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3 Criteria For Designing and Evaluating Ozone Reduction Strategies
Pages 67-92

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From page 67...
... This chapter also discusses weaknesses in the existing SIPs' use of ambient airquality data and emissions inventory data, the connections between air quality and emissions, new strategies for control, and the effectiveness of existing controls. THE CLEAN AIR ACT The Clean Air Act was the first modern environmental law enacted by Congress.
From page 68...
... In the Clean Air Act amendments of 1970, Congress set 1975 as the deadline for meeting the NAAQS. By 1977, 2 years after this deadline, many areas were still in violation of the ozone NAAQS.
From page 69...
... bNumber of years from November 15, 1990, allowed in the 1990 amendments to the Clean Air Act. CSevere areas with design values between 0.19 and 0.28 ppm are allowed 17 years to attain the ozone NAAQS.
From page 70...
... 70 REllHINK] NG llHE OZONE PROBLEM TABLE 3-2 Classification of Nonattainment Areas for Ozonea Design value, ppmb Area 1983-1985 1985-1987 1987-1989 Extreme, design value 0~28 ppm or higher Los Angeles/Long Beach CMSAC 0.36 0.35 0.33 Severe, design value 0.18 to 0~28 ppm Baltimore 0.17 0.17 0.19 Chicago 0.20 0.17 0.19 Houston CMSA 0.25 0.20 0.22 Milwaukee 0.17 0.17 0.18 Muskegon, MI 0.14 0.17 0.18 New York City, NY/NJ/CT CMSA 0.22 0.19 0.20 Philadelphia, PA/NJ CMSA 0.18 0.16 0.19 San Diego 0.21 0.18 0.19 Serious, design value 0.16 to 0.18 ppm Atlanta Bakersfield Baton Rouge Beaumont/Port Arthur, TX Boston El Paso Fresno Hartford Huntington/Ashland, WV/KY/OH Parkersburg/Marietta, WV/OH Portsmouth/D over/Rochester NH/MA Providence CMSA 0.16 0.16 0.16 0.16 0.16 0.16 0.17 0.23 0.14 0.13 0.18 0.17 0.16 0.14 0.13 0.14 0.16 0.17 0.17 0.14 0.13 0.13 0.16 0.16 0.17 0.16 0.16 0.17 0.17 0.17 0.17 0.16 0.17 0.17 0.16
From page 71...
... RETHINKING THE OZONE PROBLEM 71 Design value' ppmb Area 1983-1985 1985-1987 1987-1989 Serious, design value 0.16 to 0.18 ppm (continued) Sacramento Sheboygan, WI Springfield, MA Washington, DC/MD/VA Moderate, design value 0.138 to 0.16 ppm Atlantic City Charleston, WV Charlotte/Gastonia/Rock Hill, NC/SC Cincinnati, OH/KY/IN Cleveland Dallas/Fort Worth Dayton/Springfield Detroit Edmonson County, KY Grand Rapids Greensboro/Winston-Salem/ High Point, NC Hancock County, ME Jefferson County, NY Knox County, ME Louisville, KY/IN Kewaunee County, WI Knoxville Memphis, TN/AR/MS 0.18 0.17 0.16 0.19 0.13 0.13 0.17 0.14 0.16 0.13 0.13 0.13 0.13 0.15 0.15 0.16 0.17 - 0.17 0.15 0.17 0.14 0.13 0.14 0.13 0.16 0.13 0.13 0.13 0.13 0.13 0.15 0.16 0.13 0.13 0.15 0.14 0.16 0.16 0.16 0.14 0.14 0.14 0.14 0.14 0.15 0.13 0.14 0.16 0.15 0.15 0.14 0.14
From page 72...
... Louis, MO/IL 0.16 0.16 0.16 Smyth County, VA 0.14 Visalie/Tulare/Porterville, CA 0.13 0.15 0.15 Worcester, MA 0.13 0.13 0.15 Marginal, design value 0.121 to 0.138 ppm Albany/Schenectady/Troy 0.13 Allentown/Bethelehem, PA 0.14 0.13 0.14 Altoona, PA 0.13 Buffalo - 0.13 Birmingham 0.13 0.15 0.13 Canton, OH - 0.14 Columbus - 0.13 Erie, PA 0.13 0.13 Essex County, NY 0.13 Evansville, IN/KY 0.13 Fayetteville 0.13 0.13 0 15 0.13
From page 73...
... Petersburg/ Clearwater Waldo County, ME York, PA Youngstown, Warren, OH 0.13 0.13 - 0.14 0.13 0.13 0.14 0.14 0.13 0.13 0.13 0.14 0.13 0.15 0.14 0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.14 0.13 0.13 0.14 0.14 0.13 0.14 0.13 0.12 0.13 0.13 0.13 0.13 0.13 0.13 aBased on data from 1987-1989; bRounded to the nearest hundredth; CConsolidated Metropolitan Statistical Area. Source: OTA, 1989 and EPA, 1990b.
From page 74...
... How well these commissions carry out their responsibilities will be an early test of the effectiveness of the 1990 Clean Air Act amendments. THE STATE IMPLEMENTATION PLAN The State Implementation Plan is the technical and regulatory process for demonstrating attainment and maintenance of the requirements of the NAAQS.
