county and their appropriate average idle time were used to calculate fleet idle emissions. Note that two idle events per day were assumed for the purposes of the calculation. The output from the intermediate and final calculation steps are summarized in the tables below.

Vehicle Type County Group Avg Vehicle Speed* ( mph) Avg VMT/ day Avg Run Time ( minutes) Avg Idle Time ( minutes)

Bastrop 39.6 129.4 196.06 49.02 Caldwell 41.1 130.1 189.93 47.48 Hays 44.2 131.9 179.05 44.76 Travis 35.9 131.6 219.94 54.99 HDDV Williamson 43.7 131.1 180.00 45.00 Bastrop 39.6 54.06 81.91 18.84 Caldwell 41.1 54.06 78.92 18.15 Hays 44.2 54.06 73.38 16.88 Travis 35.9 54.06 90.35 20.78 HDGV Williamson 43.7 54.06 74.22 17.07 Table 4 3. Run and Idle Time Derivation * From TTI Vehicle Type County Group Total Fleet VMT^ ( mi/ day) Avg VMT/ day VMT Fraction* Number of Vehicles Bastrop 133,043 129.4 1.000 1,028 Caldwell 69,365 130.1 1.000 533 Hays 311,744 131.9 0.431 1,019 Travis 2,171,524 131.6 0.820 13,531 HDDV Williamson 678,264 131.1 0.733 3,792 Bastrop 33,727 54.06 1.000 624 Caldwell 16,773 54.06 1.000 310 Hays 65,220 54.06 0.520 627 Travis 464,313 54.06 0.851 7,309 HDGV Williamson 151,015 54.06 0.788 2,201 Table 4 4. Estimation of Heavy Duty Fleet Size ^ From TTI Note: VMT fraction reduced to account for IH 35 pass through traffic ( no idle time anticipated   extended Class 8 idle events excluded from analysis)

7 Unlike MOBILE5b, MOBILE6 does not provide explicit idle emission factors in grams per hour. EPA guidance suggests using the emission rate for the lowest speed bin available, and converting to g/ hr. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 14 An assumed rule penetration of 100% and effectiveness of 80% ( per TCEQ) were used to calculate the reductions shown in Table 4 5.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net NOx Reduction ( tpd) Percent Reduction (%)

ONROAD MOBILE: Heavy Duty Diesel & Gas Trucks ( HDV ) Idling Restrictions Austin Round Rock MSA ( 5 Counties) 31.82 31.63 0.19 0.6%

Table 4 5. Idling Restrictions NOx Emission Reduction ESTIMATED COST At this time we do not have a cost estimate. However, the measure will result in fuel savings.

REFERENCES ERG, Inc., Technical Support documentation: Emission Control Strategy Evaluation for the Austin/ San Marcos ( A/ SM) MSA EAC Clean Air Action Plan ( CAAP), February 17, 2004 4.2.3 Commute Emission Reduction Program ( A3)

SOURCE TYPE AFFECTED All employers with 200 or more employees per location throughout the MSA, TCEQ ( or its designated local agent), Clean Air Partners Program, CAMPO Commute Solutions Program, CAPCO.

CONTROL STRATEGY The Commute Emission Reduction Program requires every existing or future employer with 200 or more employees per location to submit a detailed plan to TCEQ or local designee that demonstrates how the employer will reduce the equivalent of their NOx and VOC commute related emissions by 10%. The 10% reduction requirement may be met by reducing emissions at least 3% per year until the 10% reduction is achieved. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 15 Employers may choose to reduce commute or any other business related emissions that occur at the location with 200 or more employees as long as the aggregate emissions reductions are equivalent to 10% of their commute related emissions for NOx or VOC.

IMPLEMENTATION To implement this measure the MSA requests that TCEQ adopt a rule applying this measure in the MSA. TCEQ or their local designee will be responsible for implementation and enforcement of the program. The plan must be implemented no later than December 31, 2005.

Commute related emissions may be calculated using a baseline of the annual average number of employees at that location in 2003, 2004 or the expected annual average number of employees for a new employer location and assuming all employees drove to work alone. The annual average number of employees multiplied by the average round trip commute ( 22.6 miles) equals the number of employee miles traveled. Employee miles traveled multiplied by the MSA's commute MOBILE6 emission factors for VOC and NOx equals the VOC and NOx commute emissions. The MOBILE6 emission factors may be for the analysis year, 2007 or any other year deemed appropriate by the TCEQ.

The MSA average round trip commute mileage may be used or an employer may choose to use employee specific round trip commute mileage. A calculation guidance packet,

including emission factors will be developed and made available to employers.

