EMISSIONS INVENTORY REPORTING REQUIREMENTS FOR THE DALLAS

FORTWORTH AND HOUSTON

- GALVESTON

- BRAZORIA NONATTAINMENT AREA S

UNDER THE 2008 EIGHT

- HOUR OZONE NAAQS
Docket ID: EPA

- R06

- OAR

- 2014

- 0554

This document provides a technical review of a revision to a Texas State Implementation Plan (SIP) to meet Clean Air Act (CAA) Emission Inventory (EI) reporting requirement s for the D allas

- Fort Worth (DFW) and the Houston

- Galveston

- Brazoria (HGB) nonattainment areas under the 2008 eight

hour ozone standards submitted by Texas Commission on Environmental Quality (TCEQ) on July1 6 , 2014.

A. General Requirements Under the Clean Air Act (CAA ) sections 172(c)(3) and 182 (a)(1) ), states are required to submit emissions inventory (EI) information for all relevant s ources for areas that are designated nonattainment for any of the National Ambient Air Quality Standards (NAAQS) for each area designated nonattainment for a NAAQS. On March 27, 2008, the United States Environmental Protection Agency (EPA) lowered the prim ary and secondary eight

- hour ozone National Ambient Air Quality Standards (NA AQS) to 0.075 parts per million (ppm) ( 73 FR 16436 ) . On May 21, 2012, the EPA published in the Federal Register ( 77 FR 30088 ) final designations for the 2008 eight

- hour ozone standard . The Dallas

- Fort Worth (DFW) area was designated moderate nonattainment and the H ouston

- Galveston

- Brazoria (HGB) area was designated marginal nonattainment. The effective date of the final rule is July 20, 2012.
EPA ’s proposed 2008 ozone standard SIP requirements rule specified that states use 2011 as a base year to address EI requ irements. T he nonattainment area base year EI emission is due no later than 24 months from the July 20, 2012 effective date and then every three years thereafter. An emissions inventory is an estimation of actual emissions of air pollutants in an area. Vol atile organic compounds (VOCs) and oxides of nitrogen (NOx) are known as “ozone precursors”, as they react with oxygen and sunlight to form ozone. Motor vehicle exhaust and industrial emissions, gasoline vapors and chemical solvents emit NOx and VOCs. Cont rolling sources of NOx and VOC emissions can lower ozone levels in the ambient air. The emissions inventory for an ozone nonattainment area contains VOC and NOx emissions, as these pollutants are precursors to ozone formation. The EIs provide data for a variety of air quality planning tasks including establishing baseline emission levels calculating federally required emission reduction targets, emission inputs into air quality simulation models, and tracking emissions over time. The total EI of VOC, NO x , and other pollutants for an area are summarized from the estimates developed for five general categories of emissions sources: point, area, on

- road mobile, non

- road mobile, and biogenic.

B. Background

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1. Dallas

- Fort Worth Compliance with the Ozone NAAQS from 1990 to Present The majority of NO x emissions in the DFW area come from on

- road mobile sources (cars and trucks) and

non

- road mobile sources (such as construction equipment, aircraft, and locomotives).
2 008 Eight

- Hour Ozone Standard (2008 to Present) On March 27, 2008, the United States Environmental Protection Agency (EPA) strengthened the primary and secondary eight

- hour ozone standard to 0.075 ppm ( 73 FR 16436 ). On May 21, 2 012, the EPA published in the Federal Register final designations for the 2008 eight

- hour ozone standard ( 77 FR 30088 ) . A ten

- county DFW area including Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise Counties was designated nonattainment and classified moderate under the 2008 eight

- hour ozone standard, effective July 20, 2012. The DFW area includes the nine counties that were designat ed nonattainment under the 1997 eight

- hour ozone standard in addition to Wise County. The attainment deadline for the DFW moderate nonattainment area is December 31, 2018. 1997 Eight

- Hour Ozone Standard (1997 to Present) In July 1997, the EPA announced a r evised NAAQS for ground

- level ozone. The EPA phased out and replaced the previous one

- hour standard with an eight

- hour standard set at 0.08 ppm to protect the public health against longer exposure to this air pollutant. The eight

