Identification and Evaluation of

Candidate Control Measures

Final

Technical Support Document

Prepared for:

Seth Barna

Ozone Transport Commission (OTC)

444 North Capitol Street, NW, Suite 638

Washington, DC  20001

(202) 508-3840

Prepared by:

MACTEC Federal Programs, Inc.

560 Herndon Parkway, Suite 200

Herndon, VA 20170

(703) 471-8383

February 28, 2007

______________________	______________________

Edward Sabo							Douglas A. Toothman

Principal Scientist						Principal Engineer

(Page intentionally left blank)Table of Contents

  TOC \o "1-4" \h \z \u    HYPERLINK \l "_Toc160602554"  1.0 EXECUTIVE
SUMMARY	  PAGEREF _Toc160602554 \h  1-1

  HYPERLINK \l "_Toc160602555"  2.0 INTRODUCTION	  PAGEREF _Toc160602555
\h  2-1

  HYPERLINK \l "_Toc160602556"  3.0 VOC ANALYSIS METHODS	  PAGEREF
_Toc160602556 \h  3-1

  HYPERLINK \l "_Toc160602557"  3.1	ADHESIVES, SEALANT, ADHESIVE PRIMER,
AND SEALANT PRIMER APPLICATION	  PAGEREF _Toc160602557 \h  3-1

  HYPERLINK \l "_Toc160602558"  3.1.1	Existing Federal and State Rules
PAGEREF _Toc160602558 \h  3-1

  HYPERLINK \l "_Toc160602559"  3.1.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602559 \h  3-3

  HYPERLINK \l "_Toc160602560"  3.1.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602560 \h  3-4

  HYPERLINK \l "_Toc160602561"  3.1.4	Cost Estimates	  PAGEREF
_Toc160602561 \h  3-4

  HYPERLINK \l "_Toc160602562"  3.2	CUTBACK AND EMULSIFIED ASPHALT
PAVING	  PAGEREF _Toc160602562 \h  3-5

  HYPERLINK \l "_Toc160602563"  3.2.1	Existing Federal and State Rules
PAGEREF _Toc160602563 \h  3-5

  HYPERLINK \l "_Toc160602564"  3.2.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602564 \h  3-7

  HYPERLINK \l "_Toc160602565"  3.2.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602565 \h  3-7

  HYPERLINK \l "_Toc160602566"  3.2.4	Cost Estimates	  PAGEREF
_Toc160602566 \h  3-7

  HYPERLINK \l "_Toc160602567"  3.3	CONSUMER PRODUCTS	  PAGEREF
_Toc160602567 \h  3-8

  HYPERLINK \l "_Toc160602568"  3.3.1	Existing Federal and State Rules
PAGEREF _Toc160602568 \h  3-8

  HYPERLINK \l "_Toc160602569"  3.3.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602569 \h  3-9

  HYPERLINK \l "_Toc160602570"  3.3.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602570 \h  3-10

  HYPERLINK \l "_Toc160602571"  3.3.4	Cost Estimates	  PAGEREF
_Toc160602571 \h  3-11

  HYPERLINK \l "_Toc160602572"  3.4	PORTABLE FUEL CONTAINERS	  PAGEREF
_Toc160602572 \h  3-11

  HYPERLINK \l "_Toc160602573"  3.4.1	Existing Federal and State Rules
PAGEREF _Toc160602573 \h  3-12

  HYPERLINK \l "_Toc160602574"  3.4.2	Description of the OTC 2006 Model
Rule	  PAGEREF _Toc160602574 \h  3-13

  HYPERLINK \l "_Toc160602575"  3.4.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602575 \h  3-14

  HYPERLINK \l "_Toc160602576"  3.4.4	Cost Estimates	  PAGEREF
_Toc160602576 \h  3-15

  HYPERLINK \l "_Toc160602577"  3.5	REGIONAL FUELS	  PAGEREF
_Toc160602577 \h  3-15

  HYPERLINK \l "_Toc160602578"  3.5.1	Existing Federal and State Rules
PAGEREF _Toc160602578 \h  3-16

  HYPERLINK \l "_Toc160602579"  3.5.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602579 \h  3-16

  HYPERLINK \l "_Toc160602580"  3.5.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602580 \h  3-16

  HYPERLINK \l "_Toc160602581"  3.5.4	Cost Estimates	  PAGEREF
_Toc160602581 \h  3-16

  HYPERLINK \l "_Toc160602582"  3.6	VOC EMISSION REDUCTION SUMMARY
PAGEREF _Toc160602582 \h  3-17

  HYPERLINK \l "_Toc160602583"  4.0 NOx ANALYSIS METHODS	  PAGEREF
_Toc160602583 \h  4-1

  HYPERLINK \l "_Toc160602584"  4.1	HEAVY-DUTY TRUCK DIESEL ENGINE CHIP
REFLASH	  PAGEREF _Toc160602584 \h  4-1

  HYPERLINK \l "_Toc160602585"  4.1.1	Existing Federal and State Rules
PAGEREF _Toc160602585 \h  4-1

  HYPERLINK \l "_Toc160602586"  4.1.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602586 \h  4-2

  HYPERLINK \l "_Toc160602587"  4.1.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602587 \h  4-2

  HYPERLINK \l "_Toc160602588"  4.1.4	Cost Estimates	  PAGEREF
_Toc160602588 \h  4-2

  HYPERLINK \l "_Toc160602589"  4.2	REGIONAL FUELS	  PAGEREF
_Toc160602589 \h  4-3

  HYPERLINK \l "_Toc160602590"  4.2.1	Existing Federal and State Rules
PAGEREF _Toc160602590 \h  4-3

  HYPERLINK \l "_Toc160602591"  4.2.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602591 \h  4-3

  HYPERLINK \l "_Toc160602592"  4.2.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602592 \h  4-4

  HYPERLINK \l "_Toc160602593"  4.2.4	Cost Estimates	  PAGEREF
_Toc160602593 \h  4-4

  HYPERLINK \l "_Toc160602594"  4.3	ASPHALT PAVEMENT PRODUCTION PLANTS
PAGEREF _Toc160602594 \h  4-4

  HYPERLINK \l "_Toc160602595"  4.3.1	Existing Federal and State Rules
PAGEREF _Toc160602595 \h  4-4

  HYPERLINK \l "_Toc160602596"  4.3.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602596 \h  4-4

  HYPERLINK \l "_Toc160602597"  4.3.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602597 \h  4-6

  HYPERLINK \l "_Toc160602598"  4.3.4	Cost Estimates	  PAGEREF
_Toc160602598 \h  4-6

  HYPERLINK \l "_Toc160602599"  4.4	CEMENT KILNS	  PAGEREF _Toc160602599
\h  4-6

  HYPERLINK \l "_Toc160602600"  4.4.1	Existing Federal and State Rules
PAGEREF _Toc160602600 \h  4-7

  HYPERLINK \l "_Toc160602601"  4.4.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602601 \h  4-8

  HYPERLINK \l "_Toc160602602"  4.4.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602602 \h  4-9

  HYPERLINK \l "_Toc160602603"  4.4.4	Cost Estimates	  PAGEREF
_Toc160602603 \h  4-9

  HYPERLINK \l "_Toc160602604"  4.5	GLASS/FIBERGLASS FURNACES	  PAGEREF
_Toc160602604 \h  4-9

  HYPERLINK \l "_Toc160602605"  4.5.1	Existing Federal and State Rules
PAGEREF _Toc160602605 \h  4-9

  HYPERLINK \l "_Toc160602606"  4.5.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602606 \h  4-10

  HYPERLINK \l "_Toc160602607"  4.5.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602607 \h  4-11

  HYPERLINK \l "_Toc160602608"  4.5.4	Cost Estimates	  PAGEREF
_Toc160602608 \h  4-11

  HYPERLINK \l "_Toc160602609"  4.6	ICI BOILERS	  PAGEREF _Toc160602609
\h  4-12

  HYPERLINK \l "_Toc160602610"  4.6.1	Existing Federal and State Rules
PAGEREF _Toc160602610 \h  4-12

  HYPERLINK \l "_Toc160602611"  4.6.2	Description of the OTC 2006
Control Measure	  PAGEREF _Toc160602611 \h  4-13

  HYPERLINK \l "_Toc160602612"  4.6.3	Emission Benefit Analysis Methods
 PAGEREF _Toc160602612 \h  4-13

  HYPERLINK \l "_Toc160602613"  4.6.4	Cost Estimates	  PAGEREF
_Toc160602613 \h  4-22

  HYPERLINK \l "_Toc160602614"  4.7	NOx EMISSION REDUCTION SUMMARY
PAGEREF _Toc160602614 \h  4-22

  HYPERLINK \l "_Toc160602615"  5.0 REFERENCES	  PAGEREF _Toc160602615
\h  5-1

List of Appendices

Appendix A – Process for Identifying and Evaluating Control Measures

Appendix B – Initial List of Control Measures

Appendix C – Control Measures Summary Sheets

Appendix D – VOC Emissions by County for 2002 and 2009

Appendix E – NOx Emissions by County for 2002 and 2009

Appendix F – ICI Boiler Regulations by State

List of Figures

List of Tables	Page

1-1	VOC Emission Reduction Benefits from OTC 2006 Control Measures	1-7

1-2	NOx Emission Reduction Benefits from OTC 2006 Control Measures	1-8

List of Tables

List of Tables	Page

1-1	Summary of OTC 2006 Control Measures	1-3

1-2	Estimated Emission Reduction Benefits in 2009 by State	1-6

3-1	Summary of OTC State Rules for Cutback and Emulsified Asphalt	3-6

3-2	Status of OTC State’s Promulgation of the OTC 2001 Model Rule for
                  Consumer Products	3-9

3-3	Consumer Products Affected by CARB’s July 2005 Rule Amendments
3-10

3-4	Status of OTC State’s Promulgation of the OTC 2001 Model Rule for
                     Portable Fuel Containers	3-14

3-5	OTC 2006 VOC Model Rule Benefits by State for 2009:

	Adhesives and Sealants Application	3-19

3-6	OTC 2006 VOC Model Rule Benefits by State for 2009:

	Cutback and Emulsified Asphalt Paving	3-20

3-7	OTC 2006 VOC Model Rule Benefits by State for 2009:

	Consumer Products	3-21

3-8	OTC 2006 VOC Model Rule Benefits by State for 2009:

	Portable Fuel Containers – Area Sources	3-22

3-9	OTC 2006 VOC Model Rule Benefits by State for 2009:

	Portable Fuel Containers – Nonroad Sources	3-23

3-10	OTC 2006 VOC Model Rule Benefits by State for 2009:

	Regional Fuels	3-24

3-11	OTC 2006 VOC Model Rule Benefits by State for 2009:

	All Five VOC Categories	3-25

4-1	OTC Resolution 06-02 Emission Guidelines for Asphalt Plants	4-5

4-2	OTC Resolution 06-02 Emission Guidelines for Cement Kilns	4-8

4-3	OTC Resolution 06-02 Emission Guidelines for Glass Furnaces	4-10

4-4	OTC Proposal for ICI Boilers	4-14

4-5	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Natural Gas-fired Boilers	4-16

4-6	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Distillate Oil-fired Boilers	4-17

4-7	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Residual Oil-fired Boilers	4-18

4-8	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Coal Wall-fired Boilers	4-19

4-9	Current State Emission Limits and Percent Reduction for OTC Proposal

	Point Source Coal Tangential-fired Boilers	4-20

4-10	Current State Emission Limits and Percent Reduction for OTC
Proposal

	Point Source Coal-fired Stoker Boilers	4-21

List of Tables (continued)

List of Tables	Page

4-11	OTC 2006 NOx Model Rule Benefits by State for 2009:

	Heavy-Duty Truck Diesel Engine Chip Reflash	4-24

4-12	OTC 2006 NOx Model Rule Benefits by State for 2009:

	Regional Fuels	4-25

4-13	OTC 2006 NOx Model Rule Benefits by State for 2009:

	Asphalt Pavement Production Plants	4-26

4-14	OTC 2006 NOx Model Rule Benefits by State for 2009:

	Cement Kilns	4-27

4-15	OTC 2006 NOx Model Rule Benefits by State for 2009:

	Glass/Fiberglass Furnaces	4-28

4-16	OTC 2006 NOx Model Rule Benefits by State for 2009:

	ICI Boilers – Area (minor) Sources	4-29

4-17	OTC 2006 NOx Model Rule Benefits by State for 2009:

	ICI Boilers – Point (major) Sources	4-30

4-18	OTC 2006 NOx Model Rule Benefits by State for 2009:

	All Seven NOx Categories	4-31

Acronyms and Abbreviations

Acronym	Description

BOTW	Beyond-on-the-Way – refers to additional emission controls that
are being considered

CAIR	Clean Air Interstate Rule

EGAS 5.0	Economic Growth Analysis System Version 5.0

EGU	Electric Generating Unit

EPA	U.S. Environmental Protection Agency

IPM	Integrated Planning Model

MANE-VU	Mid-Atlantic/Northeast Visibility Union

MARAMA	Mid-Atlantic Regional Air Management Association

MOBILE6	U.S. EPA’s emission model for onroad sources

NESCAUM	Northeast States for Coordinated Air Use Management

NH3	Ammonia

NIF3.0	National Emission Inventory Input Format Version 3.0

NONROAD	U.S. EPA’s emission model for certain types of nonroad
equipment

NOx	Oxides of nitrogen

OTB/W	On-the-Books/On-the-Way – refers to emission control programs
already adopted and proposed emission controls that will result in
post-2002 emission reductions

OTC	Ozone Transport Commission

OTC 2001 model rules	Model rules developed by the OTC in 2001

OTC 2006 model rules	Model rules developed by the OTC in 2006

PM10-PRI	Particulate matter less than or equal to 10 microns in diameter
that includes both the filterable and condensable components of
particulate matter

PM25-PRI	Particulate matter less than or equal to 2.5 microns in
diameter that includes both the filterable and condensable components of
particulate matter

SIC	Standard Industrial Classification code

SIP	State Implementation Plan

SCC	Source Classification Code

SO2	Sulfur dioxide

VOC	Volatile organic compounds

EXECUTIVE SUMMARY

The States of the Ozone Transport Region (OTR) are faced with the
requirement to submit attainment demonstration plans for the 8-hour
ozone National Ambient Air Quality Standards (NAAQS).  To accomplish
this, most of the states will need to implement additional measures to
reduce emissions that either directly impact their nonattainment status,
or contribute to the nonattainment status in other states.  As such, the
Ozone Transport Commission (OTC) undertook an exercise to identify a
suite of additional control measures that could be used by the OTR
states in attaining their goals.