The plan will include details on how the commute related emissions were calculated, how and when the 10% of total VOC and NOx reductions will be achieved, as well as how the reductions will be maintained over time. Alternative plans that detail either how the employer will achieve and maintain a verifiable employee commuter average vehicle occupancy ( AVO) of 1.2 or achieve and maintain verifiable participation in the Clean Air Partners Program at a 10% reduction level will also be accepted.

All employers with 200 or more employees at a single location will register with TCEQ or local designee by December 31, 2004 or within 60 days of beginning operations for A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 16 new locations. All plans must be submitted to TCEQ or local designee by March 31,

2005 or within 120 days of beginning operations for new locations. TCEQ or local designee will approve all plans, or inform the employer of any plan deficiencies by July 31, 2005 or within 4 months of plan submittal for new locations. In the event that plan deficiencies occur, employers will have 60 days from the date of notification of such deficiencies to revise and resubmit their plans. TCEQ or local designee will approve or reject the revised plan within 30 days from the date of re submittal.

Employers will report on the plan's implementation and results semi annually in conjunction with the MSA's EAC semi annual report. Reporting periods are May 1 through October 31 and November 1 through April 30. Copies of the Commute Emission Reduction Program report are due to TCEQ or local designee and CAPCO by November 30th and May 31st respectively. In the event that the semi annual reports indicate that the planned emission reductions are not being achieved and maintained, TCEQ or local designee may request that the employer revise their plan accordingly.

In the event TCEQ designates program responsibility to a local entity, the TCEQ and EPA will make every reasonable effort to provide adequate funding for program administration. Both the Clean Air Partners Program and the CAMPO Commute Solutions Program provide free tools and information that may be useful in complying with this measure. The Commute Solutions Program provides employee transportation coordinator training and Commute Solutions Fairs for alternatives to drive alone commutes, while Clean Air Partners provides tools, expertise and experiences of member employers. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 17 ESTIMATED EMISSION REDUCTION Expected reductions from this measure are 0.27 tons per day NOx and 0.30 tons per day VOC ( Table 4 6 and Table 4 7). An assumed rule penetration of 100% and effectiveness of 80% were used to calculate the reduction. Some workday rush hour congestion may be reduced if employers select and implement commute emission reduction measures.

The measure will also encourage business practices that improve air quality.

Table 4 6. Commute Program NOx Emission Reduction Table 4 7. Commute Program VOC Emission Reduction ESTIMATED COST At this time we do not have a cost estimate. Administrative costs to employers and the Clean Air Partners will vary according to the participation level. However, the measure will result in fuel savings.

REFERENCES Commute Solutions www. commutesolutions. com Clean Air Partners www. cleanairpartnerstx. org Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled NOx Emissions ( tpd) 2007 Controlled NOx Emissions ( tpd) Net NOx Reduction ( tpd) Percent Reduction (%) ONROAD MOBILE: Light Duty Vehicles ( LDV) Commute Emission Reduction Program Austin Round Rock MSA ( 5 Counties) 30.29 30.02 0.27 0.9%

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net VOC Reduction ( tpd) Percent Reduction (%) ONROAD MOBILE: Light Duty Vehicles ( LDV) Commute Emission Reduction Program Austin Round Rock MSA ( 5 Counties) 31.55 31.25 0.3 1.0% A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 18 4.2.4 Low Emission Gas Cans ( A4)

Portable gasoline containers, usually called " gas cans," can be a significant source of urban air emissions. The emissions arise from containers that spill, leak, and/ or allow permeation, and are measured as volatile organic compounds ( VOC).

SOURCE TYPE AFFECTED Residential and commercial lawn and garden users of gas cans will be affected by this measure. Recreational vehicles ( e. g., all terrain vehicles and off road motorcycles, and recreational marine vehicles) are included in a limited capacity.

CONTROL STRATEGY A mandate that all new gas containers purchased in the region meet spill proof, low emission standards is suggested. While we have a fairly good grasp of emissions from refueling motor vehicles, gas can emissions are highly uncertain at this time. The California Air Resources Board ( CARB) was instrumental in developing a methodology to quantify emissions from gas cans, and now several states including Texas are considering using the CARB method to help determine the need for a " no spill" gas can regulation.

Historically, gas can emissions were part of the emissions inventory for non road equipment such as lawn mowers, chainsaws, trimmers (" weed whackers"), and other portable power equipment. The 1992 Non Road Equipment and Vehicle Emissions Study ( NEVES) 8 considered refueling emissions as a function of gasoline consumption,

and included algorithms for spillage and vapor displacement. The draft NONROAD model9 has the same algorithms, which are used to estimate this part of the VOC emissions inventory. A major improvement in the NONROAD model over the NEVES was to separate commercial and residential equipment, as commercial equipment tend to be used during the week and residential equipment, which are more numerous in terms of numbers of engines, tend to be used fewer hours, mainly on the weekends. Therefore, we 8 U. S. EPA. 1991. Nonroad Engine and Vehicle Emission Study   Report. EPA 460/ 3 91 02. 9 http:// www. epa. gov/ otaq/ nonrdmdl. htm A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 19 have adapted our surveys and methods to include commercial and residential gas can emissions separately.