- hour ozone standard became effective on September 16, 1997. Effective June 15, 2004, Collin, Dallas, Denton, Tarrant, Ellis, Johnson, Kaufman, Parker, and Rockwall Counties were designated nonattainment for the 1997 eight

- hour ozone standard . The area was classified moderate nonatt ainment for the standard, with an attainment deadline of June 15, 2010. On April 27, 2005, TCEQ submitted to EPA the DFW Eight

- Hour Ozone Five Percent Increment of Progress SIP Revision t o satisfy the requirements of Phase I of the 1997 eight

- hour ozone st andard implementation rule ( 69 FR 23951 ) . The revision used a 5% increment of progress from the area’s 2002 emissions baseline beyond the reductions from federal and state measures already approved by the EPA, and was the first DFW SIP revision submitted under the 1997 eight

- hour ozone standard. In May 2007, the TCEQ submitted attainment demonstration and reasonable further progress (RFP) SIP revisions for the DFW area to the EPA. The May 2007 DFW Attainment Demonstration SIP included a plan for DFW compliance with the 1997 eight

- hour ozone standard by June 15, 2010 (based on 2009 ozone season monitoring). The RFP SIP revision demonstrated 15% total NO x an d volatile organic compound (VOC) emissions reductions between 2002 and 2008, as required. The attainment demonstration and RFP SIP revisions relied on photochemical modeling and weight of evidence (WoE) analyses that examined qualitative and other factors that could not be directly included in the models, but that nevertheless supported the projected attainment by 2010. On March 21, 2008, the EPA found the on

road motor vehicle emissions budget (MVEB) contained in the DFW attainment demonstration adequate for transportation conformity purposes ( 73 FR 15152 )

. On October 7, 2008, t he EPA approved the May 2007 DFW RFP SIP revision (which included an update d MVEB and emissio ns inventory) ( 73 FR 58475 )

.

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On December 7, 2011, the TCEQ adopted the 2011 DFW 1997 Eight

- Hour Ozone Attainment Demonstration SIP Revision and the 2011 DFW 1997 Eight

- Hour Ozone RFP SIP Revision

. The 2011 attainment demonstration SIP revision demonstrated that the state’s control strategy would result in the area’s attainment of the 1997 eight

- hour o zone standard by 2012, the attainment year for serious nonattainment areas. The 2011 attainment demonstration SIP revision used the EPA’s Motor Vehicle Emissions Simulator (MOVES) model to develop the on

- road mobile emissions inventory and attainment year MVEB. The 2011 RFP SIP revision demonstrated that an emissions reduction of at least 3% per year would occur between milestone years 2011 and 2012. The 2011 RFP SIP revision established baseline emission levels, calculated reduction targets, identified con trol strategies to meet emission target levels, and tracked actual emission reductions against established emissions growth. The 2011 RFP SIP revision also included an MVEB for each milestone year as well as a contingency plan. As with the 2011 attainment demonstration SIP revision, the 2011 RFP SIP revision used the EPA’s MOVES model to develop the base year and milestone year on

- road mobile emissions inventories and the milestone year MVEBs.
2

. Houston

- Galveston

- Brazoria Background and Ozone History Background and history of Houston

- Galveston

- Brazoria (HGB) area compliance with the National Ambient Air Quality Standards (NAAQS) for ground

- level ozone. 2008 Eight

- Hour Ozone NAAQS (2008 to Present) On March 27, 2008, EPA strengthened the primary and se condary eight

- hour ozone NA AQS to 0.075 ppm ( 73 FR 16436 ) . On March 10, 2009, the governor 1 recommended to the EPA that only counties already designated nonattainment for the 1997 eig ht

- hour ozone NAAQS (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller) be designated nonattainment for the 2008 eight

- hour ozone NAAQS

. On May 21, 2012, the EPA published final designations for the 2008 eight

- hour ozone NAA QS in the Federal Register ( 77 FR 30088 ) . An eight

- county HGB area including Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties was designated nonattainment and classified marginal under the 2008 eight

- hour ozone NAAQS effective July 20, 2012. The HGB area includes the same eight counties that were designated nonattainment under the 1997 eight