The OTC staff and member states formed several workgroups to identify
and evaluate candidate control measures.  Initially, the Workgroups
compiled and reviewed a list of approximately 1,000 candidate control
measures.  These control measures were identified through published
sources such as the U.S. Environmental Protection Agency’s (EPA’s)
Control Technique Guidelines, STAPPA/ALAPCO “Menu of Options”
documents, the AirControlNET database, emission control initiatives in
member states as well as other states including California,
state/regional consultations, and stakeholder input.  The Workgroups
developed a preliminary list of 30 candidate control measures to be
considered for more detailed analysis.  These measures were selected to
focus on the pollutants and source categories that are thought to be the
most effective in reducing ozone air quality levels in the Northeastern
and Mid-Atlantic States.

The Workgroups discussed the candidate control measures during a series
of conference calls and workshops held periodically from the spring of
2004 through the autumn of 2006.  The Workgroups collected and evaluated
information regarding emission benefits, cost-effectiveness, and
implementation issues.  Each of the candidate control measures were
summarized in a series of “Control Measure Summary Sheets”.
Stakeholders were provided multiple opportunities to review and comment
on the Control Measure Summary Sheets.

Based on the analyses by the OTC Workgroups, the OTC Commissioners made
several recommendations at the June 2006 Commissioners’ meeting in
Boston (OTC 2006a-d) and at the November 2006 Commissioners’ meeting
in Richmond (OTC 2006e-g).  The Commissioners recommended that States
consider emission reductions from the following source categories:

Consumer Products

Portable Fuel Containers

Adhesives and Sealants Application

Diesel Engine Chip Reflash

Cutback and Emulsified Asphalt Paving

Asphalt Production Plants

Cement Kilns

Glass Furnaces

Industrial, Commercial, and Institutional (ICI) Boilers

Regional Fuels

Additionally, the Commissioners directed the OTC to evaluate control
measures for Electric Generating Units (EGUs) and high electric demand
day units (these measures will be addressed in a separate OTC report)
Finally, the Commissioners requested that EPA pursue federal regulations
and programs designed to ensure national development and implementation
of control measures for the following categories: architectural and
maintenance coatings, consumer products, ICI boilers over 100 mmBtu/hour
heat input, portable fuel containers, municipal waste combustors,
regionally consistent and environmentally sound fuels, small offroad
engine emission regulation, and gasoline vapor recovery (OTC 2006d).

See Appendix A for a full description of the process used by the OTC to
identify and evaluate candidate control measures.

Table 1-1 summarizes information about the control measures identified
by the OTC Commissioners at the June 2006 and November OTC meetings.
Table 1-1 identifies the sector, the source category, and a brief
description of the control measure.  Next is a column that identifies
the recommended approach for implementing the rule, such as an OTC model
rule or updates to existing state-specific rules.  The next two columns
show the percent reduction from 2009 emission levels. The final column
provides the cost effectiveness estimate in units of dollars per ton of
pollutant removed.

Table 1-2 summarizes the expected emission reductions by pollutant,
control measure and State.  The emission reductions listed in Table 1-2
are for 2009, and take into account only the incremental reductions from
the control measures listed in Table 1-1.  Figures 1-1 and 1-2 show the
anticipated emission reductions by state for VOC and NOx, respectively.

  Table 1-1 Summary of OTC 2006 Control Measures

Sector	Source Category	Control Measure	Implementation Method	Percent
Reduction from 2009 OTB/W Emission Levels	Cost Effectiveness

NOx	VOC	($/ton)

Area	Adhesives, Sealants, Adhesive Primers, and Sealant Primers
(Industrial)	Enact VOC content limits similar to those contained in the
CARB RACT/BARCT document for adhesives and sealants (Dec. 1998)	Model
Rule	---	64	VOC: 2,500

Area	Cutback and Emulsified Asphalt Paving	Prohibits the use of cutback
asphalt during the ozone season

Limits the use of emulsified asphalt during the ozone season to that
which contains not more than 0.5 mL of oil distillate from a 200 mL
sample as determined using ASTM Method D244 	State Rule Update	---	State
specific depending on current rules	VOC: minimal

Area	Consumer Products	Adopt the CARB 7/20/05 Amendments which sets new
or revises existing VOC limits on 12 consumer product categories (does
not include reductions for Tier2 shaving gels and antistatic aerosols
since they have a later compliance date). 	Model Rule 	---	2	VOC: 4,800

Area	Portable Fuel Containers	Adopt the CARB 2006 Amendments broadening
the definition of PFCs to include kerosene and diesel containers and
utility jugs used for fuel, and other changes to make OTC Model Rule
consistent with CARB requirements. 	Model Rule	---	State specific 	VOC:
800

to 1,400

Area

and

Point	Asphalt Production Plants	Area/Point Sources

  Batch Natural Gas 0.02 lb/ton or equivalent ppm

  Batch Distillate      0.09 lb/ton or equivalent ppm

  Drum Natural Gas 0.02 lb/ton or equivalent ppm

  Drum Distillate      0.04 lb/ton or equivalent ppm

   or

   Low NOx Burners, Best Management Practices	State Rule Update	10 - 35

	---

	NOx: <500 to 1,250

Area

and

Point	Industrial/

Commercial/

Institutional (ICI)

Boilers

>250 mmBtu/hour	Option 1 – Purchase current year NOx allowances equal
to reductions needed to achieve the required emission rates

Option 2 – Phase I 2009 emission rate equal to EGUs of similar size;
Phase II 2013 emission rate equal to EGUs of similar size 	Model Rule
Boiler and State specific	---	NOx: 600 to 18,000

Area

and

Point	ICI Boilers

100-250 mmBtu/hour	NOx Strategy #1:

     Nat gas: 0.10 lb/mmBtu

     #2, #4, #6 Oil: 0.20 lb/mmBtu

     Coal: 0.08 to 0.22 lb/mmBtu, depending on

         boiler type

NOx Strategy #2:

     Reductions achievable through

     LNB/SNCR, LNB/FGR, SCR or some

          combination of these controls

NOx Strategy #3:

     60% reduction from uncontrolled

NOx Strategy #4:

     Purchase current year CAIR allowances	State Rule Update	Boiler and
State specific	---	NOx: 600 to 18,000

Area

and

Point	ICI Boilers

25-100 mmBtu/hour	NOx Strategy #1:

     Nat gas: 0.05 lb/mmBtu

     #2 Oil: 0.08 lb/mmBtu

     #4, #6 Oil: 0.20 lb/mmBtu

     Coal: 0.30 lb/mmBtu

NOx Strategy #2:

     50% reduction from uncontrolled

NOx Strategy #3:

     Purchase current year CAIR allowances	State Rule Update	Boiler and
State specific	---	NOx: 600 to 18,000

Area

and

Point	ICI Boilers

<25 mmBtu/hour	Annual boiler tune-up	State Rule Update	State specific
---

	Point	Glass Furnaces	Require furnace operators to meet the emission
limits in the San Joaquin Valley rule by 2009.   These limits are
achievable through implementation of “oxyfiring” technology for each
furnace at furnace rebuild.  If the operator does not rebuild the
furnace by 2009 or implement measures to meet the limits in the San
Joaquin Valley rule, the operator would be required to purchase NOx
allowances equal to the difference between actual emissions and the
limits in the San Joaquin Valley rule. Compliance with Rule 4354 will
allow manufacturers to use a mix of control options to meet the
suggested limits. Manufacturers may propose alternative compliance
methods to meet the specified limits, including emissions averaging.
State Rule or Permit	Source specific	---	NOx: 1,254

to 2,500

Point	Cement Plants	Require existing kilns to meet a NOx emission rate
of

3.88 lbs/ton clinker for wet kiln

3.44 lbs/ton clinker for long dry kiln

2.36 lbs/ton clinker for pre-heater kiln

1.52 lbs/ton clinker for pre-calciner kiln	State Rule Update	Source
specific	---	NOx: <2,500

Onroad

Mobile	Diesel Truck Chip Reflash	Mandatory program to upgrade the
version of software in engine electronic control module (ECM), (also
known as “chip reflash) to reduce off-cycle NOx emissions.	Model Rule
10	---	NOx: 20-30

Onroad

Mobile	Regional Fuel based on Reformulated Gasoline Options	Extend RFG
requirements to counties in OTC that currently do not have RFG.
Memorandum of Understanding - OTC	State specific	State specific

	VOC: 5,200

NOx: 3,700

Table 1-2 Estimated Emission Benefits in 2009 by State

Resulting from the OTC 2006 Control Measures

	VOC Emission Reduction Benefit

(summer tpd)	NOx Emission Reduction Benefit

(summer tpd)

State	Adhesives & Sealants	Cutback\Emulsified Asphalt Paving	Consumer
Products	PFC (Area)a	PFCs (Nonroad)a	Regional Fuels	Total VOC Reduction
Diesel Engine

Chip Reflash	Regional Fuels	Asphalt Production	Cement Kilns
Glass/Fiberglassb	ICI Boilers

Area Sources	ICI Boilers

Point Sources	Total NOx Reduction

CT	4.2	4.3	0.7	0.4	0.1	0.0	9.7	3.5	0.0	0.0	0.0	0.0	2.8	2.1	8.4

DE	1.0	0.0	0.1	0.1	<0.1	0.0	1.4	0.6	0.0	0.2	0.0	0.0	1.2	0.1	2.1

DC	0.1	0.0	0.1	0.1	<0.1	0.0	0.4	0.8	0.0	0.0	0.0	0.0	0.4	0.4	1.6

ME	2.5	10.6	0.2	0.1	<0.1	9.1	22.6	1.4	0.2	0.7	0.0	0.0	1.1	2.8	6.2

MD	5.8	0.0	1.0	1.4	0.4	3.2	11.8	5.6	0.0	0.1	13.1	0.3	1.2	2.4	22.7

MAd	8.9	8.1	10.2	1.7	0.5	0.0	29.3	6.7	0.0	0.6	0.0	1.5	6.6	6.8	22.2

NH	2.3	4.4	0.3	0.2	0.1	4.3	11.5	2.0	0.2	0.0	0.0	0.0	3.4	1.9	7.5

NJ	9.2	4.7	1.4	1.0	0.3	0.0	16.7	9.7	0.0	1.0	0.0	4.9	0.0	3.4	19.0

NY	21.5	16.4	3.7	2.6	0.8	56.9	101.9	16.1	2.1	0.0	15.3	5.8	33.8	7.0	80.1

PA	21.9	8.4	2.1	1.6	0.5	58.0	92.3	12.4	2.0	0.2	14.0	24.3	12.2	9.8	73.9

RI	1.5	1.1	0.2	0.2	<0.1	0.0	3.0	0.8	0.0	0.0	0.0	0.5	2.1	0.5	3.9

VT	2.2	1.8	0.1	0.1	<0.1	7.9	12.1	0.9	0.3	0.0	0.0	0.0	0.9	0.4	2.5

No. VAc	1.0	<0.1	0.5	0.4	0.1	0.0	1.9	2.5	0.0	0.1	0.0	0.0	3.9	0.1	6.6

OTR	82.3	59.8	20.5	9.9	3.0	139.4	314.8	63.0	4.8	3.0	42.5	37.3	69.5	37.7
257.8

The table shows the estimated emission reduction that will occur in
2009; additional reductions will occur in later years as new,
less-emitting PFCs that comply with the OTC 2006 control measure
penetrate the market.

The table show the maximum emission reduction from glass/fiberglass
furnaces when the OTC 2206 control measure is fully implemented.  No all
of the reduction shown will be achieved by 2009.

The following jurisdictions in Virginia are part of the OTR:  Arlington
County, Alexandria, Fairfax County, Fairfax City, Fall Church, Loudon
County, Manassas City, Manassas Park, and Prince William County.

MA proposed rule has a January 1, 2009 effective date and includes the
VOC limits from the OTC 2001 model rule and those in the OTC 2006 model
rule.  The 2009 benefit MA shows the benefit from both sets of limits.
For all other States, the 2009 benefit shows the change in emissions
from the OTC 2006 model rule only.

Figure 1-1 VOC Emission Reduction Benefits from OTC 2006 Control
Measures in 2009

Figure 1-2 NOx Emission Reduction Benefits from OTC 2006 Control
Measures in 2009

INTRODUCTION

The Ozone Transport Commission (OTC) is a multi-state organization
created under the Clean Air Act (CAA).  The OTC is responsible for
advising EPA on transport issues and for developing and implementing
regional solutions to the ground-level ozone problem in the Northeast
and Mid-Atlantic regions.  To supplement local and state-level efforts
to reduce ozone precursor emissions, which may not alone be sufficient
to attain federal standards, the OTC member states are considering
control measures appropriate for adoption by all states in the region as
part of their planning to attain and maintain the 8-hour ozone National
Ambient Air Quality Standards (NAAQS).

The development of the control measures described in this document
parallels a prior effort.  The OTC developed a series of model rules in
2001 for the States to consider in adopting control measures to reduce
volatile organic compound (VOC) emissions and oxide of nitrogen (NOx),
which are ozone precursors, to (1) assist in the attainment of the
one-hour ozone health standard, (2) address the VOC and NOx emission
reduction shortfalls identified by EPA, and (3) implement the State
Implementation Plans (SIP) commitments to EPA.  These model rules, which
have been adopted in many OTC states, will be referred to as the “OTC
2001 model rules” in this document.

The analysis in this report provides a description of the control
measures identified by the OTC to help states attain the 8-hour ozone
NAAQS.  It also describes the associated incremental emission reductions
and costs associated with each measure.  The control measures analyzed
in this report are those that were identified by the OTC Commissioners
at the June 2006 OTC annual meeting in Boston (OTC 2006a, OTC 2006b, OTC
2006c) and at the November 2006 OTC fall meeting in Richmond (OTC 2006d,
OTC 2006e, OTC 2006f).  These control measures will be referred to as
the “OTC 2006 control measures” in this document.  For some source
categories, the OTC has amended the OTC 2001 model rules or developed
new model rules.  These model rules will be referred to as the “OTC
2006 model rules” in this document.

The OTC 2006 model rules for volatile organic compounds (VOC) will
reduce emissions from adhesives, sealants, adhesive primer, and sealant
primer application; cutback and emulsified asphalt paving; consumer
products; regional fuels; and portable fuel containers.  The OTC 2006
control measures for oxides of nitrogen (NOx) will reduce emissions from
asphalt production plants, cement kilns, diesel engine chip reflash,
regional fuels, electric generating units (EGUs), glass and fiberglass
furnaces, and industrial, commercial, institutional (ICI) boilers.