The main emphasis of this research is on lawn and garden uses of gas cans. Lawn and garden is the largest category in the NONROAD model that is refueled entirely by gas cans. Recreational vehicles ( e. g., all terrain vehicles and off road motorcycles) are also refueled by gas cans, but their usage is not nearly as high as that for lawn and garden equipment. Recreational marine engines ( e. g., outboard motorboats and personal watercraft) can be refueled by portable gasoline containers, but pressurized marine gas tanks are much more common than the ubiquitous " gas can." Finally, some construction,

commercial, agricultural and logging equipment may be refueled with gas cans, but NONROAD assumes that these types of equipment are all refueled at the gas pump. 10 Future updates to this analysis could include a small expansion factor to account for gasoline container emissions from these other source categories.

IMPLEMENTATION Preferably state rule, developed by TCEQ, applicable in all five counties. It is recommended that TCEQ implement the measure in the eastern half of the state no later than December 31st 2005.

The TCEQ is considering a rule that would phase in new gas cans by effectively eliminating most of the gas cans in the " open" condition, eliminating refueling ( but not transport) spillage, and reducing many of the remaining categories such as permeation because of new gas can design parameters. Presumably, such a gas can rule would apply to sales of new containers. Therefore, we estimated the useful life of a gas can to be four years, using the CARB default. If a rule were implemented in 2003, it would take until 2008 for the existing gas cans to be replaced by gas cans of the new design.

10 U. S. EPA. 1998. Refueling Emissions for Nonroad Engine Modeling. Report No. NR 013 A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 20 Using the NONROAD age distribution curve, we estimated that approximately 94 percent of the gas cans would be replaced by the 2007 ozone season. This estimate is consistent with the Commercial survey finding that 40% of businesses plan to replace some or all of their current containers in the next year. In addition, the residential survey found that 14% of these cans had been replaced during the previous year. Assuming linear attrition rates, this translates to a 7 year turnover cycle for these cans as well ( e. g.,

2003 through 2009). However, to the extent that residential gas can attrition is non linear ( as is the case with most dynamic populations), potential benefits from a gas can rule would be diminished somewhat. 11 The next step is to apply reduction estimates to the uncontrolled 2007 emissions. Any reductions would be " negative emissions" that could be attributed to the effect of the TCEQ rule   and ultimately applied as potential State Implementation Plan credits.

CARB estimated percentage reductions for all five categories of gas can emissions. 12 Although we do not know the content of a new gas can rule to be adopted in Texas, if approved, we can make some educated guesses about the efficiency of such as " Gas Can Rule." After careful consideration, we applied rule penetration ( RP) and rule effectiveness ( RE) to the CARB reduction estimates, expressed as control efficiency ( CE), as follows:

Reduction (%) = CARB ( CE) * RE * RP Equation 1 The RP adjusts reductions slightly lower because the rule may not apply to 100 percent of the new gas can sales, and is probably more like 90 percent. The RE is an adjustment that says that the rule might only be followed 80 percent of the time. The product of RP and RE is 72 percent; this factor was then applied to the CARB reduction estimates where deemed to be appropriate. These kinds of adjustments are typical when dealing with the U. S. Environmental Protection Agency. Table 4 8 includes the assumptions that 11 It would require multiple years of retirement data to generate a more realistic scrappage curve, however. 12 CARB, 1999. " Initial Statement of Reasons for Proposed Rule Making: Public Hearing to Consider the Adoption of Portable Fuel Container Spillage Control Regulations." A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 21 include the default, stated CARB reductions, which were then modified by applying rule effectiveness and rule penetration.

Emission Type Total Emissions Percent Reductions  California Percent Reductions  Texas Reductions ( Tons per day of VOC)

Diurnal 52.55 70.0% 50.4% 24.94 Transport Spillage 5.75 100.0% 0.0% 0.00 Refueling Spillage 9.89 100.0% 72.0% 6.71 Displacement 3.40 40.0% 0.0% 0.00 Total 77.69 34.72 Table 4 8. 2007 State Emission Reductions Note that potential reductions were not applied to two sources: transport spillage and valor displacement. This decision was not based on actual testing but rather because common sense dictates that a no spill gas can would still have emissions during refueling operations ( the effect on vehicles in transit is not clear, either). It is quite possible that CARB also over predicted diurnal emission reduction percentages, but there is no evidence to dispute these claims at this time.

