UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION II AIR PROGRAMS BRANCH

Technical Support Document

for

EPA(s Notice of Proposed Rulemaking

for the

New Jersey State Implementation Plan Revision:

New Jersey Reasonable Further Progress Plans, Reasonably Available Control Technology, Reasonably Available Control Measures and Conformity Budgets

State Implementation Plan (SIP) Revision for the Attainment and Maintenance of the Ozone National Ambient Air Quality Standard

8-Hour Ozone Attainment Demonstration

Final, October 29, 2007

	December 2008

Table of Contents

Chapter

I.  Emission Inventory

II. Reasonably Further Progress Plans

    A.  New York City-Northern New Jersey-Long Island (Northern New Jersey)

    B.  Philadelphia-Wilmington-Atlantic City (Southern New Jersey)

III. Reasonable Available Control Technology

IV. Reasonable Available Control Measures

V.  Contingency Measures

 I. 2002 Emission Inventories

The 2002 emissions were first generated by the individual Ozone Transport Region states.  MARAMA then coordinated and quality assured the 2002 inventory data, and projected it for the relevant control years.  The 2002 emissions for non-Ozone Transport Region areas within the modeling domain were obtained from other Regional Planning Organizations for their corresponding areas.  These Regional Planning Organizations included the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), the Midwest Regional Planning Organization and the Central Regional Air Planning Association.

All references to the “New Jersey SIP submittal” or “appendices” refer to the:

	The State of New Jersey Department of Environmental Protection

	State Implementation Plan (SIP) Revision for the Attainment and Maintenance of 	the Ozone National Ambient Air Quality Standard - 8-Hour Ozone Attainment Demonstration – Final October 29, 2007

The documentation for the OTC base and control modeling inventories are presented in Appendices D7 and D8, respectively, of the NJ Attainment Demonstration SIP revision.  The use of emission inventory data from the non-Mid-Atlantic/Northeast Visibility Union (MANE-VU) states is documented in Appendix D8.

Version 3 of the 2002 base year emission inventory was used in the regional modeling exercises.  A technical support document for this inventory, which is included in Appendix D7, explains the data sources, methods, and results for preparing this version of the 2002 base year criteria air pollutant and ammonia emissions inventories for point, area, on-road, non-road, and biogenic sources for the MANE-VU Regional Planning Organization.

The inventories include annual emissions for oxides of nitrogen (NOx), volatile organic compounds (VOC), carbon monoxide, ammonia, particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers (PM10) and PM2.5.  The inventories also included summer day, winter day, and average day emissions.

The inventory and supporting data prepared includes the following:

Comprehensive, county-level, mass emissions and modeling inventories for 2002 emissions for criteria air pollutants and ammonia for the State and Local agencies included in the MANE-VU region;

The temporal, speciation, and spatial allocation profiles for the MANE-VU region inventories;

Inventories for wildfires, prescribed burning, and agricultural field burning for the southeastern provinces of Canada; and

Inventories for other Regional Planning Organizations, Canada, and Mexico.

New Jersey submitted its proposed 2002 Base Year emission inventories on February 21, 2006 and final 2002 Base Year emission inventories on May 18, 2006.  EPA proposed to approve New Jersey’s 2002 Base Year inventories on May 9, 2006, (71 FR 26895) and approved the emission inventories on July 10, 2006 (71 FR 38770).  The reader is referred to these rulemakings for additional information concerning the emission inventories and EPA’s approval.

Reasonable Further Progress Plans

A.  New York City-Northern New Jersey-Long Island

(Northern New Jersey)

PREFACE

This document is to support EPA's evaluation of the 2008 and 2009 projection inventories Reasonable Further Progress (RFP) Plans included in New Jersey’s 8-Hour Ozone Attainment Demonstration State Implementation Plan (SIP) for the New Jersey portion of the New York City-Northern New Jersey-Long Island (Northern New Jersey) moderate ozone nonattainment area.  The intended effect of this action is to evaluate inventory components required by the Clean Air Act (Act) which result in emission reductions that will help achieve attainment of the National Ambient Air Quality Standard for ozone.  The 2002 ozone Base Year emissions inventory is also an integral part of the plan.  However, detailed evaluation of the 2002 inventory will not be addressed in this document.  The reader is referred to Region 2’s document entitled New Jersey State 2002 Base Year Inventory SIP Technical Support Documentation, dated April 12, 2006 for details on the approval of New Jersey’s 2002 base year inventory.

This document contains a detailed review of the New Jersey’s submittal.  Among the topics discussed below are: background, public participation and administrative requirements; criteria for approval and EPA’s final recommendation.

BACKGROUND

REASONABLY FURTHER PROGRESS AND ATTAINMENT DEMONSTRATION ELEMENTS

2002 Base Year Emissions Inventory

Section 182 of the Clean Air Act (CAA) and EPA’s 8-hour ozone regulations (40 CFR 51.910) require each moderate and above 8-hour ozone nonattainment area to submit an emissions inventory and Reasonably Further Progress (RFP) SIP revision, which describes, how the area will achieve actual emissions reductions of volatile organic compounds (VOC) and nitrogen oxides (NOx) from a baseline emissions inventory.  An emissions inventory is an estimation of actual emissions of air pollutants in an area.  The emissions inventory for an ozone nonattainment area contains VOC and NOx emissions as these pollutants are precursors to ozone formation.  In this case, the baseline emissions inventory is for the year 2002.

The 15 Percent Reasonable Further Progress Plans and Attainment Demonstration

15 Percent Reasonable Further Progress Plans

For moderate 8-hour ozone nonattainment areas with an attainment date more than 5 years after designation, a 15% reduction in ozone precursor emissions is required within six years (2002 to 2008).  For a moderate area which contains a portion of an area with an approved 15% VOC “Rate of Progress” plan under the 1-hour ozone standard, States are allowed to treat the area as two parts each with a separate RFP target.  For the part with an approved 15% VOC "Rate of Progress" plan under the 1-hour ozone standard States can use reductions from VOC or NOx or a combination of either.  For the part without an approved 15% VOC Rate of Progress plan, States must obtain VOC reductions. These VOC reductions can be obtained from the part of the area with an approved 1-hour VOC Rate of Progress plan.

Attainment Demonstration

In addition, States are required to submit SIPs that contain attainment demonstrations for their 8-hour ozone nonattainment areas within 3 years after the effective date (June 15, 2007) of an area’s designation.  The designation date for Northern New Jersey area was June 15, 2004.  These SIPs must demonstrate that the inventory (projected into the future with growth) include control measures and rules that are adequate to provide for the timely attainment and maintenance of the 8-hour ozone National Ambient Air Quality Standard of .08 ppm.

According to EPA guidance,1,6,7moderate ozone nonattainment areas that have an attainment date of no later than June 15, 2010 must implement emission reductions needed for attainment no later than the beginning of the 2009 ozone season.  Otherwise, the emission reductions will not affect the monitored ozone in 2009, which is the last ozone season before the attainment date of June 15, 2010.  In the case, the attainment inventory is 2009.

There are general and specific components for acceptable 2008, and 2009 projection inventories, RFP and Attainment Plans.  In general, the State must submit a revision to its SIP and the aforementioned components must meet certain minimum requirements for reporting by source category.  Specifically, the source requirements are detailed below.

A review process is used to determine that all components of the projection inventories, RFP and Attainment Plans are present.  The review also evaluates the level of supporting documentation provided by the State and assesses whether the emissions were developed according to current EPA or acceptable alternative guidance.

CRITERIA FOR APPROVAL

Projection, RFP and Attainment Demonstration

There are several points that the projection inventories, RFP and Attainment Plans must adequately address.  For the projection inventories and RFP and Attainment Plans to be acceptable they must pass the following acceptance criteria:

Were the 2008, 2009 projection inventories developed in accordance with the procedures outlined EPA’s latest guidance 1,3,4,6,7?

Was the 15 Percent Plan developed in accordance with the procedures outline in EPA’s latest guidance for the Adjusted Base Year Emissions Inventory and the  Target for the 15 Percent Plans 2,3,6?

Were the Plans developed in accordance with EPA’s latest guidance for Growth Factors, Projections, and Control Strategies for the 15 Percent Rate of Progress, Post-1996 and Attainment Demonstration Plans 1,3,4,6,7?

DETAILED ACTION AND EVALUATION

This portion of the report contains a discussion and summary of the review conducted by EPA for the 2008 and 2009 projection inventories and the 15 Percent RFP Plan and Attainment Demonstration for the Northern and Southern New Jersey nonattainment areas.

Section 1:	2002 BASE YEAR INVENTORY

Calculation of 2002 Base Year Emission Inventory

The reader is referred to Region 2’s document entitled New Jersey State 2002 Base Year Inventory SIP Technical Support Documentation, dated April 12, 2006 for details on the approval of New Jersey’s 2002 base year inventory.  New Jersey submitted its proposed 2002 base year emission inventories on February 21, 2006 and final 2002 base year emission inventories on May 18, 2006.  EPA proposed to approve New Jersey’s 2002 Base Year inventories on May 9, 2006, (71 FR 26895) and approved the emission inventories on July 10, 2006 (71 FR 38770).  The reader is referred to these rulemakings for additional information concerning the emission inventories and EPA’s approval.

Table 1A below shows the revised 2002 base year volatile organic compounds (VOC) and oxides of nitrogen (NOx ) emission inventories for the Northern New Jersey ozone nonattainment area.

Table 1A: Northern New Jersey Ozone Nonattainment Area

2002 Base Year Inventory [Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

68.2

243.5

121.6

183

616.3

NOx

152.7

24.4

161

378.9

717

Table 1B

2002 VOC Base Year Emissions Inventory***

Northern New Jersey Ozone Nonattainment Area

(in Tons Per Day)

	POINT	AREA	ONROAD	NONROAD

BERGEN	5.72	36.86	36.09	22.05

ESSEX	2.95	31.53	18.26	11.92

HUDSON	7.33	21.09	9.1	5.22

HUNTERDON	0.64	5.49	5.99	3.66

MIDDLESEX	16.08	34.87	26	14.58

MONMOUTH	1.37	24.65	22.26	21.26

MORRIS	1.27	20.81	18.87	15.09

PASSAIC	1.99	19.84	10.22	6.62

SOMERSET	0.73	12.29	10.65	6.87

SUSSEX	0.25	5.69	4.62	3.86

UNION	26.56	25.26	15.92	7.75

WARREN	2.88	5.07	4.99	2.78

TOTAL	67.77	243.45	182.97	121.66

Table 1C

2002 NOx Base Year Emissions Inventory***

Northern New Jersey Ozone Nonattainment Area

 (in Tons Per Day)

	POINT	AREA	ONROAD	NONROAD

BERGEN	3.64	3.83	63.24	23.38

ESSEX	16.18	3.31	44.06	25.7

HUDSON	51.61	2.24	21.05	20.71

HUNTERDON	9.47	0.54	17.17	4.7

MIDDLESEX	44.47	3.33	58	17.54

MONMOUTH	0.86	2.23	38.15	15.74

MORRIS	1.18	2.4	35.06	11.58

PASSAIC	0.68	1.79	23.01	8.88

SOMERSET	3.6	1.44	23.85	7.57

SUSSEX	0.21	0.57	7.47	2.46

UNION	18.88	2.26	32.22	20.25

WARREN	1.93	0.47	15.6	2.48

TOTAL	152.71	24.41	378.88	160.99

***From April 2006 TSD.

Section 2:  Calculation of 2008 and 2009 Projection Year Emission Inventories

A projection of 2002 VOC anthropogenic emissions to 2008, and 2009 is required to determine the VOC reductions needed for 15 percent and attainment demonstration plan.   In addition, projection of the 2002 VOC and NOx anthropogenic emissions to 2008 and 2009 is required to determine the reductions needed for plans.  The 2008 and 2009 projection year emission inventories are calculated by multiplying the 2002 base year inventory by factors which estimate growth from 2002 to 2008 and 2009.  A specific growth factor for each source type in the inventory is required since sources typically grow at different rates.

