as $18,000 per ton. In general, for most scenarios the cost
effectiveness was estimated to be less than $5,000 per ton of NOx
removed.

NOx EMISSION REDUCTION SUMMARY

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

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

Tables 4-11 to 4-17 show State summaries of the emission benefits from
the OTC 2006 NOx control measures described previously in this Section.
For each of the seven source categories, the Tables show four emission
numbers: (1) the actual 2002 summer daily emissions; (2) the summer
daily emissions for the 2009 OTB/W scenario that accounts for growth and
for the emission control regulations that have (or will) become
effective between 2003 and 2008 that will achieve post-2002 emission
reductions; (3) the summer daily emissions for 2009 with the
implementation of the OTC 2006 control measures identified in this
Section, and (4) the emission benefit in 2009 resulting from the OTC
2006 control measure.  Table 4-18 shows the same information for the
total of all seven source categories.

The largest estimated NOx emission reductions are in the more
industrialized States – New York and Pennsylvania – which have most
of the cement kilns and glass furnaces in the OTR.  These two states
also have a large population of ICI boilers.  The emission benefits
listed for Virginia just include the Virginia counties in the northern
Virginia area that are part of the OTR.  Benefit estimates for all other
States include the entire state.  The emission benefits also assume that
all OTC members will adopt the rules as described in the previous
sections.

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

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

Heavy-Duty Truck Diesel Engine Chip Reflash

	Heavy-Duty Truck Diesel Engine Chip Reflash

Summer NOx Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	66.7	n/a	n/a	3.5

DE	21.8	n/a	n/a	0.6

DC	8.1	n/a	n/a	0.8

ME	82.8	n/a	n/a	1.4

MD	105.0	n/a	n/a	5.6

MA	152.7	n/a	n/a	6.7

NH	30.5	n/a	n/a	2.0

NJ	133.5	n/a	n/a	9.7

NY	177.6	n/a	n/a	16.1

PA	437.1	n/a	n/a	12.4

RI	8.3	n/a	n/a	0.8

VT	13.7	n/a	n/a	0.9

NOVA	16.6	n/a	n/a	2.5

OTR	1254.5	0.0	0.0	63.0

n/a – not available due to lack of 2009 emissions data for on-road
vehicles in NIF format.

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

Regional Fuels

	Regional Fuels

Summer NOx Emissions (tpd)

State	2006 Actual	2006

Base	2006

Control	2006 Benefit

CT	81.3	81.3	81.3	0.0

DE	24.8	24.8	24.8	0.0

DC	8.4	8.4	8.4	0.0

ME	44.1	44.1	43.8	0.2

MD	144.0	144.0	144.0	0.0

MA	137.4	137.4	137.4	0.0

NH	38.4	38.4	38.2	0.2

NJ	204.2	204.2	204.2	0.0

NY	381.3	381.3	379.1	2.1

PA	284.8	284.8	282.9	2.0

RI	20.5	20.5	20.5	0.0

VT	26.3	26.3	26.0	0.3

NOVA	50.8	50.8	50.8	0.0

OTR	1446.2	1446.2	1441.4	4.8

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

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

Asphalt Pavement Production Plants

	Asphalt Pavement Production Plants

Summer NOx Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	0.0	0.0	0.0	0.0

DE	0.6	0.6	0.4	0.2

DC	0.0	0.0	0.0	0.0

ME	1.7	2.0	1.3	0.7

MD	0.2	0.2	0.1	0.1

MA	1.1	1.8	1.2	0.6

NH	0.0	0.0	0.0	0.0

NJ	1.3	2.8	1.8	1.0

NY	0.0	0.1	0.0	0.0

PA	0.6	0.7	0.5	0.2

RI	0.1	0.1	0.1	0.0

VT	0.0	0.0	0.0	0.0

NOVA	0.3	0.3	0.2	0.1

OTR	5.9	8.6	5.6	3.0

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

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

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

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

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

Cement Kilns

	Cement Kilns

Summer NOx Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	0.0	0.0	0.0	0.0

DE	0.0	0.0	0.0	0.0

DC	0.0	0.0	0.0	0.0

ME	4.7	4.7	4.7	0.0

MD	17.2	17.2	4.1	13.1

MA	0.0	0.0	0.0	0.0

NH	0.0	0.0	0.0	0.0

NJ	0.0	0.0	0.0	0.0

NY	35.1	35.1	19.8	15.3

PA	44.7	44.7	30.7	14.0

RI	0.0	0.0	0.0	0.0

VT	0.0	0.0	0.0	0.0

NOVA	0.0	0.0	0.0	0.0

OTR	101.9	101.9	59.4	42.5

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

2009 Base Inventory emissions are the emissions forecasted to be the
same as in 2002 (i.e., no growth was assumed).

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

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

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

Glass/Fiberglass Furnaces

	Glass/Fiberglass Furnace

Summer NOx Emissions (tpd)

State	2002 Actual	2009

Base	Maximum

Control	MaximumBenefit

CT	0.0	0.0	0.0	0.0

DE	0.0	0.0	0.0	0.0

DC	0.0	0.0	0.0	0.0

ME	0.0	0.0	0.0	0.0

MD	0.3	0.3	0.1	0.3

MA	1.4	1.8	0.3	1.5

NH	0.0	0.0	0.0	0.0

NJ	7.7	7.1	2.2	4.9

NY	6.1	6.8	1.0	5.8

PA	36.3	44.3	20.0	24.3

RI	0.7	0.5	0.1	0.5

VT	0.0	0.0	0.0	0.0

NOVA	0.0	0.0	0.0	0.0

OTR	52.5	60.9	23.6	37.3

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

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

Maximum Control Inventory emissions are the emissions remaining after
full implementation of the beyond-on-the-way control measures described
in this Section.  Not all of the anticipated reductions from the
glass/fiberglass OTC 2006 control measure will be achieved by 2009.
This column shows the emissions remaining after full implementation of
the measure, which may not occur until 2012 or 2018.

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

Note:  The table shows the maximum emission reduction from
glass/fiberglass furnaces when the OTC 2006 control measure is fully
implemented.  Not all of the reduction shown will be achieved by 2009.

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

ICI Boilers – Area (Minor) Source

	ICI Boilers – Area (Minor) Sources

Summer NOx Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	8.9	9.4	6.5	2.8

DE	3.4	3.5	2.3	1.2

DC	1.3	1.6	1.1	0.4

ME	5.0	5.3	4.2	1.1

MD	3.5	4.0	2.9	1.2

MA	24.4	25.8	19.1	6.6

NH	21.3	24.2	20.8	3.4

NJ	20.5	15.6	15.6	0.0

NY	105.2	112.2	78.4	33.8

PA	38.0	39.8	27.6	12.2

RI	6.6	7.3	5.3	2.1

VT	2.3	2.9	1.9	0.9

NOVA	11.8	11.9	8.1	3.9

OTR	252.0	263.4	193.9	69.5

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

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

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

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

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

ICI Boilers – Point (Major) Source

	ICI Boilers – Point (Major) Sources

Summer NOx Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	5.8	5.6	3.5	2.1

DE	7.7	7.3	7.3	0.0

DC	1.0	1.1	0.8	0.4

ME	10.2	12.8	10.1	2.8

MD	14.2	11.2	8.8	2.4

MA	13.8	15.4	8.7	6.8

NH	3.9	4.8	2.9	1.9

NJ	12.9	10.8	7.4	3.4

NY	31.4	30.8	23.8	7.0

PA	33.4	36.5	26.7	9.8

RI	4.2	4.9	4.3	0.5

VT	0.7	0.9	0.5	0.4

NOVA	0.2	0.2	0.0	0.1

OTR	139.3	142.3	104.6	37.7

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

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

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

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

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

All Seven NOx Categories

	All Seven NOx Categories

Summer NOx Emissions (tpd)

State	2002 Actual	2009

Base	2009

Control	2009 Benefit

CT	162.7	n/a	n/a	8.4

DE	58.2	n/a	n/a	2.1

DC	18.8	n/a	n/a	1.6

ME	148.5	n/a	n/a	6.2

MD	284.4	n/a	n/a	22.7

MA	330.8	n/a	n/a	22.2

NH	94.1	n/a	n/a	7.5

NJ	380.0	n/a	n/a	19.0

NY	736.8	n/a	n/a	80.1

PA	874.9	n/a	n/a	74.9

RI	40.5	n/a	n/a	3.9

VT	42.9	n/a	n/a	2.5

NOVA	79.6	n/a	n/a	6.6

OTR	3252.3	n/a	n/a	257.8

n/a – not available due to lack of 2009 emissions data for on-road
vehicles in NIF format.

REFERENCES

Bodnarik 2006: Bodnarik, Andrew M., New Hampshire Department of
Environmental Services, “ICI Boiler NOx Control Cost Estimates from
OTC Methodology”, presented at the OTC Control Strategy/SAS Committee
Meeting, November 2, 2006.

CARB 1998: California Air Resources Board, “Determination of
Reasonably Available Control Technology and Best Available Retrofit
Control Technology for Adhesives and Sealants”, December, 1998.

CARB 1999: California Air Resources Board, “Initial Statement of
Reasons for Proposed Rule Making Public Hearing to Consider the Adoption
of Portable Fuel Container Spillage Control Regulations”, August 6,
1999.

CARB 2004a: California Air Resources Board, “Initial Statement of
Reasons for Proposed Amendments to the California Aerosol Coating
Products, Antiperspirants and Deodorants, and Consumer Products
Regulations, Test Method 310, and Airborne Toxic Control Measure for
Para-dichlorobenzene Solid Air Fresheners and Toilet/Urinal Care
Products Volume I: Executive Summary”, June 24, 2004.

CARB 2004b: California Air Resources Board, Letter from William V.
Loscutoff to Stakeholders, June 7, 2004.

CARB 2005a: California Air Resources  Board, “Staff Report: Initial
Statement of Reasons for Proposed Amendments to the Portable Fuel
Container Regulations”, July 29, 2005.

CARB 2005b: California Air Resources Board, “Final Statement of
Reasons: Public Hearing to Consider Amendments to the Regulations for
Portable Fuel Containers”, October 2005.

CARB 2006: California Air Resources Board, “Final Statement of
Reasons: Public Hearing to Consider Amendments to the Regulations for
Portable Fuel Containers”, July 2006.

Census 2006: U.S. Census Bureau, web site   HYPERLINK
"http://www.census.gov/popest/counties/tables/"
www.census.gov/popest/counties/tables/  containing county population
files for 2005.

EC 2001a.  European Commission, “Integrated Pollution Prevention and
Control (IPPC) Reference Document on Best Available Techniques in the
Cement and Lime Manufacturing Industries”, December 2001.

EC 2001b.  European Commission, “Integrated Pollution Prevention and
Control (IPPC) Bureau Reference Document on Best Available Techniques in
the Glass Manufacturing Industry”, December 2001.

EC/R 2000.  EC/R Incorporated, “NOx Control Technologies for the
Cement Industry – Final Report”, prepared for the U.S. Environmental
Protection Agency, September 19, 2000.

EEA 2005:  Energy and Environmental Analysis, Inc. “Characterization
of the U.S. Industrial/Commercial Boiler Population”, prepared for Oak
Ridge National Laboratory, May 2005.

ENVIRON 2006:  ENVIRON International Corporation, “Evaluation of
Candidate Mobile Source Control Measures”, prepared for Lake Michigan
Air Directors Consortium, January 5, 2006.

ERG 2005. Eastern Research Group, Inc., “Assessment of NOx Emissions
Reduction Strategies for Cement Kilns – Ellis County’, prepared for
the Texas Commission on Environmental Quality, December 19, 2005.

MACTEC 2005:  MACTEC Federal Programs, Inc., “Interim White Paper -
Midwest RPO Candidate Control Measures: Glass Manufacturing”, prepared
for Lake Michigan air Directors Consortium, December 2005.

MACTEC 2006a:  MACTEC Federal Programs, Inc., “Draft Final Technical
Support Document: Development of Emission Projections for 2009, 2012,
and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU
Region”, prepared for Mid-Atlantic Regional Air Management
Association, December 7, 2006.

MACTEC 2006b:  MACTEC Federal Programs, Inc., “Draft Documentation for
the 2002, 2009, and 2018 Emission Inventories for VISTAS”, prepared
for Visibility Improvement State and Tribal Association of the
Southeast, under development.

NESCAUM 2005a: The Clean Air Association of the Northeast States, email
from Arthur Marin NESCAUM to Chris Recchia OTC, December 7, 2005.

NESCAUM 2005b: The Clean Air Association of the Northeast States, “Low
Sulfur Heating Oil in the Northeast States: An Overview of Benefits,
Costs and Implementation Issues,” December 2005.

NESCAUM 2006a: The Clean Air Association of the Northeast States, email
from Arthur Marin NESCAUM to Seth Barna OTC, February 2006.

NESCAUM 2006b: The Clean Air Association of the Northeast States, “Low
NOx Software Upgrade for Heavy-Duty Trucks: Draft Model Rule Staff
Report, February 20, 2006.

OTC 2006a: Ozone Transport Commission, “Memorandum of Understanding
Among the States of the Ozone Transport Commission on a Regional
Strategy Concerning the Integrated Control of Ozone Precursors from
Various Sources”, June 7, 2006.