EXPECTED EMISSIONS REDUCTIONS Based on a total of 13.4 tons per day in the MSA, the potential reductions add up to 2.6 tons per day ( Table 4 9). There may be more ( or less) reductions depending on how the envisioned gas can rule is written and implemented. This analysis evaluated the potential VOC reductions resulting from adoption of TCEQ's draft Portable Fuel Container rule.

The proposed rule assumes that replacement containers would meet CARB standards.

ERG used the statewide emission reduction estimates previously developed in support of TCEQ's rulemaking effort to estimate potential reductions in the five county area. 13 This analysis provided county level baseline emissions estimates for 2007. For the five

13 ERG, " Emissions from Portable Gasoline Containers in Texas," Final Report, prepared for TRNCC, August 30, 2002. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 22 county area this comes to 1.01 tons per typical ozone season weekday for commercial uses, and 4.18 tons per day for residential uses.

The prior report also estimated that replacement cans meeting new rule requirements would result in an overall reduction of 62.4% per unit. Recent survey results indicated that commercial users replace their gas cans almost annually. 14 And EPA's NONROAD emission factor model indicates a 4 year turnover cycle for residential gas cans. So assuming that such a rule is adopted in early 2004, essentially all portable gas cans will be replaced by the 2007 evaluation period, resulting in a reduction of 0.63 tons per day from commercial uses, and 1.97 tons per day for residential uses ( 2.60 tons of VOC per day total).

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net VOC Reduction ( tpd) Percent Reduction (%) AREA SOURCES: Lawn and Garden Equipment ( Commercial& Residential) Low Emission Gas Cans Austin Round Rock MSA ( 5 Counties) 13.40 10.80 2.60 19.4%

Table 4 9. Low Emission Gas Can VOC emission reduction COSTS Costs for the program were estimated assuming an $ 11 incremental price for the larger commercial cans, and $ 8 for residential cans, as per the CARB Rulemaking documentation. The total number of effected commercial companies was determined from Texas Comptroller records for lawn and garden services in the region ( 734 as of 2002). The previous ERG survey for TCEQ also found that the average number of gas cans owned by commercial interests was 10.5. These data were combined to estimate a total annual incremental cost of $ 84,777 per year, and a cost effectiveness of $ 368 per ton for commercial gas can use.

For residential uses ERG found that each single family household ( number obtained from Census data) would own 1.35 portable gas cans on average. Accounting for turnover rates, incremental costs, and the number of households in the region, we estimate an 14 Personal communication with Marilyn Good, Texas Nursery and Landscape Association, August 2002. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 23 annual cost of $ 1,363,890 ( 4 year annualized cost), and a cost effectiveness of $ 1,899/ ton of VOC for the residential sector.

REFERENCE ERG, Inc., Technical Support Documentation: Emission control Strategy Evaluation for the Austin/ San Marcos ( A/ SM) MSA EAC Clean Air Action Plan ( CAAP), February 17th, 2004 4.2.5 Stage 1 Vapor Recovery Requirement Change ( A5)

SOURCE TYPE AFFECTED Service stations that pump over 25,000 gallons of fuel per month and fuel dispensing facilities in the MSA will be affected by this measure.

CONTROL STRATEGY Stage I vapor recovery is already in place in the Austin region for service stations that pump over 125,000 gallons of fuel per month. This measure would require Stage I on service stations pumping 25,000 gallons per month, thus increasing the number of service stations using the system. Stage I reduces VOC emissions during fuel transfer from the tanker truck to the underground storage tank through a special vapor recovery system.

IMPLEMENTATION Preferably a modification to state rule 30 TAC 115, Subchapter C, Division 2 Filling of Gasoline Storage Vessels ( Stage 1) for Motor Vehicle Fuel Dispensing Facilities,

developed by TCEQ, applicable in all five counties. The plan must be implemented no later than December 31, 2005.

Within the A/ RR MSA there are approximately 41 sites ( 94 tanks) that are not equipped with Stage 1 Vapor Recovery equipment. This is only 10% or less of the total. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 24 Table 4 10. Gasoline station throughput EXPECTED EMISSION REDUCTION The Stage I Vapor recovery control has a potential of 4.88 tpd VOC reductions ( assuming participation in all five counties). A Stage I control efficiency of 95% ( EPA 453/ R 94

002a / Stage I NESHAP), rule penetration of 64.4%, and rule effectiveness ( RE) of 80%

was assumed. The MSA gasoline sales shown in Table 4 10 were used to derive rule penetration ( RP) as presented in Table 4 11. The expected emission reductions from Stage I Vapor recovery control are presented for each county by percentage in Table 4 12 and in tons per day in Table 4 13.