Section 3 describes the methods used to estimate the emission benefits
of the VOC control measures.  For each source category, there are
subsections that describe the existing Federal and OTC State regulations
that affect the VOC emissions, summarize the major elements of the
control measures, discuss how the emission benefits were quantified, and
present information on anticipated costs and cost-effectiveness.  VOC
emissions and reductions by State and source category in 2002 and 2009
are presented at the end of Section 3.  Section 4 presents similar
information for the NOx source categories.  Section 5 presents similar
information for the SO2 source categories.  Section 6 provides a list of
references used in developing this report.

Appendix A presents a brief description of the process that the OTC
followed in identifying and evaluating candidate control measures.
Appendix B lists the approximately 1,000 control measures that were
initially analyzed.  Appendix C contains the control measure summary
sheets that were developed during this analysis.  Appendices D, E, and F
present the emission benefits by county for VOC, NOx, and SO2
respectively.  Each appendix contains a tabulation of the 2002 base
emissions, the projected 2009/2012/2018 emissions and expected emission
reduction benefit from the additional control measures in
2009/2012/2018).  Appendix G contains a listing of State ICI boiler
regulations.

VOC ANALYSIS METHODS

This Section describes the analysis of the 2006 OTC control measures to
reduce VOC emissions from five source categories:  adhesives, sealants,
adhesive primer, and sealant primer application; cutback and emulsified
asphalt paving; consumer products; regional fuels; and portable fuel
containers.  For each of the five categories, there are separate
subsections that discuss existing Federal/state rules, summarize the
requirements of the 2006 OTC control measure, describe the methods used
to quantify the emission benefit, and provide an estimate of the
anticipated costs and cost-effectiveness of the control measure.  At the
end of Section 3, we provide the estimated emissions for 2002 and 2009
by source category and State.  Appendix D provides county-by-county
summaries of the emission reductions for each of the categories and
projection years.

ADHESIVES, SEALANT, ADHESIVE PRIMER, AND SEALANT PRIMER APPLICATION

Adhesives, sealants, adhesive primer, and sealant primer are used in
product manufacturing, packaging, construction, and installation of
metal, wood, rubber, plastic, ceramics, or fiberglass materials.  In
general, an adhesive is any material used to bond two surfaces together.
 In general, a sealant is a material with adhesive properties that is
used primarily to fill, seal, waterproof or weatherproof gaps or joints
between two surfaces.

VOC emissions from this category result from evaporation of solvents
during transfer, drying, surface preparation and cleanup operations.
These solvents are the media used to solubilize the adhesive, sealant,
or primer material so that it can be applied. The solvent is also used
to completely wet the surface to provide a stronger bond.  In plastic
pipe bonding, the solvent dissolves the polyvinyl chloride pipe and
reacts with the pipe to form a bond. Solvents used to clean the surface
before bonding and to clean the application equipment after bonding also
contribute to VOC emissions.

VOC emissions in this category are primarily from industrial and
commercial operations such as wood product manufacturers, upholstery
shops, adhesives retailers and architectural trades, such as building
construction, floor covering installation and roof repair.

Existing Federal and State Rules

EPA published the consumer and commercial products rule on September 11,
1998 (40 CFR Part 59 Subpart D) under authority of Section 183(e) of the
Clean Air Act.  The Federal Part 59 Subpart C requirements for consumer
products regulate five types of “household” adhesives (aerosols,
contact, construction and panel, general purpose and structural
waterproof).  The VOC content limits for these products apply only to
“household products”, defined as “any consumer product that is
primarily designed to be used inside or outside of living quarters or
residences, including the immediate surroundings, that are occupied or
intended for occupation by individuals.”  Thus, the Part 59 rule
applies only to adhesives used in household settings and not to
adhesives used in industrial or commercial applications.

The OTC developed a model rule for consumer and commercial products in
2001 (referred to as the “OTC 2001 model rule for consumer products”
in this document) to regulate additional consumer product categories by
requiring more stringent VOC content limits than the Federal rule.  The
OTC 2001 model rule for consumer products contains VOC limits for
adhesives and sealants.  However, with the exception of aerosol
adhesives, the definitions of these products generally exempt products
sold in larger containers.  Specifically, the OTC 2001 model rule
includes the following definitions (italics added for emphasis):

Section 2(8) Adhesive.   "Adhesive" means any product that is used to
bond one surface to another by attachment. “Adhesive” does not
include products used on humans and animals, adhesive tape, contact
paper, wallpaper, shelf liners, or any other product with an adhesive
incorporated onto or in an inert substrate. For “Contact Adhesive,”
adhesive does not include units of product, less packaging, which
consist of more than one gallon. For “Construction, Panel, and Floor
Covering Adhesive,” and “General Purpose Adhesive”, adhesive does
not include units of product, less packaging, which weigh more than one
pound and consist of more than 16 fluid ounces. This limitation does not
apply to aerosol adhesives.

Section 2(148)  Sealant and Caulking Compound.  "Sealant and Caulking
Compound" means any product with adhesive properties that is designed to
fill, seal, waterproof, or weatherproof gaps or joints between two
surfaces. “Sealant and Caulking Compound” does not include roof
cements and roof sealants; insulating foams; removable caulking
compounds; clear/paintable/water resistant caulking compounds; floor
seam sealers; products designed exclusively for automotive uses; or
sealers that are applied as continuous coatings. “Sealant and Caulking
Compound” also does not include units of product, less packaging,
which weigh more than one pound and consist of more than 16 fluid
ounces. For the purposes of this definition only, “removable caulking
compounds” means a compound which temporarily seals windows or doors
for three to six month time intervals, and “clear/paintable/water
resistant caulking compounds” means a compound which contains no
appreciable level of opaque fillers or pigments; transmits most or all
visible light through the caulk when cured; is paintable; and is
immediately resistant to precipitation upon application.

Thus, the same products sold in containers larger than the above
thresholds are not covered by the OTC 2001 model rule for consumer
products.

Description of the OTC 2006 Model Rule

The OTC 2006 model rule for adhesives and sealants is based on the
reasonably available control technology (RACT) and best available
retrofit control technology (BARCT) determination by the California Air
Resources Board (CARB) developed in 1998.  The OTC 2006 model rule has
the following requirements:

Regulates the application of adhesives, sealants, adhesive primers and
sealant primers by providing options for appliers to either to use a
product with a VOC content equal to or less than a specified limit or to
use add-on controls;

Limits the VOC content of aerosol adhesives to 25 percent by weight;

Requirements for cleanup solvents;

A VOC limit for surface preparation solvents;

An alternative add-on control system requirement of at least 85 percent
overall control efficiency (capture and destruction efficiency), by
weight;

VOC containing materials must be stored or disposed of in closed
containers;

Prohibits the sale of any adhesive, sealant, adhesive primer or sealant
primer which exceeds the VOC content limits listed in the model rule;

Manufacturers must label containers with the maximum VOC content as
supplied, as well as the maximum VOC content on an as-applied basis when
used in accordance with the manufacturer’s recommendations regarding
thinning, reducing, or mixing with any other VOC containing material;
and

Prohibits the specification of any adhesive, primer, or sealant that
violates the provisions of the model rule.

Several adhesive and sealant applications and products are exempt from
this model rule: tire repair, assembly and manufacturing of
undersea-based weapon systems, testing and evaluation associated with
research and development, solvent welding operations for medical
devices, plaque laminating operations, products or processes subject to
other state rules, low-VOC products (less than 20 g/l), and adhesives
subject to the state rules based on the OTC 2001 consumer products model
rule.  Additionally, the model rule provides an exemption for adhesive
application operations at stationary sources that use less than 55
gallons per calendar year of noncomplying adhesives and for stationary
sources that emit not more than 200 pounds of VOCs per year from
adhesives operations.

Emission Benefit Analysis Methods

Emissions from this category are classified as both point sources and
area sources.  About 96 percent of adhesive and sealant VOC emissions in
the OTC states fall into the area source category.  The remaining four
percent of the VOC emissions are included in the point source inventory.

The emission reduction benefit estimation methodology for area sources
is based on information developed and used by CARB for their RACT/BARCT
determination in 1998.  CARB estimates that the total industrial
adhesive and sealant emissions in California to be about 45 tons per day
(tpd).  Solvent-based emissions are estimated to be about 35 tpd of VOC
and water-based adhesive and sealant emissions are about 10 tpd of VOC.
CARB indicated that the emission reductions would be achieved mainly due
to the switch from high-VOC to low-VOC products rather than from the use
of add-on control devices.  CARB estimated that emission reductions
achieved by statewide compliance with the VOC limits in the RACT/BARCT
determination will range from approximately 29 to 35 tpd (CARB 1998, pg.
18).  These emission reductions correspond to a 64.4 to 77.8 percent
reduction from uncontrolled levels.  For OTC modeling purposes, we used
the lower end of this range (i.e., 64.4 percent reduction) to estimate
the emission benefit for area sources due to the OTC 2006 model rule.

For point sources, we first identified those sources that were applying
adhesives and sealants (using the source classification code of
4-02-007-xx, adhesives application).  Next, we reviewed the MANEVU
inventory to determine whether sources had existing capture and control
systems.  Several sources reported capture and destruction efficiencies
in the 70 to 99 percent range.  A few sources reported capture and
destruction efficiencies of 99+ percent.  Most of the controlled sources
reported capture and destruction efficiencies in the 90-98 percent
range.  Sources with existing control systems that exceed an 85 percent
overall capture and destruction efficiency would meet the OTC 2006 model
rule provision for add-on air pollution control equipment; no additional
reductions were calculated for these sources.  For point sources without
add-on control equipment, we used the 64.4 percent reduction discussed
in the previous paragraph based on the CARB determination.

Cost Estimates

The cost of complying with the new requirements includes the cost of
using alternative formulations of low-VOC or water-based adhesives,
sealants, adhesive primers, and sealant primers and cleanup products.
Based on information provided by the Ventura County Air Pollution
Control District, CARB determined that the cost-effectiveness of their
adhesives rule ranges from a savings of $1,060 per ton to a cost of
$2,320 per ton of VOC reduced (CARB 1998, pg. 17).  These costs are
likely to be less in the OTR, because some of the one-time research and
reformulation costs incurred for products sold in California will not
have to be incurred again for products sold in the OTR.  CARB also
reports a cost-effectiveness of $9,000 to $110,000 per ton of VOC
reduced for the use of add-on control equipment to comply with the
requirements.

CUTBACK AND EMULSIFIED ASPHALT PAVING

Asphalt paving is used to pave, seal and repair surfaces such as roads,
parking lots, drives, walkways and airport runways.  Asphalt paving is
grouped into three general categories: hot-mix, cutback, and emulsified.
 Hot-mix asphalt is the most commonly used paving asphalt.  Hot-mix
asphalt produces minimal VOC emissions because its organic components
have high molecular weights and low vapor pressures.  Cutback asphalt is
used in tack and seal operations, in priming roadbeds for hot-mix
application and for paving operations for pavements up to several inches
thick.  In preparing cutback asphalt, asphalt cement is blended or
“cut back” with a diluent, typically from 25 to 45 percent by volume
of petroleum distillates, depending on the desired viscosity.
Emulsified asphalt is used in most of the same applications as cutback
asphalt but is a lower emitting alternative to cutback asphalt.  Instead
of blending asphalt cement with petroleum distillates, emulsified
asphalts use a blend of asphalt cement, water and an emulsifying agent,
such as soap.  Some emulsified asphalts contain virtually no VOC
diluents; however, some emulsified asphalts may contain up to 12 percent
VOC by volume.

Existing Federal and State Rules

The EPA published a Control Technique Guideline (CTG) for the use of
cutback asphalt in December 1977.  The CTG recommended replacing cutback
asphalt binders with emulsified asphalt during the ozone season.  In
1979, EPA added a specification for emulsified asphalt to the CTG
recommendations to limit the content of oil distillate in emulsified
asphalt to no higher than 7 percent oil distillate.

Table 3-1 summarizes the current asphalt paving rules for the 13 OTR
states.  Most of the states in the OTR have adopted the CTG banning
cutback asphalt in the ozone season.  Some states have exemptions to
this rule, allowing the use of cutback asphalt with up to 5 percent VOC.
 For emulsified asphalt, the requirements vary greatly.  The VOC content
of emulsified asphalt is limited to 0-12 percent, depending on the State
and the type of emulsified asphalt.  Delaware completely bans the use of
emulsified asphalt that contains any VOC.

Table 3-1 Summary of OTC State Rules for Cutback and Emulsified Asphalt

State	Cutback Asphalt	Emulsified Asphalt

CT	22a-174-20 (k): VOC content limited to 5% during June, July, August,
and September	Nothing specified

DE	Reg. No. 24, Section 34:  Ban during ozone season	Reg. No. 24,
Section 34:  Ban on use of emulsified asphalt that contains any VOC

DC	Chapter 7 Section 8-2:707(k): Ban during the months of April, May,
June, July, August, and September	Nothing specified

ME	Chapter 131: Ban during the period May 1 through September 15, with
some exceptions	Chapter 131: VOC content limited to 3-12%, depending on
the type of use

MD	COMAR <IP_ADDRESS>:  Ban during the period April 16 through October 14
COMAR <IP_ADDRESS>: Allowed upon approval of the Department; no VOC
content limit specified

MA	310 CMR 7.18(9): Ozone season ban on cutback asphalt with VOC content
greater than 5% by weight with exemptions including use as prime coat
Nothing Specified

NH	Env-A 1204.42: Ban during the months of June through September;
cutback with up to 5% VOC allowed upon approval of Department	Env-A
1204.42: VOC content limited to 3-12%, depending on the type of use

NJ	7:27-16.19: Ban from April 16 through October 14, with some
exemptions	7:27-16.19: VOC content limited to 8% by volume

NY	Part 211:  Ban from May 2 through October 15	Part 211: VOC content
limited to 2-12%, depending on the type of ASTM grade

PA	25 Pa. Code Section 129.64: Ban from May 1 to October 30	25 Pa. Code
Section 129.64: VOC content limited to 0-12%, depending on type

RI	Reg. No. 25: Ban from April 1 to September 30, with some exemptions
Reg No. 25: VOC content limited to 3-12%, depending on application/use

VT	5-253.15: Ban on cutback asphalt with VOC content greater than 5% by
weight, with some exemptions	5-253.15: Ban on emulsified asphalt with
VOC content greater than 5% by weight

VA	Chapter 40, Article 39: Ban during April through October	Chapter 40,
Article 39: VOC content limited to 6% by volume

Description of the OTC 2006 Model Rule

The OTC 2006 model rule for the asphalt paving control measure prohibits
the use of cutback asphalt during the ozone season and limits the use of
emulsified asphalt to that which contains not more than 0.5 mL of oil
distillate from a 200 mL sample (as determined using American Society
for Testing and Materials {ASTM} Method D244 - Test Methods for
Emulsified Asphalts) regardless of application.  This is equivalent to a
VOC content of 0.25 percent.  Exemptions may be granted under certain
circumstances upon the approval of the State commissioner.