The difference between the 2002 base year inventory and the 2008, and 2009 projection inventories are the emissions growth estimates.  Based on the difference between the 2002 inventory and the 2008 and 2009 projection year inventories, the total growth from 2002 to 2008 and 2009 for the four VOC source categories (point, area, non-road and on-road mobile) in the Northern New Jersey ozone nonattainment area is estimated at -7.1, and -1.3 tons per day (tpd), respectively.  The total growth from 2002 to 2008 and 2009 for the four NOx sources categories in the Northern New Jersey ozone nonattainment area is estimated at -149.2 and -139 tpd, respectively.

Projection Methodology

 ADVANCE \d14 Major Point Sources

 tc \l3 "Major Point Sources

For the major point source category, the projected emissions inventories were first calculated by estimating growth in each source category.  As appropriate, the 2002 actual emissions inventory was used as the base for applying factors to account for inventory growth.  The 2005 actual inventory was also calculated.  The point source inventory was grown from the 2005 inventory to 2008 and 2009 for each facility using growth factors by source classification codes utilized in EPA’s Economic Growth Analysis System (EGAS) version 4.0 and the United States Department of Energy’s (USDOE) Annual Energy Outlook Projections.

 The reader is referred to Chapter 6 of New Jersey’s Department of Environmental Protection SIP Revision for the Attainment and Maintenance of the Ozone NAAQS, 8-Hour Ozone Attainment Demonstration, Final, dated October 29, 2007.  This document provides further details and references on how projections were performed.

Since these growth indicators are some of the preferred growth indicators to use as outlined in EPA Guidance, 1,3,4,6,7EPA finds New Jersey’s methodology for projecting point sources to be acceptable.

Area Sources

For the area source category, New Jersey projected emissions from 2002 to 2008 and 2008 using state population projections, USDOE’s fuel consumption projections and employment projections from the New Jersey Department of Labor, where appropriate; state specific product output data for pesticides, asphalt paving and traffic lane mileage, and the landfill model projection data for landfill source category.  This is in accordance with EPA’s recommended growth indicators for projecting emissions for area source categories as outlined in EPA Guidance. 1,3,4,6,7

The reader is referred to Chapter 6 of  New Jersey’s Department of Environmental Protection SIP Revision for the Attainment and Maintenance of the Ozone NAAQS, 8-Hour Ozone Attainment Demonstration, Final, dated October 29, 2007.  This document provides further details and references on how projections were performed.

EPA finds New Jersey’s methodology for projecting area sources to be acceptable.

Non-Road Mobile Sources

Non-road vehicle equipment emissions were projected from 2002 to 2008 and 2009 using the NONROAD 2005.  The NONROAD 2005 model contains growth factors, which are based on the historical trends in nonroad equipment activity. This model was use to calculate past and future emission inventories for all nonroad equipment categories except commercial marine vessels, locomotives and aircrafts.

Aircrafts

Aircraft emissions were projected based on future aircraft landing and take off operations (LTO) information supplied by major and military airports and data obtained from the Federal Aviation Administration’s flight operations database for other airports in New Jersey.  The LTO counts were inputted to the Federal Aviation Agency’s modeling tool called the Emissions and Dispersion Modeling System tool.

Locomotives

Locomotive growth is based on the annual quantity of fuel consumed by locomotives from 2002 to projection years 2008 and 2009.

Commercial Marine Vessels

The 2008 and 2009 projection year inventories were determined by growing the emissions from 2002 base year inventory.  New Jersey used the future emission inventories contained in EPA's document Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines, dated November 1999, to develop 2008 and 2009 inventories by applying 2002-2008 and 2002-2009 growth factors to the 2002 inventory.

EPA finds New Jersey’s methodology for projecting non-road mobile sources to be acceptable.

Onroad Mobile Sources

For the onroad mobile source category, the primary indicator and tool for developing on-road mobile growth and expected emissions are vehicle miles traveled (VMT) and US EPA’s mobile emissions model Mobile 6.2.03 (Mobile6).  The 2008, and 2009 VOC and NOx emission factors were generated by Mobile6 and applied to the daily VMT (DVMT) projections provided by the three metropolitan planning organizations.

The reader is referred to Chapter 6 of New Jersey’s Department of Environmental Protection SIP Revision for the Attainment and Maintenance of the Ozone NAAQS, 8-Hour Ozone Attainment Demonstration, Final, dated October 29, 2007.  This document provides further details and references on how projections were performed.

Since these growth indicators are some of the preferred growth indicators to use, as outlined in EPA Guidance, 1,3,4,6,7 EPA finds New Jersey’s methodology for projecting on-road mobile sources to be acceptable.

Tables 2A, and 2B show 2008, and 2009 VOC and NOx projection emission inventories (uncontrolled after 2002 using the aforementioned growth indicators/methodologies for the Northern New Jersey ozone nonattainment area.

Tables 2C and 2D show 2008, and 2009 VOC and NOx projection emission inventories controlled after 2002 using the aforementioned growth indicators/methodologies for the Northern New Jersey ozone nonattainment area.

Table 2A

Northern New Jersey Area

2008 Projection Year Inventory (Uncontrolled)

 [Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

50.5

252.7

134

172

609.2

NOx

110.9

24.7

144.9

287.3

567.8

Table 2B

Northern New Jersey Area

2009 Projection Year Inventory (Uncontrolled)

[Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

50.9

254.1

135.6

174.4

615

NOx

113.8

24.9

147.1

292.2

578

Table 2C

Northern New Jersey Area

2008 Projection Year Inventory (Controlled)

 [Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

50.5

218.7

87.9

85.3

442.4

NOx

51.3

21.8

120.9

143.6

337.6

Table 2D

Northern New Jersey Area

2009 Projection Year Inventory (Controlled)

[Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

48.9

210.8

82.2

79

420.9

NOx

53.8

22

117.2

133.5

326.5

Section 3:   2008 RFP Demonstration

Section 3A:   15% VOC RFP Plan or 2008  RFP Demonstration

Steps involved in calculating the 2002 Percent RFP Plan:

Preparation of 2002 Anthropogenic Base Year Ozone Season Emission Inventory

Calculation of a 2002 Rate-of-Progress VOC (Baseline) Emission Inventory

Calculation of a 2002 Adjusted Baseline Emission Inventory for 2008

Calculation of the 2008 Reduction Requirement

Calculation of the non-creditable emission reductions

Calculation of Total Expected Reductions

Calculation of the 2008 Target Inventory

Calculation of Emission Reductions Require to Meet the 2008 Target Level

Calculation of 2008 Projection Year Inventory

Preparation of 2002 VOC Base Year Ozone Season Anthropogenic Emission Inventory

The reader is referred to Section 1 of this document.

 ADVANCE \d14 Calculation of a 2002 VOC Rate-of-Progress (Baseline) Emission Inventory

 tc \l3 "Calculation of a 1990 VOC Rate-of-Progress (Baseline) Emission Inventory

The reader is referred to procedure outlined in Section 2 this document.  The reader is referred to Table 3A for the calculation.

Calculation of a 2002 VOC Adjusted Baseline Emission Inventory for 2008

The 2002 adjusted baseline emission inventory for 2002 is calculated by subtracting from the 2002 baseline emission inventory the emission benefits from the pre-1990 Clean Air Act Federal Motor Vehicle Control Program (FMVCP).

The pre-1990 FMVCP reductions were determined by taking the difference between the 2002 highway mobile source emission inventory and the 2002 adjusted baseline highway mobile source emission inventory for 2008.

To estimate the expected reductions from FMVCP standards, the State prepared an additional mobile source emission inventory using the Mobile6 emission factor model, and changed the certain input variables to disable the modeling of 1990 Clean Air Act effects.  The resulting inventory is referred to as the Adjusted Baseline Highway Inventory.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey calculated the 2002 Adjusted Base Year Inventory for 2008 in accordance with EPA guidance.

Calculation of the 2008 Reduction Requirements

New Jersey calculated the required reductions by multiplying the 2002 adjusted baseline emission inventory for 2008 by 0.15.  The reader is referred to Table 3A for the calculations. This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey calculated the 2008 percent reduction requirement in accordance with EPA guidance.

Calculation of the non-creditable emission reductions

The 15 percent RFP Plan non-creditable reduction category (FMVCP) applies for the 2008 Percent RFP plans.  The reader is referred to Table 3A for the calculation.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey has calculated the non-creditable emission reductions in accordance with EPA guidance.

Calculation of Total Expected Reductions for 2008

New Jersey calculated the total expected reductions for the year 2008 by taking the sum of the non-creditable emission reductions and the 15 Percent RFP reduction requirements, respectively.  The reader is referred to Table 3A for the calculation.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

Calculation of the 2008 Target Inventory

New Jersey calculated the 2008 target inventory by subtracting the required  Percent reductions for 2008 and the non-creditable emission reductions from the 2002 baseline emission inventory. The reader is referred to Table 3A for the calculations.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey has calculated the 2008 target inventory in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of Total Emission Reductions Needed to Reach 2008 Target Levels

New Jersey calculated the total emission reductions needed to reach 2008 target levels by taking the difference between the 2008 projected emission inventory (with no additional post-2002 control measures) and the 2008 target inventory.  The reader is referred to Table 3A for the calculations.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey has calculated the 2008 total emission reductions needed to reach the 2008 target levels in accordance with EPA guidance.

Calculation of the 2008 Projection Year Inventory

The reader is referred to Section 2 of this document for more details.  This was done in accordance with the procedures outlined EPA guidance.1,3,4,6,7

New Jersey has followed EPA guidance in calculating the 2008 projection year emission inventory.

Table 3A provides a summary of the emission inventories calculated above.

 Table 3A

------------------------------------------------------------------------ -----------

2008 VOC Emissions (Tons/Day)

Northern New Jersey Ozone Nonattainment Area ------------------------------------------------------------------------ ------------------------

A. 2002 Anthropogenic Base Year Emissions Inventory	616.30

B. 2002 Rate-of-Progress Inventory	616.30

C. Emission Reds. from the Pre-1990 FMVCP and Phase II RVP Expected by 2002	 13.30

D. 2002 Adjusted Base Year Inventory(B-C)	 603.00

E. 15% Percent Reduction Requirement (D x 0.15)	 90.45

F. Total Expected Reductions (E + C) 	 103.75

G. 2008 Target Level of Emissions (B - F)	512.55

H. 2008 Projection Year Inventory (B + growth & offsets)	609.20

I. Total Emission reductions needed to reach 2008 Target Level (H - G) 96.65

------------------------------------------------------------------------ ----------------------------

Section 3B:  2008 or 15% RFP Control Measures

Table 3B

VOC Emission Reduction Measures Included in the Northern New Jersey 2008 (15%) RFP Plan

VOC CONTROL MEASURES

NORTHERN NJ OZONE NAA

(TONS PER DAY)

REQUIRED REDUCTION IN VOC TO MEET 2008 MILESTONE

96.65

POINT SOURCE CONTROL MEASURES

	NOX BUDGET PROGRAM	0

NOX RACT RULE 2006	0

CAIR	0

EPA MACT STANDARDS	0

CERTAIN CATEGORY OF ICI BOILERS	0

ACO-PSEG	0

REFINERY ENFORCEMENT INITIAVE	0

NON-ROAD MOBILE SOURCE CONTROL MEASURES

	PORTABLE FUEL CONTAINERS 2005	1

NONROAD MODEL FERERAL CONTROL MEASURES

45

PORTABLE FUEL CONTAINERS 2009 AMENDMENTS

0

ON-ROAD  MOBILE SOURCE CONTROL MEASURES

STAGE II (GASOLINE TRANSFER OPERATIONS)

1.3

ONBOARD DIAGNOSTIC (OBD) I/M	2.9

TOTAL FEDERAL CONTROL MEASURES BENEFITS IN MOBILE MODEL

82.5

NJLEV	0

STATIONARY AREA SOURDE CONTOL MEASURES

	ARCHITECTURAL SURFACE COATING 2005

15

AUTOBODY (MOBILE EQUIPMENT REPAIR AND REFINISHIING)

1.5

SOLVENT CLEANING (DEGREASING)	2.4

CONSUMER PRODUCTS 2005	6.7

CONSUMER PRODUCTS 2009 AMENDMENTS

0

PORTABLE FUEL CONTAINERS (2005 AND 2009)

2.6

STAGE I (GASOLINE TRANSFER OPERATIONS-BALANCED SUBMERGED FILLING)

5.9

NOX RACT RULE 2006	0

RESIDENTIAL WOODSTOVES NSPS	0

ADHESIVES AND SEALANTS	0

ASPHALT PAVING (CUTBACK AND EMULSIFIED)	0

TOTAL VOC BENEFITS FROM ALL SOURCES

166.8

VOC SHORTFALL = (VOC REDUCTIONS NEEDED TO MEET TARGET LEVEL) – (VOC BENEFITS FROM ALL SOURCES)

96.65-166.8 = -70.15

VOC PLAN PRESULTS IN 70.15 TPD SURPLUS

Based on Table 3B, New Jersey’s VOC control plan meets the 15 Percent Plan reduction requirements.  It results in 70.15 tpd surplus.