Table 4 11. Stage I Rule penetration for gas stations Table 4 12. Expected emission reduction from Stage I Vapor recovery control A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 25 Table 4 13. Stage I controls VOC reductions by County ESTIMATED COST To estimate costs, ERG used estimates developed for TNRCC's 1999 Stage I RACT analysis. Key costs include purchase and installation of Stage I equipment ($ 1,750/ station   high end estimate), and annual operating costs per station ($ 368   high end estimate). Next, these unit costs were combined with data from the TCEQ's PST database to obtain area wide costs. 15 The following presents the estimated number of gasoline storage tanks in each county, derived from the PST database. The database also provided a field indicating if a particular tank was equipped for Stage I recovery ( Table 4 14). 16 County Total Without Stage I Bastrop 201 137 Caldwell 108 74 Hays 235 130 Travis 1,736 1,080 Williamson 596 330 Table 4 14. Number of Retail Gasoline Tanks and Stage I Units by County ( 2003)

Using the average number of tanks per station without Stage I equipment ( 4.0  from the PST database), and the number of stations by throughput presented above, the target number of tanks was determined, as shown below ( Table 4 15).

15 http:// www. tnrcc. state. tx. us/ permitting/ r_ e/ par/ pstregis/ pstregisquery2. html. 16 Recent data indicate that the number of tanks equipped with Stage I equipment may be even higher, ( upwards of 90%), thereby lowering costs and improving cost effectiveness even further   personal communication, Scott Johnson, 1 27 04. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 26 gal/ mo Bastrop Caldwell Hays Travis Williamson < 9,999 3 2 3 22 7 10,000  24,999 21 11 20 165 50 25,000  49,999 42 23 40 335 102 50,000  124,999 71 38 67 558 170 Table 4 15. Number of Tanks Without Stage I Capability, by Throughput Using these figures, annual costs were then calculated. Initial capital and installation costs were annualized over a 5 year period at 10% for this purpose. Annual costs by throughput category are presented below ( Table 4 16).

gal/ mo Bastrop Caldwell Hays Travis Williamson < 9,999 $ 2,489 $ 1,659 $ 2,489 $ 18,252 $ 5,808 10,000  24,999 $ 17,423 $ 9,126 $ 16,593 $ 136,892 $ 41,482 25,000  49,999 $ 34,845 $ 19,082 $ 33,186 $ 277,931 $ 84,624 50,000  124,999 $ 58,905 $ 31,527 $ 55,586 $ 462,942 $ 141,040 Total $ 113,661 $ 61,394 $ 107,854 $ 896,017 $ 272,953 Table 4 16. Annual Costs by Throughput Cost effectiveness was then determined for cumulative costs and benefits for the different rule cut off levels, as on Table 4 17.

Cut Off Bastrop Caldwell Hays Travis Williamson MSA Average all $ 1,501 $ 1,477 $ 822 $ 910 $ 812 $ 925 > 10,000 $ 1,473 $ 1,438 $ 805 $ 894 $ 797 $ 908 > 25,000 $ 1,305 $ 1,267 $ 709 $ 790 $ 705 $ 803 > 50,000 $ 1,028 $ 986 $ 555 $ 621 $ 554 $ 630 Table 4 17. Cost Effectiveness by Rule Cut Off Level ($/ Ton VOC)

REFERENCES Title 30, Part 1, Chapter 115, Subchapter C, Division 2 Filling Of Gasoline Storage Vessels ( Stage I) For Motor Vehicle Fuel Dispensing Facilities, § 115.227 Exemptions ERG, Inc., Technical Support Documentation: Emission control Strategy Evaluation for the Austin/ San Marcos ( A/ SM) MSA EAC Clean Air Action Plan ( CAAP), February 17th, 2004 A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 27 4.2.6 Degreasing Controls ( A6)

A degreaser is any equipment designed and used for holding a solvent to carry out solvent cleaning operations including, but not limited to, batch loaded cold cleaners,

open top vapor degreasers, conveyorized ( in line) degreasers, and air tight and airless cleaning systems. Solvent cleaning machines are used to dry materials and remove soils,

such as grease, wax, and oil from metal parts, circuit boards, sheet metal, assemblies, and other materials. Emissions of VOC primarily result from air/ solvent interface losses ( e. g., evaporation and subsequent release from the machine) and workload losses ( e. g.,

carry out of solvent on parts).

SOURCE TYPE AFFECTED The metalworking industries are the major users of solvent degreasing. These include automotive, electronics, plumbing, aircraft, refrigeration, and business machine industries. The printing, chemical, plastics, rubber, textiles, glass, paper, and electric power industries also use solvent degreasing operations. This category does not include dry cleaning.

CONTROL STRATEGY Cold cleaning was the largest degreasing emissions in the inventory and the one we targeted. In cold cleaning, the part is dipped into or sprayed with solvent. To reduce the amount of solvent evaporation, control requirements including equipment and operating procedures shall be required.