Emission Benefit Analysis Methods

The OTC 2006 control measure for asphalt paving calls for a complete ban
on the use of cutback asphalt during the ozone season.  As shown in
Table 3-1, current state regulations generally ban the use of cutback
asphalt during the ozone season.  However, there are exemptions from the
ban and as a result there are VOC emissions from the use of cutback
asphalt during the ozone season.   The OTC 2006 control measure
eliminates any exemptions and totally eliminates any VOC emissions from
the use of cutback asphalt during the ozone season.

The emission reductions resulting from OTC 2006 control measure for
emulsified asphalt vary by State.  The two percent VOC content limit on
emulsified asphalt depend on the baseline VOC content of emulsified
asphalt.  The control measure limits emulsified asphalt to not more than
0.5 mL of oil distillate from a 200 mL sample as determined using ASTM
Method D244.  This is equivalent to a VOC content of 0.25 percent.  The
baseline VOC content may range from 0 to 12 percent.  New Jersey used a
VOC content of 8 percent in their baseline emission calculations (based
on the 8 percent limit in their current rule).  Reducing the VOC content
to 0.25 percent in New Jersey will result in a 96.9 percent reduction.
Delaware already bans the use of emulsified asphalt that contains any
VOC, so there is no reduction in Delaware.  Several other states used an
average VOC content of 2.5 percent when developing their emission
inventory.  Thus, reducing the average VOC content from 2.5 percent to
0.25 percent results in a 90 percent reduction in VOC emissions.  For
States that did not supply a baseline VOC content for asphalt paving, we
used the 90 percent reduction in VOC emissions from emulsified asphalt
paving during the ozone season.

Cost Estimates

Low-VOC alternatives are currently available and no additional costs are
expected from their use.

CONSUMER PRODUCTS

Consumer and commercial products are those items sold to retail
customers for personal, household, or automotive use, along with the
products marketed by wholesale distributors for use in commercial or
institutional settings such as beauty shops, schools and hospitals.  VOC
emissions from these products are the result of the evaporation of
propellant and organic solvents during use.  Consumer and commercial
products include hundreds of individual products, including personal
care products, household products, automotive aftermarket products,
adhesives and sealants, FIFRA-related insecticides, and other
miscellaneous products.

Existing Federal and State Rules

EPA published the Federal consumer and commercial products rule on
September 11, 1998 (40 CFR Part 59 Subpart D) under authority of Section
183(e) of the Clean Air Act.  This rule limits the VOC content of 24
product categories representing 48 percent of the consumer and
commercial products inventory nationwide.  According to EPA, VOC
emissions from those 24 product categories were reduced by 20 percent.
But since over half of the inventory is unaffected by the rule, the
Federal rule is estimated to yield VOC reductions of 9.95 percent of the
total consumer products inventory (Pechan 2001, pg 7).

Since over half of the inventory is unregulated by the Federal Part 59
rule, the OTC developed a model rule for consumer and commercial
products in 2001 (referred to as the “OTC 2001 model rule for consumer
products” in this document) to be used by the OTC jurisdictions to
develop regulations for additional consumer product categories and to
specify more stringent VOC content limits than the Federal rule.  The
VOC content limits and products covered in the OTC 2001 model rule are
similar to the rules developed by CARB in the late 1990s.  The OTC 2001
model rule for consumer products provides background for OTC
jurisdictions to develop programs to regulate approximately 80 consumer
product categories and includes technologically feasible VOC content
limits.  The emission reductions for state programs based on the OTC
2001 model rule are estimated to be 14.2 percent of the total consumer
product inventory beyond the national rule reduction (Pechan 2001, pg.
8).

Most, but not all, states in the OTR have adopted regulatory programs
based on the OTC 2001 model rule for consumer products.  Table 3-2
summarizes the adoption status for the 13 OTR jurisdictions.

Table 3-2 Status of OTC State’s Promulgation

of the OTC 2001 Model Rule for Consumer Products.

State	Effective Date of VOC Limits	Regulatory Citation

CT a	Initiated process to adopt in 2006	R.C.S.A. section 22a-174-40

DE	Effective January 1, 2005	Regulation Number 41

DC	Effective June 30, 2004	Regulation 719

ME	Effective May 1, 2005	Chapter 152

MD	Effective January 1, 2005	COMAR 26.11.32

MA b	In progress – proposed effective date is January, 2009	310 CMR
7.25(12)

NH	Effective January 1, 2007	Chapter Env-A 4100

NJ	Effective Janaury 1, 2005	Chapter 27, Subchapter 24

NY	Effective January 1, 2005	Chapter 3, Part 235

PA	Effective January 1, 2005	25 Pa. Code Chapter 130, Subchapter B

RI	Intend to develop in 2006	n/a

VT	Under Consideration	n/a

VA c	Effective July 1, 2005	Chapter 40, Article 50

a) Connecticut’s proposed rule includes both the VOC limits from the
OTC 2001 model rule and the new and revised VOC emissions limits and
related provisions that were adopted by the California Air Resources
Board on July 20, 2005.  These new and revised VOC limits are identical
to those in the OTC 2006 model rule.

b) Massachusett’s proposed rule includes the VOC limits from the OTC
2001 model rule and those in the OTC 2006 model rule.

c) Virginia’s rule applies only in Northern Virginia VOC Emission
Control Area (10 northern Virginia jurisdictions in the OTR)

Description of the OTC 2006 Model Rule

The OTC 2001 model rule for consumer products closely mirrored a series
of five CARB consumer products rules.  CARB recently amended their
consumer products rules in July 2005.  As shown in Table 3-3, these
amendments to the CARB rule affected 18 categories of consumer products
(14 new categories, including subcategories, with new product category
definitions and VOC limits; one previously regulated category with a
more restrictive VOC limit; and two previously regulated categories with
additional requirements).

Table 3-3 Consumer Products Affected by CARB’s July 2005 Rule
Amendments

New Categories with VOC Limits for Regulation

Adhesive Remover

– 4 subcategories

Anti-Static Product

Electrical Cleaner

Electronic Cleaner

Fabric Refresher	Footwear or Leather Care Product

Hair Styling Producta

Graffiti Remover

Shaving Gel

Toilet/Urinal Care Product

Wood Cleaner

Previously Regulated Category with More Restrictive Limit

Contact Adhesiveb

Previously Regulated Categories with Additional Requirements

Air Fresheners 	General Purpose Degreasers

a) This product category will incorporate Hair Styling Gel and include
additional forms of hair styling products (i.e., liquid, semi-solid, and
pump spray) but does not include Hair Spray Product or Hair Mousse.

b) This product category has been separated into 2 subcategories:
General Purpose and Special Purpose

Most of these new CARB limits become effective in California by December
31, 2006.  Two of the limits, anti-static products (aerosol) and shaving
gels, have effective dates in either 2008 or 2009.  For shaving gels,
there is a VOC limit that becomes effective on December 31, 2006, with a
more stringent second tier limit that becomes effective on December 31,
2009.  The anti-static product (aerosol) limit becomes effective on
December 31, 2008.

The OTC 2006 model rule will modify the OTC 2001 model rule based on the
CARB July 20, 2005 amendments.  The OTC is not including the anti-static
aerosol products and the second tier shaving gel limit in its revisions
to the OTC 2001 model rule because of industry concerns that meeting
these limits may not be feasible.  CARB acknowledged these concerns by
requiring a technology review of these product categories in 2008 to
determine whether the limits are achievable.

Emission Benefit Analysis Methods

The emission reduction benefit estimation methodology is based on
information developed by CARB.  CARB estimates 6.05 tons per day of VOC
reduced in California from their July 2005 amendments (CARB 2004a, pg.
8), excluding the benefits from the two products (anti-static products
and shaving gels) with compliance dates in 2008 or 2009.  This equates
to about 2,208 tons per year in California.  The population of
California as of July 1, 2005 is 36,132,147 (Census 2006).  On a per
capita basis, the emission reduction from the CARB July 2005 amendments
equals 0.122 lbs/capita.

Since the OTC’s 2006 control measure is very similar to the CARB July
2005 amendments (with the exclusion of the anti-static products and
shaving gel 2008/2009 limits), the per capita emission reductions are
expected to be the same in the OTR.  The per capita factor after the
implementation of the OTC 2001 model rule is 6.06 lbs/capita (Pechan
2001, pg. 8).  The percentage reduction from the OTC’s 2006 control
measure was computed as shown below:

Current OTC Emission Factor	=	6.06 lbs/capita

Benefit from CARB 2005 amendments	=	0.122 lbs/capita

Percent Reduction	=

=	100%*(1 - (6.06 – 0.122)/6.06)

2.0%

Cost Estimates

CARB estimates that the cost effectiveness of VOC limits with an
effective date of December 31, 2006, to be about $4000 per ton of VOC
reduced (CARB 2004, pg. 21).  CARB further estimates that the average
increase in cost per unit to the manufacturer to be about $0.16 per
unit.  Assuming CARB’s estimates for the OTR provides a conservative
estimate, because some of the one-time research and reformulation costs
incurred for products sold in California will not have to be incurred
again for products sold in the OTR.

PORTABLE FUEL CONTAINERS

Portable fuel containers (PFCs) are designed for transporting and
storing fuel from a retail distribution point to a point of use and the
eventual dispensing of the fuel into equipment.  Commonly referred to as
“gas cans,” these products come in a variety of shapes and sizes
with nominal capacities ranging in size from less than one gallon to
over six gallons.  Available in metal or plastic, these products are
widely used to refuel residential and commercial equipment and vehicles
when the situation or circumstances prohibits direct refueling at a
service station.  PFCs are used to refuel a broad range of small
off-road engines and other equipment (e.g., lawnmowers, chainsaws,
personal watercraft, motorcycles, etc.).  VOC emissions from PFCs are
classified by five different activities:

Transport-spillage emissions from PFCs occur when fuel escapes from PFCs
that are in transit.

Diurnal emissions result when stored fuel vapors escape to the air
through any possible openings while the container is subjected to the
daily cycle of increasing and decreasing ambient temperatures.  Diurnal
emissions depend on the closed- or open- storage condition of the PFC.

Permeation emissions are produced after fuel has been stored long enough
in a container for fuel molecules to infiltrate and saturate the
container material, allowing vapors to escape through the walls of
containers made from plastic.

Equipment refueling vapor displacement and spillage emissions result
when fuel vapor is displaced from nonroad equipment (e.g., lawnmowers,
chainsaws, personal watercraft, motorcycles, etc.) and from gasoline
spillage during refueling of the equipment with PFCs.  These VOC
emissions are already taken into account in the nonroad equipment
emission inventory by the NONROAD model.

Diurnal evaporative emissions are the largest category.

Existing Federal and State Rules

The OTC developed a model rule for PFCs in 2001.  The OTC 2001 model
rule was very similar to a rule adopted by CARB in 2000.  The OTC 2001
model rule provides background for OTC jurisdictions to develop
regulatory programs that require spill-proof containers to meet
performance standards that reduce VOC emissions.  The performance
standards include a requirement that all PFCs to have an automatic
shut-off feature preventing overfilling and an automatic closing feature
so the can will be sealed when it is not being used.  The performance
standards also eliminate secondary venting holes and require new
plastics to reduce vapor permeation through container walls.  There is
no requirement for owners of conventional PFCs to modify their PFCs or
to scrap them and buy new ones.  Compliance will be accomplished
primarily through attrition.  As containers wear out, are lost, damaged,
or destroyed, consumers will purchase new spill-proof containers to
replace the conventional containers.  CARB determined that the average
useful life of a PFC is five years.  The OTC chose to assume a more
conservative ten-year turnover rate, with 100 percent rule penetration
occurring 10 years after adoption of the rule.

CARB estimated that the performance standards would reduce VOC emissions
by 75 percent.  CARB’s 2004 analysis (CARB 2004b) reevaluated the
estimate reductions due to some unforeseen issues with the new cans and
new survey information.  Based on CARB’s updated data, CARB estimated
that VOC emissions would be reduced by 65 percent from the first set of
amendments.

CARB has also adopted a second set of amendments in two phases.  The
first phase was filed on January 13, 2006, effective February 12, 2006.
For Phase I, CARM amended their PFC regulation to address the use of
utility jugs and kerosene containers that are sometimes used by
consumers for gasoline.  The second phase of the amendments was filed on
September 11, 2006, effective October 11, 2006.  These amendments (CARB
2006) will:

Establish a mandatory certification program and accompanying test
procedures;

Amend the existing performance standards to eliminate the automatic
shutoff performance standard effective July 1, 2007;

Amend the existing performance standards to eliminate the fill height
and flow rate performance standards;

Amend the existing PFC pressure standard;

Amend the current test methods;

Change the permeability standard from 0.4 to 0.3 grams/gallon-day;

Establish a voluntary consumer acceptance-labeling program that allows
participating manufacturers to label their PFCs with an ARB “Star
Rating” indicating how consumers rate their products’ ease of use;
and

Combine the currently separate evaporation requirement and permeation
standard and test method into a single diurnal standard and test method.

In February 2007, EPA finalized a national regulation to reduce
hazardous air pollutant emissions from mobile sources.  Included in the
final rule are standards that would reduce PFC emissions from
evaporation, permeation, and spillage.  EPA included a performance-based
standard of 0.3 grams per gallon per day of hydrocarbons, determined
based on the emissions from the can over a diurnal test cycle specified
in the rule.  The standard applies to containers manufactured on or
after January 1, 2009.  The standards are based on the performance of
best available control technologies, such as durable permeation
barriers, automatically closing spouts, and cans that are well-sealed.

Description of the OTC 2006 Model Rule

As shown in Table 3-4, most states in the OTR have already adopted PFC
regulations based on the OTC 2001 model rule.  The OTC 2001 model rule
for PFCs closely mirrors the 2000 version of CARB’s PFC rule.  CARB
recently amended their gas can regulation as discussed above in Section
3.4.1.  The OTC 2006 model rule closely mirrors these CARB amendments.
The 2006 amendments are estimated to reduce VOC emissions by 18.4 tons
per day in California at full implementation in the year 2015, in
addition to the benefits from the existing regulation.  The OTC 2006
model rule will modify the OTC 2001 model rule based on the recent CARB
amendments.