In addition, the New Jersey plan also controls NOx sources.  Since there is a surplus in the VOC control plan all NOx emissions except those due to the pre-1990 FMVCP reductions and correction of deficiencies in RACT rules are consider as surplus emissions from 2002-2008.Section 3C:   NOx Substitution Requirements to Satisfy the 0% Shortfall

Steps involved in calculating the NOx Reductions Needed to Satisfy the 0% Percent shortfall:

	Preparation of 1990 NOx Base Year Ozone Season Emission Inventory

	Calculation of a 1990 Rate-of-Progress NOx  (Baseline) Emission Inventory

	Calculation of a 1990 NOx Adjusted Baseline Emission Inventory for 2002

	Calculation of the 0%  Reduction Requirement

	Calculation of the non-creditable emission reductions

	Calculation of Total Expected Reductions

	Calculation of the NOx 2002 Target Inventory

	Calculation of Emission Reductions Require to Meet the 2002 Target Level

	Calculation of 2002 Projection Year Inventory

Preparation of 2002 NOx Base Year Ozone Season Emission Inventory

The reader is referred to Section 1 of this document.

 ADVANCE \d14

 tc \l3 " Calculation of a 2002 NOx Rate-of-Progress (Baseline) Emission Inventory

The reader is referred to Section 2 (same procedure as VOC is applied here) is applied  this document.  The reader is referred to Table 3C for the calculation.

 ADVANCE \d14

 tc \l3 " Calculation of a 2002 NOx Adjusted Baseline Emission Inventory for 2008

The 2002 adjusted baseline emission inventory for 2002 is calculated by subtracting from the 2002 baseline emission inventory the emission benefits from the pre-1990 Clean Air Act FMVCP.

The pre-1990 FMVCP reductions were determined by taking the difference between the 2002 highway mobile source emission inventory and the 2002 adjusted baseline highway mobile source emission inventory for 2008.

To estimate the expected reductions from FMVCP standards, the State prepared an additional mobile source emission inventory using the Mobile^ emission factor model, and changed the input variables to disable the modeling of 1990 Clean Air Act effects.  The resulting inventory is referred to as the Adjusted Baseline Highway Inventory.  This was done in accordance with the procedures outlined in EPA Guidance. 2,3,6

New Jersey calculated the 2002 NOx Adjusted Base Year Inventory in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of the 0% Reduction Requirement

New Jersey calculated the required 0 percent reductions by multiplying the 2002 adjusted baseline emission inventory for 2008 by 0.  The reader is referred to Table 3C  for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

New Jersey calculated the 0 percent reduction requirement in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of the non-creditable emission reductions

The same 15 percent RFP non-creditable reduction category (FMVCP) applies as for the NOx RFP plan.  The reader is referred to Table 3C for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

New Jersey has calculated the non-creditable emission reductions in accordance with EPA guidance.

Calculation of Total Expected NOx Reductions for 2002

New Jersey calculated the total expected reductions by taking the sum of the non-creditable emission reductions and the 0 Percent reduction requirement.  The reader is referred to Table 3C for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

Calculation of the 2008 Target Inventory

New Jersey calculated the 2008 target inventory by subtracting the required Percent reductions for 2008 and the non-creditable emission reductions from the 2002 baseline emission inventory. The reader is referred to Table 3C  for the calculation.   This was done in accordance with the procedures in EPA Guidance.2,3,6

 New Jersey has calculated the 2008 target inventory in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of Total Emission Reductions Needed to Reach 2008 Target Level

New Jersey calculated the total emission reductions needed to reach 2008 NOx target level by taking the difference between the 2008 projected emission inventory (with no additional control measures and including any pre-1990 banked emission reduction credits) and the 2008 NOx target inventory.  The reader is referred to Table 4C for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

 tc \l3 " New Jersey has calculated the total emission reductions needed to reach 2008 target level in accordance with EPA guidance.

Calculation of the 2008 Projection Year Inventory

The reader is referred to Section 2 of this document for more details.  This was done in accordance with the procedures in EPA Guidance.1,3,4,6,7

New Jersey has followed EPA guidance in calculating its 2008 projection year emission inventory.

Table 3C  provides a summary of the emission inventories calculated above.

Table 3C

------------------------------------------------------------------------ ------------------------------------------

2008 NOx Emissions (Tons/Day) Northern-New Jersey NAA ------------------------------------------------------------------------ ------------------------------------------

A. 2002 Anthropogenic Base Year Emissions Inventory	717.00

B. 2002 Rate-of-Progress Inventory	717.00

C. Emission Reductions from the Pre-1990 FMVCP and Phase II RVP Expected by 2008	 6.90

D. 2002 Adjusted Base Year Inventory(B-C)	 710.10

E. 0% Percent Reduction Requirement (D x 0.00)	 0.00

F. Total Expected Reductions (E + C) 	6.90

G. 2008 Target Level of Emissions (B - F)	710.10

H. 2008 Projection Year Inventory (B + growth & offsets)	567.80

I. Total Emission reductions needed to reach 2008 NOx Target Level (H - G)	-142.3

------------------------------------------------------------------------ ------------------------------------------

The 2008 projection inventory is 142.3 tpd below the 2008 Target level, therefore no NOx emission reduction are necessary to meet the 2008 target level.

Section 3D:  NOx Control Measures to Satisfy the 0% Shortfall

Table 3D

2008 NOx Emission Reduction Measures Included in the Northern New Jersey Plan

NOX CONTROL MEASURES

NORTHERN NJ OZONE NAA

(TONS PER DAY)

REQUIRED REDUCTION IN NOX TO MEET 2008 MILESTONE

0

POINT SOURCE CONTROL MEASURES

	NOX BUDGET PROGRAM	44

NOX RACT RULE 2006	4.5

CAIR	0

EPA MACT STANDARDS	0

CERTAIN CATEGORY OF ICI BOILERS	0

ACO-PSEG	11.1

REFINERY ENFORCEMENT INITIATIVE	0

NON-ROAD MOBILE SOURCE CONTROL MEASURES

	PORTABLE FUEL CONTAINERS 2005	0

NONROAD MODEL FEDERAL CONTROL MEASURES

24

PORTABLE FUEL CONTAINERS 2009 AMENDMENTS

0

ON-ROAD  MOBILE SOURCE CONTROL MEASURES

STAGE II (GASOLINE TRANSFER OPERATIONS)	0

ONBOARD DIAGNOSTIC (OBD) I/M	4.2

TOTAL FEDERAL CONTROL MEASURES BENEFITS IN MOBILE MODEL

139.5

NJLEV	0

STATIONARY AREA SOURCE CONTOL MEASURES

	ARCHITECTURAL SURFACE COATING 2005	0

AUTOBODY (MOBILE EQUIPMENT REPAIR AND REFINISHIING)

0

SOLVENT CLEANING (DEGREASING)	0

CONSUMER PRODUCTS 2005	0

CONSUMER PRODUCTS 2009 AMENDMENTS	0

PORTABLE FUEL CONTAINERS (2005 AND 2009)	0

STAGE I (GASOLINE TRANSFER OPERATIONS-BALANCED SUBMERGED FILLING)

0

NOX RACT RULE 2006	2.9

RESIDENTIAL WOODSTOVES NSPS	0

ADHESIVES AND SEALANTS	0

ASPHALT PAVING (CUTBACK AND EMULSIFIED)	0

TOTAL VOC BENEFITS FORM ALL SOURCES

	230.2

VOC SHORTFALL = (VOC REDUCTIONS NEEDED TO MEET TARGET LEVEL) – (VOC BENEFITS FROM ALL SOURCES)

0 -230.2= -230.2

NOX PLAN RESULTS IN 230.2 TPD IN REDUCTIONS

Based on Table 3D, New Jersey’s NOx plan satisfies the 0 percent shortfall.  It results in 230.2 tpd NOx in reductions.

B.  Philadelphia-Wilmington-Atlantic City

(Southern New Jersey)

PREFACE

This document is to support EPA's evaluation of the 2008 and 2009 projection inventories Reasonable Further Progress (RFP) Plans included in New Jersey’s 8-Hour Ozone Attainment Demonstration State Implementation Plan (SIP) for the Philadelphia-Wilmington-Atlantic City (Southern New Jersey) moderate ozone nonattainment area.  The intended effect of this action is to evaluate inventory components required by the Clean Air Act (Act) which result in emission reductions that will help achieve attainment of the National Ambient Air Quality Standard for ozone.  The 2002 ozone base year Emission Inventory is also an integral part of the plan.  However, detailed evaluation of the 2002 inventory will not be addressed in this document.  The reader is referred to Region 2’s document entitled New Jersey State 2002 Base Year Inventory SIP Technical Support Documentation, dated April 12, 2006 for details on the approval of New Jersey’s 2002 base year inventory.

This document contains a detailed review of the New Jersey’s submittal.  Among the topics discussed below are: background, public participation and administrative requirements; criteria for approval and EPA’s final recommendation.

BACKGROUND

REASONABLE FURTHER PROGRESS AND ATTAINMENT DEMONSTRATION ELEMENTS

2002 Base Year Emissions Inventory

Section 182 of the Clean Air Act (CAA) and EPA’s 8-hour ozone regulations (40 CFR 51.910) require each moderate and above 8-hour ozone nonattainment area to submit an emissions inventory and RFP SIP revision, which describes, how the area will achieve actual emissions reductions of volatile organic compounds (VOC) and nitrogen oxides (NOx) from a baseline emissions inventory.  An emissions inventory is an estimation of actual emissions of air pollutants in an area.  The emissions inventory for an ozone nonattainment area contains VOC and NOx emissions as these pollutants are precursors to ozone formation.  In this case, the baseline emissions inventory is for the year 2002.

The 15 Percent Reasonable Further Progress Plans and Attainment Demonstration

15 Percent Reasonable Further Progress Plans

For moderate 8-hour ozone nonattainment areas with an attainment date more than 5 years after designation, a 15% reduction in ozone precursor emissions is required within six years (2002 to 2008).  For a moderate area which contains a portion of an area with an approved 15% VOC “Rate of Progress” plan under the 1-hour ozone standard, States are allowed to treat the area as two parts each with a separate RFP target.  For the part with an approved 15% VOC "Rate of Progress" plan under the 1-hour ozone standard States can use reductions from VOC or NOx or a combination of either.  For the part without an approved 15% VOC Rate of Progress plan, States must obtain VOC reductions. These VOC reductions can be obtained from the part of the area with an approved 1-hour VOC Rate of Progress plan.