IMPLEMENTATION Under 30 TAC 106.454 Degreasing Units, anyone obtaining a state air permit for a degreasing unit is required to meet with § 115.412 and § 115.415 as of November 1st,

2001. It is requested that TCEQ extend state rule 30 TAC 115, Subchapter E, Division 1,

§ § 11.412, 115.413, 115.415. 417, 117.419 to the Austin/ Round Rock MSA. Therefore the extension of this rule would only apply to operations permitted prior to November 1st,

2001. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 28 The National Degreasing rule ( Halogenated Solvent Cleaning NESHAP) only covers those degreasers using one of the listed six halogenated HAPs ( methylene chloride,

perchloroethylene, trichloroethylene, 1,1,1 trichloroethane, carbon tetrachloride, and chloroform). Therefore, the national rule does not regulate other degreasing solvents that may be VOCs, but not HAPs.

EXPECTED REDUCTIONS It is estimated that 50% of the market is in compliance with the current rules. This was based on the fact that one large degreasing supplier is estimated to have 50% of the market in the MSA and is in compliance with the current rules. The remaining 50%

creates a potential for reduction from the 2007 baseline. Degreasing controls are expected to reduce VOC emissions by 6.38 tons of VOC per day. An estimated control efficiency of 85% ( TCEQ estimate), rule efficiency of 80% ( EPA default), and rule penetration of 100% was used to in this calculation. Table 4 18 presents the degreasing emissions in 2007.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net VOC Reduction ( tpd) Percent Reduction (%) AREA SOURCES: Degreasing ( Cold Cleaning) SCCs: 2415300000, 2415360000, 2415355000, 2415330000, 2415320000, 2415305000, 2415325000, 2415340000, 2415345000, 2415365000, 2415310000, 2415335000 Degreasing Reduction Measures Austin Round Rock MSA ( 5 Counties) 9.38 3.00 6.38 68.0%

Table 4 18. Cold Cleaning Degreasing VOC Emission Reduction COSTS At this time we do not have a cost estimate. However, the measure is expected to save money in transitioning from solvent based cleaners to aqueous. There is additional cost savings in reduced solvent evaporative losses.

References South Coast Air Quality Management District ( SCAQMD), 1997. Final Staff Report for Proposed Amendments to Rule 1122  Solvent Degreasers. June 6, 1997. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 29 SCAQMD, 2002. South Coast Air Quality Management District Rule 1122  Solvent Degreasers. Amended December 6, 2002.

4.2.7 Autobody Refinishing Controls ( A7)

The autobody refinishing category is the repairing of worn or damaged automobiles, light trucks, and other vehicles, and refers to any coating applications that occur subsequent to those at original equipment manufacturer ( OEM) assembly plants. The majority of these operations occur at small body shops that repair and refinish automobiles. Emissions of VOC results from the paint solvents, thinning solvents, and solvents used for surface preparation and cleanup.

SOURCE TYPE AFFECTED Facilities performing autobody refinishing operations are classified with the Standard Industrial Classification ( SIC) code 7532 ( establishments primarily engaged in the repair of automotive tops, bodies, and interiors, or automotive painting and refinishing) ( EIIP,

2000).

CONTROL STRATEGY Adopt California Autobody Refinishing Control standards to reduce VOC emissions from this source by 45%. Rule requires lowering the VOC content of the products used,

improving the application technique so that less coating is used and controlling the use of clean up solvents ( proper handling of gun cleaning and clean up solvents). Emissions occur at all three process stages ( surface preparation, painting and equipment cleaning)

due to evaporation of solvents in the primers, paints and other coatings, and in the cleaning solutions.

Lower VOC Coatings The South Coast Air Quality Management District ( SCAQMD) performed studies on the feasibility of using lower VOC content coatings than the federal rule. SCAQMD determined that each of the coating categories in the Federal rule could be lowered to reduce overall VOC emissions. They determined that these lower VOC coatings are A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 30 currently available on the market and compatible with existing coatings. Table 4 19 compares the VOC limits between the two rules.

Coating Category VOC Limits from Federal Rule ( grams/ liter) VOC Limits from SCAQMD ( grams/ liter)

Pretreatment Wash Primer 780 600 Primer/ Primer Surfacer 580 250 Primer Sealer 550

Single/ 2 Stage Topcoats 600 420 Topcoats of 3 or more stages 630 540 Metallic Topcoat  520 Multi colored topcoats 680

Specialty Coatings 840

Table 4 19. Comparison of VOC Limits of the Federal Rule and SCAQMD The publications from U. S. EPA Design for the Environment and Office of Pollution Prevention and Toxics described additional emission control measures. The options included higher transfer efficiency application equipment, automated equipment cleaning and equipment maintenance, work practices, and spray booths with emission controls.