Table 3-4 Status of OTC State’s Promulgation

of the OTC 2001 Model Rule for Portable Fuel Containers

State	Date When New Containers are Required	Regulatory Citation

CT	Effective May 1, 2004	Section 22a-174-43

DE	Effective January 1, 2004	Reg. No. 41, Section 3

DC	Effective November 15, 2003	Rule 720

ME	Effective January 1, 2004	Chapter 155

MD	Effective January 1, 2003	COMAR <IP_ADDRESS>

MAa	In progress (effective date will be January 1, 2009)	n/a

NH	Effective March 1, 2006	Env-A 4000

NJ	Effective January 1, 2005	Subchapter 24 (7:27-24.8)

NY	Effective January 1, 2003	Part 239

PA	Effective January 1, 2003	25 Pa. Code Chapter 130, Subchapter A

RI	In progress (late 2006 target date for final rule)	n/a

VT	Under Consideration	n/a

VAb	Effective January 1, 2005	Chapter 40, Article 42

a) Massachusetts’ proposed rule will be based only on the OTC 2006
model rule; Massachessetts will not adopt the OTC 2001 model rule.

b) Virginia’s rule applies only in Northern Virginia VOC Emission
Control Area (10 northern Virginia jurisdictions in the OTR)

Emission Benefit Analysis Methods

Emissions from PFCs are accounted for in both the area and nonroad
source inventories.   The NONROAD model accounts for equipment refueling
vapor displacement and spillage emissions result when fuel vapor is
displaced from nonroad equipment (e.g., lawnmowers, chainsaws, personal
watercraft, motorcycles, etc.) and from gasoline spillage during
refueling of the equipment with PFCs.  The area source inventory
accounts for diurnal and permeation emissions associated with the fuel
present in stored PFCs and transport-spillage emissions associated with
refueling of a gas can at the gasoline pump.  Based on the OTC 2001
model rule (Pechan 2001, pg. 11) roughly 70 percent of the VOC emissions
are accounted for in the area source inventory, while the remaining 30
percent is from equipment refueling vapor displacement and spillage that
is accounted for in the nonroad inventory.

The emission benefits have been calculated for the emissions accounted
for in both the area and nonroad source inventory.  Emissions from the
nonroad category were estimated to be 30 percent of the PFC emissions
accounted for in the area source inventory.

Also note that the OTC baseline emissions (i.e., 2002 emissions) do not
include changes to the emission estimation methodology made by CARB in
2004. CARB conducted a new survey of PFCs in 2004, which included
kerosene containers and utility jugs.  Using this survey data, CARB
adjusted their baseline emissions; a similar adjustment to the OTC
baseline inventory has not been made.

Estimated emission reductions were based on information compiled by CARB
to support their recent amendments.  CARB estimated that PFC emissions
in 2015 will be 31.9 tpd in California with no additional controls or
amendments to the 2000 PFC rules (CARB 2005a, pg. 10).  CARB further
estimates that the 2006 amendment will reduce emission from PFCs by 18.4
tpd in 2015 in California compared to the 2000 PFC regulations (CARB
2005a, pg. 23).  Thus, at full implementation, the expected incremental
reduction is approximately 58 percent, after an estimated 65 percent
reduction from the original 2000 rule.

The OTC calculations assume that States will adopt the rule by July 2007
(except in Massachusetts) and provide manufacturers one year from the
date of the rule to comply.  Thus, new compliant PFCs will not be on the
market until July 2008.  Assuming a 10-year turnover to compliant cans,
only 10 percent of the existing inventory of PFCs will comply with the
new requirements in the summer of 2009.  Therefore, only 10 percent of
the full emission benefit estimated by CARB will occur by 2009 – the
incremental reduction will be 5.8 percent in 2009.

Cost Estimates

CARB estimates that the cost-effectiveness of the 2005/2006 amendments
will range from $0.40 to $0.70 per pound of VOC reduced, or $800 to
$1,400 per ton of VOC reduced (CARB 2005a, pg. 27).  Assuming CARBs
costs for the OTR provides a conservative estimate, because some of the
one-time research and reformulation costs incurred for products sold in
California will not have to be incurred again for products sold in the
OTR.

REGIONAL FUELS

The Clean Air Act Amendments of 1990 required significant changes to
conventional fuels used by motor vehicles.  Beginning in 1995,
“reformulated” gasoline must be sold in certain non-attainment areas
and other states with non-attainment areas are permitted to opt-in.
Reformulated gasoline results in lower VOC emissions than would occur
from the use of normal “baseline” gasoline.

Existing Federal and State Rules

All but two states in the OTR are participating, in whole or in part,
with the federal reformulated gasoline program.  However, nearly
one-third of the gasoline sold in the OTR is not reformulated gasoline.
NESCAUM has estimated the following fraction of gasoline that is
reformulated by State:

State	Current RFG Fraction	State	Current RFG Fraction

CT	100%	NJ	100%

DC	100%	NY	54%

DE	100%	PA	24%

MA	100%	RI	100%

MD	86%	NoVA	100%

ME	0%	VT	0%

NH	64%

Description of the OTC 2006 Control Measure

The Energy Policy Act of 2005 provides the opportunity for the OTR to
achieve a single clean-burning gasoline and is consistent with what OTR
states have promoted through the long debate over MTBE/ethanol/RFG.
Approximately one-third of the gasoline currently sold in the OTR is not
reformulated.  The new authority plus the potential for emission
reductions from the amount of non-reformulated gasoline sold in the OTR
provides an opportunity for additional emission reductions in the region
as well as for a reduced number of fuels, and possibly a single fuel, to
be utilized throughout the region.  The OTC Commissioners recommended
that the OTC member states pursue a region fuel program consistent with
the Energy Act of 2005 (OTC 2006b).

Emission Benefit Analysis Methods

Emission benefits resulting from extending reformulated gasoline to all
areas of the OTR have been calculated for 2006 by NESCAUM (NESCAUM
2006a).

Cost Estimates

According to USEPA’s regulatory impact analysis for reformulated
gasoline (USEPA 1993), the cost per ton of VOC reduced for Phase I RFG
is $5,200 to $5,900.  USEPA also estimated the cost of Phase II RFG was
$600 per ton of VOC reduced – this reflects the incremental cost over
the cost of implementing Phase I of the RFG program.

VOC EMISSION REDUCTION SUMMARY

The results of the emission benefit calculations for the OTC states are
described in this subsection.  The starting point for the quantification
of the emission reduction benefits is the MANEVU emission inventory,
Version 3 (Pechan 2006, MACTEC 2006a) and the VISTAS emission inventory,
BaseG (MACTEC 2006b), for the northern Virginia counties that are part
of the OTR.  The MANEVU and VISTAS inventories include a 2002 base year
inventory as well as projection inventories for 2009 and 2018 (MANEVU
also has projections for 2012, but VISTAS does not).  The projection
inventories account for growth in emissions based on growth indicators
such as population and economic activity.  The projection inventories
also account for “on-the-books/on-the-way” (OTB/W) emission control
regulations that have (or will) become effective between 2003 and 2008
that will achieve post-2002 emission reductions.  For example, many
States have already adopted the 2001 OTC model rules for consumer
products and portable fuel containers.  The emission reduction benefit
from the 2001 OTC model rules are already accounted for in the MANEVU
and VISTAS projection inventories.  Emission reductions from existing
regulations are already accounted for to ensure no double counting of
emission benefits occurs.

Note that the emission reductions contained in this Section are
presented in terms of tons per summer day.  The MANEVU base and
projection emission inventories do not contain summer day emissions for
all States and source categories; the VISTAS inventory only contains
annual values.  When States provided summer day emissions in the MANEVU
inventory, these values were used directly to quantify the emission
benefit from the 2006 OTC control measure.  When summer day emissions
were missing from the MANEVU or VISTAS inventories, the summer day
emissions were calculated using the annual emissions and the seasonal
throughput data from the NIF Emission Process table.  If the seasonal
throughput data was missing, the summer day emissions were calculated
using the annual emissions and a summer season adjustment factor derived
from the monthly activity profiles contained in the SMOKE emissions
modeling system.

Tables 3-5 to 3-10 show State summaries of the emission benefits from
the OTC 2006 VOC control measures described previously in this Section.
For each of the source categories, the Tables show four columns: (1) the
actual 2002 summer daily emissions; (2) the summer daily emissions for
the 2009 OTB/W scenario that accounts for growth and for the emission
control regulations that have (or will) become effective between 2003
and 2008 that will achieve post-2002 emission reductions; (3) the summer
daily emissions for 2009 with the implementation of the OTC 2006 control
measures identified in this Section, and (4) the emission benefit in
2009 resulting from the OTC 2006 control measure.  Table 3-11 shows the
same information for the total of all six source categories.

The largest estimated VOC emission reductions are in the most populous
States – New York and Pennsylvania.  The emission benefits listed for
Virginia just include the Virginia counties in the northern Virginia
area that are part of the OTR.  Benefit estimates for all other States
include the entire state.  The emission benefits also assume that all
OTC members will adopt the rules as described in the previous sections.

The requirement for a regional fuel throughout the OTR provides the
largest emission benefit, about 139.4 tons per day across the OTR.  The
adhesives and sealants application model rule provides the second
largest emission benefit in 2009 – 82.3 tons per day across the OTR.
The incremental benefits accrued from the amendments to State’s
existing consumer products and portable fuel container model rules are
not as large, since the States already have accrued substantial benefits
from the adoption of these rules.

Appendix D provides county-by-county summaries of the VOC emission
benefits from the OTC 2006 VOC model rules described previously in this
Section.  Appendix D also provides additional documentation regarding
the data sources and emission benefit calculations that were performed.
These tables can be used by the States to create additional summaries,
for example, by nonattainment area.

Table 3-5 OTC 2006 VOC Model Rule Benefits by State for 2009

Adhesives and Sealants Application

	Adhesives/Sealants Application

Summer VOC Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	4.8	6.6	2.4	4.2

DE	1.4	1.6	0.6	1.0

DC	0.2	0.2	0.1	0.1

ME	3.1	3.9	1.4	2.5

MD	6.9	9.1	3.3	5.8

MA	10.6	14.7	5.8	8.9

NH	2.5	3.6	1.3	2.3

NJ	14.9	15.2	6.0	9.2

NY	24.7	33.4	11.9	21.5

PA	25.5	34.0	12.2	21.8

RI	1.8	2.4	0.9	1.5

VT	2.4	3.4	1.2	2.2

NOVA	1.2	1.6	0.6	1.0

OTR	99.8	129.8	47.5	82.3

2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures.

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section.

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Table 3-6 OTC 2006 VOC Model Rule Benefits by State for 2009

Cutback and Emulsified Asphalt Paving

	Cutback and Emulsified Asphalt Paving

Summer VOC Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT*	4.5	4.5	0.3	4.3

DE	0.1	0.1	0.1	0.0

DC	0.0	0.0	0.0	0.0

ME	8.6	10.6	0.0	10.6

MD	0.0	0.0	0.0	0.0

MA*	8.4	8.6	0.5	8.1

NH	3.8	4.8	0.5	4.4

NJ	4.9	4.8	0.1	4.7

NY	15.4	18.3	1.8	16.4

PA	7.7	9.3	0.9	8.4

RI	1.0	1.2	0.1	1.1

VT	1.4	1.8	0.0	1.8

NOVA	<0.1	<0.1	<0.1	<0.1

OTR	55.9	64.0	4.3	59.8

2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures.

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section.

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

* CT and MA provided revised emission estimates that differ from those
in the MANEVU Version 3 inventories.

Table 3-7 OTC 2006 VOC Model Rule Benefits by State for 2009

Consumer Products

	Consumer Products

Summer VOC Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	40.1	35.4	34.7	0.7

DE	7.3	6.7	6.5	0.1

DC	5.7	5.1	5.0	0.1

ME	10.9	9.7	9.5	0.2

MD	52.8	48.4	47.4	1.0

MA*	62.2	64.1	53.9	10.2

NH	13.7	12.6	12.4	0.3

NJ	82.9	71.9	70.5	1.4

NY	209.6	183.3	179.6	3.7

PA	119.6	104.4	102.4	2.1

RI	10.6	9.3	9.1	0.2

VT	6.1	5.6	5.5	0.1

NOVA	21.5	23.0	22.5	0.5

OTR	642.9	579.5	559.0	20.5

2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures.

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section.

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

* MA proposed rule has a January 1, 2009 effective date and includes the
VOC limits from the OTC 2001 model rule and those in the OTC 2006 model
rule.  The 2009 benefit for MA shows the benefit from both sets of
limits.  For all other States, the 2009 benefit shows the change in
emissions from the OTC 2006 model rule only.

Table 3-8 OTC 2006 VOC Model Rule Benefits by State for 2009

Portable Fuel Containers – Area Sources

	Portable Fuel Containers

Summer VOC Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	9.7	6.5	6.1	0.4

DE	3.0	2.1	1.9	0.1

DC	3.6	2.5	2.4	0.1

ME	3.6	2.4	2.3	0.1

MD	39.6	24.5	23.1	1.4

MA*	18.1	18.6	16.9	1.7

NH	3.6	3.0	2.8	0.2

NJ	24.4	17.7	16.7	1.0

NY	76.6	45.0	42.4	2.6

PA	47.0	27.6	26.0	1.6

RI	3.0	2.7	2.5	0.2

VT	1.7	1.5	1.5	0.1

NOVA	8.6	6.1	5.7	0.4

OTR	242.5	160.1	150.3	9.9

2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions are based on the emissions forecasted in
the MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures.

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section.

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Note:  The table shows the estimated emission reduction that will occur
in 2009; additional reductions will occur in later years as new,
less-emitting PFCs that comply with the OTC 2006 control measure
penetrate the market.

* MA PFC regulation will be based on only the OTC 2006 model rule (which
updates the provisions of the OTC 2001 model rule) and will have an
effective date of January 1, 2009.  The 2009 base emissions in MA are
uncontrolled emissions.  The 2009 emission benefits represent the total
emission reductions from the MA rule.

Table 3-9 OTC 2006 VOC Model Rule Benefits by State for 2009

Portable Fuel Containers – Nonroad Sources

	Portable Fuel Containers

Summer VOC Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	2.9	1.9	1.8	0.1

DE	0.9	0.6	0.6	0.0

DC	1.1	0.8	0.7	0.0

ME	1.1	0.7	0.7	0.0

MD	11.9	7.4	6.9	0.4

MA*	5.4	5.6	5.1	0.5

NH	1.1	0.9	0.8	0.1

NJ	7.3	5.3	5.0	0.3

NY	23.0	13.5	12.7	0.8

PA	14.1	8.3	7.8	0.5

RI	0.9	0.8	0.8	0.0

VT	0.5	0.5	0.4	0.0

NOVA	2.6	1.8	1.7	0.1

OTR	72.8	48.0	45.1	3.0

2002 Actual emissions estimated to be 30 percent of area source
emissions (based on Pechan 2001, pg. 11)

2009 Base Inventory emissions estimated to be 30 percent of area source
emissions, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures.