OTC 2006b: Ozone Transport Commission, “Resolution 06-02 of the Ozone
Transport Commission Concerning Coordination and Implementation of
Regional Ozone Control Strategies for Certain Source Categories”, June
7, 2006.

OTC 2006c: Ozone Transport Commission, “Statement of the Ozone
Transport Commission Concerning Multi-Pollutant Emission Control of
Electric Generating Units”, June 7, 2006.

OTC 2006d: Ozone Transport Commission, “Resolution 06-03 of the Ozone
Transport Commission Concerning Federal Guidance and Rulemaking for
Nationally-Relevant Ozone Control Measures”, June 7, 2006.

OTC 2006e: Ozone Transport Commission, “Modified Charge of the Ozone
Transport Commission to the Stationary Area Source Committee Regarding
Electric Generating Units”, November 15, 2006.

OTC 2006f: Ozone Transport Commission, “Statement of the Ozone
Transport Commission Concerning Regional and State Measures to Address
Emissions from Mobile Sources”, November 15, 2006.

OTC 2006g: Ozone Transport Commission, “Addendum to Resolution 06-02
of the Ozone Transport Commission Concerning Coordination and
Implementation of Regional Ozone Control Strategies for Various
Sources”, November 15, 2006.

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Emission Inventory, Version 3”, prepared for Mid-Atlantic Regional Air
Management Association, April 2006.

USEPA 1993.  U.S. Environmental Protection Agency, “Final Regulatory
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Control Techniques Document – NOx Emissions from Glass
Manufacturing”, EPA-453/R-94-037, June 1994.

Appendix A – Process for Identifying and Evaluating Control Measures

Background

The States of the Ozone Transport Region (OTR) are faced with the
requirement to demonstrate attainment with the 8-hour ozone NAAQS 8-hour
ozone National Ambient Air Quality Standards (NAAQS) by June 15, 2008.
To accomplish this, most of the states will need to implement additional
measures to reduce emissions that either directly impact their
nonattainment status, or contribute to the nonattainment status in other
states.  In addition, the States are conducting attainment planning work
to support development of PM2.5 and regional haze State Implementation
Plans (SIPs).  As such, the Ozone Transport Commission (OTC) undertook
an exercise to identify a suite of additional control measures that
could be used by the OTR states in attaining their goals.

In March 2005, the Ozone Transport Commission (OTC) established the
Control Strategies Committee as an ad-hoc committee to assist with
coordination of the attainment planning work.  The Control Strategies
Committee works with three other OTC committees.  The Stationary and
Area Source (SAS) Committee evaluates control measures for specific
stationary source sectors or issues.  The Mobile Source Committee
examines control measures for on-road and non-road mobile sources.  And
the Modeling Committee develops and implements a strategic plan for
SIP-quality modeling runs to support attainments demonstrations.

The SAS Committee is comprised of various workgroups that evaluate
control measures for specific sectors or issues.  These workgroups
included:

Control Measures Workgroup focuses on stationary area sources;

Reasonably Available Control Technology (RACT) workgroup focuses on
major point sources;

Multi-Pollutant Workgroup focuses on electric generating units (EGUs);

High Electric Demand Day (HEDD) examines EGU peaking units; and

Industrial, Commercial, and Institutional (ICI) Boiler Workgroup focuses
on control technologies for different fuels and boiler size ranges.

The OTC also issued a contract to MACTEC to help the SAS Committee
identify and evaluate candidate control measures as well as to quantify
expected emission reductions for each control measure.

Workgroup Activities

Initially, the Workgroups compiled and reviewed a list of approximately
1,000 candidate control measures.  These control measures were
identified through published sources such as the U.S. Environmental
Protection Agency’s (EPA’s) Control Technique Guidelines,
STAPPA/ALAPCO “Menu of Options” documents, the AirControlNET
database, emission control initiatives in member states as well as other
states including California, state/regional consultations, and
stakeholder input.  Appendix B provides the initial list of control
measures that were evaluated.

Based on the review of the 1,000 candidate control measures, the
Workgroups developed a short list of measures to be considered for more
detailed analysis.  These measures were selected to focus on the
pollutants and source categories that are thought to be the most
effective in reducing ozone air quality levels in the Northeastern and
Mid-Atlantic States.  The Workgroups reviewed information on current
emission levels, controls already in place, expected emission reductions
from the control measures, when the emission reductions would occur,
preliminary cost and cost-effectiveness data, and other implementation
issues.  Each of the candidate control measures on the short list were
summarized in a series of “Control Measure Summary Sheets”.  The
Control Measure Summary Sheets are contained in Appendix C.  The
Workgroups discussed the candidate control measures during a series of
conference calls and workshops to further refine the emission reduction
estimates, the cost data, and any implementation issues.  The Workgroups
also discussed comments from stakeholders.  The Workgroups prioritized
the control measures and made preliminary recommendations regarding
which measures to move forward on.

OTC Commissioners’ Recommendations

Based on the analyses by the OTC Workgroups, the OTC Commissioners made
several recommendations at the Commissioner’s meeting in Boston June
2006 and November 2006.  The Commissioners recommended that States
consider emission reductions from the following source categories:

Consumer Products

Portable Fuel Containers

Adhesives and Sealants Application

Diesel Engine Chip Reflash

Cutback and Emulsified Asphalt Paving

Asphalt Production Plants

Cement Kilns

Glass Furnaces

Industrial, Commercial, and Institutional (ICI) Boilers

Regional Fuels

Electric Generating Units (EGUs)

Additionally, the Commissioners requested that EPA pursue federal
regulations and programs designed to ensure national development and
implementation of control measures for the following categories:
architectural and maintenance coatings, consumer products, ICI boilers
over 100 mmBtu/hour heat input, portable fuel containers, municipal
waste combustors, regionally consistent and environmentally sound fuels,
small offroad engine emission regulation, and gasoline vapor recovery.
The various recommendations by the OTC Commissioners made from 2004 to
2006 are summarized in Table A-1.

Stakeholder Input

Stakeholders were provided multiple opportunities to review and comment
on the Control Measure Summary Sheets.  Table A-2 lists the public
meetings that were held as an opportunity for stakeholders to review and
respond to the Control Measure Summary Sheets and Commissioner’s
recommendations.  Stakeholders provided written comments, as listed in
Table A-3.  In addition to submitting written comments, the Workgroups
conducted teleconferences with specific stakeholder groups to allow
stakeholders to vocalize their concerns directly to state staff and to
discuss the control options.  These stakeholder conference calls and
meeting are listed in Table A-4.  The OTC staff and state Workgroups
carefully considered the verbal and written comments received during
this process.

Table A-1: OTC Formal Actions, 2004-2006

Date	Action/Synopsis

Nov. 10, 2004	Charge to Stationary and Area Sources Committee  Directs
SAS Committee to continue to seek out innovative programs to address
emissions from all stationary and area sources.

Nov. 10, 2004	Charge to Stationary and Area Sources Committee Regarding
Multi-Pollutant Emission Control for Electrical Generating Units and
Large Industrial Sources  Directs the SAS Committee to develop an
implementation strategy for to implement the OTC’s multi—pollutant
position, recommend methods for allocating NOx and SO2 caps, assess
methods to advance the OTC’s Multi0Pollutant position beyond the OTR,
develop a program implementation structure, and present a Memorandum of
Understanding for consideration by the Commission.

Nov. 10, 2004	Charge to the Mobile Source Committee  Directs the Mobile
Source Committee to identify selected scenarios to be modeled and
evaluate strategies including anti-idling programs, voluntary and
regulatory retrofit programs, VMT growth strategies, port and marine
engine programs, national mobile source programs, California Low
Emission Vehicle programs, and model incentive programs.

Nov. 10, 2004	Statement on OTC Modeling  Directs the Modeling Committee
to coordinate inventories and modeling needed for ozone, regional haze,
and PM; seek input for air directors and OTC committees on regional
strategies for modeling; continue to use CALGRID as a screening tool;
and continue to explore application of emerging tools.

June 8, 2005	Resolution of the States of the Ozone Transport Commission
Regarding Development of a Regional Strategy for the Integrated Control
of Ozone Precursors and Other Pollutants of Concern from Electrical
Generating Units (EGUs) and Other Large Sources  Resolves that member
States: develop a regional Multi-Pollutant program to assist in
attaining and maintaining the 8-hour ozone NAAQS; seek to gain support
from other states for a broader inter-regional strategy; develop an
emissions budget and region-wide trading program; explore all feasible
options to utilize the CAIR framework; and develop implementation
mechanisms including a Memorandum of Understanding among the states.

Nov. 3, 2005	Statement of the Ozone Transport Commission With Regard to
Advancement of Potential Regional Control Measures for Emission
Reduction from Appropriate Sources and State Attain Planning Purposes
Directs the staff of the OTC to continue investigation and modeling work
associated with all potential regional control measures.

Feb. 23, 2006	Action Items Directs OTC staff to continue efforts on the
following issues:  Letter to EPA on Small Engines, Consumer Products,
Architectural/Industrial Maintenance Coatings (AIM), Chip Reflash,
Diesel Emissions Reductions, Modeling Efforts.

June 7, 2006	Memorandum of Understanding Among the States of the Ozone
Transport Commission on a Regional Strategy Concerning the Integrated
Control of Ozone Precursors from Various Sources  Commits OTC States to
continue to work with interested stakeholders and pursue state-specific
rulemakings as needed and appropriate regarding the following sectors to
reduce emission of ozone precursors: Consumer Products, Portable Fuel
Containers, Adhesives and Sealants, and Diesel Engine Chip Reflash.

June 7, 2006	Statement of the Ozone Transport Commission Concerning
Multi-Pollutant Emission Control of Electric Generating Units  Directs
OTC staff and its workgroups to continue to formulate a program beyond
CAIR to address emissions from this sector and to evaluate and recommend
options to address emissions associated with high electrical demand days
during the ozone season.

June 7 2006	Resolution 06-02 of the Ozone Transport Commission
Concerning Coordination and Implementation of Regional Ozone Control
Strategies for Certain Source Categories  Resolves that OTC States
continue to work with interested stakeholders and pursue state-specific
rulemakings as needed to establish emission reduction percentages,
emission rates or technologies as appropriate for the following source
categories: asphalt paving (cutback and emulsified), asphalt plants,
cement kilns, regional fuels, glass furnaces, and ICI boilers.

June 7, 2006	Resolution 06-03 of the Ozone Transport Commission
Concerning Federal Guidance and Rulemaking for Nationally-Relevant Ozone
Control Measures  Resolves that OTC States request that EPA pursue
federal regulations and programs for national implementation of control
measures comparable to the levels the OTC has adopted; these areas
include AIM Coatings, Consumer Products, ICI Boilers over 100 MMBTU,
Portable Fuel Containers, Municipal Waste Combustors, Regional Fuels,
Small Engine Emission Regulation, and Gasoline Vapor Recovery.

Nov. 15, 2006	Modified Charge of the Ozone Transport Commission to the
Stationary Area Source Committee Regarding Electric Generating Units
Directs the SAS Committee and workgroups to continue work on EGU
emission reduction strategies to incorporate “CAIR Plus” and High
Energy Demand Day (HEDD) emission reduction strategies.

Nov. 15, 2006	Statement of the Ozone Transport Commission Concerning
Regional and State Measures to Address Emissions from Mobile Sources
Supports the aggressive implementation of a suite of controls through
the OTC Clean Corridor Initiative including: diesel retrofits, the
Smartways program, California Low Emission Vehicle programs, anti-idling
programs, low-NOx diesel alternatives, transportation demand management
to reduce the growth in VMT, and voluntary action and outreach programs.

Nov. 15, 2006	Addendum to Resolution 06-02 of the Ozone Transport
Commission Concerning Coordination and Implementation of Regional Ozone
Control Strategies for Various Sources  Resolves that OTC States
continue to pursue state-specific rulemakings as needed to establish
emission reduction percentages, emission rates or technologies as
appropriate for the following source categories: asphalt plants, glass
furnaces, and ICI boilers.

