TCEQ TxLED Stakeholder Meeting October 14, 2005

Air Quality Planning and Implementation Division • TxLED Stakeholder WHJ: October 14, 2005 • Page 1

TCEQ TxLED Stakeholder Meeting

October 14, 2005

Air Quality Planning and Implementation Division October 14, 2005


Purpose of this Stakeholder Group

• The purpose of this group is to receive input on the draft concept paper for changing the TxLED program prior to bringing a formal rule revision before the commission.

• Specifically the focus is on changing the rules to facilitate EPA approval of alternative plans.


Why does the Alternative Plans Section Need Revisions?

• Currently, alternative plans are a mixture of various strategies and different calculation methodologies, with little standardization or linkage to current SIP reductions or inventories.

• The complexity and diversity of these plans requires extensive TCEQ and EPA review to approve the plans.

• Reductions may not be consistent with SIP inventories.


Why does the Alternative Plans Section Need Revisions?

• TCEQ rules require EPA approval of each alternative plan and/or revision

• EPA takes the position their approval can only follow a SIP revision including public review and comment.

• Currently, EPA has provided a temporary mechanism to allow entities to operate under alt. Plans until this rule making is complete


What Is a Solution?

• Utilize current SIP reductions, inventories, and previously approved EPA methods to formulate a replicable procedure for approving alternative plans.

• Require all alternative plans to ultimately fit within this process.


What Advantages Are Afforded by this Solution?

• Using up-to-date SIP inventories and emission factors helps to ensure that the reductions counted on in the SIP remain whole.

• If a replicable procedure is used, the approval of individual alternative plans will not require a SIP revision


How Long is a Producer’s Current Alternative Plan Good For?

• Current draft concept would allow approved alternative plans to be used 60 days beyond this rule’s effective date.

• Anticipated adoption of these revisions is mid-2006.


Is an Alternative Plan the Only Way to Comply Short of Making TXLED?

• There are multiple ways to comply with the TxLED rules:– Make TxLED;– Make California diesel fuel;– Make a California approved alternative formulation;– Make a TCEQ approved alternative formulation; and– Achieve equivalent reductions using an alternative

emission reduction plan.


Make TxLED

• Follow §114.312 (a) and produce a diesel fuel with:– A maximum aromatic content of 10% by volume;– and a minimum cetane number of 48.


Make California Diesel fuel

• Make California diesel fuel under §114.312(e)

– California diesel fuel produced under a small refiner exemption cannot be used to satisfy TxLED requirements under this section.

– Includes California diesel that complies with the “designated equivalent limits” allowed under CARB regulations:

Aromatic Hydrocarbon Content (% by wt.) 21.0 PAH Content (% by wt.) 3.5 API Gravity 36.9 Cetane Number 53 Nitrogen Content (ppmw) 500 Sulfur Content (ppmw) 160 before 6/1/06, 15 starting 6/1/06


Make a California approved Alternative Formulation

• §114.312(e) also allows alternative diesel formulations that are approved for use in California to be used under the TxLED program.

• These formulations can and do include additive strategies (for example: Kern KOR-4c is an approved formulation under this section of the TxLED rules).


Make a TCEQ Approved Alternative Formulation

• Following procedures in §114.312(f), produce an alternative formulation of diesel fuel that has been approved by TCEQ.

• There are currently four of these formulations approved by TCEQ:– Lubrizol PuriNOx– Biofriendly Green Plus– GTAT California Viscon– Biodiesel Industries B20 with Viscon


Make a TCEQ Approved…Continued

• A producer/importer could also produce or import an alternative formulation approved under §114.315(d) by demonstrating compliance through use of the EPA’s Unified Model.

• Using this method, each gallon would need to meet the minimum emission reduction requirements.


Questions?


Two Proposed Replicable Procedures

• Use of the Unified Model

• Use of early gasoline sulfur reduction


Using the Unified Model

• Demonstrate the average of all on-road diesel fuel produced in any calendar year that is sold, offered for sale, supplied, or offered for supply in affected counties achieves at least 5.5% reduction in NOX emissions from

on-road engines, and 6.2% for non-road engines in 2007.

• These overall percent reductions much be achieved for the attainment counties listed in §114.319, and each individual non-attainment area.

• An updated version of EPA’s unified model will be available on TCEQ’s Web site within the coming weeks.


Background:Gasoline Off-Set Ratios

• Producers have been allowed to use early gasoline sulfur reductions to offset compliance with TxLED in future years.

– Example: If a producer produced gasoline with a sulfur level lower than the EPA default assumptions in 2003, ’04, or ’05 the NOx benefit can be pulled forward and used in ’06 and ’07.

– This strategy is limited to the attainment areas (does not include DFW, HGB, or BPA).


Why Use Off-Set Ratios as a Replicable Stategy?

• Some producers have expressed an interest in using NOx reductions from lower sulfur gasoline produced in ’03, ’04, and ‘05 to substitute for the NOx reductions achieved from producing TxLED in ’06 and ’07.

• Different methodologies have been used to determine equivalency.