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section.

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).

Note:  The table shows the estimated emission reduction that will occur
in 2009; additional reductions will occur in later years as new,
less-emitting PFCs that comply with the OTC 2006 control measure
penetrate the market.

* MA PFC regulation will be based on only the OTC 2006 model rule (which
updates the provisions of the OTC 2001 model rule) and will have an
effective date of January 1, 2009.  The 2009 base emissions in MA are
uncontrolled emissions.  The 2009 emission benefits represent the total
emission reductions from the MA rule.

Table 3-10 OTC 2006 VOC Model Rule Benefits by State for 2009

Regional Fuels

	Regional Fuels

Summer VOC Emissions (tpd)

State	2006 Actual	2006

Base	2006

Control	2006 Benefit

CT	87.9	87.9	87.9	0.0

DE	26.6	26.6	26.6	0.0

DC	9.1	9.1	9.1	0.0

ME	56.2	56.2	47.1	9.1

MD	158.7	158.7	155.6	3.2

MA	148.6	148.6	148.6	0.0

NH	45.3	45.3	41.0	4.3

NJ	219.6	219.6	219.6	0.0

NY	465.0	465.0	408.1	56.9

PA	363.0	363.0	305.0	58.0

RI	22.2	22.2	22.2	0.0

VT	35.9	35.9	27.9	7.9

NOVA	54.9	54.9	54.9	0.0

OTR	1693.1	1693.1	1553.7	139.4

Note: NESCAUM analysis was only completed for 2006.  Data for 2002 and
2009 are not currently available

Table 3-11 OTC 2006 VOC Model Rule Benefits by State for 2009

All Six VOC Categories

	All Six Categories

Summer VOC Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	149.9	142.9	133.2	9.7

DE	39.3	37.7	36.3	1.4

DC	19.6	17.6	17.2	0.4

ME	83.5	83.6	60.9	22.6

MD	270.0	248.1	236.3	11.8

MA	253.3	260.1	230.8	29.3

NH	70.0	70.3	58.8	11.5

NJ	354.1	334.6	317.9	16.7

NY	814.2	758.4	656.5	101.9

PA	576.8	546.7	454.3	92.3

RI	39.5	38.6	35.6	3.0

VT	48.0	48.7	36.5	12.1

NOVA	88.8	87.4	85.4	1.9

OTR	2,807.0	2,674.6	2,359.8	314.8

2002 Actual emissions based on the MANEVU 2002 Version 3 inventory and
VISTAS 2002 Base G inventory (for the 10 northern Virginia jurisdictions
that are part of the OTR).

2009 Base Inventory emissions based on the emissions forecasted in the
MANEVU 2009 OTB/W Version 3.1 inventory and the VISTAS 2009 Base G
inventory, and account for growth and any emission reductions associated
with on-the-books/on-the-way controls measures.

2009 Control Inventory emissions are the emissions remaining after
implementation of the beyond-on-the-way control measures described in
this Section.  Assumes that 2009 reductions from RFG are the same as
those calculated for 2006.

2009 Emission Reduction Benefit is the incremental emission reduction
from the control measures described in this section (i.e., the
difference between the 2009 base emissions and the 2009 control
emissions).  Assumes that 2009 reductions from RFG are the same as those
calculated for 2006.

NOx ANALYSIS METHODS

This Section describes the analysis of the 2006 OTC control measures to
reduce NOx emissions from six source categories:  diesel engine chip
reflash, regional fuels, asphalt production plants, cement kilns,
glass/fiberglass furnaces, ICI boilers.  For each of the categories,
there are separate subsections that discuss existing Federal/state
rules, summarize the requirements of the 2006 OTC control measure,
describe the methods used to quantify the emission benefit, and provide
an estimate of the anticipated costs and cost-effectiveness of the
control measure.  At the end of Section 4, we provide the estimated
emissions for 2002 and 2009 by source category and State.  Appendix E
provides county-by-county summaries of the emission reductions for each
of the categories.

HEAVY-DUTY TRUCK DIESEL ENGINE CHIP REFLASH

In the mid-1990s, the U.S. Department of Justice (DOJ), EPA, and CARB
determined that seven major engine manufacturers had designed their 1993
through 1998 model heavy-duty diesel engines to operate with advanced
electronic engine controls that resulted in excessive NOx emissions.
When these engines were operated in the vehicle under “real world”
conditions, the electronic calibration would change, altering the fuel
delivery characteristics and resulting in elevated NOx levels.  DOJ, EPA
and ARB developed Consent Decrees that required the manufacturers to
provide software (the “Low-NOx Rebuild Kit” or “chip reflash”)
that modifies the injection timing adjustment that caused the excess NOx
emissions.  The kits are to be installed at the time the vehicle is
brought in for a major engine rebuild/overhaul.  The rate of rebuild has
been considerably lower than what was envisioned under the Consent
Decrees; the primary reasons being that engine rebuilds occur at
considerably higher elapsed vehicle mileage than what was contemplated
when the Consent Decrees were negotiated, and there is no federal
oversight program to ensure that individual rebuilds are occurring at
the time of rebuild.  In response to this low rebuild rate, CARB has
adopted a mandatory program, not tied to the time of rebuild, but rather
to a prescribed period of time, within which owners must bring their
vehicles into the dealer to have the reflash operation performed, with
all costs borne by the engine manufacturers. (NESCAUM 2006b).

Existing Federal and State Rules

California entered into Settlement Agreements, separate from the federal
Consent Decrees, but with analogous requirements for low-NOx rebuilds.
The slow rate of progress in California mirrored the progress
nationally.  Accordingly, California embarked upon its own program, by
rule, to accelerate and ultimately complete the rebuilds for trucks
registered in California and for out-of-state registered trucks
traveling on roadways within the state.  The ARB rule, effective March
21, 2005, mandates that rebuilds occur over a prescribed time period,
with a final rebuild compliance date of December 31, 2006.  The CARB
mandatory program faced two separate legal challenges, alleging that
CARB has breached its settlement agreement and alleging that CARB is
illegally establishing different emissions standards on “new
engines”.  The Sacramento County Superior Court ruled that the Low NOx
Software Upgrade Regulation is invalid.  CARB indicates that it will not
appeal that ruling and is suspending further enforcement of this
regulation.

Description of the OTC 2006 Control Measure

NESCAUM developed a model rule for consideration by its member states to
implement a low-NOx rebuild program, similar California’s program.
The regulation applies to the engine manufacturers and to owners,
lessees, and operators of heavy-duty vehicles powered by the engines
that are required to have the low-NOx rebuild.  Consistent with the
Consent Decrees, the engine manufacturers are required to provide the
rebuild kits at no cost to dealers, distributors, repair facilities,
rebuild facilities, owners, lessees, and operators, upon their request
and to reimburse their authorized dealers, distributors, repair
facilities and rebuild facilities for their labor costs.

Emission Benefit Analysis Methods

NESCUAM estimated potential NOx emissions reductions (tons per day) if
the Northeast States were to adopt a rebuild program similar to the
California program.  These estimates are based on the ratio of Northeast
to California in-state heavy-duty vehicle registrations, and
ARB-estimated California NOx reductions of 35 TPD (NESCAUM 2006b, pg.
5).  NESCAUM also estimated potential NOx emissions reductions for the
Mid-Atlantic States by scaling the NESCAUM projections based on
population.  For the Mid-Atlantic States, the NOx benefit was calculated
based on the per capita factors of a one ton per day reduction for each
one million people (NESCAUM 2005).

Cost Estimates

The cost associated with the reflash has been estimated at $20-$30 per
vehicle, which is borne by the engine manufacturer.  There may be costs
associated with potential downtime to the trucking firms, and
record-keeping requirements on the dealer performing the reflash and the
vehicle owner.  The MRPO estimated cost effectiveness to be $1,800 to
$2,500 (depending on vehicle size) due to incremental “fuel penalty”
of 2 percent increase in fuel consumption (ENVIRON 2006).

REGIONAL FUELS

The Clean Air Act Amendments of 1990 required significant changes to
conventional fuels used by motor vehicles.  Beginning in 1995,
“reformulated” gasoline (RFG) must be sold in certain non-attainment
areas and other states with non-attainment areas are permitted to
opt-in.  Reformulated gasoline results in lower VOC emissions than would
occur from the use of normal “baseline” gasoline.  Phase II of the
RFG program began in 2000.

Existing Federal and State Rules

All but two states in the OTR are participating, in whole or in part,
with the federal RFG program.  However, nearly one-third of the gasoline
sold in the OTR is not RFG.  NESCAUM has estimated the following
fraction of gasoline that is reformulated by State:

State	Current RFG Fraction	State	Current RFG Fraction

CT	100%	NJ	100%

DC	100%	NY	54%

DE	100%	PA	24%

MA	100%	RI	100%

MD	86%	NoVA	100%

ME	0%	VT	0%

NH	64%

Description of the OTC 2006 Control Measure

The Energy Policy Act of 2005 provides the opportunity for the OTR to
achieve a single clean-burning gasoline and is consistent with what OTR
states have promoted through the long debate over MTBE/ethanol/RFG.
Approximately one-third of the gasoline currently sold in the OTR is not
reformulated.  The new authority plus the potential for emission
reductions from the amount of non-reformulated gasoline sold in the OTR
provides an opportunity for additional emission reductions in the region
as well as for a reduced number of fuels, and possibly a single fuel, to
be utilized throughout the region.  The OTC Commissioners recommended
that the OTC member states pursue a region fuel program consistent with
the Energy Act of 2005 (OTC 2006b).

Emission Benefit Analysis Methods

Emission benefits resulting from extending reformulated gasoline to all
areas of the OTR have been calculated for 2006 by NESCAUM (NESCAUM
2006a).

Cost Estimates

According to USEPA’s regulatory impact analysis for reformulated
gasoline (USEPA 1993), the cost per ton of NOx reduced for Phase II RFG
is $5,200 to $3,700.

ASPHALT PAVEMENT PRODUCTION PLANTS

Hot mix asphalt (HMA) is created by mixing and heating size-graded, high
quality aggregate (which can include reclaimed asphalt pavement) with
liquid asphalt cement.  HMA can be manufactured by batch mix, continuous
mix, parallel flow drum mix, or counterflow drum mix plants.  The dryer
operation is the main source of pollution at hot mix asphalt
manufacturing plants.  Dryer burner capacities are usually less than 100
mmBtu/hr, but may be as large as 200 mmBtu/hr.  Natural gas is the
preferred source of heat used by the industry, although oil, electricity
and combinations of fuel and electricity are used.  The reaction of
nitrogen and oxygen in the dryer creates nitrogen oxide (NOx) emissions
in the combustion zone,

Existing Federal and State Rules

Only two of the OTR states have regulations that specifically address
NOx emissions from asphalt pavement manufacturing plants.  New Hampshire
limits NOx emissions to 0.12 pound per ton of asphalt produced, or 0.429
lb per mmBtu {Chapter Env-A 1211.08 (c)} for units greater than 26
mmBTU/hour in size.  New Jersey limits NOx emissions to 200 ppmvd at
seven percent oxygen {7:27-19.9(a)}.  Asphalt plants in other OTR states
are subject to more general fuel combustion requirements or case-by-case
RACT determinations.

Description of the OTC 2006 Control Measure

NOx emissions from asphalt plants can be reduced through installation of
low-NOx burners and flue gas recirculation (FGR).  The OTC Commissioners
recommended that OTC member states pursue as necessary and appropriate
state-specific rulemakings or other implementation methods to establish
emission reduction percentages, emission rates or technologies that are
consistent with the guidelines shown in Table 4.1 (OTC 2006b).

Table 4.1 Addendum to OTC Resolution 06-02 Emission Guidelines

for Asphalt Plants

Plant Type	Emission Rate

(lbs NOx/ton asphalt produced)	% Reduction

Area/Point Sources

   Batch Mix Plant – Natural Gas	0.02	35

   Batch Mix Plant – Distillate/Waste Oil	0.09	35

   Drum Mix Plant – Natural Gas	0.02	35

   Drum Mix Plant – Distillate/Waste Oil	0.04	35

or Best Management Practices

Industry leaders have identified a number of Best Management Practices
that allow for substantial reduction in plant fuel consumption and the
corresponding products of combustion including NOx.  Best management
practices include:

Burner tune-ups: A burner tune-up may reduce NOx emissions by up to 10
percent and may also help reduce fuel consumption. In other words, there
can be a direct pay-back to the business from regular burner tune-ups.

Effective stockpile management to reduce aggregate moisture content:
Current information indicates that effective stockpile management can
reduce aggregate moisture content by about 25 percent, corresponding to
a reduction in fuel consumption by approximately 10 - 15 percent. There
are a number of ways to reduce aggregate moisture: covering stockpiles,
paving under stockpiles, and sloping stockpiles are all ways that
prevent aggregate from retaining moisture. Best Practices are plant- and
geographic locale-specific.

Lowering mix temperature: A Technical Working Group of FHWA is currently
investigating a number of newer formulation technologies, to understand
the practicality and performance of lowering mix temperatures.
Substantial reductions in mix temperatures, on the order of 20 percent
or more, appear to be plausible. Lowering mix temperatures, by this
amount, may reduce fuel consumption, as less heat is needed to produce
the mix.

Other maintenance and operational best practices: Additional practices
can be employed throughout the plant to help optimize production and
operations. For example, regular inspection of drum mixing flites and
other measures can be taken – all in the effort to make a plant
operate more efficiently, thereby using less fuel.

Emission Benefit Analysis Methods

The emission rates and percent reductions estimates shown above for
major sources were developed the state of New York based on the use of
low-NOx burners and FGR.  For minor sources, the requirement is the use
of low-NOx burner technology.  NOx emissions can be reduced by 35 to 50
percent with low-NOx burners and FGR, and by 25 to 40 percent with
low-NOx burners alone.  For modeling purposes, a 35 percent reduction
was assumed to apply all types of asphalt plants.

The reductions estimated for this category only include emissions
included in the MANEVU point source emission inventory.  Only emissions
from major point sources are typically included in the MANEVU point
source database.  Emissions from non-major sources are not explicitly
contained in the area source inventory.  The emissions from non-major
asphalt plants are likely lumped together in the general area source
industrial and commercial fuel use category.  Reductions from area
source emissions at asphalt production plants are included in the ICI
boiler source category.  Therefore, there is some uncertainty regarding
the actual reductions that will occur as no accurate baseline exists for
both major and minor facilities.