OTC formal actions can be found on the OTC website at the following
address:

  HYPERLINK "http://www.otcair.org/document.asp?fview=Formal"
http://www.otcair.org/document.asp?fview=Formal

Table A-2: OTC Control Measures Public Meetings, 2004-2006

Date	Meeting	Location

June 8-9, 2004	OTC/MANE-VU Annual Meeting	Red Bank, NJ

Nov. 9-10, 2004	OTC Fall Meeting	Annapolis, MD

Apr. 21-22, 2005	OTC Stationary and Area Source/Mobile Source Committee
Meeting	Linthicum, MD

June 7-8, 2005	OTC Annual Meeting	Burlington, VT

Oct. 5, 2005	OTC Control Strategy Committee Meeting	Linthicum, MD

Nov. 2-3, 2005	OTC Fall Meeting	Newark, DE

Jan. 24, 2006	OTC Control Strategy Committee Meeting	Linthicum, MD

Feb. 22-23, 2006	OTC Special Meeting	Washington, DC

Apr. 5-6, 2006	OTC Control Strategy Committee Meeting	Linthicum, MD

June 6-7, 2006	OTC Annual Meeting	Boston, MA

July 28, 2006	OTC/RTO/ISO Meeting	Herndon, VA

Sep. 18, 2006	OTC High Energy Demand Day Workgroup Meeting	Herndon, VA

Sep. 19, 2006	OTC Stationary and Area Source Committee Meeting	Herndon,
VA

Nov. 2, 2006	OTC Control Strategies and Stationary and Area Source
Committee Meeting	Linthicum, MD

Nov. 15, 2006	OTC Fall Meeting	Richmond, VA

Dec. 5-6, 2006	OTC High Energy Demand Day Workgroup Meeting	Hartford, CT

Meeting agendas and presentations can be found on the OTC website at the
following address:

  HYPERLINK "http://www.otcair.org/document.asp?fview=meeting"
http://www.otcair.org/document.asp?fview=meeting

Table A-4: Stakeholder Comments on OTC Control Strategies

Stakeholder	Source Category

  HYPERLINK ""  Adhesive and Sealant Council 	Adhesives and Sealants

National Paint & Coatings Association (  HYPERLINK ""  NPCA) 	Adhesives
and Sealants

  HYPERLINK ""  Ameron International 	AIM Coatings

  HYPERLINK ""  McCormick Paints 	AIM Coatings

  HYPERLINK ""  National Paint and Coatings Association (NPCA) 	AIM
Coatings

  HYPERLINK ""  Painting and Decorating Contractors of America (PDCA)
AIM Coatings

  HYPERLINK ""  PROSOCO, Inc. 	AIM Coatings

  HYPERLINK ""  RUDD Company Inc. 	AIM Coatings

  HYPERLINK ""  TEX COTE 	AIM Coatings

  HYPERLINK ""  The Master Painters Institute (MPI) 	AIM Coatings

  HYPERLINK ""  The Society for Protective Coatings (SSPC) 	AIM Coatings

  HYPERLINK ""  Wank Adams Slavin and Associates, LLC (WASA) 	AIM
Coatings

  HYPERLINK ""  NAPA Asphalt Production 	Asphalt Production

  HYPERLINK ""  MATRIX Systems Auto Refinishing 	Auto Refinishing

  HYPERLINK ""  Portland Cement Association (PCA)  	Cement Kilns

  HYPERLINK ""  St Lawrence Cement 	Cement Kilns

  HYPERLINK ""  Consumer Specialty Products Association (CSPA) 	Consumer
Products

  HYPERLINK ""  Cosmetic, Toiletry and Fragrance Association (CTFA)
Consumer Products

  HYPERLINK ""  National Paint & Coatings Association (NPCA) 	Consumer
Products

  HYPERLINK ""  Clean Air Task Force 	Diesel Retrofits

Center for Energy and Economic Development, Inc. (  HYPERLINK ""  CEED)
EGUs

  HYPERLINK ""  Chesapeake Bay Foundation 	EGUs

  HYPERLINK ""  Clean Air Task Force 	EGUs

  HYPERLINK ""  Conectiv Energy 	EGUs

  HYPERLINK ""  Dominion 	EGUs

  HYPERLINK ""  Exelon 	EGUs

International Brotherhood of Electrical Workers , United Mine Workers of
America, Center for Energy & Economic Development, Inc., Pennsylvania
Coal Association	EGUs

  HYPERLINK ""  NRG 	EGUs

  HYPERLINK ""  PPL Services 	EGUs

  HYPERLINK ""  The Clean Energy Group 	EGUs

  HYPERLINK ""  National Lime Association (NLA) 	Lime Kilns

  HYPERLINK ""  Debra Jacobson, Prof. Lecturer in Energy Law 	NOx
Sources

  HYPERLINK ""  Flexible Packaging Association (FPA)s 	Printing/Graphic
Arts

  HYPERLINK ""  Graphic Arts Coalition Flexography Air Regulations
Printing – Flexography

  HYPERLINK ""  Graphic Arts Coalition Printing & Graphic Arts
Printing/Graphic Arts

  HYPERLINK ""  Graphic Arts Coalition Screen Litho Air Regulations
Printing – Lithography

Stakeholder comments can be found on the OTC website at the following
address:

  HYPERLINK
"http://www.otcair.org/projects_details.asp?FID=95&fview=stationary"
http://www.otcair.org/projects_details.asp?FID=95&fview=stationary

Table A-4: OTC Conference Calls and Meetings with Stakeholders, 2006

Source Category	Date(s)	Industry Lead

Adhesives and Sealants	Aug. 30, 2006	Adhesives Council

Asphalt Paving	Mar. 30, 2006

Sep. 21, 2006

Sep. 28, 2006

Oct. 13, 2006	National Asphalt Paving Association (meeting)

National Asphalt Paving Association

Asphalt Emulation Manufacturers Association

Asphalt Emulation Manufacturers Association

Asphalt Production	Oct. 25, 2006	National Asphalt Paving Association
(meeting)

Consumer Products	Mar. 24, 2006

June 22, 2006

June 22, 2006

Aug. 29, 2006	Consumer Specialty Products Association

American Solvents Council (meeting)

Consumer Specialty Products Association

Consumer Specialty Products Association

Glass Manufacturers	July 5, 2006

Aug. 16, 2006

Sep. 14, 2006

Oct. 19, 2006	North American Insulation Manufacturers Assoc.

North American Insulation Manufacturers Assoc.

Glass Association of North America

Glass Association of North America

ICI Boilers	Mar. 14, 2006

Mar. 24, 2006

July 18, 2006

Aug. 1, 2006	Council of Industrial Boiler Owners

Institute of Clean Air Companies

Council of Industrial Boiler Owners (meeting)

Council of Industrial Boiler Owners (conference)

Appendix B – Initial List of Control Measures

The comprehensive list of control measures can be found at:

  HYPERLINK "http://www.otcair.org"  http://www.otcair.org

Appendix C – Control Measure Worksheets

This Appendix contains the Control Measure Summary Worksheets for the
following source categories:

Manufacture and Use of Adhesives and Sealants

Architectural and Industrial Maintenance Coatings

Asphalt Paving (Emulsified and Cutback)

Asphalt Production Plants

Automotive Refinish Coatings

Cement Kilns

Chip Reflash (Heavy Duty Diesel Engines)

Consumer Products

Glass and Fiberglass Furnaces

Industrial, Commercial, Institutional Boilers

Industrial Surface Coatings – Fabric Printing, Coating, and Dyeing

Industrial Surface Coatings – Large Appliances

Industrial Surface Coatings – Metal Cans

Industrial Surface Coatings – Metal Coils

Industrial Surface Coatings – Metal Furniture

Industrial Surface Coatings – Miscellaneous Metal Parts

Industrial Surface Coatings – Paper and Web Coating

Industrial Surface Coatings – Plastics Parts

Industrial Surface Coatings – Wood Building Products

Industrial Surface Coatings – All Categories

Lime Kilns

Municipal Waste Combustors

Printing and Graphic Arts

Portable Fuel Containers

Reformulated Gasoline

CONTROL MEASURE SUMMARY

Manufacture and Use of Adhesives and Sealants

(SCC-<PHONE_NUMBER>)

Control Measure Summary

The provisions of this model rule limit emissions of volatile organic
compounds (VOCs) from adhesives, sealants and primers.  The model rule
achieves VOC reductions through two basic components: sale and
manufacture restrictions that limit the VOC content of specified
adhesives, sealants and primers sold in the state; and use restrictions
that apply primarily to commercial/industrial applications.  By reducing
the availability of higher VOC content adhesives and sealants within the
state, the sales prohibition is also intended to address adhesive and
sealant usage at area sources.  Emissions from residential use of
regulated products are addressed through the sales restrictions and
simple use provisions.

A reasonably available control technology determination prepared by the
California Air Resources Board (CARB) in 1998 forms the basis of this
model rule.  In the years 1998-2001, the provisions of the CARB
determination were adopted in regulatory form in various air pollution
control districts in California including the Bay Area, South Coast,
Ventura County, Sacramento Metropolitan and San Joaquin Valley.

Costs and Emissions Reductions

2002 existing measure:  No existing limitations for this category

Candidate measure:  Approximately 75% of VOC emissions originate from
solvent-based adhesives and sealants, the remaining 25% of VOC in this
category are due to water-based materials. VOC content limits have been
enacted by various APCD in California from 1998 to 2001.

Emissions reductions: VOC content limits for the solvent-based materials
can result in 64.4% reduction in total emissions from this category.
(CARB RACT/BARCT for Adhesives/ Sealants, Dec 1998)

Control costs:  Costs for control by reformulation are estimated by the
CARB at less than $2500 / ton (1999$).  Many manufacturers have either
reformulated solvent-based products to reduce the VOC content or have
developed low-VOC water-based latex and acrylic products, or
polyurethane or silicone products in response to the adoption of similar
regulations in California.  Thus, the actual costs in the OTC region are
anticipated to be lower.

Estimated costs for add-on controls carbon and thermal oxidizers ranged
from $10,000 to $100,000 per ton.

Timing of implementation: 01/01/09

Implementation area:  Region-wide	Annual VOC

2002 Emissions: 35,489 tpy

2009 Emissions: 46,241 tpy

2009 Reduction: 29,438 tpy

2009 Remaining: 16,803 tpy

Summer VOC

2002 Emissions:  99.8 tpd

2009 Emissions: 129.8 tpd

2009 Reduction:  82.3 tpd

2009 Remaining:  47.5 tpd

Interaction with other OTC Model Rules

The products regulated in this model rule do not overlap with the
products regulated by either the architectural and industrial
maintenance (AIM) or consumer product rules.  A “coating,” as
contemplated in the AIM rule, is a “material applied onto or
impregnated into a substrate for protective, decorative or functional
purposes.”  Because the coating is applied only to one substrate, it
is clearly distinguished from adhesives and sealants, which are defined
in both the consumer product and adhesive rules by application to two
surfaces; in the case of adhesives, the two surfaces are directly bonded
while in the case of sealants, a gap between two surfaces is filled.

The overlap between the consumer product and adhesive rules is addressed
mainly by an exemption in the adhesive rule for adhesives and sealers
subject to the state’s consumer products regulation.

Reference:

California Air Resources Board.  Determination of Reasonably Available
Control Technology and Best Available Retrofit Technology for Adhesives
and Sealants.  December 1998.  Page 18 provides the emission reduction
estimates for California: the ARB emission inventory estimates 45 tons
per day pre-rule; reductions will range from approximately 29 to 35 tons
per day.  We used the low end of this range to calculate the percent
reduction of 64.4% (i.e. 29 tpd/45 tpd).  Page 17 provides the
cost-effectiveness information:  the cost of complying with the
determination reflects the cost of using alternative formulations of
low-VOC or water-based adhesives, sealants, and cleanup products.
Ventura County APCD staff determined that the cost-effectiveness of
their adhesives rule ranges from a savings of $0.53 per pound to a cost
of $1.16 per pound of VOC reduced ($1,060 to 2,320). The use of add-on
control equipment to comply was $4.50 to $55.00 per pound ($9,000 to
$110,000).

CONTROL MEASURE SUMMARY FOR

AIM Coatings

Control Measure Summary: VOC emission reductions can be obtained through
modifying the current formulation of the coating to obtain a lower VOC
content. The regulatory approach for reducing emissions is to establish
VOC content limits for specific coatings that manufacturers are required
to meet either through reformulating products or substituting products
with compliant coatings.	Emissions (tons/year)

2001 existing measure:  Federal AIM rules 40CFR Part 59

Emission Reductions:  20% reduction from uncontrolled levels

Control Cost:  $228 per ton

Timing of Implementation:  Compliance required by September 1999

Implementation Area:  Nationwide	VOC (with Part 59 limits)

2002 OTR total:    124,173

2009 On-the-Way Measure:  OTC Model Rule based on a model rule adopted
by the California Air Resources Board (CARB) in June, 2000 for 33 air
control districts.

Emission Reductions:  31% beyond Federal AIM rule

Control Cost:  $6,400 per ton 	VOC (After OTC Model Rule)

2009 Reduction:    -25,150

2009 Remaining:    99,023

Candidate measure: Follow CARB 2007 Rulemaking.  Modify rule as
appropriate when complete (in time for 2009) Participate actively in
CARB process.  Conduct survey in 2006 for 2005 sales data.

Emission Reductions :  6% emissions reduction

For modeling purposes we split the difference between SCAQMD and OTC
model rule. But we go 75% of the way toward SCAQMD on the top four sales
products, and set a 250 g/l VOC limit for Industrial Maintenance
coatings. The reductions are calculated using the “reg neg”
spreadsheet.

Control Cost:  Cost of OTC Survey (revise with cost data from the future
CARB SCM when available in 2007)  SCAQMD estimated the overall
cost-effectiveness for their 1999 Amendments to $13,317 per ton.  For
Dec. 5 2003 amendments to Rule 1113, SCAQMD estimated the
cost-effectiveness to be in the range of $4,229 to $11,405 per ton

Timing of Implementation: 01/01/09

Implementation Area:  Throughout OTR and MRPO	VOC (After CARB 2007 Rule)

2009 Reduction:    -5,941

2009 Remaining:   93,082

REFERENCES:

2002 Existing Measure (Federal Part 59 Rules):

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation
Report, September 2005.  Pages III-1347 and III-1348 shows the 20%
reduction for the Federal Part 59 rule at a cost of $228 per ton
(1990$).

2009 On-the-Books Measure (OTC Model Rule):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001.
Table II-6 shows 31% reduction (OTC Model Rule beyond Federal rule).
Page 15 presents cost of $6,400 per ton based on CARB’s 2000 Staff
Report for the Suggested Control Measure for Architectural Coatings.