Attainment Demonstration

In addition, States are required to submit SIPs that contain attainment demonstrations for their 8-hour ozone nonattainment areas within 3 years after the effective date (June 15, 2007) of an area’s designation.  The designation date for the Southern New Jersey area was June 15, 2004.  These SIPs must demonstrate that the inventory (projected into the future with growth) include control measures and rules that are adequate to provide for the timely attainment and maintenance of the 8-hour ozone National Ambient Air Quality Standard of .08 ppm.

According to EPA guidance,1,6,7moderate ozone nonattainment areas that have an attainment date of no later than June 15, 2010 must implement emission reductions needed for attainment no later than the beginning of the 2009 ozone season.  Otherwise, the emission reductions will not affect the monitored ozone in 2009, which is the last ozone season before the attainment date of June 15, 2010.  In the case, the attainment inventory is 2009.

There are general and specific components for acceptable 2008, and 2009 projection inventories, RFP and Attainment Plans.  In general, the State must submit a revision to its SIP and the aforementioned components must meet certain minimum requirements for reporting by source category.  Specifically, the source requirements are detailed below.

A review process is used to determine that all components of the projection inventories, RFP and Attainment Plans are present.  The review also evaluates the level of supporting documentation provided by the State and assesses whether the emissions were developed according to current EPA or acceptable alternative guidance.

Projection, RFP and Attainment Demonstration

There are several points that the projection inventories, RFP and Attainment Plans must adequately address.  For the projection inventories RFP and Attainment Plans to be acceptable they must pass the following acceptance criteria:

1.  Were the 2008, 2009 projection inventories developed in accordance with the procedures outlined EPA’s latest guidance 1,3,4,6,7?

2.  Was the 15 Percent Plan developed in accordance with the procedures outline in EPA’s latest guidance for the Adjusted Base Year Emissions Inventory and the  Target for the 15 Percent Plans 2,3,6?

3.  Were the Plans developed in accordance with EPA’s latest guidance for Growth Factors, Projections, and Control Strategies for the 15 Percent Rate of Progress, Post-1996 and Attainment Demonstration Plans 1,3,4,6,7?

Section 1:	2002 Base Year Emission Inventory

Calculation of 2002 Base Year Emission Inventory

The reader is referred to Region 2’s document entitled New Jersey State 2002 Base Year Inventory SIP Technical Support Documentation, dated April 12, 2006 for details on the approval of New Jersey’s 2002 base year inventory.  New Jersey submitted its proposed 2002 base year emission inventories on February 21, 2006 and final 2002 base year emission inventories on May 18, 2006.  EPA proposed to approve New Jersey’s 2002 Base Year inventories on May 9, 2006, (71 FR 26895) and approved the emission inventories on July 10, 2006 (71 FR 38770).  The reader is referred to these rulemakings for additional information concerning the emission inventories and EPA’s approval.

Table 1A below shows the revised 2002 base year volatile organic compounds (VOC) and oxides of nitrogen (NOx ) emission inventories for the Southern New Jersey ozone nonattainment areas.

Table 1A

Southern New Jersey Ozone Nonattainment Area

2002 Base Year Inventory [Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

45.4

126.4

99

91.8

362.6

NOx

127.7

11.5

70.6

179.8

389.6

Table 1B

2002 Base Year Emissions Inventory

Southern New Jersey Ozone Nonattainment Area

VOC

(in Tons Per Day)

	POINT	AREA	ONROAD	NONROAD

ATLANTIC	0.15	11.04	12.85	10.25

BURLINGTON	4.02	17.54	15.8	10.01

CAMDEN	1.23	22.68	13.8	7.23

CAPE MAY	0.2	5.26	4.72	22.61

CUMBERLAND	0.46	8.93	5.37	11.03

GLOUCESTER	32.01	20.39	9.1	5.91

MERCER	2.13	13.06	11.6	7.01

OCEAN	0.26	24.01	14.3	21.54

SALEM	4.92	3.47	4.23	3.37

TOTAL	45.38	126.38	91.77	98.96

Table 1C

2002 Base Year Emissions Inventory

Southern New Jersey Ozone Nonattainment Area

NOx

(in Tons Per Day)

	POINT	AREA	ONROAD	NONROAD

ATLANTIC	1.67	1.17	24.5	6.26

BURLINGTON	12.35	1.77	31.1	12.88

CAMDEN	2.69	2.1	27	9.44

CAPE MAY	19.15	0.42	8.82	5.92

CUMBERLAND	10.5	0.65	10.61	7.94

GLOUCESTER	14.48	1.01	18.5	8.01

MERCER	47.87	1.72	22.7	9.32

OCEAN	3.68	2.39	24.65	7.57

SALEM	15.36	0.31	11.91	3.21

TOTAL	127.75	11.54	179.79	70.55

Section 2:	 Calculation of 2008 and 2009 Projection Year Emission Inventories

A projection of 2002 VOC anthropogenic emissions to 2008, and 2009 is required to determine the VOC reductions needed for 15 percent and attainment demonstration plan.   In addition, projection of the 2002 VOC and NOx anthropogenic emissions to 2008 and 2009 is required to determine the reductions needed for plans. The 2008 and 2009 projection year emission inventories are calculated by multiplying the 2002 base year inventory by factors which estimate growth from 2002 to 2008 and 2009.  A specific growth factor for each source type in the inventory is required since sources typically grow at different rates.

The difference between the 2002 base year inventory and the 2008, and 2009 projection inventories are the emissions growth estimates.  Based on the difference between the 2002 inventory and the 2008 and 2009 projection year inventories, the total growth from 2002 to 2008 and 2009 for the four VOC source categories (point, area, non-road and on-road mobile) in the Southern New Jersey ozone nonattainment area is estimated at -.3 and 1.7 tons per day (tpd), respectively.  The total growth from 2002 to 2009 growth for the four NOx sources categories in the Southern New Jersey ozone nonattainment area is estimated at -12.32 and -5.27 tpd, respectively.

Projection Methodology

 ADVANCE \d14 Major Point Sources

 tc \l3 "Major Point Sources

For the major point source category, the projected emissions inventories were first calculated by estimating growth in each source category.  As appropriate, the 2002 actual emissions inventory was used as the base for applying factors to account for inventory grown.  The 2005 actual inventory was also calculated.  The point source inventory was growth from the 2005 inventory to 2008 and 2009 for each facility using growth factors by source classification codes utilized in EPA’s Economic Growth Analysis System (EGAS) version 4.0 and the United States Department of Energy’s (USDOE) Annual Energy Outlook Projections.

The reader is referred to Chapter 6 of New Jersey’s Department of Environmental Protection SIP Revision for the Attainment and Maintenance of the Ozone NAAQS, 8-Hour Ozone Attainment Demonstration, Final, dated October 29, 2007.  This document provides further details and references on how projections were performed.

Since these growth indicators are some of the preferred growth indicators to use, as outlined in EPA Guidance, 1,3,4,6,7EPA finds New Jersey’s methodology for projecting point sources to be acceptable.

Area Sources

For the area source category, New Jersey projected emissions from 2002 to 2008 and 2008 using state population projections, USDOE fuel consumption projections, employment projections from the New Jersey Department of Labor, where appropriate; state specific product output data for pesticides, asphalt paving and traffic lane mileage, and the landfill model projection data for landfill source category.  This is in accordance with EPA’s recommended growth indicators for projecting emissions for area source categories as outlined in EPA Guidance. 1,3,4,6,7

The reader is referred to Chapter 6 of  New Jersey’s Department of Environmental Protection SIP Revision for the Attainment and Maintenance of the Ozone NAAQS, 8-Hour Ozone Attainment Demonstration, Final, dated October 29, 2007.  This document provides further details and references on how projections were performed.

EPA finds New Jersey’s methodology for projecting area sources to be acceptable.

Non-Road Mobile Sources

Non-road vehicle equipment emissions were projected from 2002 to 2008 and 2009 using the NONROAD 2005.  The NONROAD 2005 model contains growth factors, which are based on the historical trends in nonroad equipment activity. This model was use to calculate past and future emission inventories for all nonroad equipment categories except commercial marine vessels, locomotives and aircrafts.

Aircrafts

Aircraft emissions were projected based on future aircraft landing and take off operations (LTO) information supplied by major and military airports and data obtained from the Federal Aviation Administration’s flight operations database for other airports in New Jersey.  The LTO counts were inputted to the Federal Aviation Agency’s modeling tool called the Emissions and Dispersion Modeling System tool.

Locomotives

Locomotive growth is based on the annual quantity of fuel consumed by locomotives from 2002 to projection years 2008 and 2009.

Commercial Marine Vessels

The 2008 and 2009 projection year inventories were determined by growing the emissions from 2002 base year inventory.  New Jersey used the future emission inventories contained in EPA's document Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines, dated November 1999 to develop 2008 and 2009 inventories by applying 2002-2008 and 2002-2009 growth factors to the 2002 inventory.

EPA finds New Jersey’s methodology for projecting non-road mobile sources to be acceptable.

Onroad Mobile Sources

For the onroad mobile source category, the primary indicator and tool for developing on-road mobile growth and expected emissions are vehicle miles traveled (VMT) and US EPA’s mobile emissions model Mobile 6.2.03 (Mobile6).  The 2008, and 2009 VOC and NOx emission factors were generated by Mobile6 and applied to the daily VMT (DVMT) projections provided by the three metropolitan planning organizations.

The reader is referred to Chapter 6 of New Jersey’s Department of Environmental Protection SIP Revision for the Attainment and Maintenance of the Ozone NAAQS, 8-Hour Ozone Attainment Demonstration, Final, dated October 29, 2007.  This document provides further details and references on how projections were performed.

Since these growth indicators are some of the preferred growth indicators to use, as outlined in EPA Guidance, 1,3,4,6,7 EPA finds New Jersey’s methodology for projecting on-road mobile sources to be acceptable.

Tables 2A, and 2B show 2008, and 2009 VOC and NOx projection emission inventories (uncontrolled after 2002) using the aforementioned growth indicators/methodologies for the Southern New Jersey ozone nonattainment area.

Tables 3A and 3B show 2008, and 2009 VOC and NOx projection emission inventories (uncontrolled after 2002) using the aforementioned growth indicators/methodologies for the Southern New Jersey ozone nonattainment area.

Table 2A

Southern New Jersey Area

2008 Projection Year Inventory (Uncontrolled)

 [Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

28

130.3

104.8

99.2

362.3

NOx

92.5

11.7

70.98

202.1

377.28

Table 2B

Southern New Jersey Area

2009 Projection Year Inventory (Uncontrolled)

[Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

28

130.8

104.7

100.8

364.3

NOx

95

11.8

72.03

205.5

384.33

Table 3A

Southern New Jersey Area

2008 Projection Year Inventory (Controlled)

 [Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

28

114.8

80.1

48.8

271.7

NOx

17.5

10.5

63.18

111.3

202.48

Table 3B

Southern New Jersey Area

2009 Projection Year Inventory (Controlled)

[Ozone Season VOC and NOx Emissions (Tons/Day)]

Pollutant

Major Point Sources

Area Sources

Nonroad Mobile Sources

Onroad Mobile Sources

Total

VOC

26

110.3

76.2

45.4

257.9

NOx

25.9

10.6

62.13

105.9

204.53

Section 3: 2008 RFP Demonstration

Section 3A:   15% VOC RFP Plan or 2008  RFP Demonstration

Steps involved in calculating the 2002 Percent RFP Plan:

Preparation of 2002 Anthropogenic Base Year Ozone Season Emission Inventory

Calculation of a 2002 Rate-of-Progress VOC (Baseline) Emission Inventory

Calculation of a 2002 Adjusted Baseline Emission Inventory for 2008

Calculation of the 2008 Reduction Requirement

Calculation of the non-creditable emission reductions

Calculation of Total Expected Reductions

Calculation of the 2008 Target Inventory

Calculation of Emission Reductions Require to Meet the 2008 Target Level

Calculation of 2008 Projection Year Inventory

Preparation of 2002 VOC Base Year Ozone Season Anthropogenic Emission Inventory

The reader is referred to Section 1 of this document.