Cost Estimates

The anticipate costs for control are similar to those of small to
midsize boilers or process heaters.  Low NOx burners range from $500 to
$1,250 per ton and low-NOx burners in combination with FGR range from
$1,000 to $2,000 per ton.  These cost-effectiveness data were provided
by NYSDEC.  These control efficiencies and cost-effectiveness estimates
for low-NOx burners plus FGR are generally consistent EPA’s published
data for small natural gas-fired and oil-fired process heaters and
boilers (Pechan 2005).

CEMENT KILNS

Portland cement manufacturing is an energy intensive process in which
cement is made by grinding and heating a mixture of raw materials such
as limestone, clay, sand and iron ore in a rotary kiln.  Nationwide,
about 82 percent of the industry’s energy requirement is provided by
coal.  Waste-derived fuels (such as scrap tires, used motor oils,
surplus printing inks, etc.) provide about 14 percent of the energy.
NOx emissions are generated during fuel combustion by oxidation of
chemically-bound nitrogen in the fuel and by thermal fixation of
nitrogen in the combustion air.

There are four main types of kilns used to manufacture portlant cement:
long wet kilns, long dry kilns, dry kilns with preheaters, dry kilns
with precalciners.  Wet kilns tend to be older units and are often
located where the moisture content of feed materials from quarries tends
to be high.

Cement kilns are located in Maine, Maryland, New York, and Pennsylvania.
 There are no cement kilns in the other OTR states. According to the
MANEVU 2002 inventory (Pechan 2006), the number of cement kilns
operating in 2002 by size and type was:

State	Number of Facilities	Number of Long Wet Kilns	Number of Long Dry
Kilns	Number of Preheater or Precalciner Kilns

Maine	1	1	0	0

Maryland	3	2	2	0

New York	3	2	1	0

Pennsylvania	10	5	11	5

Existing Federal and State Rules

The NOx SIP Call required states to submit revisions to their SIPs to
reduce the contribution of NOx from cement kilns.  All kilns in the OTR,
except for the one kiln in Maine, are subject to the NOx SIP Call.
Based on its SIP Call analysis, EPA determined 30 percent reduction of
baseline uncontrolled emission levels was highly cost-effective for
cement kilns emitting greater than 1 ton/day of NOx.  Some states
elected to include cement kilns in their NOx Budget Trading Programs.
For example, requirements in Pennsylvania’s regulations in 25 Pa. Code
Chapter 145 set a kiln allowable limit of 6 pounds per ton of clinker
produced, and require sources to purchase NOx allowances for each ton of
NOx actual emissions that exceed the allowable limits.  Maryland did not
include kilns in the trading program but instead provided two options
for reducing NOx emissions:

Option 1 – for long wet kilns, meet NOx emission limit of 6.0 pounds
per ton of clinker produced; for long dry kilns, meet limit of 5.1
pounds per ton of clinker produced; and for pre-heater/pre-calciner or
pre-calciner kilns, meet limit of 2.8 pounds per ton of clinker
produced;

Option 2 – install low NOx burners on each kiln or modify each kiln to
implement mid-kiln firing.

The one kiln in Maine is a wet process cement kiln and has been licensed
to modernize by converting to the more efficient dry cement
manufacturing process.  The new kiln is subject to BACT requirements.

Description of the OTC 2006 Control Measure

There is a wide variety of proven control technologies for reducing NOx
emissions from cement kilns.  Automated process control has been shown
to lower NOx emissions by moderate amounts.  Low-NOx burners have been
successfully used, especially in the precalciner kilns.  CemStarSM is a
process that involves adding steel slag to the kiln, offering moderate
levels of NOx reduction by reducing the required burn zone heat input.
Mid-kiln firing of tires provides moderate reductions of NOx emissions
while reducing fuel costs and providing an additional revenue stream
from receipt of tire tipping fees.  SNCR technology has the potential to
offer significant reductions on some precalciner kilns.  SNCR is being
used in numerous cement kilns in Europe.  A recent study (EC 2001a)
indicates that there are 18 full-scale SNCR installations in Europe.
Most SNCR installations are designed and/or operated for NOx reduction
rates of 10-50% which is sufficient to comply with current legislation
in some countries.  Two Swedish plants installed SNCR in 1996/97 and
have achieved a reduction of 80-85%. A second recent study (ERG 2005) of
cement kilns in Texas has identified a variety of NOx controls for both
wet and dry cement kilns, with reductions in the 40 to 85% range.

The OTC Commissioners recommended that OTC member states pursue, as
necessary and appropriate, state-specific rulemakings or other
implementation methods to establish emission reduction percentages,
emission rates or technologies that are consistent with the guidelines
shown in Table 4.2 (OTC 2006b).  The guidelines were presented in terms
of both an emission rate (lbs/ton of clinker by kiln type) as well as a
percent reduction from uncontrolled levels.

Table 4.2 OTC Resolution 06-02 Emission Guidelines for Cement Kilns

Kiln Type	Emission Rate

(lbs NOx/ton of clinker produced)	% Reduction from Uncontrolled

Wet Kiln	3.88	60

Long Dry Kiln	3.44	60

Pre-heater Kiln	2.36	60

Pre-calciner Kiln	1.52	60

Emission Benefit Analysis Methods

To calculate the additional reductions from the OTC 2006 Control
Measure, MACTEC calculated the 2002 emission rate (lbs NOx per ton of
clinker produced) for each kiln.  The 2002 emission rate was compared to
the OTC 2006 control measure emission rate list above to calculate a
kiln-specific percent reduction.  The kiln-specific percent reduction
was then applied to the 2002 actual emissions to calculate the emissions
remaining after implementation of the control measure.

Cost Estimates

The TCEQ study (ERG 2005) estimated a cost-effectiveness of $1,400-1,600
per ton of NOx removed for an SNCR system achieving a 50 percent
reduction on modern dry preheat precalcination kilns.  The study also
estimate a cost-effectiveness of $2,200 per ton of NOx removed for SNCR
systems achieving a 35 percent reduction on wet kilns.  The most recent
EPA report (EC/R 2000) shows data for two SNCR technologies, biosolids
injection and NOXOUT®.  These technologies showed average emission
reductions of 50 and 40 percent, respectively.  The cost effectiveness
was estimated to be $1,000-2,500/ton depending on the size of the kiln.
Costs and the cost effectiveness for a specific unit will vary depending
on the kiln type, characteristics of the raw material and fuel,
uncontrolled emission rate, and other source-specific factors.

GLASS/FIBERGLASS FURNACES

The manufacturing process requires raw materials, such as sand,
limestone, soda ash, and cullet (scrap and recycled glass), be fed into
a furnace where a temperature is maintained in the 2,700°F to 3,100°F
range.  The raw materials then chemically react creating a molten
material, glass.  The reaction of nitrogen and oxygen in the furnace
creates NOx emissions.

The main product types are flat glass, container glass, pressed and
blown glass, and fiberglass.  In the OTR, the preponderance of glass
manufacturing plants is in Pennsylvania.  New York and New Jersey also
have several plants.  Massachusetts, Maryland, and Rhode Island each
have one glass manufacturing plant.

Existing Federal and State Rules

Only Massachusetts and New Jersey have specific regulatory limits for
NOx emissions from glass melting furnaces.  Massachusetts has a 5.3
pound per ton of glass removed limit for container glass melting
furnaces having a maximum production of 15 tons of glass per day or
greater.  New Jersey has a 5.5 pound per ton of glass limit for
commercial container glass manufacturing furnaces and an 11 pound per
ton of glass for specialty container glass manufacturing furnaces.  New
Jersey also required borosilicate recipe glass manufacturing furnaces to
achieve at least a 30 percent reduction from 1990 baseline levels by
1994.  The regulations for other states with glass furnaces (Maryland,
New York, Pennsylvania, and Rhode Island) do not contain specific
emission limitation requirements, but rather require RACT emission
controls as determined on a case-by-case basis.

Description of the OTC 2006 Control Measure

Several alternative control technologies are available to glass
manufacturing facilities to limit NOx emissions (MACTEC 2005).  These
options include combustion modifications (low NOx burners, oxy-fuel
firing, oxygen-enriched air staging), process modifications (fuel
switching, batch preheat, electric boost), and post combustion
modifications (fuel reburn, SNCR, SCR).  Oxyfiring is the most effective
NOx emission reduction technique and is best implemented with a complete
furnace rebuild.  This strategy not only reduces NOx emissions by as
much as 85 percent, but reduces energy consumption, increases production
rates by 10-15 percent, and improves glass quality by reducing defects.
Oxyfiring is demonstrated technology and has penetrated into all
segments of the glass industry.

The OTC Commissioners recommended that OTC member states pursue, as
necessary and appropriate, state-specific rulemakings or other
implementation methods to establish emission reduction percentages,
emission rates or technologies that are consistent with the guidelines
shown in Table 4.3 (OTC 2006g).  The guidelines were presented in terms
of both an emission rate (lbs/ton of glass produced) as well as a
percent reduction from uncontrolled levels for the different types of
glass manufactured.

Table 4.3 Addendum to OTC Resolution 06-02 Guidelines for Glass Furnaces

Type of Glass	Emission Rate

(lbs NOx/ton of glass pulled)

Block 24-hr Ave.	Emission Rate

(lbs NOx/ton of glass pulled)

Rolling 30-day Ave.

Container Glass	4.0 	n/a

Flat Glass	9.2 	7.0

Pressed/blown Glass	4.0 	n/a

Fiberglass	4.0 	n/a

Note: Compliance date is 2009.  NOx allowances may be surrendered in
lieu of meeting the emission rate based on a percentage of the excess
emissions at the facility, at the discretion of the State.

Emission Benefit Analysis Methods

The NOx emission reduction benefit calculation varied by State depending
upon the availability of data:

New Jersey DEP evaluated the existing controls at each facility.  NJDEP
identified furnaces that have closed, indicated whether the facility
requested banking of emissions, and specified whether the emissions from
the closed furnace should remain in the projection year inventory.
NJDEP also identified furnace-specific projected emission rates based on
the use of oxyfuel technology.

Pennsylvania DEP provided 2002 throughput (tons of glass pulled) and
emission rate data (lbs NOx/ton of glass pulled).  The 2002 emission
rate was compared to the OTC 2006 control measure emission rate list
above to calculate a furnace-specific percent reduction.  The
furnace-specific percent reduction was then applied to the 2002 actual
emissions to calculate the emissions remaining after implementation of
the control measure.  If a furnace had an emission rate below the OTCC
2006 control measure emission rate, then no incremental reduction was
calculated.  PADEP also identified several furnaces that have shut down
– emissions from these furnaces were set to zero in the projection
year inventory.

For all other States with glass furnaces (MA, MD, NY, and RI), furnace
specific data were not available.  The NOx emission reduction benefit
was calculated by applying an 85 percent reduction for oxyfiring
technology to the projected 2009 base inventory.  This approach does not
take into account existing controls at the facilities.

Cost Estimates

A recent study by the European Commission (EC 2001b) reports a 75 to 85
percent reduction in NOx based on oxyfiring technology, resulting in
emission rates of 1.25 to 4.1 pounds of NOx per ton of glass produced.
The cost effectiveness was determined to be $1,254 to $2,542 depending
on the size of the furnace.  EPA’s Alternative Control Techniques
Document (USEPA 1994) estimated an 85 percent reduction in NOx emissions
for oxyfiring with a cost-effectiveness of $2,150 to $5,300.

Other technologies may be used to meet the limits in Table 4.3.  The
costs associated with meeting those limits are source-specific and
depend on the existing controls in place and the emission rates being
achieved.  Site-specific factors greatly influence the actual achievable
performance level and control costs at a particular facility.

ICI BOILERS

Industrial/commercial/institutional (ICI) boilers combust fuel to
produce heat and process steam for a variety of applications.
Industrial boilers are routinely found in applications the chemical,
metals, paper, petroleum, food production and other industries.
Commercial and institutional boilers are normally used to produce steam
and heat water for space heating in office buildings, hotels, apartment
buildings, hospitals, universities, and similar facilities.  Industrial
boilers are generally smaller than boilers in the electric power
industry, and typically have a heat input in the 10-250 mmBtu/hr range;
however, industrial boilers can be as large as 1,000 mmBtu/hr or as
small as 0.5 mmBtu/hour.  Most commercial and institutional boilers
generally have a heat input less than 100 mmBtu/hour.  It is estimated
that 80 percent of the commercial/institutional population is smaller
than 15 mmBtu/hour.  The ICI boiler population is highly diverse –
encompassing a variety of fuel types, boiler designs, capacity
utilizations and pollution control systems – that result in
variability in emission rates and control options.

For emission inventory purposes, emissions from ICI boilers are included
in both the point and area source emission inventories.  Generally, the
point source emission inventory includes all ICI boilers at major
facilities.  The point source inventory lists individual boilers, along
with their size and associated emissions.  The area source inventory
generally includes emissions for ICI boilers located at non-major
facilities.  It does not provide emissions by the size of boiler, as is
done in the point source inventory.  Area sources emissions are
calculated based on the fuel use not accounted for in the point source
inventory.  This is done by taking the total fuel consumption for the
state (by fuel type and category), as published by the U.S. Department
of Energy, and subtracting out the fuel usage reported in the point
source inventory.  Emissions are then calculated on a county-by-county
basis using the amount of fuel not accounted for in the point source
inventory and average emission factors for each fuel type.

Existing Federal and State Rules

ICI boilers are subject to a variety of Clean Air Act programs.
Emission limits for a specific source may have been derived from NSPS,
NSR, NOx SIP Call, State RACT rules, case-by-case RACT determinations,
or MACT requirements.  Thus, the specific emission limits and control
requirements for a given ICI boiler vary and depend on fuel type, boiler
age, boiler size, boiler design, and geographic location.

The OTC developed a draft model rule in 2001 with the following
thresholds and limits:

OTC 2001 Model Rule ICI Boiler Thresholds and Limits

Applicability Threshhold	Emission Rate Limit	Percent NOx Reduction

5-50 mmBtu/hr	None	Tune-up Only

50-100 mmBtu/hr	Gas-fired:  0.10 lbs/mmBtu

Oil-fired:   0.30 lbs/mmBtu

Coal-fired: 0.30 lbs/mmBtu	50%

100-250 mmBtu/hr	Gas-fired:  0.10 lbs/mmBtu

Oil-fired:   0.20 lbs/mmBtu

Coal-fired: 0.20 lbs/mmBtu	50%

>250 mmBtu/hr*	Gas-fired:  0.17 lbs/mmBtu

Oil-fired:   0.17 lbs/mmBtu

Coal-fired: 0.17 lbs/mmBtu	50%

* Only for boilers not subject to USEPA’s NOx SIP Call

Implementation of the OTC 2001 model rule limits varied by State –
some OTC states adopted these limits while others did not.  MACTEC
researched current State regulations affecting ICI boilers and
summarized the rules in Appendix F.  The specific requirements for each
state were organized into a common format to efficiently include the
State-by-State differences by fuel type and boiler size.  This
organization oversimplifies the source categories and size limitations
that differ from State-to-State.  This simplification was necessary to
match the rules to the organization of the emission data bases (i.e.,
Source Classification Codes) being used in the analysis.