Candidate Measure (CARB 2007 Suggested Control Measure):

CARB is in the process of updating the 2000 Suggested Control Measure
(SCM) for Architectural Coatings this year.  They will be using 2004
survey data as an important resource to update the SCM, but will not
begin the formal SCM update process until the survey is completed. They
anticipate bringing the SCM update to our Board in mid to late 2007.

CARB is developing an analysis of costs for implementing an updated
it’s Suggested Control Measure.  Results of the analysis will not be
available until 2007.

Cost information for the South Coast Phase rules were obtained from:

South Coast Air Quality Management District.  Final Staff Report for
Proposed Amended Rule 1113 – Architectural Coatings.  December 5,
2003.  “estimated the cost-effectiveness to be in the range of $4,229
to $11,405 per ton of VOC reduced. The low end of the range was
determined based on the retail cost of compliant coatings reported by
coating manufacturers surveyed by staff. The upper end of the range was
derived by estimating the increased cost at the retail level due to the
increase in cost of raw materials, reformulation, testing and packaging
a new product prior to commercialization.”  The Dec. 2003 amendments
lowered the VOC limit for the following specialty coating categories:
clear wood finishes including varnishes and sanding sealers, roof
coatings, stains, and waterproofing sealers including concrete and
masonry sealers.

South Coast Air Quality Management District.  Appendix F Addendum to
Staff Report, Final Socioeconomic Impact Assessment, Proposed Amendments
to Rule 1113.  May 1999.  The May 1999 amendments to Rule 1113 lower VOC
limits for the coating categories of industrial maintenance; non-flats;
primers, sealers, and undercoaters; quick-dry enamels; quick-dry
primers, sealers, and undercoaters; roof coatings; floor coatings, rust
preventative coatings, stains, and waterproofing wood sealers.  The
overall cost-effectiveness of the proposed amendments, (total
costs/total emission reductions) over the years 2002-2015, is estimated
to be $13,317 per ton.

CONTROL MEASURE SUMMARY FOR EMULSIFIED AND CUTBACK ASPHALT PAVING

Control Measure Summary: OTC Regional Ban on Cutback Asphalt in Ozone
Season, with lower VOC/Solvent Contents for Emulsified Asphalt. 	VOC
Emissions in

Ozone Transport Region

2002 existing measures:

1. Cutback asphalt: The OTC states typically ban the use of cutback
asphalt during the ozone season.  States do provide various exemptions
to the ban, most notably  allowances may be made for cutbacks which
contain less than 5% VOC.

2. Emulsified asphalt:  Ten of the OTC states regulate emulsified
asphalt by providing allowable VOC content limits for the various
applications.  Three of the states do not address emulsified asphalts in
their regulation.

Control Cost:  According to the 1977 CTG (EPA-450/2-77-037), which
formed the basis for the existing regulations, the use of emulsified
asphalts (no VOC) presented a cost savings.

Timing of Implementation: All regulations implemented in 1990s or
earlier under the 1-hour ozone standard.

Implementation Area:  OTC 1-hour ozone non-attainment areas.

Annual VOC

2002 cutback:    9,154 tpy

2002 emulsified:  10,379 tpy

2002 total:  19,533 tpy

Summer VOC

2002 cutback:  17.5 tpd

2002 emulsified:  38.5 tpd

2002 total:        56.0 tpd

Candidate measure: For cutback asphalt paving

Measure ID: BOTW09-AP-Cutback

Place a complete prohibition on the use of cutback asphalt during the
ozone season.

Emission Reductions: to be achieved from using lower VOC content
emulsified asphalt products or working outside the ozone season.

Control Cost:  Negligible.

Timing of Implementation:  01/01/09

Implementation Area: All OTC 8-hour ozone non-attainment counties or
individual state-wide.

Summer VOC

2009 OTB:  19.9 tpd

2009 Reduction:  19.9 tpd

2009 Remaining:   0.0 tpd

Candidate measure: For emulsified asphalt paving

Measure ID: BOTW09-AP-Emulsified

Proposes to limit ozone season use of emulsified asphalt to that which
contains not more than 0.5 ml of oil distillate from the 200 mL sample
using the ASTM D244 test method regardless of application (which is
0.25% VOC by volume)

Emission Reductions: to be achieved from using lower VOC content
emulsified asphalt products or working outside the ozone season.

Control Cost:  Negligible

Timing of Implementation:  01/01/09

Implementation Area: All OTC 8-hour ozone non-attainment counties or
individual state-wide.

Summer VOC

2009 OTB:  44.2 tpd

2009 Reduction:   39.9 tpd

2009 Remaining:  4.3 tpd

d

Control Measure Recommendation:

States implement most stringent measure possible to achieve VOC
reductions by 2009 from OTB projections in OTC states, with out
disrupting state and county paving operations.

Brief Rationale for Recommended Strategy:

(1) Delaware already implements and complies with the most stringent
proposed control strategy.

(2) The control strategy is supported by the 1977 Control Techniques
Document EPA-450/2-77-037.

CONTROL MEASURE SUMMARY FOR

Asphalt Production Plants

Control Measure Summary: NOx emission reductions can be obtained through
installation of low NOx burners and flue gas recirculation.  SO2 can be
reduced by reducing the sulfur in fuel limits for distillate oil to 500
ppm.	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  No existing limitations for this specific
category have been identified.

	2002 NOx Base:

2002 SO2 Base:	827

847

Candidate Measure:

Emission Reductions: NOx can be reduced between 35% to 50% with low NOx
burners and flue gas recirculation (FGR).  SO2 can be reduced 25% to 75%
by reducing the sulfur in fuel limits for distillate oil to 500 ppm.

The MANEVU data for this category is incomplete.  Only major point
sources are typically included in the point source database.  Non-major
source emissions are likely lumped into the area source inventory with
other industrial/commercial boilers/heaters.  The point source data
projects only 800+ tons per year (TPY) of both NOx and SO2 actual
emissions in 2002 for the entire region.  New York actual emissions are
over 600 TPY of NOx and 400 TPY of SO2.  Therefore, it is unknown what
the actual reductions will produce as no accurate baseline exists for
both major and minor facilities.

Control Cost:  Costs for control are similar to those of small to
midsize boilers or process heaters.  Low NOx burners range from $500 to
$1250 per ton.  While Low NOx burners in combination with FGR range from
$1000 to $2000 per ton.

Projected cost increase from lowing sulfur in distillate oil is
approximately 2 to 3 cents per gallon.

Timing of Implementation: Similar to the NOx RACT procedures of 1994.
Require a NOx compliance plan by the spring of 2008 with full
implementation and compliance within one year (01/01/09).

Unknown for sulfur-in-fuel reductions.

Implementation Area:  Region-wide

	NOx

2009 Base:

2009 Reduction:

2009 Remaining:

SO2

2009 Base:

2009 Reduction:

2009 Remaining:

1,276

-549

727

1,266

-950

316

Recommended Strategy: States should support rules that encourage a
combination of Best Management Practices, Low NOx Burners and FGR in
asphalt production plants to achieve a 20-35% reduction in NOx emissions
form a 2002 base, and encourage the use of low-sulfur oil.

Area source emissions from asphalt plants are not included in this
summary.

REFERENCES:

Note: The reductions estimated for this category only include emissions
from point sources.  Area source emissions from fuel combustion at
asphalt production plants are not explicitly contained in the area
source emissions.  These emissions are likely lumped together in the
general area source industrial and commercial fuel use category.
Reductions from area source emissions at asphalt production plants are
included in the ICI boiler source category.

Candidate Measure (Low NOx Burners plus FGR; low sulfur fuel oil):

The emission reduction estimates and cost-effectiveness data were
provided by NYSDEC.  These control efficiencies and cost-effectiveness
estimates for Low NOx Burners plus FGR are generally consisten with the
data presented in E.H. Pechan & Associates, Inc., AirControlNET Version
4.1: Documentation Report, September 2005.  Information in this report
for small oil-fired process heaters and ICI boilers provide similar
levels of control and cost-effectiveness.

Candidate Measure (Best Management Practices)

Best Practices to Reduce Fuel Consumption and/or Lower Air Emissions:
HMA industry leaders have identified a number of Best Practices that, if
implemented, allow for substantial reduction in plant fuel consumption
and the corresponding products of combustion including NOx. In today’s
business environment, there is significant incentive to reduce fuel
usage.  For this reason, implementing best practices to reduce fuel
consumption and NOx emissions, forms the basis of a sustainable
strategy.

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

Burner tune-ups: As identified in OTC Resolution 06-02 and companion
control measures summaries, a burner tune-up may reduce NOx emissions by
up to 10 percent. From a contractor’s perspective, this also is
helpful in reducing fuel consumption. In other words, there can be a
direct pay-back to the business from regular burner tune-ups.

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

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

Plant Type	Emission Rate

(lbs NOx/ton asphalt produced)	% Reduction

Area/Point Sources (State emissions option)

   Batch Mix Plant – Natural Gas	0.02	35

   Batch Mix Plant – Distillate/Waste Oil	0.09	35

   Drum Mix Plant – Natural Gas	0.02	35

   Drum Mix Plant – Distillate/Waste Oil	0.04	35

Area/Point Sources (State technology option)

   Batch/Drum Mix Plant – Natural Gas	Low-NOx Burner Technology

and/or Best Management Practices

   Batch/Drum Mix Plant – Distillate/Waste Oil	Low-NOx Burner
Technology

and/or Best Management Practices

CONTROL MEASURE SUMMARY FOR

Auto Refinish Coatings – Area Source

Control Measure Summary: Limiting the concentration of solvents in Auto
Refinishing Coatings in order to reduce VOC emissions. Encourage the use
of high transfer-efficiency painting methods (e.g., high volume low
pressure spray guns), and controls on emissions from equipment (e.g.,
spray gun) cleaning, housekeeping activities (e.g., use of sealed
containers for clean-up rags), and operator training.	Emissions
(tons/year) in Ozone Transport Region

2002 existing measure:  Federal Auto Body Refinishing rules 40CFR Part
59 Subpart B

Emission Reductions:  37% reduction from Part 59 (from Pechan OTC Model
Rule Report) due to Part 59 VOC content limits

Control Cost:  $118 per ton for Part 59 rules

Timing of Implementation:  Part 59 compliance required by January 1999

Implementation Area:  Part 59 – Nationwide;	VOC Uncontrolled:

2002 Reduction:

2002 Base:

50,759

-18,781

31,978

OTB Control Measure:  OTC Model Rule for Mobile Equipment Repair and
Refinishing

Emission Reductions:  38% reduction from 2002 Levels in those States
that adopted OTC model Rule (per Pechan March 31, 2001 OTC Model Rule
Report)

Control Cost:  $1,534 per ton of VOC

Timing of Implementation: Assuming 2007 effective date of rule, emission
reductions are achieved 01/01/09.

Implementation Area: All counties in the OTR.

	VOC:

2009 Reduction:

2009 Remaining:

-10,468

21,510

Candidate measure:  CARB October 20, 2005 SCM Staff Report – Lowers
VOC limits, combines coatings categories, simplifies recording.

Emission Reductions: CARB estimates a 65% reduction in VOC emissions
from a 2002 baseline; the OTC model rule is very similar to the CARB
2002 baseline, so a similar reduction would be expected in the OTR.

Control Cost:  $2,860 per ton

Timing of Implementation: Assuming 2007 effective date of rule, emission
reductions are achieved in beginning 01/01/09.

Implementation Area: All counties in the OTR.

	VOC:

2009 Reduction:

2009 Remaining:

-13,981

7,529

REFERENCES:

2002 Existing Measure (Federal Part 59 Rules):

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation
Report, September 2005.  Pages III-1364 shows the Federal Part 59 rule
at a cost of $118 per ton (1990$) and a reduction of 37 percent from
uncontrolled levels.

2009 On-the-Books Measure (OTC Model Rule):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001.
Table II-6 shows 37% reduction for Federal Part 59 rule and 38% (OTC
Model Rule beyond Federal rule).  Page 17 presents cost of $1,534 per
ton based on estimates used for PA Rule 129.75.

Candidate Measure (CARB 2005 Suggested Control Measure):

California Air Resources Board.  Staff Report for the Proposed Suggested
Control Measure for Automotive Coatings.  October 2005.  Table V-3 shows
the estimated 65% reduction from 2002 baseline emissions for new
automotive coatings limits.  A similar reduction is expected for the
OTR.  Page VII-6 indicates that the cost-effectiveness of the SCM is
estimated to be $1.43 per pound of VOC reduced ($2,860 per ton). The
CARB SCM coating categories and VOC limits are:

The OTC Model Rule coating categories and VOC limits are:

OTC Model Rule

Limit

Coating Type

Grams per Liter

Pounds per gallon

Automotive pretreatment primer

780

6.5

Automotive primer-surfacer

575

4.8

Automotive primer-sealer

550

4.6

Automotive topcoat:

single stage-topcoat

600

5.0

2 stage basecoat/clearcoat

600

5.0

3 or 4-stage basecoat/clearcoat

625

5.2

Automotive Multi-colored Topcoat

680

5.7

Automotive specialty

840

7.0

CONTROL MEASURE SUMMARY FOR

Cement Kilns

Control Measure Summary:	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  NSR; PSD; State RACT.