From page 75...
... amount of VOC emission reductions." In addition, Section 182(f) mandates that the control provisions required for major stationary sources of VOCs also apply to major stationary sources of NOX unless EPA determines that net air-quality benefits in an area are greater in the absence of NOX reductions, or that NOX reductions would not con
From page 76...
... Emissions NOX ~ Alr quality ' / /\ \ ~ VOC sources / reduction \ · Mobile Compile · Stationary Inventory · Area Annual Inventory tracking reasonable further progress (REP) VOCe, Reactivity J reductlone <~~ Blogenic ~· Methanol ~ tual Control measures NOx source \ roductlons / ~ ~ Mobile ~ · Stationary Implementation phase ~ EPA approval Attaln~mont and I rodo.`gnatlon FIGURE 3-2 Three components of state implementation planning process.
From page 77...
... For example, the accommodative SIP would rely on emission reductions from federally mandated control measures and existing controls and thus allow for expected emissions growth in some areas. This approach would be applied only in the most marginal nonattainment areas.
From page 78...
... Section 173 of the 1990 Clean Air Act amendments allows for offsets or a market-based approach to be used to reduce emissions from existing sources. These approaches are similar to the acid rain provisions of the Clean Air Act, which allow sources to comply with emission requirements by obtaining offsetting reductions from other sources.
From page 79...
... Emissions Inventories The Clean Air Act and ozone SIPs place specific emphasis on the development of reliable estimates of VOC and NOX emissions. The emissions inventory is used to determine source types by area, the quantity and rate of pollutants emitted, and the kinds of processes and controls used at each source.
From page 80...
... The Office of Technology Assessment (OTA) , on behalf of the Congressional subcommittees considering the reauthorization of the Clean Air Act, undertook a comprehensive evaluation of the costs and uncertainties in attaining the ozone NAAQS (OTA, 1989~.
From page 81...
... (Nonmethane hydrocarbons are used to represent VOCs.) The Clean Air Act Amendments of 1990 require ozone nonattainment areas designated as extreme, severe, serious, or multistate moderate to demonstrate attainment of the ozone NAAQS through photochemical gridbased modeling or any other analytical method determined by EPA to be at least as effective.
From page 82...
... These included NOX controls on major existing stationary sources; I/M for NOX; more stringent NOX standards for motor vehicle exhaust, control of organic solvent evaporation; alternative fuels for passenger vehicles; and transportation control measures (TCMs)
From page 83...
... OTA estimated that emissions from solvents, highway motor vehicles, and gasoline refueling will account for 70% of the remaining VOC inventory, suggesting the need for longer-term strategies that include lowering or restricting organic solvent emissions, implementing long-term TCMs, and using alternative motor vehicle fuels such as methanol and compressed natural gas. OTA also concluded that in many nonattamment areas, exhaustive exploration of potential control measures will be required to identify reductions to attain "or come as close as possible to" the NAAQS.
From page 84...
... * Indicates that emissions reductions would also be achieved in areas in attainment of the ozone NAAQS.
From page 85...
... RACI = reasonable available control technology required for existing stationary sources. Enhanced I/M = inspection and maintenance of motor vehicles.
From page 86...
... Rule Effectiveness A major fallacy of existing SIPs is the presumption that control measures achieve 100% effectiveness. The number and diversity of VOC sources, the uncertain reliability of existing controls, and limitations in state and local resources make 100% compliance extremely unlikely.
From page 87...
... . In addition, the Clean Air Act amendments of 1990 require EPA to review emission factors at least every 3 years.
From page 88...
... Miscellaneous industrial solvent uses Miscellaneous nonindustrial solvents Publicly owned treatment works Cutback asphalt paving FuBtive emissions, SOCMIb Bulk terminals/bulk plants Refinery fugitive emissions Process emissions, bakeries Pharmaceutical emissions Synthetic fibers. Crude oil- and gas-products fields Hazardous-waste TSDFsC 95 86 100 100 83 70 85 83 52 88 88 90 57 90 90 90 88 90 47 85 85 20 90 100 56 91 93 90 90 85 93 90 Values provided by states based on in-use experience; bsynthetic organic chemical manufacturing industry; Ctransportation, storage, and disposal facility.
From page 89...
... The essential components of SIP development include monitoring of ambient pollutant concentrations to determine whether the NAAQS has been exceeded and, if so, by how much and where; collection and analysis of meteorological data and air-quality data needed to develop the appropriate emissions-air quality relationship; inventorying of emissions from point, area, and mobile sources to determine the emission reductions necessary to attain the NAAQS; projecting the emissions inventory to future years; identifying and selecting specific emissions control measures and demonstrating that the control strategy will be adequate to achieve the air-quality god.
From page 90...
... Finally, individual control measures for motor vehicles and stationary sources were falsely assumed to meet their emission reduction targets, and provisions were not made for evaluating actual reductions. The magnitude of shortfalls in effectiveness is uncertain because of the general lack of data in all areas regarding in-use controls.
From page 91...
... Establish feedback between the SIP development and implementation phases. If control measures are not being implemented effectively for technical or other reasons, adjustments to the plan must be made.


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