- hour ozone NAAQS. Matagorda County was designated attainment/unclassifiable. The attainment deadline for the HGB marginal nonattainment area is December 31, 2015. 1997 Eight

- Hour Ozone NAAQS (1997 to Present)

Note: The HGB area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgo mery, and Waller Counties) is currently classified severe nonattainment for the 1997 eight

- hour ozone NAAQS, with an attainment deadline of June 15, 2019. On July 18, 1997, the EPA published the revised NAAQS for ground

- level ozone in the Federal Register ( 62 FR 38856 ) , and it became effective on September 16, 1997. The EPA phased out and replaced the

1 See the governor’s 2009 designation recommendation letter: http://www.epa.gov/ozonedesignations/2008standards/rec/letters/06_TX_rec.pdf

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previous one

- hour ozone NAAQS with an eight

- hour NAAQS set at 0 .08 ppm based on the three

- year average of the annual fourth

- highest daily maximum eight

- hour average ozone concentrations measured at each monitor within an area. Effective June 15, 2004, Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgome ry, and Waller Counties were designated nonattainment in the first phase of the EPA's implementation rule for the 1997 eight

- hour ozone NAAQS ( 69 FR 23951 ) . The HGB area was classified moderate nonattainment for the standard, with an attainment deadline of June 15, 2010. The TCEQ was required to submit a state implementation plan (SIP) revision for the 1997 eight

- hour ozone NAAQS to the EPA by June 15, 2007. The E PA addressed the control obligations that apply to areas designated nonattainment for the 1997 eight

- hour ozone NAAQS in the second phase of the implementation rule ( 70 FR 71612 )

. On May 23, 2007 , TCEQ submitted the 2007 HGB 1997 Eight

- Hour Ozone Nonattainment Area SIP revision as the first s tep in addressing the 1997 eight

- hour ozone NAAQS in the HGB area and the 2007 HGB 1997 Eight

- Hour Ozone Nonattainment Area Reasonable Further Progress (RFP) SIP revision , which demonstrated that a required 15% emissions reduction in ozone precursors (VOC and nitrogen oxides (NO x ) would be met for the 2001 through 2008 RFP analysis period. On June 15, 2007, the state requested that the HGB area be reclassified from a moderate to a severe nonattainment area for the 1997 eight

- hour ozone NAAQS, wit h an attainment deadline of June 15, 2019 2

. On December 31, 2007, the EPA published its proposal took comments on a range of dates for the state to submit a revised SIP ( 72 FR 74252 ) . The TCEQ provided comments 3 to the EPA that supported the reclassification and justification for an April 2010 SIP submission date. On October 1, 2008, the EPA published approval to reclassify the HGB ozone nonattainment area from a moderate to a severe nonattainment area for the 1997 ozone NAAQS ( 73 FR 56983 ) effective October 31, 2008. The EPA set April 15, 2010 as the date for the state to submit a revised SIP address ing the

severe

- oz one nonattainment requirements. On March 10, 2010, the commission adopted two revisions to the Texas SIP for the HGB ozone nonattainment area. The 2010 HGB Attainment Demonstration SIP Revision for the 1997 Eight

- Hour Ozone Standard included a photochemical mod eling analysis and a weight of evidence analysis to demonstrate attainment of the 1997 eight

- hour ozone NAAQS by the June 15, 2019 deadline.
The 2010 HGB RFP SIP Revision for the 1997 Eight

- Hour Ozone Standard d emonstrated that an 18% emissions reduction requirement will be met for the 2002 through 2008 RFP analysis period and that an average of 3% per year emissio ns reduction will occur between each of the milestone years 2008, 2011, 2014, 2017, and 2018. This SIP revision established baseline emission levels, calculated reduction targets, identified control strategies to meet emission target levels, and tracked ac tual emission reductions against established emissions growth. This revision also included an MVEB for each milestone year and a

2 See the governor's 2007 reclassification request letter: http://www.tceq.state.tx.us/assets/public/implementation/air/sip/miscdocs/AR