 	 NOx

2002 Base:

31,960

On the Books:  NOx SIP Call

Measure ID: NOx SIP Call

Emission Reductions:  The SIP Call requirements were estimated by EPA to
result in NOx reductions of approximately 25 percent from the cement
industry.

Control Cost:  $2,000 per ton

Timing of Implementation:  2004

Implementation Area:  OTR 	NOx

2009 Base:

2009 Reduction:

2009 Remaining:

31,960

-7,990

23,970

Candidate measure:  Use of proven control technologies (such as SNCR) or
other methods to meet recommended emission limits.

Emission Reductions:  source specific, varies from 0-63% based upon 2002
base rates.

Control Cost:  less than 2,500 per ton

Timing of Implementation:  01/01/09

Implementation Area:  OTR	                   NOx

2009 Base:

Candidate Reduction:

2009 Remaining:

31,960

-13,231

18,279

Policy Recommendation:  It is recommended that a program be developed
reduces NOx emissions from existing cement kilns by requiring existing
kilns to meet a NOx emission rate of

3.88 lbs/ton clinker for wet kiln

3.44 lbs/ton clinker for long dry kiln

2.36 lbs/ton clinker for pre-heater kiln

1.52 lbs/ton clinker for pre-calciner kiln.

Trading between facilities would not be permitted, but averaging at a
facility would be permissible.

Brief Rationale for Recommended Strategy:  This limit is consistent with
the emission reduction capabilities of SNCR.  There are 18 full-scale
SNCR installations in Europe.

REFERENCES

EC/R Incorporated.  NOx Control Technologies for the Cement Industry –
Final Report. September 19, 2000.  This report for EPA shows data for
two SNCR technologies, biosolids injection and NOXOUT®. These
technologies showed average emission reductions of 50 and 40 percent,
respectively.  For biosolids injection, “Cost effectiveness for this
kiln is based on the annualized costs of ($320,000/year), the emission
reduction achieved at that facility (emissions decreased from 2.4 lb/ton
of clinker to 1.2 lb/ton of clinker), a kiln capacity of 215 tons/hr,
and an annual operation of 8,000 hr/yr. Cost effectiveness is a credit
of ($310/ton) for installing biosolids injection on this kiln” due to
tipping fee for using biosolids (dewatered sewage sludge)  For NOXOUT®,
“40 percent NOX reduction based on the available test data. Cost
effectiveness for the two kilns, using urea as the reagent, is based on
an uncontrolled emission rate of 3.8 lb NOX/ton of clinker, kiln
capacities of 92 and 130 tons/hr respectively, annual operation of 8,000
hr/yr, and a NOX control efficiency of 40%. Cost effectiveness is
$1,000/ton for the smaller kiln and $2,500/ton for the larger kiln.”

European Commission.  Integrated Pollution Prevention and Control (IPPC)
Reference Document on Best Available Techniques in the Cement and Lime
Manufacturing Industries.  December 2001.  These report indicates that
there are 18 full-scale SNCR installation in Europe.  Most SNCR
installations are designed and/or operated for NOx reduction rates of
10-50% which is sufficient to comply with current legislation in some
countries.  Two Swedish plants installed SNCR in 1996/97 and have
achieved a reduction of 80-85% at both kilns.

Emission Rates:

Table 4-5 of the EPA’s NOx Control Technologies for the Cement
Industry, September 19, 2000 provides the following uncontrolled
emission rates for the four types of cement kilns:

Kiln Type	Heat Input Requirement

(mmBtu/ton of clinker)	Average NOx Uncontrolled Emission Rate

(lb/ton of clinker)	Range of NOx Uncontrolled Emission Rate

(lb/ton of clinker)

Wet 	6.0	9.7	3.6 to 19.5

Long Dry	4.5	8.6	6.1 to 10.5

Preheater	3.8	5.9	2.5 to 11.7

Precalciner	3.8	3.8	0.9 to 7.0

The OTC Control Measure Summary Sheet calls for a 60% reduction from
uncontrolled emissions.  Using this percent reduction figure and the
uncontrolled emission rates above, the following controlled emission
rates were calculated:

Kiln Type	Percent Reduction from Uncontrolled	Low-End NOx Controlled
Emission Rate

(lb/ton of clinker)	Average NOx Controlled Emission Rate

(lb/ton of clinker)	High-End NOx Controlled Emission Rate

(lb/ton of clinker)

Wet 	60	1.44	3.88	7.80

Long Dry	60	2.44	3.44	4.20

Preheater	60	1.00	2.36	4.68

Precalciner	60	0.36	1.52	2.80

The State/workgroup lead recommended the use of the the average NOx
Controlled emission rates in the above table (expressed as lb/ton of
clinker).

CONTROL MEASURE SUMMARY FOR

Chip Reflash

Control Measure Summary: Upgrade the version of software in engine
electronic control module (ECM) aka “Chip Reflash”. Software
reprograms the vehicle's computer and reduces off-cycle NOx emissions.
The installation process typically takes between one-half to one hour.
Emissions Reductions (tons/day)

2002 existing measure:

No existing measure in the OTR other than the EPA program resulting from
the consent decrees on 7 heavy duty engine manufacturers.  The results
of the EPA program thus far are significantly lower than the level
originally projected by the Agency (less than 10% implementation). CARB
implemented a voluntary program that did not achieve its expected
results, so the Board’s backstop mandatory program was triggered. The
CARB mandatory program is facing two separate legal challenges, alleging
that CARB has breached its settlement agreement and alleging that CARB
is illegally establishing different emissions standards on “new
engines”.

Candidate measure:

Measure ID: Model rule for Mandatory Chip Reflash Program in the OTR

Emission Reductions:  NOx reduction (TPD) from in-state registered
vehicles

Control Cost:  Moderate – manufacturers must provide the rebuild kits
free to any truck operator who requests it.  The cost associated with
the reflash has been estimated at $20-$30 per vehicle, which is borne by
the engine manufacturer.  There may be costs associated with potential
downtime to the trucking firms, and record-

keeping requirements on the dealer performing the reflash and the
vehicle owner. For the MRPO, ENVIRON estimated cost effectiveness to be
“$1,800 to $2,500 (depending on vehicle size) due to incremental
“fuel penalty” of 2% increase in fuel consumption).  However, in
reality, no fuel penalty has been documented on vehicles that have
already been reflashed.

Timing of Implementation: The kits are currently available, so once the
states adopt the rule, retrofits can begin according to the schedule.

Implementation Area: All OTR and MRPO states (NOx reductions 109 TPD)

LADCO

Northeast

states

Mid-Atlantic

States

Total OTR

46 TPD

41 TPD

22 TPD

63 TPD

Policy Recommendation of State/Workgroup Lead:  Expand scope of the
model rule for the Northeast states to the entire OTR and MWRPO

Brief Rationale for Recommended Strategy:  While the EPA program
provides a good platform for chip reflash retrofits, the federal program
is not even achieving 10% of its estimated emission reductions.  The
kits are available and must be given to the truckers for free; yet
without additional motivation, it is unlikely that the implementation
rate will improve due to fuel consumption and/or performance perceptions
and the ability to extend the time to next major rebuild/overhaul.  The
states in the OTR do not face the prospect of breach-of-settlement
allegations that CARB did in adopting a mandatory program, since they
did not participate in the negotiation of the CD settlements.  And there
are significant emission reductions that can be achieved through a
mandatory program, even though installing the kits will not result in
the engines operating at the same emission levels required for the EPA
engine certification test.  Nevertheless, this is a relatively simple
fix for a problem that our states will face if they rely on the federal
program alone to produce emission reductions from these sources.

CONTROL MEASURE SUMMARY FOR

Consumer Products

Control Measure Summary: Consumer Products

This control measure establishes limits on the VOC content of consumer
products.  It is based on the California Air Resources Board (CARB)
consumer products rules, with some region specific modifications.  It
regulates categories such as hairspray, air fresheners, glass and
general purpose cleaners, adhesives, anti-perspirants and deodorants,
insecticides and automotive aftermarket products.  	VOC Emissions in
Ozone Transport Region

2002 Existing Measure: The Federal Consumer Products Rule Part 59

Emission Reductions:  20 % reduction of the categories being regulated
or 9.95 % reduction of the entire consumer products inventory (about 40
% of products were included in rule).

Control Cost:  $237 per ton of VOC reduced

Timing of Implementation: 12/98

Implementation Area: Nationwide 	2002 Annual

Uncontrolled:

Reduction:

Remaining:

2002 Summer

Uncontrolled:

Reduction:

Remaining:

258,537 tpy

25,724 tpy

232,813 tpy

713.9 tpd

71.0 tpd

642.9 tpd

2009 On-the-Books Measure: Adopt the 2001 OTC Model Rule for Consumer
Products in all OTC states (this model rule was based on a series of
five CARB consumer products rules).

Emission Reductions:  14.2 % beyond federal rule or a total of 21 % from
the uncontrolled state.

Control Cost: $800 per ton VOC reduced

Timing of Implementation:  1/1/05 effective date of VOC limits (though
some states were later and some have yet to adopt)

Implementation Area: OTR	2009 Annual

Reduction:

Remaining:

2009 Summer

Reduction:

Remaining:

22,916 tpy

209,897 tpy

63.4 tpd

579.5 tpd

Candidate Measure #1: Adopt the CARB amendments to their consumer
products rule, adopted 7/20/05, with the exception of the 12/31/09
shaving gel, and 12/31/08 anti-static aerosol VOC limits.  This rule
sets new VOC limits for 11 categories, revises the existing VOC limit
for 1 category and includes some additional requirements.  See more
detailed limits below.

Emission Reductions:  CARB estimates their rule will achieve a 6.3
ton/day reduction of VOC in California, which is equivalent to about
11.3 tons per day in the OTR or a 2% reduction beyond the on-the-books
measure.

Control Cost: $4,800 per ton of VOC reduced

Timing of Implementation: 01/01/09

Implementation Area OTR	2009 Annual

Reduction:

Remaining:

2009 Summer

Reduction:

Remaining:

7,453 tpy

202,444 tpy

20.6 tpd

558.9 tpd

Candidate Measure #2:  Follow and adopt as appropriate CARB ‘s next
round of amendments  to their consumer products rule, to be developed
and proposed by approximately late 2006/early 2007 with limits effective
in 2010.

Emission Reductions: The CONS-2 amendments are estimated by CARB to
achieve VOC reductions of about 20-35 tpd in California by 2010 which is
equivalent to about 36-63 tpd in the OTR (The mid-point of this range
was used in the calculations, 49.5 tpd).

Control Cost:  Unknown at present;

Timing of Implementation: 01/01/10

Implementation Area OTR	VOC not modeled:

2009 Annual

Reduction:

Remaining:

2009 Summer

Reduction:

Remaining:

Not Available

Summary of Candidate Measure #1:  The proposed VOC limits based on
CARB’s 7/20/05 amendments are as follows:

Summary of Candidate Measure #1:  The proposed VOC limits based on
CARB’s 7/20/05 amendments are as follows:

PRODUCT CATEGORY

CARB VOC CONTENT LIMIT %

OTC PROPOSED CONTENT LIMIT%

CARB EFFECTIVE DATE

OTC

PROPOSED EFFECTIVE DATE

Adhesive, Contact – General purpose *

55

55

12/31/2006

1/1/2009

                                  Special Purpose*

80

80

12/31/2006

1/1/2009

Adhesive Remover - Floor or Wall covering

5

5

12/31/2006

1/1/2009

                                  Gasket or Thread Locking

50

50

12/31/2006

1/1/2009

                                  General Purpose

20

20

12/31/2006

1/1/2009

                                   Specialty

70

70

12/31/2006

1/1/2009

Anti-static - non-aerosol

11

11

12/31/2006

1/1/2009

Electrical Cleaner

45

45

12/31/2006

1/1/2009

Electronic Cleaner

75

75

12/31/2006

1/1/2009

Fabric refresher – aerosol

15

15

12/31/2006

1/1/2009

                      non-aerosol

6

6

12/31/2006

1/1/2009

Footware or Leather Care  - aerosol

75

75

12/31/2006

1/1/2009

                                              Solid

55

55

12/31/2006

1/1/2009

                                      all other forms

15

15

12/31/2006

1/1/2009

Graffiti Remover –aerosol

50

50

12/31/2006

1/1/2009

                       non-aerosol

30

30

12/31/2006

1/1/2009

Hair Styling Products – aerosol & pump sprays

6

6

12/31/2006

1/1/2009

                               all other forms

2

2

12/31/2006

1/1/2009

Shaving Gel

7

7

12/31/2006

1/1/2009

Toilet/Urinal Care – aerosol

10

10

12/31/2006

1/1/2009

                         non-aerosol

3

3

12/31/2006

1/1/2009

Wood Cleaner – aerosol

17

17

12/31/2006

1/1/2009

                   non-aerosol

4

4

12/31/2006

1/1/2009

* Change to an existing category

References:

2002 Existing Measure (Federal Part 59 Rules):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001.

E.H. Pechan & Associates, Inc., AirControlNET Version 4.1: Documentation
Report, September 2005.  Pages III-1377 shows the Federal Part 59 rule
at a cost of $237 per ton (1990$).

2009 On-the-Books Measure (OTC Model Rule):

E.H. Pechan & Associates, Inc., Control Measure Development Support
Analysis of Ozone Transport Commission Model Rules, March 31, 2001.
Table II-6 shows 14.2% reduction (OTC Model Rule beyond Federal rule).
Page 8 presents cost of $800 per ton based on CARB’s Sept. 1999
Initial Statement of Reasons for Proposed Amendments to the California
Consumer Products Regulation.