Application Equipment The two most common coating application tools are conventional spray guns and high volume low pressure ( HVLP) spray guns. In conventional spray guns, a low volume of air is pressurized and forced through the spray nozzle. The paint or coating is atomized in the air at the nozzle throat. Air is supplied by an air compressor during spraying operations. With a conventional spray gun, paints or coatings are typically atomized with air pressures of approximately 450 kPa ( 65 psig). The major disadvantage to conventional spray guns is the excessive spray mist and overspray fog due to the high pressure used at the nozzle. This excessive overspray results in a low transfer efficiency ( the ratio of the amount of coating solids deposited onto the surface of the coated part to the total amount of coating solids that exit the spray gun nozzle). Studies have shown conventional spray gun transfer efficiencies as low as 20 percent. A low transfer A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 31 efficiency results in increased material usage, increased cost, and higher mist particle emissions ( U. S. EPA, 2002).

HVLP spray guns use a high volume of air to atomize the coatings at a relatively low air pressure ( 69 kPa ( 10 psig)) at the spray nozzle. Some HVLP spray guns are gravity assisted, with the paint cup above the atomization nozzle, and some are " suction" or " siphon cup" spray guns, with the cup below the nozzle. With siphon cup HVLP spray guns, a controlled air pressure is used to meter the flow of paint into the orifice where atomization occurs. HVLP spray guns typically have a higher transfer efficiency than conventional spray guns ( e. g., up to 65 percent), but cost more to purchase ( U. S. EPA,

2002).

A third type of application tool is an electrostatic spraying system. The transfer efficiencies of these systems are between 60 and 90percent and are widely used in U. S.

automotive assembly plants. Air powered, electrostatic spray guns function in essentially the same way as electrostatic spray guns. Although transfer efficiencies for powder spray guns are similar to wet spray guns, the powder can be reused and these systems can operate with powder utilization rates of up to 98 percent. Neither of these systems are practical for refinishing systems; however, for the following reasons: ( 1) prohibitively high cost of electrostatic spray guns, ( 2) large amount of coating contained in the hose connecting electrostatic spray gun to pot, which must be removed when changing colors,

( 3) high curing temperatures required for powder systems ( i. e., resulting in damage to other vehicle components), and ( 4) grounding methods required for electrostatic systems in an OEM environment cannot be duplicated for automobile refinishing ( U. S. EPA,

1997).

Other paint spray equipment are compared in Table 4 20; however the most commonly used application equipment for autobody refinishing facilities are conventional and HVLP guns ( U. S. EPA, 1997). A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 32 IMPLEMENTATION Preferably state rule, developed by TCEQ, applicable in all five counties. The plan must be implemented no later than December 31, 2005. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 33 Table 4 20. Comparison of Characteristics of Paint Spray Equipment for Automotive Refinishers Performance Characteristics Type of Painting System Advantages Disadvantages System Transfer Efficiency (%) Cost Range ($) Population of Shops Using Equipment Conventional Low cost Low maintenance Excellent material atomization Excellent operator control Quick color change capabilities Coating can be applied by syphon or under pressure Uses high volume of air Develops excessive spray dust and overspray fog Does not adapt to high volume material output ( economics of scale)

Low transfer efficiency Pressure fuel systems require high volumes of coatings 20 to 40 up to 350 Specific population data is unknown.

Some states have mandated the use of HVLP systems by automotive refinishers.

High Volume Low Pressure Low blowback and spray fog Will apply high viscosity high solid coatings ( low VOC coatings)

Relatively easy to clean Can be used for intricate parts Good operator controls High initial cost Slower application speed with some coatings Does not fully atomize some coatings Higher maintenance costs Requires operator training At least 65 500 1000 64% of all shops Low Volume Low Pressure Low blowback and spray fog Will apply high viscosity high solid coatings Easy to clean Can be used for intricate parts Good operator controls Needs less air compression then HVLP Lower energy requirements High initial cost Slower application speed than HVLP Does not fully atomize some coatings Higher maintenance costs Requires operator training Still relatively new to the market At least 65 500 1000 Population data is unknown Powder Coating Almost zero VOC emissions Excess or waste powder can often be melted Powder can be applied to hot or cold parts Ideal for robotic application Applied in single coal system Economical for long runs of a few colors Generally, capital equipment outlay is greater than for conventional coatings High energy usage due to high temperature ovens Some powders require temperatures as high as 500 ° F for curing Not suited for every application ( parts that can not tolerate high temperature plastics, rubber,

upholstery) Up to 95 5000 10,000 Population data is unknown Powder coating systems are used primarily in OEM operations.

Source: U. S. EPA, May 1997. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 34 ESTIMATED EMISSION REDUCTION An OTAG Technical Support Document calculated a Future Control Efficiency ( FCE) of 53% based on coatings reformulation and high volume, low pressure ( HVLP) spray equipment. The limits set by TCEQ rules reduce the Austin MSA emissions by 45%.

