1. Template Emission Controls Affecting Northeast Texas Presentation to the NETAC Policy and Technical Committees Sue Kemball-Cook, Krish Vijayaraghavan, Allison DenBleyker and Greg Yarwood June 13, 2013 skemballcook@environcorp.com

2. Impact of Local Emissions on Northeast Texas Ozone CAMx modeling results from June, 2006 episode Largest ozone impacts from elevated point sources, on- road mobile, off-road mobile, well-head compressors Karnack similar to Tyler 2 Longview Ozone ImpactsTyler Ozone Impacts

3. Federal Emission Control Programs Affecting Northeast Texas Overview of programs that affect Northeast Texas emissions source categories that have largest impact on local ozone –EGU NOx/SOx control programs –New Source Performance Standards affecting oil and gas sources –Tier 4 regulations for off-road mobile sources –Proposed Tier 3 regulations for on-road mobile sources Additional federal and Texas regulations apply (e.g. East Texas Combustion Rule) 3

4. Federal Control Programs Affecting EGUs Good Neighbor provision of Clean Air Act requires EPA and states to address transport of air pollution –2005: Clean Air Interstate Rule (CAIR) –2011: Cross-State Air Pollution Rule (CSAPR) 4

5. Clean Air Interstate Rule (CAIR) Cap-and-trade system for achieving SO 2 and NOx reductions –2 step phase-in for NOx: 2009 and 2015 A state must either: –meet its emission budget by requiring EGUs to participate in an EPA-administered cap and trade program, or –meet its emissions budget through measures of the state’s choosing In 2008, D.C. Circuit Court of Appeals vacated CAIR, then remanded it back to EPA, leaving the Rule in place until a replacement could be issued 5 Figure from http://www.epa.gov/airmarkets/progsregs/cair/index.html

6. Cross-State Air Pollution Rule (CSAPR) Developed in response to 2008 CAIR decision NOx/SOx reductions Vacated by D.C. Circuit Court in August, 2012 –Litigation is on-going –CAIR remains in place 6

7. Oil and Gas Sources: NSPS Subpart OOOO New Source Performance Standards apply to new, modified, or reconstructed major and minor emission sources EPA promulgated the Subpart OOOO rules in April 2012 Controls VOC and SO 2 at new and existing oil and natural gas wells and gas plants Mandatory controls for well site sources that were previously unregulated –Well completions, pneumatic devices, condensate tanks and dehydrators 7

8. NSPS OOOO Requirements Reduced emission completions (green completions ) required after 6/1/2015. –Flaring allowed until then Well site compressors and compressor stations are controlled through other regulations 8

9. Stationary Engines: NSPS JJJJ NSPS Subpart JJJJ regulates NOx emissions from new and modified engines with a wide range of horsepower ratings –NOx emission standards phased in over time, eventually requiring that all engines meet a 1.0 g/bhp-hr NOx emissions rate Some states have implemented more stringent regulations (e.g. the East Texas Combustion Rule) –Outside these areas, NSPS Subpart JJJJ remains the primary regulatory control on compressor engines Subpart JJJJ addresses only new and modified engines –Existing gas development areas may continue use of engines that do not meet the Subpart JJJJ requirements 9

10. Tier 4 Standards for Non-Road Diesel Engines EPA emissions standards for new non-road diesel engines: HC, NOx, CO and PM Implemented in tiers, with different standards and start years for different engine power ratings –Tier 4 emission standards phased in over 2008-2015 Over time, off-road fleet turns over and higher-emitting engines are replaced with lower-emitting engines Tier 4 standards require that emissions of PM and NOx be further reduced by about 90% –Exhaust aftertreatment  Reduction in fuel sulfur allows use of control technologies such as catalysts 10 Graphic from http://www.cumminspower.com/www /literature/technicalpapers/PT-9010-Tier4EmissionRegImpact.pdf