Candidate Measure #1 (CARB 2005 and 2006/2007 Amendments):

California Air Resources Board.  Initial Statement of Reasons for
Proposed Amendments, Volume 1: Executive Summary.  June 24, 2004.  Table
2 of the Executive Summary shows that the CONS-1 amendments will achieve
reductions of about 6.8 tons per day state wide (6.3 tons per day
without the 12/31/09 Shaving gel, and 12/31/08 anti-static aerosol
regs..  Page 21 states the cost of CONS-1 will be $2.40 per pound
($4,800 per ton).  Since OTC’s model rule is very similar to the
CARB’s rule, and emissions are proportional to population, CARB’s
6.3 ton per day reduction was prorated to the OTC region based on the
ratio of OTR 2002 population (63 million) to CA 2002 population (35
million) yielding approximately 11.3 tons per day in the OTR (4,139 tons
per year).

Page 4 states that the estimated reductions from CONS-2 (not yet
proposed) will achieve 20-35 tons per day statewide by 2010.  Since
OTC’s model rule is very similar to the CARB’s rule, and emissions
are proportional to population, the mid-point of CARB’s 20-35 ton per
day reduction (i.e., 27.5 tons per day) was prorated to the OTC region
based on the ratio of OTR 2002 population (63 million) to CA 2002
population (35 million) yielding approximately 49.5 tons per day in the
OTR (18,068 tons per year).

CONTROL MEASURE SUMMARY FOR

Glass/Fiberglass Furnaces

Control Measure Summary:	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  NSR; PSD; State RACT.

	 NOx

2002 Base:

18,840

Candidate measure:  Use of oxyfiring or other methods to meet
recommended emission limits.

Emission Reductions:  source specific, varies from 0-85% depending upon
2002 base rates.

Control Cost:  $ 924 to 2,232 per ton

Timing of Implementation:  01/01/09

Implementation Area:  OTR 	NOx

2009 projected:

Reduction at full implementation:

Remaining after full implementation:

21,893

-13,474

8,419

Control Measure Recommendation:  Develop a control strategy that
requires implementation of an “oxyfiring” program for each furnace
at the next furnace rebuild.  Alternatively, states may allow
manufacturers to propose compliance methods based on California’s San
Joaquin Valley Rule 4354 which allows a mix of control options to meet
specified emission limits.  Prior to furnace rebuild, owners/operators
may be allowed, by the state, to meet emissions limits by purchasing a
state specified number of NOx allowances. Continuous emission monitoring
systems would be used to determine emissions.  This Measure should be
modeled at 85% reduction.

Brief Rationale for Recommended Strategy:  Oxyfiring is best
implemented, and provides the most effective NOx emission reductions,
with a complete furnace rebuild.  This strategy not only reduces NOx
emissions by as much as 85 percent, but reduces energy consumption,
increases production rates by 10-15%, and improves glass quality by
reducing defects.  Oxyfiring is demonstrated technology and has
penetrated into all segments of the glass industry.

REFERENCES

European Commission, Integrated Pollution Prevention and Control (IPPC)
Bureau.  Reference Document on Best Available Techniques in the Glass
Manufacturing Industry.  December 2001.  This document reports 75 to 85%
reduction in NOx and emission rates of 1.25 to 4.1 lbs NOx/ton.  The
cost effectiveness was determined to be $1,254 to $2,542 depending on
the size of the furnace.

U.S. EPA Alternative Control Techniques Document – NOx Emissions from
Glass Manufacturing, EPA-453/R-94-037, June 1994.  Oxyfiring reduction
of 85%, cost-effectiveness of $2,150 to $5,300.

Emission rates based on San Joaquin Valley Rule 4354

Type of Furnace	Block 24-hour Average	Rolling 30-day average

   Container Glass	4.0 pounds of NOx per ton of glass pulled	4.0 pounds
of NOx per ton of glass pulled

   Fiberglass	4.0 pounds of NOx per ton of glass pulled	4.0 pounds of
NOx per ton of glass pulled

   Flat Glass	9.2 pounds of NOx per ton of glass pulled	7.0 pounds of
NOx per ton of glass pulled

CONTROL MEASURE SUMMARY FOR

Industrial, Commercial, Institutional (ICI) Boilers – Jointly
processed with MANE-VU

Addendum to OTC Resolution 06-02 Guidelines for ICI Boilers

ICI Boiler Size

(mmBtu/hr)

	Control Strategy/

Compliance Option	NOx Control Measure

5-25

Annual Boiler Tune-Up

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

#2 Fuel Oil:            0.08 lb NOx/mmBtu

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

Coal:                       0.30 lb NOx/mmBtu**

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

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

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

#2 Fuel Oil:             0.20 lb NOx/mmBtu

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

Coal:

     Wall-fired           0.14 lb NOx/mm Btu

     Tangential           0.12 lb NOx/mm Btu

     Stoker                  0.22 lb NOx/mm Btu

     Fluidized Bed      0.08 lb NOx/mm Btu

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

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

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

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

	Option #2	Phase I – 2009

Emission rate equal to EGUs of similar size

Phase II – 2012

Emission rate equal to EGUs of similar size

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Fabric Printing

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Fabric Printing, Coating and Dyeing - 2002 existing measures:

    NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

      EPA CTG RACT limit: 2.9 lbs VOC/gal coating [0.35 kg/liter] (minus
H2O & exempt solvents)

       Applicability:  Sources 3 lbs/hour, 15 lb/day or 10 tons/year
uncontrolled emissions

       OTC state RACT limits: MD, NJ, NH = 2.9 lbs/gal coating

           MA = 4.8 lbs VOC/gal of solids applied  (equivalent to 2.9
lbs/gal coating)	VOC

Actual 2002:	(not available)

Fabric Printing, Coating and Dyeing - 2009 On-the-Books measures:

   MACT Std. - Subpart OOOO (68 FR 32172, 5/29/03)

      EPA MACT limits existing sources:

                Coating and printing operations -   0.12 kg HAP/liter
solids

                Dyeing and finishing operations  -   0.016 kg HAP/liter
solids

                    Dyeing operations only             -   0.016 kg
HAP/liter solids

                    Finishing operations only        -    0.0003 kg
HAP/liter solids

Emission Reductions:

     Nationwide – 60% HAP reduction from 1997 baseline

      MACT Organic HAP control efficiency option: 97% for existing
sources

           MACT Estimated VOC reduction 60% (Pechan Table)

Control Cost:

    Nationwide –$14.5 million/yr for 4,100 tons/yr = $3,537/ton

Timing of Implementation: Compliance Date (existing) May 29, 2006

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Fabric Printing, Coating and Dyeing

Candidate measure 1:  Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: Permanent Total Enclosure

      Emission Reductions: Estimated VOC reduction 95-97%

        (Air Control Net 3.0 Table)

Control Cost:  $1,459-$1,565/ton

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties

	                       VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Large Appliances

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Large Appliances - 2002 existing measures:

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties;

       EPA CTG RACT limit: 2.8 lbs VOC/gal coating [0.34 kg/liter]

                                                 (minus H2O & exempt
solvents)	VOC

Actual 2002:

(not available)

Large Appliances - 2009 On-the-Books measures:

   MACT Std. – Subpart NNNN (67 FR 48254, 7/23/02)

        EPA MACT limits existing sources: 0.13 kg HAP/liter solids

Emission Reductions:

     Nationwide – 45% HAP reduction from 1995 baseline

    MACT Organic HAP control efficiency option: xx% for existing sources

           Estimated VOC reduction: 0% (Pechan Table)  - 60%??

Control Cost:

    Nationwide – $1.63 million/yr for 1,190 tons/yr = $1,370/ton

Timing of Implementation: Compliance Date (existing) July 23, 2005

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Large Appliances

Candidate measure 1:  Adopt More Stringent RACT regulations (e.g., ICAC
letter 2/16/2001); lower applicability thresholds, extend geographic
coverage

Measure ID:

   ICAC Option 1 -  Nationwide – 80% HAP reduction from 1995 baseline
( Additional 250 tons/per HAP)

   ICAC Option 2 -  Nationwide – 98% HAP reduction from 1995 baseline
( Additional 1,190 tons/per HAP)

Emission Reductions:

Control Cost:

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation of: Final recommendation not made as of June,
2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Metal Cans

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Metal Can - 2002 existing measures:

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties;

    EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

         Sheet basecoat & over varnish                               2.8
 [0.34 kg/l]

         2 and 3-piece can interior & 2-piece can              4.2
[0.50 kg/l]

         3-piece can side-seam spray
5.5  [0.66 kg/l]

         End sealing compound
3.7  [0.44 kg/l]

       Applicability:  10 tons/year uncontrolled emissions

       OTC state RACT limits: MD, NJ, NH same limits as CTG;

             MA (4.5,  9.8, 21.8, 7.7 lbs/gallon of solids applied)	VOC

Actual 2002:

(not available)

Metal Can - 2009 On-the-Books measures:

   MACT Std. – Subpart KKKK (68 FR 64432 , 11/13/03)

    EPA MACT limits existing sources:

         Sheet coating
0.03 kg HAP/l solids

         Body Coating

                2-piece beverage cans                             0.07
kg HAP/l solids

                2-piece food cans
0.06 kg HAP/l solids

                1-piece aerosol cans                                0.12
kg HAP/l solids

         3-piece can assembly

                Inside Spray
0.29 kg HAP/l solids

                Aseptic side seam strips on food cans      1.94 kg HAP/l
solids

                Nonaseptic side seam strips on food cans  0.79 kg HAP/l
solids

                Side seam strips on non-food cans             1.18 kg
HAP/l solids

                Side seam strips on aerosol cans                1.46 kg
HAP/l solids

         End sealing compound

                Aseptic end seal compounds                       1.94 kg
HAP/l solids

         Nonaseptic end seal compounds                 0.00 kg HAP/l
solids

         Repair spray coatings                                  2.06 kg
HAP/l solids

         Emission Reductions:

     Nationwide – 70% HAP reduction from 1997 baseline

    MACT Organic HAP control efficiency option: xx% for existing sources

    Estimated VOC reduction 70% (Pechan Table)

Control Cost:

    Nationwide – $58.7 million/yr for 6,800 tons/yr = $8,632/ton

Timing of Implementation: Compliance Date (existing) Nov. 13, 2006

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:

(not available)

Metal Can (Continued)

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: Permanent Total Enclosure

      Emission Reductions:  Estimated VOC reduction 95%

                                         (Air Control Net 3.0 Table)

Control Cost: $7,947/ton

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties.
               VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Metal Coils

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Metal Coil - 2002 existing measures:

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties;

       EPA CTG RACT limit: 2.6 lbs VOC/gal coating [0.31 kg/liter]

                                                 (minus H2O & exempt
solvents)

       Applicability:  Sources 10 tons/year uncontrolled emissions

       OTC state RACT limits:  NH - same limits as CTG	VOC

Actual 2002:	(not available)

Metal Coil – 2009 On-the-Books measures:

   MACT Std. – Subpart SSSS (67 FR 39794 , 6/10/02)

       EPA MACT limits existing sources: 0.046 kg HAP/liter solids

Emission Reductions:

    Nationwide – 53% HAP reduction from current levels?

    MACT Organic HAP control efficiency option: xx% for existing sources

         Estimated VOC reduction 53% (Pechan Table)

Control Cost:

    Nationwide – $7.6 million/yr for 1,316 tons/yr = $5,775/ton

Timing of Implementation: Compliance Date (existing) June 10, 2005

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Metal Coil

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID:

Emission Reductions:

Control Cost:

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties.

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Metal Furniture

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Metal Furniture - 2002 existing measures:

      NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

       EPA CTG RACT limit: 3.0 lbs VOC/gal coating [0.36 kg/liter]

                                                 (minus H2O & exempt
solvents)

       Applicability:  Sources 10 tons/year uncontrolled emissions

       OTC state RACT limits:  NH - same limits as CTG	VOC

Actual 2002:	(not available)

Metal Furniture – 2009 On-the-Books measures:

   MACT Std. – Subpart RRRR (67 FR 28606 , 5/23/03)

       EPA MACT limits existing sources: 0.10 kg HAP/liter solids

Emission Reductions:

           Nationwide – 73% HAP reduction from 1997/1998 baseline

    MACT Organic HAP control efficiency option: xx% for existing sources

          Estimated VOC reduction 0% (Pechan Table)

Control Cost:

          Nationwide – $14.8 million/yr for 16,300 tons/yr = $908/ton

Timing of Implementation: Compliance Date (existing) May 23, 2006

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Metal Furniture

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID: Permanent Total Enclosure

      Emission Reductions:  Estimated VOC reduction 95%

                                         (Air Control Net 3.0 Table)

Control Cost:  $20,115/ton

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: (1) 8-hr ozone nonattainment areas, (2) 8-hr ozone
nonattainment areas plus adjacent counties, or (3) all counties.