Description of the OTC 2006 Control Measure

The OTC Commissioners recommended that OTC member states pursue as
necessary and appropriate state-specific rulemakings or other
implementation methods to establish emission reduction percentages,
emission rates or technologies for ICI boilers (OTC 2006b).  These
guidelines have undergone revision based on a more refined analyses.
Table 4.4 provides the current OTC proposal for ICI boilers.

Emission Benefit Analysis Methods

The emission reduction benefits resulting from the OTC ICI boiler
control measure were calculated differently for point and area sources.
For point sources, the emission reductions were estimated by comparing
the emission limits in the existing (2006) state regulations with the
limits contained in the OTC ICI boiler proposal.

Table 4.4 Addendum to OTC Resolution 06-02 Guidelines for ICI Boilers

ICI Boiler Size

(mmBtu/hr)

	Control Strategy/

Compliance Option	NOx Control Measure

5-25

Annual Boiler Tune-Up

25-100	Option #1	Natural Gas:           0.05 lb NOx/mmBtu

#2 Fuel Oil:            0.08 lb NOx/mmBtu

#4 or #6 Fuel Oil:   0.20 lb NOx/mmBtu

Coal:                       0.30 lb NOx/mmBtu**

	Option #2	50% reduction in NOx emissions from uncontrolled baseline

	Option #3	Purchase current year CAIR NOx allowances equal to reducted
needed to acheiv the required emission rates

100-250	Option #1	Natural Gas:            0.10 lb NOx/mmBtu

#2 Fuel Oil:             0.20 lb NOx/mmBtu

#4 or #6 Fuel Oil:    0.20 lb NOx/mmBtu

Coal:

     Wall-fired           0.14 lb NOx/mm Btu

     Tangential           0.12 lb NOx/mm Btu

     Stoker                  0.22 lb NOx/mm Btu

     Fluidized Bed      0.08 lb NOx/mm Btu

	Option #2	LNB/SNCR, LNB/FGR, SCR, or some combination of these controls
in conjunction with Low NOx Burner technology

	Option #3	60% reduction in NOx emissions from uncontrolled baseline

	Option #4	Purchase current year CAIR NOx allowances equal to reducted
needed to acheiv the required emission rates

>250	Option #1	Purchase current year CAIR NOx allowances equal to
reducted needed to acheiv the required emission rates

	Option #2	Phase I – 2009

Emission rate equal to EGUs of similar size

Phase II – 2012

Emission rate equal to EGUs of similar size

Tables 4-5 through 4-10 shows the current state emission limits by size
range and fuel type, and the percentage reduction from the OTC proposed
limits to the current state requirement.  In cases where a state did not
have a specific limit for a given size range, then the more general
percent reduction from uncontrolled values in Table 4-4 was used.  The
fuel types/boiler types shown in Tables 4-5 through 4-10 were matched to
SCCs in the point source inventory.  MACTEC used the SCC and design
capacity (mmBtu/hour) from the MANEVU and VISTAS emission inventories to
apply the appropriate state specific reduction factor to estimate the
emission reduction benefit.

The emission limits shown in Tables 4-5 through 4-10 generally apply
only to ICI boilers located at major sources (i.e. point sources).  ICI
boilers located at minor sources (i.e., area sources) are generally not
subject to the emissions limits.  In general, emissions from area source
ICI boilers are uncontrolled (except possibly for an annual tune-up
requirement).  The one exception is New Jersey: beginning on March 7,
2007, N.J.A.C. 27.27-19.2 requires any ICI boiler of at least 5 mmBtu/hr
heat input to comply with applicable NOx emission limits whether or not
it is located at a major NOx facility.

To calculate the reductions from area source ICI boilers, MACTEC applied
the general percent reduction from uncontrolled values in Table 4-4 to
the area source inventory (i.e., 10 percent reduction for annual
tune-ups for boilers < 25 mmBtu/hr, and a 50 percent reduction for
boilers between 25 and 100 mmBtu/hr).

The area source inventory does not provide information on the boiler
size.  To estimate the boiler size distribution in the area source
inventory, we first assumed that there were no boilers > 100 mmBtu/hr in
the area source inventory.  Next, we used boiler capacity data from the
USDOE’s Oak Ridge National Laboratory (EEA 2005) to estimate the
percentage of boiler capacity in the < 25 mm Btu/hr and 25-100 mm Btu/hr
categories.  Third, we assumed that emissions were proportional to
boiler capacity.  Finally, we calculated the weighted average percent
reduction for area source ICI boilers based on the capacity in each size
range and the percent reduction by size range discussed in the previous
paragraph.  For industrial boilers, the weighted average reduction was
34.5 percent; for commercial/institutional boilers, the weighted average
reduction was 28.1 percent.

Table 4.5 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Natural Gas-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold

mmBtu/hour Heat Input

Applicability Threshold

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.10	0.05	0.05	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	50.0	75.0	75.0	10.0

DE	0.10	0.10	LNB	NL	NL

0.0	0.0	0.0	0.0	0.0

DC	0.20	0.20	NL	NL	NL

40.0	50.0	50.0	50.0	10.0

ME	0.20	NL	NL	NL	NL

40.0	60.0	50.0	50.0	10.0

MD	0.20	0.20	0.20	0.20	0.20

40.0	50.0	75.0	75.0	10.0

MA	0.20	0.20	0.10	NL	NL

40.0	50.0	50.0	50.0	10.0

NH	0.10	0.10	0.10	NL	NL

0.0	0.0	50.0	50.0	10.0

NJ	0.10	0.10	0.10	NL	NL

0.0	0.0	50.0	50.0	10.0

NY	0.20	0.20	0.10	NL	NL

40.0	50.0	50.0	50.0	10.0

PA	Source Specific NOx RACT

29.4	50.0	50.0	50.0	10.0

SE PA	0.17	0.10	Source Specific RACT

29.4	0.0	50.0	50.0	10.0

RI	0.10	0.10	0.10	NL	NL

0.0	0.0	50.0	50.0	10.0

VT	0.20	NL	NL	NL	NL

40.0	60.0	50.0	50.0	10.0

NOVA	0.2	0.2	0.2	0.2	0.2	 	40.0	50.0	75.0	75.0	10.0

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.6 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Distillate Oil-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold

mmBtu/hour Heat Input

Applicability Threshold

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.20	0.08	0.08	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	0.0	60.0	60.0	10.0

DE	0.10	0.10	LNB	NL	NL

0.0	0.0	0.0	0.0	0.0

DC	0.30	0.30	0.30	NL	NL

60.0	33.3	73.3	50.0	10.0

ME	0.20	0.30	0.30	NL	NL

40.0	33.3	73.3	50.0	10.0

MD	0.25	0.25	0.25	0.25	0.25

52.0	20.0	68.0	68.0	10.0

MA	0.25	0.30	0.12	NL	NL

52.0	33.3	33.3	50.0	10.0

NH	0.30	0.30	0.12	NL	NL

60.0	33.3	33.3	50.0	10.0

NJ	0.20	0.20	0.12	NL	NL

40.0	0.0	33.3	50.0	10.0

NY	0.25	0.30	0.12	NL	NL

52.0	33.3	33.3	50.0	10.0

PA	Source Specific NOx RACT

29.4	33.3	33.3	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	0.0	33.3	50.0	10.0

RI	0.12	0.12	0.12	NL	NL

0.0	0.0	33.3	50.0	10.0

VT	0.30	NL	NL	NL	NL

60.0	60.0	50.0	50.0	10.0

NOVA	0.25	0.25	0.25	0.25	0.25	 	52.0	20.0	68.0	68.0	10.0

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.7 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Residual Oil-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold

mmBtu/hour Heat Input

Applicability Threshold

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.20	0.20	0.20	NL

CT	0.25	0.25	0.25	0.25	0.25

52.0	20.0	20.0	20.0	10.0

DE	0.10	0.10	LNB	NL	NL

0.0	0.0	0.0	0.0	0.0

DC	0.30	0.30	0.30	NL	NL

60.0	33.3	33.3	50.0	10.0

ME	0.20	0.30	0.30	NL	NL

40.0	33.3	33.3	50.0	10.0

MD	0.25	0.25	0.25	0.25	0.25

52.0	20.0	20.0	20.0	10.0

MA	0.25	0.30	0.30	NL	NL

52.0	33.3	33.3	50.0	10.0

NH	0.30	0.30	0.30	NL	NL

60.0	33.3	33.3	50.0	10.0

NJ	0.20	0.20	0.30	NL	NL

40.0	0.0	33.3	50.0	10.0

NY	0.25	0.30	0.30	NL	NL

52.0	33.3	33.3	50.0	10.0

PA	Source Specific NOx RACT

29.4	33.3	33.3	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	0.0	50.0	50.0	10.0

RI	LNB/FGR	LNB/FGR	LNB/FGR	NL	NL

0.0	0.0	0.0	50.0	10.0

VT	0.30	NL	NL	NL	NL

60.0	60.0	50.0	50.0	10.0

NOVA	0.25	0.25	0.25	0.25	0.25	 	52.0	20.0	20.0	20.0	10.0

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.8 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Coal Wall-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold

mmBtu/hour Heat Input

Applicability Threshold

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.14	0.30	0.30	NL

CT	0.38	0.38	0.38	0.38	0.38

68.4	63.2	21.1	21.1	10.0

DE	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

DC	0.43	0.43	NL	NL	NL

72.1	67.4	50.0	50.0	10.0

ME	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

MD	0.38	0.65	0.38	0.38	0.38

68.4	78.5	21.1	21.1	10.0

MA	0.45	0.45	NL	NL	NL

73.3	68.9	50.0	50.0	10.0

NH	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NJ	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NY	0.45	0.5	NL	NL	NL

73.3	72.0	50.0	50.0	10.0

PA	Source Specific NOx RACT

29.4	72.0	50.0	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	30.0	50.0	50.0	10.0

RI	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

VT	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NOVA	0.38	0.38	0.38	0.38	0.38	 	68.4	63.2	21.1	21.1	10.0

n/a indicates that there are no coal-fired ICI boilers in the state.

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.9 Current State Emission Limits and Percent Reduction Estimated
from Adoption of OTC ICI Boiler Proposal

Point Source Coal Tangential-Fired Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold

mmBtu/hour Heat Input

Applicability Threshold

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.12	0.30	0.30	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	40.0	0.0	0.0	10.0

DE	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

DC	0.43	0.43	NL	NL	NL

72.1	72.1	50.0	50.0	10.0

ME	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

MD	0.38	0.65	0.38	0.38	0.38

68.4	81.5	21.1	21.1	10.0

MA	0.38	0.38	NL	NL	NL

68.4	68.4	50.0	50.0	10.0

NH	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NJ	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NY	0.42	0.5	NL	NL	NL

71.4	76.0	50.0	50.0	10.0

PA	Source Specific NOx RACT

29.4	76.0	50.0	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	40.0	50.0	50.0	10.0

RI	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

VT	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NOVA	0.38	0.38	0.38	0.38	0.38	 	68.4	68.4	21.1	21.1	10.0

n/a indicates that there are no coal-fired boilers in the state.

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Table 4.10 Current State Emission Limits and Percent Reduction
Estimated from Adoption of OTC ICI Boiler Proposal

Point Source Coal-Fired Stoker Boilers

 	Current 2006 NOx RACT Limit (lbs/mmBtu)	 	OTC 2006 Percent Reduction

 	(from State regulations)

(Current State reg compared to OTC Limit)

 	Applicability Threshold

mmBtu/hour Heat Input

Applicability Threshold

mmBtu/hour Heat Input

State	> 250*	100 to 250	50 to 100	25 to 50	5 to 25	 	> 250*	100 to 250
50 to 100	25 to 50	<25

 	 	 	 	 	 	OTC Limits (lbs/mmBtu):	0.12	0.22	0.30	0.30	NL

CT	0.20	0.20	0.20	0.20	0.20

40.0	0.0	0.0	0.0	10.0

DE	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

DC	0.43	0.43	NL	NL	NL

72.1	48.8	50.0	50.0	10.0

ME	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

MD	0.38	0.65	0.38	0.38	0.38

68.4	66.2	21.1	21.1	10.0

MA	0.33	0.33	NL	NL	NL

63.6	33.3	50.0	50.0	10.0

NH	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NJ	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NY	0.3	0.3	NL	NL	NL

60.0	26.7	50.0	50.0	10.0

PA	Source Specific NOx RACT

29.4	26.7	50.0	50.0	10.0

SE PA	0.17	0.20	Source Specific RACT

29.4	0.0	50.0	50.0	10.0

RI	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

VT	n/a	n/a	n/a	n/a	n/a

0.0	0.0	0.0	0.0	0.0

NOVA	0.4	0.4	0.4	0.4	0.4	 	70.0	45.0	25.0	25.0	10.0

n/a indicates that there are no coal-fired boilers in the state.

NL indicates no limit specified in a state rule; in those cases, the
more general percent reduction from Table 4-4 was used.

Source Specific NOx RACT indicates that there are no specific limits in
the States’ rule (i.e., limits were determined on a case-by-case
basis); in those cases, the more general percent reduction from Table
4-4 was used.

SE PA refers to the five southeastern Pennsylvania counties (Bucks,
Chester, Delaware, Montgomery, and Philadelphia) affected by
Pennsylvania’s Addition NOx Requirements (129.201)

NOVA refers to the following jurisdictions in Virginia are part of the
OTR:  Arlington County, Alexandria, Fairfax County, Fairfax City, Fall
Church, Loudon County, Manassas City, Manassas Park, and Prince William
County.

Cost Estimates

The OTC recently completed an analysis of ICI boiler NOx control cost
estimates (Bodnarik 2006) using detailed information on direct capital
equipment costs, direct installation costs, indirect capital costs, and
direct and indirect operating costs.  The analysis examined five types
of NOx control technologies – low-NOx burners (LNB), ultra low-NOx
burners (ULNB), LNB plus flue gas recirculation (LNB+FGR), LNB plus
selective non-catalytic reduction (LNB+SNCR), and selective catalytic
reduction (SCR).  The analysis also considered various fuel types –
coal, residual oil, distillate oil, and natural gas.  The cost
effectiveness varies by fuel type, boiler size, current regulatory
requirements, current control technology, and boiler firing type.  The
annual cost-effectiveness was found as low as $600 per ton and as high