1. Texas Commission on Environmental Quality
How will Current Regulations be Revised to Improve Air Quality? Randy Wood October 21, 2003
Texas Commission on Environmental Quality

2. December 2000 Revision
On December 6, 2000 the TCEQ adopted a 1-hour ozone SIP revision for the 8-county area
Total reduction of NOx emissions of more than 750 tons per day were necessary to demonstrate attainment in the area
Houston has until 2007 to attain the 1-hour ozone standard

3. Houston/Galveston Emissions (tons per day)
(2007 Future Case)
Attainment
289 tons

4. Control Strategies Adopted
90% reduction in point source NOx
Required an overall 90% reduction in power plant, refineries, and chemical plants - including grandfathered sources
Emissions banking and trading
Provides flexibility in meeting the 90% requirement

5. Control Strategies cont.
Speed limit reduction
Reduced all speed limits 60 mph and higher to 55 mph
Airport GSE
Agreements reached to get equivalent reductions at area airports
California Large Spark Off-Highway Equipment

6. Control Strategies cont.
Lawn and Garden Equipment Use Restrictions
6 a.m. – noon ban during ozone season
VOC RACT
various controls for some bakeries, printers and chemical batch processes.
Vehicle Idling Restriction

7. Control Strategies cont.
Inspection and Maintenance
Cleaner Diesel Fuel
Construction Equipment Operation Restrictions
Accelerated Purchase requirement for federal Tier 2/3 equipment

8. Control Strategies cont.
Transportation Control Measures
Signal timing, bicycle/pedestrian projects, HOV lanes, etc.
Voluntary Projects
Various voluntary projects such as bus fare promotions, alternative fuel programs, an ozone action days.

9. Lawsuit January 2001: BCCA-AG sues the TCEQ over the 90% requirement
Results of TXAQS 2000 gives a directional indication that HRVOCs contribute to ozone formation in the HGA area

10. September 2001 Revision
Incorporated revisions to the cleaner diesel fuel rules, point source NOx rules, and emissions banking and trading program
The December 2000 and September 2001 revisions were approved by EPA October 15, 2001

11. December 2002 Revision Rules were for four source categories:
TCEQ adopted HRVOC rules in exchange for 80% NOx reduction (as opposed to 90%) requirements as a result of settlement w/ BCCA-AG
Rules were for four source categories:
Flares, vents, cooling towers, and fugitives

12. March 2003 Proposal HRVOC rules are reopened for technical clean-up
Scheduled for adoption October 22
Rules correct inconsistencies and replace ambiguous language that may otherwise result in unduly burdensome requirements for which compliance dates are imminent

13. What is the Goal?
Submit approvable SIPs to EPA to prevent federal intervention
Submit a 1-hr/8-hr SIP to EPA in Oct. 2004

14. Why Don’t We Have the Answers Today?
The photochemical modeling process has not been completed
CAA requires photochemical grid modeling

15. The Modeling Process Three Models Combined Meteorological Model
Temperature and sunlight affect reaction rates
and mixing layer height
Emissions Model
Emissions from cars, planes, construction
equipment, factories, power plants
Photochemical
Model
Chemical Model
Chemistry changes during day and night
33 chemical groups, more than 80 reactions
Complex System of differential equations

16. The Modeling Process

17. Emissions Inventory Where no data exists, we must build estimates
Uncertainty regarding the VOC emissions inventory
Incorporating real world air monitoring data in the current emissions inventory

18. Modeling Goals
Purpose of model is to compare effectiveness of various control strategies
Determine what controls are most effective

19. The Modeling Process Process is not static Stakeholder input necessary
The typical SIP development process takes 3 years
EPA requires periodic update of SIPs

20. Why Don’t We Have the Answers Today?
The modeling must be defendable
The process can be completed quickly, but the results won’t be defendable
Important to replicate what is really happening in the atmosphere

21. Texas Air Quality Study 2000
VOCs from industry are primarily responsible for high ozone in Houston.
VOC emissions are substantially under-reported by industry.
VOC concentrations in Houston are very different from other cities
Ozone is produced faster and yields more in Houston than in other cities

22. Complete the Modeling TexAQS did not answer all questions
Should VOCs or NOx be controlled to reach attainment?
What combination of NOx and VOC reductions will attain the standard?
How much VOCs are actually being emitted from industry (80+ plants) in Houston?
Which VOCs are the most effective to control?

23. What Are We Going to Do to Achieve the Goal?
Complete development of photochemical model w/ control strategies
Develop control strategies/rules to achieve the necessary emission reductions
Not all control strategies are rules

24. Dependant on photochemical modeling results
Rule Development
Dependant on photochemical modeling results
Requires extensive research
Searching inventories for sources
Investigating accuracy of inventories
Evaluating new technologies
Calling vendors

25. Rule Development Research literature and other states’ requirements
Stakeholder input (with advisory group restrictions), public comment period and policy decisions necessary

26. Control Strategy Obstacles
Federal Pre-empted from regulating source
Ex: Locomotives, ocean going vessels, diesel engines
Texas Legislature removed TCEQ’s regulatory authority
Ex: Fuels, Speed Limit, Construction Equipment Related Rules

27. Control Strategies Obstacles
Available technology and verification/certification of technology
There are a limited number of EPA verified or CARB certified technologies
EPA’s verification process is costly and timely

28. Efforts to Overcome Obstacles
TCET funded to test technologies for verification purposes
TCEQ has urged EPA to expedite its verification process
TCEQ in partnership w/ CARB and NY have pressured EPA to improve verification process and implement cleaner engine/fuel standards