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Miscellaneous Metal Parts

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Miscellaneous Metal Parts - 2002 existing measures:

  NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

  EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

         Clear or transparent top coat
 4.3 [0.52 kg/l]

         Air dries Coatings
         3.5 [0.42 kg/l]

         Coating used in extreme environmental conditions 3.5 [0.42
kg/l]

         All other coatings
          3.0 [0.35 kg/l]

       Applicability:  10 tons/year uncontrolled emissions

       OTC state RACT limits: NH same limits as CTG	VOC

   Actual 2002:

(not available)

Miscellaneous Metal Parts – 2009 On-the Books measures:

  MACT Std. – Subpart MMMM (69 FR 130 , 1/2/04)

     EPA MACT limits existing sources:

         General use  Coating                                       0.31
kg HAP/l solids

         High Performance Coating                             3.30 kg
HAP/l solids

         Rubber-to-Metal Coating                                4.50 kg
HAP/l solids

         Extreme Performance Fluoropolymer          1.5   kg HAP/l
solids

Emission Reductions:

    Nationwide – 48% HAP reduction from 1997 baseline

          MACT Organic HAP control efficiency option: xx% for existing
sources

   Estimated VOC reduction 0% (Pechan Table)

Control Cost:

          Nationwide – $57.3 million/yr for 26,000 tons/yr = $2204/ton

Timing of Implementation: Compliance Date (existing) Jan. 2, 2007

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:

(not available)

Miscellaneous Metal Parts

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID:

Emission Reductions:

Control Cost:

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area:

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Paper and Other Web

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Paper & Other Web - 2002 existing measures:

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

        EPA CTG RACT limit: 2.9 lbs VOC/gal coating [0.35 kg/liter]

                                                 (minus H2O & exempt
solvents)

       Applicability:  Sources 3 lbs/hour, 15 lb/day or 10 tons/year

                                 uncontrolled emissions

       OTC state RACT limits: MD, NJ, NH = 2.9 lbs/gal coating

           MA = 4.8 lbs VOC/gal of solids (equivalent to 2.9 lbs/gal
coating)	VOC

Actual 2002:

	Paper & Other Web – 2009 On-the-Books measures:

  MACT Std. – Subpart JJJJ (67 FR 72330 , 12/4/02)

      EPA MACT limits existing sources: 0.2 kg organic HAP/kg coating
solids

Emission Reductions:

    Nationwide – 80% HAP reduction from current levels??

          MACT Organic HAP control efficiency option: 95% for existing
sources

          Estimated VOC reduction 80% (Pechan Table)

Control Cost:

    Nationwide – $64 million/yr for 34,500 tons/yr = $1,855/ton

Timing of Implementation: Compliance Date (existing) Dec. 5, 2005

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Paper & Other Web

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID:

Emission Reductions:

Control Cost:

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area:

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Plastic Parts

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Plastic Parts - 2002 existing measures:

   NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

  EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

                                                                 Auto
Interior          Auto Exterior

   High Bake Prime                                 3.8 [0.46 kg/l]
               --

   High Bake Prime - Flexible                          --
      5.0 [0.60 kg/l]

   High Bake Prime – Nonflexible                   --
    4.5 [0.54 kg/l]

   High Bake Color                                  4.1 [0.49 kg/l]
     4.6 [0.55 kg/l]

   Low Bake Prime                                  3.5 [0.42 kg/l]
    5.5 [0.66 kg/l]

   Low Bake Color                                   3.5 [0.42 kg/l]
     5.6  red or black

   Low Bake Color                                             --
            4.5 all others

       Applicability:  NH - 50 tons/year uncontrolled emissions

       OTC state RACT limits: NH - same limits as CTG	VOC

Actual 2002:

(not available)

Plastic Parts - 2009 On-the Books measures:

  MACT Std. – Subpart PPPP (69 FR 20968 , 4/19/04)

   EPA MACT limits existing sources:

       General Use Coating                            -   0.16 kg HAP/kg
coating solids

       Automotive Lamp Coating                  -   0.45 kg HAP/kg
coating solids

       Thermoplastic Olefins                         -   0.26 kg HAP/kg
coating solids

       New Assembled On-Road Vehicles    -   1.34 kg HAP/kg coating
solids

Emission Reductions:

    Nationwide – 80% HAP reduction from 1997 baseline

          Estimated VOC reduction 0% (Pechan Table)

Control Cost:

    Nationwide – $10.9 million/yr for 7,560 tons/yr = $1,442/ton

Timing of Implementation: Compliance Date (existing) April 19, 2007

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:

(not available)

Plastic Parts

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID:

      Emission Reductions:

Control Cost:

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: 	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings Wood Building Products

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Wood Building Products - 2002 existing measures:

  NSPS; PSD/NSR; State RACT rules in 1-hour non-attainment counties

  EPA CTG RACT limit: lbs VOC/gal coating (minus H2O&exempt solvents)

	VOC

Actual 2002:

	 (not available)

Wood Building Products - 2009 On-the-Books measures:

  MACT Std. – Subpart QQQQ (68 FR 31746 , 5/28/03)

    EPA MACT limits existing sources:

                                   -                        kg HAP/liter
of solids (lb HAP/gal solids)

      Doors, Windows & Misc.                         0.231
      (1.93)

      Flooring                                                     0.093
                    (0.78)

      Interior Wall Paneling & Tileboard       0.183
(1.53)

      Other Interior Panels                               0.020
           (0.17)

      Exterior Siding & Primed Door Skins   0.007
(0.06)

Emission Reductions:

    Nationwide – 63% HAP reduction from 1997 baseline

          MACT Organic HAP control efficiency option: xx% for existing
sources

          Estimated VOC reduction 63% (Pechan Table)

Control Cost:

    Nationwide –$22.5 million/yr for 4,900 tons/yr = $4,592/ton

Timing of Implementation: Compliance Date (existing) May 28, 2006

Implementation Area:  Nationwide	VOC

Actual 2002:

OTB 2009:

Reduction from OTB:	(not available)

Wood Building Products

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID:

Emission Reductions:

Control Cost:

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area:

	VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

	(not available)

Policy Recommendation of State/Workgroup Lead: Final recommendation not
made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

CONTROL MEASURE SUMMARY FOR

Industrial Surface Coatings All Categories

Control Measure Summary: This category includes several source types:
Fabric, Printing, Coating and Dyeing; Large Appliances; Metal Can
coating, Metal Coil coating; Metal Furniture coating; Misc. Metal Parts
coating; Paper and Other Web coating; Plastic Parts coating; & Wood
Building Products coating	Emissions (tons/year) in Ozone Transport
Region

Industrial Surface Coatings Category Total - 2002 existing measures:

    NSPS: PSD/NSR; State RACT rules in 1-hour non-attainment counties
Total VOC

Point &Area

Actual 2002:	164,445

Industrial Surface Coatings Category Total - 2009 On-the-Books measures:

   MACT Stds. – Subpart OOOO (68 FR 32172, 5/29/03)

                            Subpart NNNN (67 FR 48254, 7/23/02)

                            Subpart KKKK (68 FR 64432 , 11/13/03)

                            Subpart SSSS (67 FR 39794 , 6/10/02)

                            Subpart RRRR (67 FR 28606 , 5/23/03)

                            Subpart MMMM (69 FR 130 , 1/2/04)

                            Subpart JJJJ (67 FR 72330 , 12/4/02)

                            Subpart PPPP (69 FR 20968 , 4/19/04)

                            Subpart QQQQ (68 FR 31746 , 5/28/03)

Emission Reductions:

    OTC Regional – x,xxx from 2002 baseline

Control Cost:

   OTC Regional –$ xx.x million/yr for x,xxx tons/yr = $4,592/ton

Timing of Implementation: Compliance Dates (existing) 5/29/06;

 (existing) 7/23/05;

 (existing) 11/13/06;

 (existing) 6/10/05;

 (existing) 5/23/06;

 (existing) 1/2/07;

 (existing) 12/5/05;

 (existing) 4/19/07;

 (existing) 5/28/06

Implementation Area:  Ozone Transport Region	Total VOC

Point & Area

Actual 2002:

OTB 2009:

Reduction from OTB:

MANE-VU

2002 Point*

MANE-VU

2002 Area*

(Ed Sabo’s

        e-mail

      01/06/06)

164,445

-175,983

 -11,448

  24,931

139,512

From 10/04/05 draft emission inventory

Industrial Surface Coatings Category Total

Candidate measure 1: Adopt More Stringent RACT regulations; lower
applicability thresholds, extend geographic coverage

Measure ID:

      Emission Reductions:

Control Cost:

Timing of Implementation: Assuming 2007 or 2008 effective date of rule,
emission reductions in 2009 or 2010

Implementation Area: 	                      VOC

OTB 2009:

BOTW 2009:

Reduction from

BOTW:

(not available)

Policy Recommendation: Final recommendation not made as of June, 2006.

Brief Rationale for Recommended Strategy:  See additional discussion in
briefing paper

Background Information

Industrial surface coatings are used during the manufacture of a wide
variety of products including: fabrics, paper, large appliances, metal
cans, metal coils, metal furniture, metal parts, plastic parts, and wood
building materials.  Surface coating is the process by which paints,
inks, varnishes, adhesives or other decorative or functional coatings
are applied to a substrate (e.g., fabric, metal, wood, or plastic) to
protect or decorate the substrate.  Industrial surface coatings can be
applied by brushing, rolling, spraying, dipping, flow coating,
electro-coating, or combinations and variations of these methods.  The
process used to coat a particular product is dependent on the
composition of the coating, the substrate to which the coating is
applied and the intended end use of the final product.  After a coating
is applied, it is dried or cured either by conventional curing through
the use of thermal drying ovens, or through the use of radiation.
During conventional curing, heat from thermal ovens is used to evaporate
the solvents and/or water trapped in the coating and release them into
the atmosphere.  Two types of radiation curing processes currently in
use are ultraviolet (UV) curing and electron beam (EB) curing.

Emissions are released by the evaporation of the solvents used in the
coatings and the evaporation of any additional solvents used to dilute
(thin) the coating prior to application and for cleaning the coating
equipment after use.  Emissions from surface preparation and coating
applications are a function of the VOC content of product used.
Emissions are also a function of the type of coating process used
(rolling, dipping, spraying, etc.) and the transfer efficiency of the
process.  Transfer efficiency is the percentage of the coating solids
that are applied (e.g., sprayed) which actually adhere to the surface
being coated.  Emissions from cleaning vary with the type of cleanup and
the housekeeping practices used.

Industrial surface coating is estimated to account for approximately
164,000 tons per year of VOC emissions in the Mid-Atlantic/Northeast
Visibility Union (MANE-VU) region in 2002 from both point and area
sources.  It is important to consider two aspects regarding the accuracy
of this emissions estimate when assessing this category for additional
controls:

The MANE-VU VOC emissions inventory for the industrial surface coating
category includes emissions from both point and area sources.  While the
2002 VOC emissions inventory for the MANE-VU region indicates that VOC
emission from area sources in this category are substantial, the area
source part of the emissions inventory is highly uncertain and may be
substantially overestimated.  The method used to estimate area source
VOC emissions relies heavily on employee emission factors and employment
data.  These emission factors are based on data collected by EPA in the
1980s and may not accurately portray the types of coatings, the type of
coating equipment, or the type of control technology currently in use.

At least nine types of industrial surface coating point sources are
already controlled due to state specific VOC RACT regulations or will
soon be controlled prior to 2009 as a result of the recently promulgated
Maximum Achievable Control Technology (MACT) standards.  Since the MACT
standards were  designed to control air toxic emissions and not
necessarily VOC emissions the  effectiveness of the MACT standards for
controlling VOC emissions will vary with the industrial surface coating
subcategory (e.g., metal cans, wood building products, etc.) and the
type of  coating equipment and the type of solvents used in that
subcategory.

Regulatory History

	Industrial surface coating processes are currently subject to multiple
state and federal regulations pursuant to Titles I and III of the Clean
Air Act.  Title I imposes Standards of Performance for New Stationary
Sources (NSPS) on new and modified large stationary sources.  In the
early 1990s, EPA promulgated NSPSs for various types of industrial
surface coating operations.  These regulations applied to surface
coating operations that were constructed or modified after effective
dates specified in each NSPS.  In general, surface coating operations
constructed or modified after 1980 are subject to NSPS requirements.
The NSPS generally established VOC emission rate limits that could be
complied with using either compliant coatings or add-on capture and
control equipment.  For certain source categories the NSPS also set
transfer efficiency requirements.

	New and modified large stationary sources that increase their emissions
can also be subject to the New Source Review (NSR) requirements of Title
I.  NSR requires a control technology review for large new plants and
for modifications at existing plants that result in a significant
increase in emissions, subjecting these sources to Best Available
Control Technology (BACT) in attainment areas and Lowest Achievable
Emission Rate (LAER) in nonattainment areas.  BACT and LAER control
requirements are updated over time to reflect improvements in control
equipment and are reviewed on a case-by-case basis during state
permitting process.

	Criteria pollutants, which include VOCs, nitrogen oxides (NOx), sulfur
dioxide (SO2), fine particulate matter (PMfine), carbon monoxide (CO)
and lead (Pb), are also regulated by the State Implementation Plans
(SIPs) required by Title I.  SIPs set forth the states’ strategies for
achieving reductions of criteria pollutants for which the state is
currently out of attainment.  SIPs must include requirements that all
major stationary sources located in nonattainment areas must install
reasonably available control technology (RACT).  RACT levels must be
basedon the level of emissions reduction that can be reasonably achieved
at a reasonable cost.  The U.S. EPA has issued a series of Control
Technology Guidelines (CTGs) and Alternative Control Technologies (ACT)
documents to assist states in defining RACT for a number of industrial
surface coating categories.  For categories not covered by a CTG or ACT
document, state regulations require that a case-by-case RACT
determination be made.  Most of the EPA’s CTGs and ACT documents for
the industrial surface coating category were developed prior to 1990.
While specific RACT requirements will vary from state to state, some OTC
states have already adopted RACT regulations that are more stringent
than the CTG/ACT requirements.