 ADVANCE \d14 Calculation of a 2002 VOC Rate-of-Progress (Baseline) Emission Inventory

 tc \l3 "Calculation of a 1990 VOC Rate-of-Progress (Baseline) Emission Inventory

The reader is referred to procedure outlined in Section 2 this document.  The reader is referred to Table 3A for the calculation.

Calculation of a 2002 VOC Adjusted Baseline Emission Inventory for 2008

The 2002 adjusted baseline emission inventory for 2002 is calculated by subtracting from the 2002 baseline emission inventory the emission benefits from the pre-1990 Clean Air Act Federal Motor Vehicle Control Program (FMVCP).

The pre-1990 FMVCP reductions were determined by taking the difference between the 2002 highway mobile source emission inventory and the 2002 adjusted baseline highway mobile source emission inventory for 2008.

To estimate the expected reductions from FMVCP standards, the State prepared an additional mobile source emission inventory using the Mobile6 emission factor model, and changed the certain input variables to disable the modeling of 1990 Clean Air Act effects.  The resulting inventory is referred to as the Adjusted Baseline Highway Inventory.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey calculated the 2002 Adjusted Base Year Inventory for 2008 in accordance with EPA guidance.

Calculation of the 2008 Reduction Requirements

New Jersey calculated the required reductions by multiplying the 2002 adjusted baseline emission inventory for 2008 by 0.15.  The reader is referred to Table 3A for the calculations. This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey calculated the 2008 percent reduction requirement in accordance with EPA guidance.

Calculation of the non-creditable emission reductions

The 15 percent RFP Plan non-creditable reduction category (FMVCP) applies for the 2008 Percent RFP plans.  The reader is referred to Table 3A for the calculation.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey has calculated the non-creditable emission reductions in accordance with EPA guidance.

Calculation of Total Expected Reductions for 2008

New Jersey calculated the total expected reductions for the year 2008 by taking the sum of the non-creditable emission reductions and the 15 Percent RFP reduction requirements, respectively.  The reader is referred to Table 3A for the calculation.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

Calculation of the 2008 Target Inventory

New Jersey calculated the 2008 target inventory by subtracting the required  Percent reductions for 2008 and the non-creditable emission reductions from the 2002 baseline emission inventory. The reader is referred to Table 3A for the calculations.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey has calculated the 2008 target inventory in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of Total Emission Reductions Needed to Reach 2008 Target Levels

New Jersey calculated the total emission reductions needed to reach 2008 target levels by taking the difference between the 2008 projected emission inventory (with no additional post-2002 control measures) and the 2008 target inventory.  The reader is referred to Table 3A for the calculations.  This was done in accordance with the procedures outlined in EPA Guidance.2,3,6

New Jersey has calculated the 2008 total emission reductions needed to reach the 2008 target levels in accordance with EPA guidance.

Calculation of the 2008 Projection Year Inventory

The reader is referred to Section 2 of this document for more details.  This was done in accordance with the procedures outlined EPA guidance.1,3,4,6,7

New Jersey has followed EPA guidance in calculating the 2008 projection year emission inventory.

Table 3A provides a summary of the emission inventories calculated above.

 Table 3A

------------------------------------------------------------------------ -----------

2008 VOC Emissions (Tons/Day)

Southern New Jersey Ozone Nonattainment Area ------------------------------------------------------------------------ ------------------------

A. 2002 Anthropogenic Base Year Emissions Inventory	362.60

B. 2002 Rate-of-Progress Inventory	362.60

C. Emission Reds. from the Pre-1990 FMVCP and Phase II RVP Expected by 2002	 6.90

D. 2002 Adjusted Base Year Inventory(B-C)	 355.70

E. 15% Percent Reduction Requirement (D x 0.15)	 53.36

F. Total Expected Reductions (E + C) 	 60.26

G. 2008 Target Level of Emissions (B - F)	302.34

H. 2008 Projection Year Inventory (B + growth & offsets)	362.30

I. Total Emission reductions needed to reach 2008 Target Level (H - G) 59.96

------------------------------------------------------------------------ ----------------------------

Section 3B:  2008 or 15% RFP Control Measures

Table 3B

VOC Emission Reduction Measures Included in the Southern New Jersey 2008 (15%) RFP Plan

VOC CONTROL MEASURES

SOUTHERN NJ OZONE NAA

(TONS PER DAY)

REQUIRED REDUCTION IN VOC TO MEET 2008 MILESTONE

59.96

POINT SOURCE CONTROL MEASURES

	NOX BUDGET PROGRAM	0

NOX RACT RULE 2006	0

CAIR	0

EPA MACT STANDARDS	0

CERTAIN CATEGORY OF ICI BOILERS	0

ACO-PSEG	0

REFINERY ENFORCEMENT INITIAVE	0

NON-ROAD MOBILE SOURCE CONTROL MEASURES

	PORTABLE FUEL CONTAINERS 2005	.4

NONROAD MODEL FEDERAL CONTROL MEASURES

24.3

PORTABLE FUEL CONTAINERS 2009 AMENDMENTS

0

ON-ROAD  MOBILE SOURCE CONTROL MEASURES

STAGE II (GASOLINE TRANSFER OPERATIONS)	.8

ONBOARD DIAGNOSTIC (OBD) I/M	1.6

TOTAL FEDERAL CONTROL MEASURES BENEFITS IN MOBILE MODEL

48.0

NJLEV	0

STATIONARY AREA SOURCE CONTROL MEASURES

	ARCHITECTURAL SURFACE COATING 2005	7.0

AUTOBODY (MOBILE EQUIPMENT REPAIR AND REFINISHIING)

.5

SOLVENT CLEANING (DEGREASING)	.8

CONSUMER PRODUCTS 2005	3.0

CONSUMER PRODUCTS 2009 AMENDMENTS

0

PORTABLE FUEL CONTAINERS (2005 AND 2009)

1.3

STAGE I (GASOLINE TRANSFER OPERATIONS-BALANCED SUBMERGED FILLING)

2.9

NOX RACT RULE 2006	0

RESIDENTIAL WOODSTOVES NSPS	0

ADHESIVES AND SEALANTS	0

ASPHALT PAVING (CUTBACK AND EMULSIFIED)	0

TOTAL VOC BENEFITS FROM ALL SOURCES

90.6

VOC SHORTFALL = (VOC REDUCTIONS NEEDED TO MEET TARGET LEVEL) – (VOC BENEFITS FROM ALL SOURCES)

59.96-90.6 = -30.64

VOC PLAN PRESULTS IN 30.64 TPD SURPLUS

Based on Table 3B, New Jersey’s VOC control plan meets the 15 Percent Plan reduction requirements.  It results in 30.64 tpd surplus.

In addition, New Jersey has plans to control NOx sources.  Since there is a surplus in the VOC control plan, all NOx emissions except those due to the pre-1990 FMVCP reductions and correction of deficiencies in RACT rules are consider as surplus emissions from 2002-2008.

Section 3C:   NOx Substitution Requirements to Satisfy the 0% Shortfall

Steps involved in calculating the NOx Reductions Needed to Satisfy the 0% Percent shortfall:

	Preparation of 1990 NOx Base Year Ozone Season Emission Inventory

	Calculation of a 1990 Rate-of-Progress NOx  (Baseline) Emission Inventory

	Calculation of a 1990 NOx Adjusted Baseline Emission Inventory for 2002

	Calculation of the 0%  Reduction Requirement

	Calculation of the non-creditable emission reductions

	Calculation of Total Expected Reductions

	Calculation of the NOx 2002 Target Inventory

	Calculation of Emission Reductions Require to Meet the 2002 Target Level

	Calculation of 2002 Projection Year Inventory

Preparation of 2002 NOx Base Year Ozone Season Emission Inventory

The reader is referred to Section 1 of this document.

 ADVANCE \d14

 tc \l3 " Calculation of a 2002 NOx Rate-of-Progress (Baseline) Emission Inventory

The reader is referred to Section 2 (same procedure as VOC is applied here) is applied  this document.  The reader is referred to Table 3C for the calculation.

 ADVANCE \d14

 tc \l3 " Calculation of a 2002 NOx Adjusted Baseline Emission Inventory for 2008

The 2002 adjusted baseline emission inventory for 2002 is calculated by subtracting from the 2002 baseline emission inventory the emission benefits from the pre-1990 Clean Air Act FMVCP.

The pre-1990 FMVCP reductions were determined by taking the difference between the 2002 highway mobile source emission inventory and the 2002 adjusted baseline highway mobile source emission inventory for 2008.

To estimate the expected reductions from FMVCP standards, the State prepared an additional mobile source emission inventory using the Mobile^ emission factor model, and changed the input variables to disable the modeling of 1990 Clean Air Act effects.  The resulting inventory is referred to as the Adjusted Baseline Highway Inventory.  This was done in accordance with the procedures outlined in EPA Guidance. 2,3,6

New Jersey calculated the 2002 NOx Adjusted Base Year Inventory in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of the 0% Reduction Requirement

New Jersey calculated the required 0 percent reductions by multiplying the 2002 adjusted baseline emission inventory for 2008 by 0.  The reader is referred to Table 3C  for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

New Jersey calculated the 0 percent reduction requirement in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of the non-creditable emission reductions

The same 15 percent RFP non-creditable reduction category (FMVCP) applies as for the NOx RFP plan.  The reader is referred to Table 3C for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

New Jersey has calculated the non-creditable emission reductions in accordance with EPA guidance.

Calculation of Total Expected NOx Reductions for 2002

New Jersey calculated the total expected reductions by taking the sum of the non-creditable emission reductions and the 0 Percent reduction requirement.  The reader is referred to Table 3C for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

Calculation of the 2008 Target Inventory

New Jersey calculated the 2008 target inventory by subtracting the required Percent reductions for 2008 and the non-creditable emission reductions from the 2002 baseline emission inventory. The reader is referred to Table 3C  for the calculation.   This was done in accordance with the procedures in EPA Guidance.2,3,6

 New Jersey has calculated the 2008 target inventory in accordance with EPA guidance.

 ADVANCE \d14

 tc \l3 " Calculation of Total Emission Reductions Needed to Reach 2008 Target Level

New Jersey calculated the total emission reductions needed to reach 2008 NOx target level by taking the difference between the 2008 projected emission inventory (with no additional control measures and including any pre-1990 banked emission reduction credits) and the 2008 NOx target inventory.  The reader is referred to Table 3C for the calculation.  This was done in accordance with the procedures in EPA Guidance.2,3,6

 tc \l3 " New Jersey has calculated the total emission reductions needed to reach 2008 target level in accordance with EPA guidance.

Calculation of the 2008 Projection Year Inventory

The reader is referred to Section 2 of this document for more details.  This was done in accordance with the procedures in EPA Guidance.1,3,4,6,7

New Jersey has followed EPA guidance in calculating its 2008 projection year emission inventory.

Table 3C  provides a summary of the emission inventories calculated above.

Table 3C

------------------------------------------------------------------------ ------------------------------------------

2008 NOx Emissions (Tons/Day) Southern New Jersey NAA ------------------------------------------------------------------------ ------------------------------------------

A. 2002 Anthropogenic Base Year Emissions Inventory	389.60

B. 2002 Rate-of-Progress Inventory	389.60

C. Emission Reductions from the Pre-1990 FMVCP and Phase II RVP Expected by 2008	 3.90

D. 2002 Adjusted Base Year Inventory(B-C)	 385.70

E. 0% Percent Reduction Requirement (D x 0.00)	 0.00

F. Total Expected Reductions (E + C) 	3.90

G. 2008 Target Level of Emissions (B - F)	395.70

H. 2008 Projection Year Inventory (B + growth & offsets)	377.28.80

I. Total Emission reductions needed to reach 2008 NOx Target Level (H - G)	-8.42

------------------------------------------------------------------------ ------------------------------------------

The 2008 projection inventory is 8.42 tpd below the 2002 Target level, therefore no NOx emission reduction are necessary to meet the 2008 target level.