- M550U_20070616_014613.pdf

3 See the TCEQ's comments concerning the EPA's proposed redesignation http://www.tceq.state.tx.us/assets/public/implementation/air/sip/hgb/HGB_Letter_Comments.pdf

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contingency plan. On January 25, 2011, the EPA published a notice of its determination that the MVEBs in the March 10, 2010 SIP revisions, which were developed using the on

- road mobile source emissions inventories based on the EPA's MOBILE 6.2 model, were adequate for transportation conformity purposes ( 76 FR 4342 ) . On January 2, 2014, the EPA published approval of this RFP SIP revision ( 79 FR 51 )

. On December 7, 2011, th e commission adopted the 2011 HGB RACT Analysis Update SIP Revision for the 1997 Eight

- Hour Ozone Standard . This SIP revision updated the RACT analysis for VOC emis sion sources to include the seven CTG documents issued by the EPA from 2006 through 2008 that were not addressed in the 2010 HGB Attainment Demonstration SIP revision. This SIP revision incorporated concurrent CTG

- related rulemaking that revises Chapter 11 5, Subchapter E to implement RACT for those CTG emission source categories in the HGB area. On April 23, 2013, the commission adopted the 2013 HGB 1997 Eight

- Hour Ozone Standard Nonattainment Area MVEB Update SIP Revision . This SIP revision updated on

- road mobile source emissions inventories and MVEBs for the HGB area using the EPA's latest mobile emissions estimation model, the Motor Vehicle Emissions Simulator (MOV ES2010a). This SIP revision also met the primary obligation of the mid

- course review commitment in the 2010 HGB attainment demonstration SIP revision by demonstrating that the outstanding 3% contingency requirement was fulfilled. Updated on

- road inventorie s and emissions analysis based on the EPA’s August 30, 2012 vehicle miles traveled offset guidance and a modified version of the MOVES model demonstrated compliance with the CAA requirements for transportation control measures in severe nonattainment areas . On January 2, 2014, the EPA published approval of this MVEB SIP update to the 2010 attainment demonstration SIP revision ( 79 FR 57 )

.

C. EPA’s Analysis
EPA has reviewed the Texas submittal for consistency with the requirements of EPA regulations. The following is a summary of the analysis based on the information provided by Texas. 1. Base Year Emissions Inventory The 2011 Base Year Inventory is the starting point for calculating the reductions necessary to meet the requirements of the CAA. Sections 172 (c)(3) and 182(b)(1) of the CAA require that nonattainment plan provisions include an inventory of actual emissions from all sources of relevant pollutants in the nonattainment area. The federal Air Emissions Reporting Requirements (AERR) rule requires states to develop and submit periodic EIs to EPA every three years. The 2011 inventory was the first periodic emission inventory (PEI) submitted under AERR. Per t he AERR, the 2011 PEI was reported to the EPA’s National Emissions Inventory (NEI) as a comprehensive and detailed estimate of air emissions, including ozone pre cursors (NO x and VOC). The year 2011 is also the year for a required EI submission under the existing AERR rule. As directed by the AERR, the NEI includes statewide coverage. Annual and summer day emissions are reported on a three

- year cycle for the AERR. States can rely on peri

odic AERR EI submittals to satisfy ongoing SIP EI submission requirements every three years. The Texas submitted the 2011 base year inventory to EPA as part of a SIP revision for the HGB and DFW 8

- hour ozone non

- attainment area. EPA reviewed the 2011 base year inventory and determined that it was developed in accordance with EPA guidelines. The inventory includes all area, point, non

- road

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mobile, and on

- road mobile source emissions in the HGB and DFW ozone nonattainment area. The inventory also includes a d escription of the meth ods used to estimate emissions:
Point Source Emissions : Industrial sources are required to submit emissions data to TCEQ annually. TCEQ stores the data in the State of Texas Air Reporting System ( STARS ) database. The 2011 base year po int source EI data were extracted from STARS on April 1, 2014. The extracted data contain ozone season daily and annual NO x and VOC emissions for each site in the HGB and DFW 2008 eight

- hour ozone nonattainment areas that submitted a 2011 emissions invento ry questionnaire, including revisions reviewed approved, and entered on or before the extract date . A more detailed description site level 2011 NO x and VOC emissions data can be f ound in chapter 2 and Appendix K of the S tate submittal.
Area Source Emissions : Area sources are small