11. Proposed Tier 3 Rule for On-Road Mobile Sources Reduce exhaust and evaporative emissions through more stringent emission standards for on-road LDVs, MDVs and some HDVs (all fuel types) and lower sulfur in gasoline –10 ppm sulfur (annual average) compared to 30 ppm average in Tier 2 New standards phase in 2017 to 2025. 11 Exhaust Pollutant Emission Standard (mg/mi) Vehicles and Test procedure Old (Tier 2)Tier 3 NMOG+NO x 16030Light and Medium Duty <10,000 lbs. GVWR a ; FTP test 10050Light and Medium Duty <10,000 lbs. GVWR; SFTP test 278178Heavy Trucks 8,501-10,000 lbs. GVWR; FTP test 451247Heavy Trucks 10,001-14,000 lbs. GVWR; FTP test NoneVaried b Heavy Trucks 8,501-14,000; SFTP test Particulate Matter 103Light and Medium Duty <10,000 lbs. GVWR; FTP test N/A10 or 20 c Light and Medium Duty <10,000 lbs. GVWR; US06 cycle N/A8 or 10 c Heavy Trucks 8,501-14,000 lbs. GVWR; FTP test NoneVaried b Heavy Trucks 8,501-14,000; SFTP test a Gross Vehicle Weight Rating b First-time heavy-duty standards on the SFTP cycle vary by vehicle class and power-to-weight ratio c Emission standard depends on weight

12. ENVIRON studies of LEV-III effects Modeled summer + winter incremental benefits in ozone and PM 2.5 from successive US LDV standards (but not change in gasoline sulfur) –Journal article published in 2012 Effects of light duty gasoline vehicle emission standards in the United States on ozone and particulate matter. Atmospheric Environment. 60:109-120. Gasoline LDV scenarios modeled for year 2022 (assuming that a different standard existed in each scenario in 2022): –Tier 0 –Tier 1 –Tier 2 –LEV-III adopted nationwide –Zero-out all emissions from gasoline LDVs Follow-on summertime ozone study that considered the effect of reduced gasoline sulfur on VOC and NOx emissions –http://www.api.org/~/media/Files/News/2013/13-April/ENVIRON-Sep2012-Effects- of-LDV-Emiss-Stds-Gasoline-Sulfur-level-on-Ozone.pdfhttp://www.api.org/~/media/Files/News/2013/13-April/ENVIRON-Sep2012-Effects- of-LDV-Emiss-Stds-Gasoline-Sulfur-level-on-Ozone.pdf 12

13. ENVIRON studies of LEV-III effects State-of-the-science models –MOVES to estimate nationwide on-road emissions –EMFAC model to estimate the incremental benefit of LEV III over LEV II –California Predictive model to estimate the VOC and NOx emissions effects of ~10 ppm gasoline sulfur relative to ~30 ppm sulfur –NMIM, MEGAN, SMOKE to estimate other emissions –CAMx to model ozone and PM 2.5 at nested 36/12 km grid resolution. 13

14. CONUS Total On-road Emissions (tons/day), July 2022 14 NO x VOC

15. Monthly Mean of Daily Max 8-hr Ozone in July 2022 (Change in gasoline sulfur not considered) 15 Tier 1Tier 2LEV III Tier 2-Tier 1LEVIII-Tier 2No g-LDVs – Tier 2 Tier 2 up to 11% lower than Tier 1 Very small reduction (< 0.2%) Eliminating cars and light trucks: up to 6% lower than Tier 2 Source: Vijayaraghavan et al., 2012

16. Monthly Mean of Daily Max 8-hr Ozone in July 2022 (consider effect of gasoline sulfur change on VOC & NOx) Tier 2 – Tier 1: Tier 2 is up to 12 ppb lower than Tier 1 LEV III – Tier 2 (note different scale) LEV III is up to 0.5 ppb lower than Tier 2

17. Summary Large reductions in summertime ozone in 2022 from Tier 1 to Tier 2 Relatively small reductions in ozone in 2022 from Tier 2 to a nationwide implementation of a LEVIII–like standard (“Tier 3”) considering both emissions and gasoline sulfur reductions Reasons –Relatively small decrease in LDV emissions by 2022 from Tier 2 to LEV III compared to decrease from Tier 1 to Tier 2 –VOC and NOx from on-road LDVs are a relatively small fraction of the total 2022 inventory compared to other source categories Additional air quality benefits are expected beyond 2022 as more LEV III vehicles enter the vehicle fleet and the standard phases in. 17