Section 3D:  NOx Control Measures to Satisfy the 0% Shortfall

Table 3D

2008 NOx Emission Reduction Measures Included in the Southern New Jersey Plan

NOX CONTROL MEASURES

SOUTHERN NJ OZONE NAA

(TONS PER DAY)

REQUIRED REDUCTION IN NOX TO MEET 2008 MILESTONE

0

POINT SOURCE CONTROL MEASURES

	NOX BUDGET PROGRAM	35.6

NOX RACT RULE 2006	2.1

CAIR	0

EPA MACT STANDARDS	0

CERTAIN CATEGORY OF ICI BOILERS	0

ACO-PSEG	37.3

REFINERY ENFORCEMENT INITIATIVE	0

NON-ROAD MOBILE SOURCE CONTROL MEASURES

	PORTABLE FUEL CONTAINERS 2005	.1

NONROAD MODEL FERERAL CONTROL MEASURES

7.7

PORTABLE FUEL CONTAINERS 2009 AMENDMENTS

0

ON-ROAD  MOBILE SOURCE CONTROL MEASURES

STAGE II (GASOLINE TRANSFER OPERATIONS)	0

ONBOARD DIAGNOSTIC (OBD) I/M	2.3

TOTAL FEDERAL CONTROL MEASURES BENEFITS IN MOBILE MODEL

88.5

NJLEV	0

STATIONARY AREA SOURDE CONTOL MEASURES

	ARCHITECTURAL SURFACE COATING 2005	0

AUTOBODY (MOBILE EQUIPMENT REPAIR AND REFINISHIING

0

SOLVENT CLEANING (DEGREASING)	0

CONSUMER PRODUCTS 2005	0

CONSUMER PRODUCTS 2009 AMENDMENTS	0

PORTABLE FUEL CONTAINERS (2005 AND 2009)	0

STAGE I (GASOLINE TRANSFER OPERATIONS-BALANCED SUBMERGED FILLING)

0

NOX RACT RULE 2006	1.2

RESIDENTIAL WOODSOTOVES NSPS	0

ADHESIVES AND SEALANTS	0

ASPHALT PAVING (CUTBACK AND EMULSIFIED)	0

TOTAL NOX BENEFITS FROM ALL SOURCES (IN TPD)

174.8

Based on Table 3D, New York’s NOx plan satisfies the 0 percent shortfall.  It results in 174.8 tpd NOx benefit.

Emission Inventory Guidance Documents

1Emission Inventory Improvement Program guidance document titled Volume X, Emission Projections, dated December 1999

2Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15 Percent Rate of Progress Plans, dated October 1992

3Guidance for Growth Factors, Projections, and Control Strategies for the 15 Percent Rate of Progress Plans, dated March 1993

4Guidance on the Post-1996 Rate of Progress Plan and Attainment Demonstration, dated January 1994?

5Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005

6EPA’s follow-up memo “8-Hour Ozone National Ambient Air Quality Standards Implementation-Reasonable Further Progress (RFP), dated August 2006

7Guidance on the Use of Models and Other Analyses for Demonstration Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze, dated April 2007

III.  Reasonably Available Control Technology

Note: This portion based on “New Jersey 8-Hour Ozone Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Demonstration Adopted – August 1, 2007;

BACKGROUND -

Volatile organic compounds (VOCs) and nitrogen oxides (NOx) in the presence of sunlight can lead to the formation of ground-level ozone or “smog”.  The Clean Air Act (CAA) Sections 172(c)(1) and 182 require areas that are designated at moderate or above for ozone non-attainment to adopt reasonably available control technology (RACT).  All of New Jersey falls under this requirement since it is designated under two moderate ozone non-attainment areas under the 8-hour national ambient air quality standard for ozone (40 CFR 81.332).  Therefore, New Jersey must, at a minimum, adopt RACT level controls for sources covered by a Control Techniques Guidelines (CTG) document and for any major non-CTG source.  The following provides a brief discussion of RACT and how it differs from other types of control levels such as those for new sources.  RACT level controls is defined by 40 CFR 51.100(o) as devices, systems, process modifications, or other apparatus or techniques that are reasonably available.  RACT is required to take into account the social, environmental, and economical impact of controls.  Because it takes economic impacts into consideration, a RACT determination for one State does not necessarily define RACT for another State.

RACT level controls apply to existing sources in non-attainment areas and differs from the more stringent lowest achievable emission rate (LAER) controls required for new sources in non-attainment areas.  LAER is defined in CAA Section 171(3) and 40 CFR 51.165(a)(1)(xiii) as “the most stringent emissions limitation which is contained in the implementation plan of any State for such class or category of source, unless the owner or operator of the proposed source demonstrate that such limitations are not achievable; or … the most stringent emissions limit which is achieved in practice by such class or category of stationary sources.”

Best available control technology (BACT) controls apply to new major sources in areas that have attained the national ambient air quality standards and applies an emission limitation based on the maximum degree of reduction taking into account energy, environmental, and economic impacts and other costs.

One important distinction between RACT and LAER is that RACT is required to take into account the economic impact of the controls.  Therefore, if a certain type of emission control or emission limitation is determined to be too costly compared to the amount of emission reduction it achieves, that control might not be considered RACT. Also, as economic factors may vary within a State and between different States, a control technology or emission limitation designated as meeting RACT in one location does not necessarily define RACT for another location.  In contrast, LAER level controls are more heavily focused towards applying the most stringent emission limitations achievable.

Section IV.G of EPA’s final rule to implement the 8-hour ozone national ambient air quality standard (70 FR 71612, November 29, 2005) discusses RACT requirements.  It states in part that where a RACT SIP is required, State SIPs implementing the 8-hour standard generally must assure that RACT is met, either through a certification that previously required RACT controls represent RACT for 8-hour implementations purposes or through a new RACT determination.

The preamble to the final rule further explains that “many areas subject to the major source RACT requirement under the 8-hour ozone standard have previously addressed the RACT requirement with respect to the 1-hour ozone standard…. We believe that, in many cases, a new RACT determination under the 8-hour standard would result in the same or similar control technology as the initial RACT determination under the 1-hour standard because the fundamental control techniques, as described in the CTGs and ACTs, are still applicable.”

It adds that “States and other interested parties should consider available information that may supplement the CTG and ACT documents. In cases where additional information is presented, for example, as part of notice-and-comment rulemaking on a RACT SIP submittal, States (and EPA) would necessarily consider the additional data in reviewing what control obligation is consistent with RACT.

Therefore, in portions of 8-hour ozone nonattainment areas where major sources or source categories were previously reviewed and controls applied to meet the RACT requirement under the 1-hour standard, States should review and, if appropriate, accept the initial RACT analysis as meeting the RACT requirements for the 8-hour standard. Absent data indicating that the previous RACT determination is no longer appropriate, the State need not submit in its SIP a new RACT requirement for these sources. In such cases, the State should submit a certification as part of its SIP revision, with appropriate supporting information, such as consideration of new data, that these sources are already subject to SIP-approved requirements that still meet the RACT obligation.”  (70 FR 71654)

SUBMITTAL SUMMARY

New Jersey’s submittal:

Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS) and other Associated State Implementation Plan (SIP) Revisions for the Fine Particulate Matter National Ambient Air Quality Standard (NAAQS), Regional Haze, and the Clean Air Act Requirements on Transport of Air Pollution, dated August 1, 2007, and

Letter dated December 14, 2007, to Walter Mugdan, Director, DEPP, from William O’Sullivan, Director, Division of Air Quality, New Jersey Department of Environmental Protection providing status of recently revised CTGs.

On August 1, 2007, the NJDEP submitted their RACT SIP analysis which documented their review of state rules and sources within the state and an outreach effort to the public, industry, and environmental organizations to review existing control requirements and to identify feasible new control measures.  The full RACT report and New Jersey’s commitments to adopt more stringent controls were the subject of a public hearing and the State addressed all the comments that were received.

EPA EVALUATION – EPA evaluated the following elements of New Jersey’s RACT SIP submittal.

Efforts to identify all source categories within the State requiring RACT

Negative declarations where there are no facilities subject to a CTG

State rules that implement CTGs and ACTs,

Whether the State adopted rules are included in the SIP,

Results of New Jersey’s analysis and commitments, and

Review of public comments and State response.

The following documents were also used in our review:

Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard (70 FR 71612; November 29, 2005).

Letter from William T. Harnett to Regional Air Division Directors, (May 18, 2006), “RACT Qs & As – Reasonably Available Control Technology (RACT) Questions and Answers”.

State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 (57 FR 13498; April 16, 1992).

The following summarizes New Jersey’s actions to address the above elements and EPA’s evaluation of those actions.

	1.  Efforts to identify all source categories within the State requiring RACT

New Jersey’s submittal:

New Jersey combined the results of three separate information gathering efforts from industry, environmental groups and the general public in order to get the greatest input on identifying all source categories within the State requiring RACT controls.  These efforts also looked at the stringency of the existing requirements and the possibility of new RACT controls.  The first effort was the exchange of information and experience through a public forum entitled, “Reducing Air Pollution Together” (a multi-pollutant effort), the second was through state participation in regional control development efforts, and the third was an internal NJDEP assessment of RACT controls.  The internal assessment included a review of EPA’s 56 CTGs and Alternative Control Techniques (ACTs) where the CTG’s and ACT’s level of control and applicability were compared to New Jersey’s regulations (see section 3 below), and a review of the State’s existing case-by-case determinations, or alternative emission limits (AELs) and facility specific emission limits (FSELs).  Under the 1-hour ozone standard, a major facility was one with the potential to emit (PTE) 25 tons per year of NOx and/or 25 tons per year of VOC; any source operation with a PTE of ten tons per year of NOx located at a major NOx facility, and any source operation with a PTE of at least 3.5 pounds per hour of VOC located at a major VOC facility.

The results of these three efforts were consolidated and presented to the NJDEP Air Quality Management team for its consideration.  The Air Quality Management team then discussed and prioritized the recommendations resulting in a list of approximately 60 potential control measures for further evaluation.  The NJDEP’s engineers and scientists were assigned the task of further investigating and writing white papers for each potential control measure.  Each control measure was evaluated based on information collected regarding emission benefits, implementation issues, cost-effectiveness, and existing controls.  The white papers were then made available to the public for its review and comment and the evaluated control measures were added to the other recommended control measures for further evaluation.  New Jersey’s RACT evaluation, “Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS) and other Associated State Implementation Plan (SIP) Revisions for the Fine Particulate Matter National Ambient Air Quality Standard (NAAQS), Regional Haze, and the Clean Air Act Requirements on Transport of Air Pollution” dated August 1, 2007, addressed approximately 115 source categories covering multiple pollutants, as well as New Jersey’s commitments to adopt more stringent controls for the 8-hour ozone, PM2.5 and Regional Haze SIP’s based on the evaluation results and was the subject of a public hearing.

EPA evaluation:

EPA has reviewed New Jersey’s efforts to identify all potential sources which should have RACT applied in order to meet the Sections 172(c)(1), 182(b)(2) and 182(f) of the Act requirements for nonattainment areas designated as moderate or above for ozone to adopt RACT.  Based on this review, we concluded that there were no obvious sources that the State missed and the State reviewed and considered all sources, including those at the higher classification of severe, in the preparation of this SIP revision.

	2.  Submit negative declarations where there are no facilities subject to a CTG

New Jersey’s submittal:

NJDEP compared the sources covered in the existing CTGs and ACTs with New Jersey’s adopted rules, and searched the New Jersey Environmental Management System permitting and emission inventory databases, and emission statements for source categories by Standard Industrial Code (SIC), New Jersey determined that for the following CTGs and ACTs, either no sources exist in New Jersey, or the sources fall below the CTG/ACT applicability thresholds:

	1) Surface Coating of Automobiles and Light–Duty Trucks;

	2) Manufacture of Vegetable Oils;

	3) Manufacture of Pneumatic Rubber Tires;

	4) Aerospace Coatings;

	5) Iron and Steel Mills;

	6) Cement Manufacturing;

	7) Nitric and Adipic Manufacturing Plants;

	8) Flat Wood Paneling Coatings; and

	9) Shipbuilding and Ship Repair Operations.