Policy Recommendation

   As can be noted from the background information, the regulatory
history, and the information contained in summary tables, the industrial
surface coatings category includes at least nine different major source
types and multiple processes for each source type with regulations and
emissions limits that vary not only by major source type, but also by
individual process and individual product.  In addition, the industrial
surface coatings category is already subject to a variety of regulations
(NSPS; PSD/NSR, state RACT, MACT, state specific rules on hazardous air
pollutants) that were adopted to achieve different goals.  Some
regulations (e.g., RACT) were designed to reduce VOC emissions.  Other
regulations (e.g., MACT) were designed to reduce emissions of hazardous
air pollutants but have the side benefit of reducing VOC emissions as
well.

    Analysis of the potential benefits and costs of adopting additional
VOC control measures, Beyond On-The-Way (BOTW) measures) is further
complicated by the following:

Uncertainty as to the accuracy of the current (2002) MANE-VU VOC
emissions inventory for the industrial surface coatings category;

Difference in current VOC RACT limits among the OTC states;

Difference in the estimates of the potential VOC reductions from MACT
standards; and

Difference in the source size and geographic area covered by a specific
regulation.

   The most recent version of the (2002) MANE-VU VOC emissions inventory
for the MANE-VU region estimates total VOC emissions from the industrial
surface coatings category to be 164, 445 tons (24,931 tons of VOC from
point sources and 139,512 tons from area sources).   Further
investigation into the amount of VOC emissions from area sources will
most likely reveal that these VOC emissions are substantially
overestimated due in part to the emission factors and employment data
used and in part to the cutpoints used by various states for
distinguishing a point source from an area source.

   A quick sampling of the current VOC RACT limits in the OTC states
reveals differences not only in the limits for existing sources (lbs.
VOC per gallon of coating  minus water and exempt solvents), but also in
the size of source to which these limits apply.

   Several complications arise when trying to calculate the potential
VOC reductions from a particular MACT standard including the following:

Not all toxics regulated under the MACT are VOCs;

MACT standards are expressed as kg HAP/liter of solids or lbs.
HAP/gallon of solids not lbs. VOC/gallon of coating minus water and
exempt solvent so the MACT limit applies to all HAPs not just VOCs; and

The specific types of processes and coatings regulated under the MACT
standards are different than the types of processes and coatings
regulated under the RACT standards.

These complications have lead to widely varying estimates of the
potential additional VOC reductions from the application of a particular
MACT requirement (from 0% to as much as 80% VOC reduction nationwide).

   RACT standards and MACT standards apply to sources located in
different geographic areas throughout the Ozone Transport Region.  For
some OTC states RACT standards apply only to sources located in 1-hour
ozone nonattainment counties while in other OTC states RACT standards
apply statewide.  MACT standards are applicable nationwide and only to
major HAP sources (10 tons/year of individual HAP or 25 tons/year of
combined HAPs).

Given all of these uncertainties the following options are available:

OTC states that currently have higher VOC RACT limits than the EPA
CTG/ACT VOC RACT limits can adopt more stringent RACT regulations;

OTC states can extend the geographic coverage for RACT limits to
statewide;

OTC states can lower the RACT applicability thresholds

OTC states can adopt more stringent control requirements for specific
industrial surface coating categories (e.g., permanent total enclosures
for metal can coating processes).

Policy recommendations:

1) Due to uncertainty in current MANE-VU VOC emissions inventory for
this category, develop an improved, state specific VOC emissions
inventory for point and area sources for each subcategory of industrial
surface coatings before requiring additional controls beyond MACT.

CONTROL MEASURE SUMMARY FOR

Lime Kilns

Control Measure Summary: Good combustion practices and kiln operation
for Lime Kilns.  These kilns are used for the calcination of limestone.
Lime kilns are also often associated with paper mills.	Emissions
(tons/year) in Ozone Transport Region

2002 existing measure:  NSR; PSD; State RACT.

Emission Reductions:

Control Cost:

Timing of Implementation:

Implementation Area:  OTR 	 NOx

  Uncontrolled:

2002 Reduction:

2002 Base:

4,649

      0

 4,649

Candidate measure:  Good combustion practices and kiln operation

Emission Reductions: Under Evaluation

Control Cost:  less than $2,000 per ton

Timing of Implementation:  01/01/09

Implementation Area:  OTR	                   NOx

2009 Base including growth:

2009 Reduction:

2009 Remaining:

5,228

TBD

Policy Recommendation: Final recommendation not made as of June, 2006.

Recommended Strategy:  See additional discussion in briefing paper

REFERENCES:

European Commission, Integrated Pollution Prevention and Control (IPPC)
Bureau.  Reference Document on Best Available Techniques in the Cement
and Lime Manufacturing Industries.  December 2001. “The direct
transfer of low-NOx burner technology from cement kilns to lime kilns is
not straightforward. In cement kilns, flame temperatures are higher and
low-NOx burners have been developed for reducing high initial levels of
‘thermal NOx’. In most lime kilns the levels of NOx are lower and
the ‘thermal NOx’ is probably less important.”

Northeast States for Coordinated Air Use Management.  Assessment of
Control Technology Options for BART-Eligible Sources: Steam Electric
Boilers, Industrial Boilers, Cement Plants, and Paper and Pulp
Facilities.  March 2005.  “Due to the design of the lime kiln, SNCRs
and SCRs are not viable NOx reduction techniques.  Installing low-NOx
burners is also not a practical NOx reduction technique according to a
BACT analysis conducted on a new lime kiln in 1997…combustion
modification such as decreasing excess air is the best way to reduce NOx
emissions”.

CONTROL MEASURE SUMMARY FOR

Municipal Waste Combustiors

(Only NOx reductions are evaluated under this strategy)

Control Measure Summary	Emissions (tons/year) in Ozone Transport Region

2002 existing measure:  Federal performance standards and emissions
guidelines for large MWCs (40 CFR 60 Subparts Cb and Eb).  No control
technology is mandated to meet the emissions limitations.  EPA approved
state trading programs for NOx compliance are allowed as is
facility-wide averaging for NOx compliance.

Emission Reductions:  19,000 Mg NOx/yr nationally (increment over 1991
40 CFR 60 Subpart Ca standards).

Control Cost:  $7.2 per Mg municipal solid waste combusted.

Timing of Implementation: Compliance required December 19, 2000.

Implementation Area:  Nationwide.	 NOx

2002 Base:	26,139

	SO2:

2002 Base	3,865

	VOC:

2002 Base	473

Implement Federal Rules:

Measure ID:

Emission Reductions:  Varies per state depending on the number of MWC
units, incinerator technology and chosen emissions limitations.  In
Connecticut, this measure resulted in NOx emissions reductions of 1.6
tons/summer day and 592 tons/year.

Control Cost:  $0 to approximately $1,500/MMBtu/hr depending on whether
SNCR was installed in response to the federal emissions guidelines and
whether SNCR is feasible.

Timing of Implementation:  Assuming timely adoption of state rule
amendments, compliance with emissions limitations could be required by
May 1, 2009.

Implementation Area:  Maine, Maryland, Massachusetts, New Hampshire, New
Jersey, New York and Pennsylvania report operating MWC units (assuming
state NOx emissions limitations are at the level of the federal
emissions guidelines).

	NOx

2009 Reduction:

2009 Remaining:

-3,610

22,529

	SO2	***

VOC

***

Policy Recommendation of State/Workgroup Lead:

Individual states with operating MWCs should evaluate the possible
reduction of state NOx emissions limitations to produce creditable
emissions reductions.  At the regional level, this strategy should not
be emphasized as it is state-specific in nature (depending on the MWC
population, current control level and current state standards); does not
require regional implementation to maximize its effectiveness; emissions
from MWCs are a minor portion of the regional inventory given MACT-based
standards required under Section 129 of the Clean Air Act; and EPA has
proposed more stringent NOx emission limits for MWCs that states will be
required to adopt and implement as of April 2009.

Recommended Strategy:

MWCs are subject to stringent MACT emissions standards, including
standards for NOx, under Section 129 of the Clean Air Act.  To comply
with these MACT standards, many MWC owners and operators installed
control technologies, including SNCR, to comply with the federal
deadline of December 19, 2000.  Many MWCs may be operated to reduce
emissions to a level below the current federal standards.  For example,
Connecticut includes a state NOx emission reduction credit (ERC) trading
program in its MWC rule.  Recognizing that the "excess emissions"
produced in Connecticut's MWC NOx ERC trading program could yield
creditable emissions reductions if the required NOx emissions limits
were reduced, in October 2000, the Department amended the state MWC rule
to require the MWC owners and operators to meet more stringent NOx
emissions limits as of May 1, 2003.  The resulting emissions reductions
of 1.62 tons of NOx per summer day (248 tons per ozone season) were used
for compliance with the "shortfall" emission reduction obligation needed
for EPA approval of the attainment demonstration for the 1-hour ozone
national ambient air quality standard.

Other states in the OTC region have operating MWC units that now comply
with MACT-based state emissions limitations.  Many MWC units now operate
with SNCR to control NOx emissions.  For MWC units that do not now have
SNCR, SNCR is likely a feasible RACT measure capable of reducing NOx
emissions below the state limits.  Thus, the reduction of the state MWC
NOx limits may produce creditable NOx emissions reductions.
Furthermore, since MWCs are not subject to the Clean Air Interstate Rule
(CAIR) and may not participate in a CAIR NOx trading program, reduction
of state MWC NOx emissions limitations could be considered an equity
measure that places MWC owners in a position similar to the owners of
large electric generating units subject to CAIR.  However, the amount of
creditable emissions reductions a state may obtain from this strategy is
limited given EPA's December 19, 2005 proposal of reduced emissions
limitations for MWCs.

BACKGROUND INFORMATION

In December 1995, EPA adopted new source performance standards (NSPS)
(40 CFR 60 subpart Eb) and emission guidelines (subpart Cb) for MWC
units with a combustion capacity greater than 250 tons per day.  Both
the NSPS and emission guidelines require compliance with emission
limitations for nine pollutants including NOx that reflect the
performance of maximum achievable control technology (MACT).  The
emission guidelines required compliance by December 2000 for all
existing MWCs, while the NSPS apply to new MWCs.  On December 19, 2005,
EPA proposed revisions to the emissions guidelines to reflect the levels
of performance achieved due to the installation of control equipment (70
FR 75348).  This proposal includes reduced NOx emissions limitations
that states will be required to adopt and implement by April 2009, if
the proposal is finalized.  Selective non-catalytic reduction (SNCR) is
considered MACT for NOx under both the 1995 guidelines and the 2005
proposal.

Connecticut's MWC regulation, section 22a-174-38 of the Regulations of
Connecticut State Agencies (R.C.S.A.) (Attachment A), was adopted in
June 1999 with NOx emissions limits equivalent to the federal emissions
guidelines (Phase I NOx limits).  Owners and operators of the state's 15
MWC units were required to comply with the emissions limits no later
than December 19, 2000.  R.C.S.A. section 22a-174-38 was amended in
October 2000 to include more stringent NOx emissions limits (Phase II
NOx limits), for which compliance was required no later than May 1,
2003.  The following NOx emissions reductions, relative to emissions
levels under the Phase I NOx limits, are attributed to the Phase II NOx
limits in Connecticut:

592 tons per year;

248 tons per ozone season; and

1.62 tons per day during the ozone season.

EPA's December 19, 2005 proposal to update the 1995 emissions standards
will substantially reduce the ability of other states to achieve the
same level of emissions reductions that Connecticut achieved by
implementing this measure in 2003.

Add-on NOx Control

The number of NOx-reduction technologies for MWCs are limited as these
units use a heterogeneous, wet fuel; are less thermally efficient than
fossil fuel-fired boilers of comparable heat input; and require larger
amounts of excess air and less densely-packed heat recovery systems.
Low-NOx burners, fuel switching and load curtailment are not possible
control options.

The only generally applicable and feasible add-on control technology for
reducing NOx emissions from MWCs is SNCR.  SNCR is a chemical process
for removing NOx from flue gas.  In the SNCR process, a reagent,
typically liquid urea or anhydrous gaseous ammonia is injected within a
boiler or in ducts in a region where the temperature is between 900 and
1100 degrees Celsius.  The reaction converts NOx to nitrogen gas and
water vapor.  SNCR performance depends on factors specific to each type
of combustion equipment, including flue gas temperature, residence time
for the reagent and flue gas, amount of reagent injected, reagent
distribution, uncontrolled NOx level and carbon monoxide and oxygen
concentrations.

Some disadvantages arise from the use of SNCR including:  the high
operating temperatures required; ineffectiveness at high temperatures
with low concentrations of NOx; the need to accommodate enough residence
time to complete the chemical reaction at high temperatures; and
undesirable excess ammonia and urea emissions ("ammonia slip") that
arise from an incomplete chemical reaction (Thermal Energy
International, 2000).

All of Connecticut's large MWC units are equipped with SNCR, including