CAPCO estimated that by 2007 emissions from autobody refinishing would be 202 tons per year. Therefore, the additional 8% reduction is approximately 100 tons per year or 0.05 tpd ( Table 4 21).

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net VOC Reduction ( tpd) Percent Reduction (%) AREA SOURCES: Autobody Shops SCCs: 2401070000, 2401001025 & 2401005000 Autobody Refinishing Controls Austin Round Rock MSA ( 5 Counties) 0.64 0.59 0.05 8.0%

Table 4 21. Autobody Refinishing VOC Emission Reduction ESTIMATED COST Table 4 22 below compares the potential emission reduction techniques and their estimated cost to the facilities.

Potential Control Options Potential Emissions Reduction (%) Control Option Estimated Cost 1. Low VOC coating products 1. SCAQMD has VOC limits that are about 30% lower than the federal rule 1. The cost should be low because these coating are available since the SCAQMD facilities are using them and should be approximately the same cost as the federal rule compliant coatings.

2. High Volume Low Pressure ( HVLP) spray guns 2. HVLP spray guns have > 25% better transfer efficiency than conventional spray guns and result in less VOC emissions and uses 40 55% less coating than conventional spray guns. 2. Conventional guns are about $ 350 and HVLP guns are ~$ 500. Use less amount of coatings. The same air compressor can be used.

Table 4 22. Comparison of Control Options, Source: U. S. EPA, 2002. A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 35 REFERENCES U. S. EPA, 2002. Design for the Environment ( DfE). Isocyanate and Volatile Organic Compound Emissions from Auto Refinishing Facilities ( Draft Final) , U. S. Environmental Protection Agency, Washington, DC, September 2002. U. S. EPA, 1997. Office of Pollution Prevention and Toxics ( OPPT). Automotive Refinishing Industry Isocyanate Profile, U. S. Environmental Protection Agency, Washington, DC, May 1997 Emission Inventory Improvement Program ( EIIP), 2000. Volume III: Chapter 13  Auto Body Refinishing. Prepared for: Area Sources Committee Emission Inventory Improvement Program, Research Triangle Park, NC. January 2000.

4.2.8 Cut Back Asphalt ( A8)

SOURCE TYPE AFFECTED Asphalt Suppliers and Paving Contractors are largely affected by this measure. The Texas Department of Transportation will also be affect through their contracts.

CONTROL STRATEGY The use of conventional cutback asphalt containing VOC solvents for the paving of roadways, driveways, or parking lots is restricted to no more than 7.0% of the total annual volume averaged over a two year period of asphalt used by or specified by any state, municipal, or county agency who uses or specifies the type of asphalt application.

When asphalt emulsion is used or produced, the maximum VOC content shall not exceed 12% by weight or the following limitations, whichever is more stringent:

A. 0.5% by weight for seal coats;

B. 3.0% by weight for chip seals when dusty or dirty aggregate is used;

C. 8.0% by weight for mixing with open graded aggregate with less than 1.0% by weight of dust or clay like materials adhering to the coarse aggregate fraction ( 1/ 4 inch in diameter or greater); and D. 12% by weight for mixing with dense graded aggregate when used to produce a mix designed to have 10% or less voids when fully compacted.

Exemptions: A/ RR MSA Emissions Reduction Strategies CAPCO March 2004 4 36 1. asphalt concrete made with cutback asphalt, used for patching, which is stored in a long life stockpile ( longer than one month storage); and 2. cutback asphalt used solely as a penetrating prime coat.

IMPLEMENTATION This measure would restrict the use of cut back asphalt in the MSA through a TCEQ rule revision ( Chapter 115, Subchapter F, Division § § 115.510, 115.512, 115.513, 115.515

115.517, 115.519) to include the MSA counties in the requirements of these sections. The plan must be implemented no later than December 31, 2005.

EXPECTED EMISSION REDUCTIONS A conservative rule efficiency of 80% and rule penetration of 80% were used in this calculation. Together with an efficiency of 60%, this brings the total reduction to 38.4%.

Therefore, the expected emission reductions from this measure are 1.03 tons per day VOC ( Table 4 23). There is no NOx reduction for this measure.

Emissions Category Control Strategy Area Affected by this rule 2007 Uncontrolled VOC Emissions ( tpd) 2007 Controlled VOC Emissions ( tpd) Net VOC Reduction ( tpd) Percent Reduction (%)

AREA SOURCES: Asphalt Aplications SCC: 2461020000 Cutback Asphalt Restrictions Austin Round Rock MSA ( 5 Counties) 2.68 1.65 1.03 38.4%

Table 4 23. Asphalt Paving VOC Emission Reduction ESTIMATED COST At this time we do not have a cost estimate.

4.2.9 Low Reid Vapor Gas ( A9)