Under the 1-hour ozone SIP, the Shipbuilding and Ship Repair Operations category was not regulated because the facilities in New Jersey fell below the CTG applicability threshold.  As part of addressing the new CTG issued in October 2008, New Jersey committed to reevaluating this source category.  New Jersey will propose to either adopt a RACT rule to implement the CTG for this category, or require these facilities to obtain a FSEL under section 16.17, if they are covered by the new CTG.

EPA evaluation:

EPA agrees with New Jersey’s findings and their negative declaration for the above source categories.

	3.   State regulations that implement CTGs and ACTs

New Jersey has implemented numerous controls Statewide to meet the Clean Air Act RACT requirements.  These RACT controls were promulgated in the New Jersey Administrative Code. Title 7: Chapter 27, Air Pollution Control:

	- Subchapter 16, "Control and Prohibition of Air Pollution from Volatile Organic 	 	Compounds,”

	- Subchapter 19, "Control and Prohibition of Air Pollution from Oxides of Nitrogen,”

	- Subchapter 23, “Prevention of Air Pollution From Architectural Coatings.”

These rules were submitted as part of New Jersey’s SIP and approved by EPA.

Table 4 of New Jersey’s RACT SIP revision (included below), lists all the CTG and ACT documents and identifies the regulations adopted by New Jersey and whether they have been approved by the EPA.  It characterizes the level of control required by New Jersey rules as: same, equivalent or beyond the CTG emission limitation/requirements, and the applicability as: same or lower than what was recommended by the respective CTGs or ACTs.  Table 4 also indicates if the NJDEP has determined that previously adopted 1-hour ozone RACT controls still represent RACT for the more stringent 8-hour standard, or whether the State intends to require more up-to-date controls.  A “Y” in the 8-hour RACT column indicates that the Department has determined that currently effective emission limits for that particular source category represent RACT.  An “N” indicates those source categories where subsequent technology developments might be considered RACT at this time.  Some source categories are currently under additional evaluation by the OTC, MARAMA, NESCAUM, and National Association of Clean Air Agencies (NACAA, formerly STAPPA/ALAPCO) for promising emission reductions on a regional basis. These are indicated in Table 4 as “to be determined” (TBD).  The results of this evaluation were incorporated into the States three phase process used to more broadly determine RACT.  Some of the TBD categories were included along with the other potential control measures identified in other efforts for further analysis on the State level.  The results are included in section 5, below.

Table 4:  RACT Determinations Based on Existing USEPA Guidance

List of the USEPA’s Control Technique Guidelines (CTG) and Alternative Control Techniques (ACT) for Control of VOC Emissions from Stationary Sources

Pre 1990 CTG Documents

Rules

Adopted

EPA

Approved

Control Techniques

Applicability

N.J.A.C.

7:27

8-hour O3

RACT

Group I

1.  Stage I Vapor Control Systems	Y	Y	Beyond	Same	16.3	TBD

2.  Surface Coating of Cans	Y	Y	Same	Lower	16.7	TBD

3.  Surface Coating Metal Coils	Y	Y	Same	Lower	16.7	TBD

4.  Surface Coating Paper Products	Y	Y	Same	Lower	16.7	TBD

5.  Surface Coating Fabrics	Y	Y	Same	Lower	16.7	TBD

6.  Surface Coating Auto/Light trucks	Y	Y	Same	Same	16.7	NS

7.  Misc. Refinery Sources	Y	Y	Same	Same	16.6	TBD

8.  Solvent Metal Cleaning	Y	Y	Beyond	Lower	16.6	Y

9.  Gasoline Loading Terminals	Y	Y	Same	Same	16.3	Y

10. Surface Coating Metal Furniture	Y	Y	Same	Lower	16.7	TBD

11. Surface Coating Magnet Wire	Y	Y	Same	Lower	16.7	TBD

12. Surface Coating Large Appliances	Y	Y	Same	Lower	16.7	TBD

13. Bulk Gasoline Plants	Y	Y	Same	Lower	16.3	Y

14. Fixed Roof Petroleum Tanks	Y	Y	Same	Lower	16.2	Y

15. Use of Cutback Asphalt	Y	Y	Same	Same	16.19	N

Group II

16. Surface Coating Misc. Metal Parts	Y	Y	Same	Same	16.7	TBD

17. Surface Coating Flat Wood Panel	Y	Y	Beyond	Same	16.7	New CTG

18. Manufacture Vegetable Oils	NS	--	--	--	--	NS

19. Leaks from Refinery Equipment	Y	Y	Same	Same	16.18	N

20. Synthetic Pharmaceutical Product	Y	Y	Equivalent	Same	16.16	Y

21. Pneumatic Rubber Tires	NS	--	--	--	--	NS

22. Graphic Arts – Roto & Flex	Y	Y	Beyond	Lower	16.7	New CTG

23. External Floating Roof Tanks	Y	Y	Same	Same 	16.2	N

24. Perchloroethylene Dry Cleaning	NA	--	--	--	--	--

25. Leaks from Gasoline Tank Trucks and Vapor Collection System	Y	Y Beyond	Lower	16.3	Y

Group III

26. Large Petroleum Dry Cleaners	Y	Y	Same	Same	16.20	Y

27. High-Density Polyethylene	Y	Y	Equivalent	Same	16.16	Y

28. Nat.Gas/Gasoline Process Leaks	Y	Y	Same	Same	16.18	Y

29. Syn Chemical Mfg Equip Fugitives	Y	Y	Same	Same	16.18	Y

30. Air Oxidation Processes in Synthetic Organic Chemical Mfg Industry (SOCMI)

	Y	Y	Equivalent	Same	16.16	Y

Post 1990 CTG Documents

Rules

Adopted

EPA Approved

Control Techniques

Applicability

N.J.A.C. 7:27

8-hour O3 RACT

1.   Reactors and Distillation SOCMI	Y	Y	Equivalent	Same	16.16	Y

2.   Offset Lithographic Printing	N	--	--	--	16.17	New

CTG

3.   Wood Furniture Manufacturing	Y	Y	Same	 Same	16.7	TBD

4.   Ship Building and Repair	N	--	--	--	16.7	TBD

5.   Aerospace Coatings	NS	--	--	--	--	NS

Pre 1990 ACT Documents

Rules

Adopted

EPA Approved

Control Techniques

Applicability

N.J.A.C. 7:27

8-hour O3 RACT

1.   Traffic Markings (NR)

Y

Y

Beyond

Lower

23.3

Y

2.   Auto Refinishing (NR)	Y	Y	Beyond	Lower	16.12	Y

3.   Halogenated Solvent Cleaners

	Y	Y	Beyond	Lower	16.6	Y

Post 1990 ACT Documents

Rules Adopted

EPA Approved

Control Techniques

Applicability

N.J.A.C7:27

8-hour O3

RACT

1.   Agricultural Pesticide Application

Y

--

--

--

*

NA

2.   Batch Processes	Y	Y	Same	Lower	16.16	Y

3.   Volatile Organic Liquids Storage	Y	Y	Same	Same	16.2	N

4.   Industrial Cleaning Solvents	Y	Y	Beyond 	Lower	16.6	New CTG

5.   Surface Coating Plastic Parts	Y	Y	Same	Same	16.7	Y

6.   Automobile Refinishing (NR)	Y	Y	Beyond	Lower	16.12	Y

7.   Ship Building and Repair	NS	--	--	--	--	TBD

8.   Industrial Wastewater	Y	Y	Same	Same	16.6	TBD

9.   Offset Lithographic Printing

	N	--	--	--	16.17	New

CTG

List of USEPA’s Alternative Control Techniques (ACT) for Control of NOx Emissions from Stationary Sources

Post 1990 ACT Documents

Rules Adopted

EPA Approved

Control Techniques

Applicability

N.J.A.C7:27

8-hour O3

RACT

1.   Iron and Steel Mills

NS

--

--

--

--

NS

2.   ICI Boilers	Y	Y	Beyond	Lower	19.7	N

3.   Glass Manufacturing	Y	Y	Same	Lower	19.10	N

4.   Stationary RICE	Y	Y	Beyond	Lower	19.8	Y

5.   Process Heaters	Y	Y	Beyond	Lower	19.7	N

6.   Stationary Gas Turbines	Y	Y	Beyond	Lower	19.5	N

7.   Utility Boilers	Y	Y	Beyond	Lower	19.4	N

8.   Cement Manufacturing	NS	--	--	--	--	NS

9.   Nitric and Adipic Mfg Plants

	NS	--	--	--	--	NS

TBD indicates this control measure is currently being reevaluated by Regional Organizations

N indicates that rules were not adopted, or current RACT control technology does not meet 8-hour RACT

NS indicates no sources

NA indicates not applicable since CTG is no longer relevant or is superseded

NR indicates national rule was issued after the CTG/ACT

New CTG indicates that USEPA has issued a final CTG effective 10/05/06

Y indicates that rules were adopted by the State, approved by USEPA , or that previously adopted 1-hour RACT controls still represent RACT for 8-hour ozone standard

* N.J.A.C. 7:30, New Jersey Pesticide Control Rules

EPA evaluation:

For many source categories, the existing New Jersey rules go beyond the recommendations contained in the CTG/ACT documents in terms of more stringent emission rates or limitations and lower applicability thresholds (that is, requirements apply to sources with lower emissions than what was originally included in a CTG or ACT).  This is especially true based on New Jersey’s 8-hour classification of moderate where major VOC sources would be defined as 50 tons per year (TPY) and major NOx sources would be defined as 100 tons per year.  Based on the original 1-hour ozone levels in New Jersey, major VOC sources were defined as those with emissions of 25 TPY and major NOx sources were defined as those with emissions of 25 TPY.  However, anti-back sliding provisions prohibit relaxing existing requirements and the State is not changing any of these applicabilities.

EPA performed a spot check of New Jersey’s rules against the applicable CTGs, and rules from surrounding states.  From this review, we conclude the New Jersey rules meet RACT level controls and in some cases, go beyond RACT.  While some CTGs may not have been revised since being issued, and therefore controls in those CTGs may be argued as being old, a comparison of emission limits and controls in the New Jersey rules against those found in other states did not generally uncover more stringent controls or lower applicability levels being applied elsewhere.  Therefore, for major sources of VOC and NOx, the existing rules start out being more stringent that what would be required for a classification of moderate under the 8-hour ozone NAAQS.

EPA also checked whether the rules relied upon by New Jersey for their RACT SIP analysis were actually SIP approved and whether more recent versions of those rules had been adopted by the State but not yet submitted for SIP approval. This was done by cross matching EPA Region II’s database of SIP approved rules and New Jersey’s on-line compilation of rules.  Two of the rules had undergone minor revisions and have not yet been submitted for SIP approval.  These revisions do not substantively differ from the SIP approved rules and the corresponding RACT limits and requirements and do not affect New Jersey’s RACT SIP analysis.  In addition, these same rules are currently being revised to incorporate new more stringent RACT limits and requirements for several source categories developed as part of the RACT evaluation effort and New Jersey has committed to submitting them as SIP revisions upon their adoption.

The CTG and ACT categories which New Jersey identified as possibility having more stringent RACT levels were further evaluated as part of the broader RACT evaluation and those where more stringent controls are identified are addressed in section 4 below.