• The TCEQ proposal would remove the burden of modeling by each producer to show equivalency


What Is An Off-Set Ratio?

• An off-set ratio is a ratio of the low sulfur gasoline barrels offered for sale in an earlier year to the number of non-compliant diesel fuel barrels offered for sale in a future year.

• The offset ratio takes into account the differences in the NOx inventories between gasoline and diesel fuels, and the differences in the emission reductions between the two fuel strategies.


What’s an example of an off-set?

• Acme Refining produced 3,000 barrels of low sulfur gasoline in 2003 for use in the attainment counties covered by the TxLED rule.

• In 2006, Acme plans to market 1,000 barrels of TxLED in these same attainment counties, however Acme wishes to use its gasoline “credits” in lieu of supplying TxLED.


What’s an example of an off-set (cont.)?

• If an off-set of 3:1 has been established,

• Acme could use its 3,000 barrels of low sulfur gasoline produced in 2003 to off-set its obligation for 1,000 barrels of TxLED required to be supplied in 2006.


Why Establish Off-Set Ratios by Rule?

• Establishing off-set ratios by rule accomplished three objectives:

1. Establishes consistency.

2. Incorporates approved SIP inventories and uses Mobile 6 to establish the ratios.

3. Facilitates EPA approval of this replicable procedure.


What counties are covered by the gasoline off-set ratio strategy?

• 90 attainment counties: Anderson, Angelina, Aransas, Atascosa, Austin, Bastrop, Bee, Bell, Bexar, Bosque, Bowie, Brazos, Burleson, Caldwell, Calhoun, Camp, Cass, Cherokee, Colorado, Comal, Cooke, Coryell, De Witt, Delta, Falls, Fannin, Fayette, Franklin, Freestone, Goliad, Gonzales, Grayson, Gregg, Grimes, Guadalupe, Harrison, Hays, Henderson, Hill, Hood, Hopkins, Houston, Hunt, Jackson, Jasper, Karnes, Lamar, Lavaca, Lee, Leon, Limestone, Live Oak, Madison, Marion, Matagorda, McLennan, Milam, Morris, Nacogdoches, Navarro, Newton, Nueces, Panola, Polk, Rains, Red River, Refugio, Robertson, Rusk, Sabine, San Jacinto, San Patricio, San Augustine, Shelby, Smith, Somervell, Titus, Travis, Trinity, Tyler, Upshur, Van Zandt, Victoria, Walker, Washington, Wharton, Williamson, Wilson, Wise, and Wood counties.

• These are basically the attainment counties along and east of IH-35 and IH-37 from Corpus Christi to the Oklahoma border.


What years of low sulfur gasoline qualify?

• Lower sulfur gasoline needed to be produced in 2003, 2004, or 2005 in order to be eligible to use the off-set.

• Sulfur levels will need to be verified through the records submitted to EPA under the anti-dumping provisions of 40 CFR part 80.105 (2003), and the low sulfur gasoline reporting provisions of 40 CFR 80.370 (2004 and 2005).


What sulfur levels were assumed in the SIP?

• For SIP inventory development purposes, staff used the Mobile 6 default sulfur levels for determining NOx emissions.

Sulfur Level

ppm

2003 2004 2005 2006

Average 259 121 92 33

Cap 1000 303 303 87


What sulfur levels generate credit?

• Ranges of sulfur level reductions are as follows: 2003

Sulfur

ppm

25 to 49% below Fed.

baseline

50 to 74% below Fed. Baseline

75% to just above Fed.

Baseline

Federal Limit or lower

Average Range

131-194 66-130 31-65 30 or lower

Cap Range 501-750 251-500 21-250 80 or lower

Off-Set

Ratio

5.13 2.47 1.53 1.19




Sulfur

ppm

50% below Fed. Baseline

Federal limits or Lower

Average Range 31-65 30 or lower

Cap Range 80 or lower 80 or lower

Off-Set

Ratio

3.32 1.96




Sulfur

ppm

Federal Limits or Lower

Average 30 or lower

Cap 80 or lower

Off-Set

Ratio

2.26


How Were the Off-sets Determined?

• Mobile 6 was run with baseline assumptions varying the sulfur level accordingly.

• Emission factors were weighted by the amount of the NOx inventory they represent.– For example, light duty gasoline vehicle represented

48.7% of the on-road NOx inventory.– Note: diesel vehicles are not impacted by gasoline

sulfur changes.



• TxLED achieves NOx reductions from both the on-road and off-road mobile inventories.

• Lower sulfur gasoline achieves NOx reductions only from the on-road inventory.

• TxLED achieves an average of 5.7% reduction.

• Lower sulfur gasoline achieves a varying NOx reduction depending on sulfur level and year models using the fuel.



• The total diesel NOx inventory (on and off-road) is larger than just the on-road gasoline NOx inventory.

• The on-road gasoline NOx inventory is only about 41% of the on and off-road diesel NOx inventory.

• For this reason and the variable emission reductions based on gasoline sulfur level, a 1:1 offset ratio will not work.


Questions?

Documents

TCEQ TxLED Stakeholder Meeting October 14, 2005