	4.  Results of New Jersey’s RACT analysis and commitments

The results of NJDEP’s assessment of RACT for the CTG and ACT categories, non-CTG major sources regulated by the State, as well as certain categories which State and Local Regional Organizations are studying the feasibility of regional model rules are identified in Table E.1 below from New Jersey’s RACT SIP revision.  Table E.1 lists the RACT source categories for which the State will propose new or revised emission standards along with the targeted pollutants and affected rules and categories that will be the subject of future rule revisions.  In order for these potential new requirements to be adopted, they must be proposed and the public, including industry, given the opportunity to comment on the technical feasibility as well as the cost of the new controls.

Table E.1: Summary of New Jersey Candidate Source Categories and Future Rule Revisions

Candidate Source Categories	Targeted Pollutants 	Affected Rules

	NOx	VOC	SO2	PM2.5

	Ozone Transport Commission (OTC)

Asphalt Paving

X

	N.J.A.C.1 7:27-16.19

Asphalt Production	X

N.J.A.C. 7:27-19.9

Glass Furnaces	X

N.J.A.C. 7:27-19.2, 19.10

Industrial Adhesives & Sealants

X

	N.J.A.C. 7:27-26 (New Rule)

Industrial, Commercial &

   Institutional Boilers	X

N.J.A.C. 7:27-19.2, 19.7

Coal-fired EGU2 Boilers	X

X	X	N.J.A.C. 7:27-4, 10 & 19.4

EGUs	X

N.J.A.C. 7:27-19.4

High Electrical Demand Day EGUs	X

N.J.A.C. 7:27-19.4, 19.5, & 19.29

Mid-Atlantic Regional Air Management Association (MARAMA)

Petroleum Refineries4	X	X	X

N.J.A.C. 7:27-33 (New Rule)

State of New Jersey

Petroleum and VOC Storage Tanks

X

	N.J.A.C. 7:27-16.2

Facility-Specific Emission Limit & Alternative Emission Limit	X	X

	N.J.A.C. 7:27-16.17 & 19.13

BART3-affected Equipment	X

X	X	N.J.A.C. 7:27-33 (New rule)

Municipal Waste Combustors	X

N.J.A.C. 7:27-19.12

Publicly-owned Treatment Works (sewage sludge incinerators)	X

N.J.A.C. 7:27-19.28

CTGs issued after 20064

X

	N.J.A.C. 7:27-16.7

Process Heaters & Boilers at Petroleum Refineries4	X

N.J.A.C. 7:27-33 (New Rule)

1 -  N.J.A.C. - New Jersey Administrative Code

2  - EGU - Electric Generating Unit

3  - BART - Best Available Retrofit Technology

4  - Future Rule Revisions

EPA evaluation:

The source categories New Jersey identified have the potential to provide additional emission reductions.  The level of controls New Jersey anticipates proposing will need to be subject to public comment in order to insure that they are both technologically and economically feasible.

	5. Review of public comments and State response.

New Jersey received comments from five parties and involving 27 comments.  A summary of the comments and the State’s response is contained in Appendix G. Public Participation Process, Attachment 3, Hearing Report - Responses to Comments Received and NJDEP-initiated Changes dated August 1, 2007.  The comments can be grouped into the following categories: Updates to current ownership identified in the RACT document; Ozone Transport; Implementation of Overlapping SIP revisions; Public outreach; MARAMA Stakeholder Process, Technical Support Document and Model Rules for Petroleum Refineries; and RACT.  Based on the responses to comments, New Jersey has considered all comments.  Many of the comments are more appropriately addressed when the rule provisions are actually proposed as rule revisions then as part of the RACT SIP where the concept is being included and not the actual wording of the requirements.

	6.  EPA’s Conclusions

In summary, EPA believes the RACT SIP analysis performed by New Jersey is reasonable and demonstrates that their rules meet RACT with the exception of those source categories identified by New Jersey that are currently being proposed for revisions.  New Jersey did a thorough job of involving interested parties in evaluating the currently adopted control provisions and in identifying potential controls measures, which could be implemented in New Jersey considering available information.

As discussed above, public comments were received on the RACT SIP analysis and New Jersey considered all of them before submitting the RACT evaluation.  We further believe that as part of New Jersey’s rule development process to review emission controls and limits not only in the CTGs/ACTs but also in other States, New Jersey rules meet or exceed RACT level controls.   However, New Jersey must fulfill the commitments to the rulemaking for the source categories it identified where RACT is different from the existing rules.

IV. Reasonable Available Control Measures

The evaluation criteria used for this analysis included:

	- technological feasibility,

	- economic feasibility,

	- other local considerations including measures that do not cause “substantial widespread and long-term adverse impacts” and measures that are not “absurd, unenforceable, or impracticable,” and

	- ability to advancement the attainment date.

Transportation Control Measures

The New Jersey Department of Transportation (NJDOT) conducted the RACM analysis for Transportation Control Measures (TCMs).  The New Jersey Department of Transportation identified 26 control measures.  Details for each control measure include: description, methodology used, inputs and assumptions, and the results of the analysis are included in Appendix F.1 of the New Jersey SIP.

Non-transportation Control Measures

A list of 457 potential non-transportation control measures (TCMs) was compiled through review of various sources, including Regional Planning Organizations (RPOs), other State Organizations, existing NJDEP documents, USEPA regional efforts, and Early Action documents.

Summary

A total of 28 measures, 17 non-TCMs and 11 TCMs, passed the technological feasibility, economic feasibility and “other local considerations” RACM criteria.  See Table 7.4 (below) for a list of the 17 potential Non-TCMs and Table7.5 (below) for a list of the 11 potential TCMs that past the screening tests.

Table 7.4: List of 17 Potential Non-TCM RACMs

Identifier	Measure Name

Area

2	Consumer Products

3	Portable Fuel Containers

4	Adhesives and Sealants (Industrial)

5	Smoke Management Plan

18	Degreasing Controls

20	Tehama County: TCAPCD Rule 4.22: Industrial Use of Organic Solvents

25	Emission Reductions from Composting

26	Reformulation of Aerosol Coatings to CARB Tier 2 Standards

Onroad

32	Onroad Vehicle Idling

34	Opacity Cutpoint Revision

36	Medium Duty Vehicle Inspection

63	Technology to Identify Smoking Vehicles

Nonroad

74	Nonroad Idling

75	Idling Reduction for Train Engines

78	Insure Proper Disposal of Fuel Samples After Daily Aircraft Pre-Flight Checks

89	Graduated Registration Fees for Recreational Boats

97	Auxiliary Power Units (APUs) for Locomotives

Table 7.5: Potential Transportation Control Measures (TCMs)

Identifier	Measure Name	Description

Onroad

DOT8	Truck Idling Restrictions	Truck idling restrictions will be implemented statewide. It is assumed, in an effort to avoid fines and other negative repercussions resulting from continued idling, both fleet and individual

truck owners will invest in idling reduction

technology (auxiliary power units, diesel driven heating systems and automatic shut-down/startup systems).

DOT9	Impact of Various Transit Projects	Encourage the use of transit through the completion of significant fixed guideway/rail projects

DOT11	Adoption of Smart Growth Land Use Policies	Analysis of compact development in the NYNJ- CT Region

DOT13	Clean Fleets Replacements	100 9 year old vehicles replaced with 100 hybrid vehicles in each county

DOT16	School Bus Replacements	Twenty percent (4,246) of all Model Year 2002 and older school buses are replaced by Model year 2007 diesel buses

DOT17	IdleAire Installations	A total of 210 parking spaces at truck stops would be equipped with IdleAire technology statewide

DOT18	Transit Bus Replacements	All Model Year 2002 and older transit buses are replaced by Model Year 2007 diesel buses

DOT20	School Bus Retrofit	All Model Year 1992-2002 school buses will utilize retrofit technology

DOT22	Commercial Vehicle Information Systems and Networks (CVISN) Analyzed as the adoption of high-speed weigh in motion devices to replace off-line weigh stations

DOT23	Implementation of Express E-Z Pass Toll Collection	Analysis includes the impacts of adding high speed, no toll booth EZ-Pass lanes to the Union, Essex and Barnaget toll plazas

Nonroad

DOT3	Retrofit Construction Equipment	Assume 10% of total inventory of equipment will be used on state contracted projects and that 20% of those vehicles must use a combination of ULSD and retrofit technology

RACM Analysis

The State has reviewed all of the potential control measures to determine if they could meet the RACM criteria discussed in Section 7.2.  Several measures are available (see Table 7.8 below) that can provide moderate levels of emission reductions, however, none of these measures, singly or combined, can provide sufficient benefits by the start of the 2008 ozone season to advance the date by which New Jersey will attain the 8-hour ozone standard.  Therefore, these potential control measures cannot satisfy the RACM requirement for a moderate nonattainment area and it is unnecessary to include any of these measures in the State’s attainment plan.

Table 7.8: Summary of the Potential RACMs

	Estimated 2009 Benefits

 (VOC tpd + NOx tpd Combined)

New Jersey Identifier	Measure Name	NNJ/NY/CT NAA	SNJ/Phila. NAA

4	Adhesives and Sealants (Industrial)	6.1	2.9

26	Reformulation of Aerosol Coatings to CARB Tier 2 Standards	3.9	1.8

2	Consumer Products	0.9	0.4

DOT11	Adoption of Smart Growth Land Use Policies	1.1	0.6

DOT8	Truck idling restrictions	1.1	0.5

DOT17	IdleAire Installations	1.0	0.5

DOT22	Commercial Vehicle Information Systems and Networks (CVISN)	0.7 0.4

18	Degreasing Controls	0.7	0.3

Total Benefit	15.5	7.4

RACM Conclusion

New Jersey evaluated all source categories that could contribute meaningful emission reductions and identified and evaluated an extensive list of potential control measures.   The State considered the time needed to develop and adopt regulations and the time it would take to see the benefit from these measures achieved as a further screen of their reasonableness and availability.  The State has proceeded with developing several of the measures as part of its RACT control program.  EPA has reviewed the RACM analysis and finds that there are no RACM that would advance the moderate area attainment date of 2010 for the two nonattainment areas in which the New Jersey counties are located.

V.  Contingency Measures

Contingency Measures for the 2008 RFP Demonstration

EPA requires that the contingency measures account for one year of RFP reductions, or 3 percent of the adjusted baseline VOC emissions inventory for the particular projection year.   Thus, the contingency measures for the 2008 RFP must total 3 percent of the 2002 adjusted base year VOC emissions inventory.  EPA also allows for substitution of NOx reductions for VOC reductions in the contingency measure plans on a percentage basis.   However, the EPA requires that at least 0.3 percent of the total 3 percent reduction be VOC emission reductions.  Furthermore, the EPA allows the use of emission reductions from the early implementation of strategies to be used for contingency measure reduction.   Table 8.1 of the New Jersey SIP shows the calculation of the necessary reductions for RFP in 2008 (RFP contingency targets), as well as the contingency measures and their associated emission reductions, for both of the New Jersey portions of its multi-state 8-hour ozone nonattainment areas.

EPA evaluation:

New Jersey determined the required emission reductions for its RFP contingency plans consistent with the Act, as interpreted in EPA’s regulations, guidance and policies and identified the specific measures needed to achieve them.  All the emission reductions included in the RFP contingency plans are from adopted measures and have not been used in the SIP to meet some other requirement.  EPA is satisfied that the State’s RFP contingency plans meet agency requirements.

Contingency measures are also required for the attainment plan, that is, additional reductions in case a state does not attain in the year it is suppose to.  New Jersey provided contingency measures for its attainment year, but EPA is deferring action on the attainment contingency measures.  EPA will act on these measures when it acts on an approvable attainment demonstration.

 57 FR 13498 (April 16, 1992).

 USEPA. NOx Substitution Guidance. United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, December 1993.

 USEPA Memorandum from Michael H. Shapiro to Region Air Directors, “Guidance on Issues Related to 15 Percent Rate-of-Progress Plans,” August 23, 1993.

 USEPA Memorandum from Gary T. Helms, Chief, Ozone/Carbon Monoxide Branch, “Early

Implementation of Contingency Measures for Ozone and Carbon Monoxide (CO) Nonattainment Areas,” August 13, 1993.

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