- scale industrial, commercial, and residential sources that generate emissions. TCEQ developed the 2011 area s ource emission inventory in according to the AERR reporting requirements, using a combination of methodologies an d data: EPA

- generated EIs, TCEQ

contracted projects, TCEQ staff projects, and c ategories grown from the 2008 EI. EPA developed EIs for states to use for many source categories as part of the NEI. These source categories include but are not limited to indus trial coatings, degreasing; residential, commercial/institutional, and industrial fuel use, commercial cooking; aviation fuel use; and consumer products. For some source categories, the TCEQ developed state

- specific emissions estimates by acquiring current state specific activity data and applying appropriate emissions factors. These source categories include but are not limited to: storage tanks, structural fires, dry cleaners, automobile fires and oil and gas. Significant re sources were expended to improv e the oil and gas area source inventory production for 2011. The improvement included the development and refinement of a state

- specific oil and gas area source emissions calculator that us es county

- level production and local equipment activity data with l ocal emissions requirement to estimate emissions for individual production categories including compressors engines, condensate and oil storage tanks, loading operations, heaters, and dehydrators . We have reviewed these approaches and have deter mined that they are acceptable.
Non

- road Emissions Inventory : The non

- road category is composed of a diverse collection of equipment, many of which are powered by diesel engines. Non

- road emissions sources include, but are not limited to: agricultural equipment, loco motives, drilling equipment, lawn and garden equipment, aircraft and airport equipment, locomotives, drilling rigs and commercial marine vessels (CMV). For the 2011 EI, emissions inventories for non

- road sources were developed as subcategories: NONROAD mod el categories; airports; CMVs; drilling rigs; and locomotives. TCEQ has updated the HGB and DFW non

- road emissions by using area specific information and the latest version of models as well data obtained from studies and surveys of industrial and construction equipment. TCEQ conducted several equipment survey studies which focused on various equipment categories operating in different areas in Texas. The resulting survey studies data were use d as inputs to more accura tely estimate non

- road emissions for the state of Texas

. We find the approach and methodology used by TCEQ acceptable. A full detailed description of the approach is detailed in sectio n 2.4 of the state’s submittal.
On

- road Emissi

on Inventory : On

- road emission sources consist of automobiles, trucks, motorcycles, and other motor vehicles travelling on public roadways. On

- road mobile source emissions are usually categorized as either combustion

- related emissions or evap orative hydroc arbon emissions. Combustion

related emissions are estimated for vehicle engine exhaust. Evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources on the vehicle engine exhaust. TCEQ

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updated the on

- road emissions u sing the latest available data, current emissions factors (developed from EPA’s Motor Vehi

cle Emissions Simulator (MOVES)) 4 for on

- road mobile sources, and the most current plannin g assumptions. On

- road mobile emission models are models that predict gram p er mile emissions of hydrocarbons (HC), carbon monoxide (CO), NO x , carbon dioxide (CO 2 ), particulate matter (PM), and toxics from cars, trucks, and motorcycles under various conditions. EPA reviewed the on

- road emission estimates approach and methodology a nd determined that they are acceptable. A detailed description of

on

- road emission estimates is found in section 2.5 of the TCEQ submittal.

Table 1. DFW 2011 Emissions Inventory ( t ons per day or tpd )

Source Type NOx VOC Point 39.95 29.80 Area 42.64 292.49 On

- road Mobile 238.87 98.36 Non

- road Mobile 120.61 55.00 Total 442.08 475.65

Table 2. HGB 2011 Emissions Inventory ( tpd )

Source Type NOx VOC Point 108.44 94.83 Area 21.14 308.73 On

- road Mobile 196.21 82.62 Non

- road Mobile 121.11 49.93 Total 446.90 536.12

Biogenic Sources: Biogenic sources include VOC emissions from crops, lawn grass, and trees as well as a small amount of NOx emissions from soils. Plants are sources of VOC emissions such as isoprene, monoterpene, and alpha

- pinene. Biogenic emissions are estimated by the EP A using its biogenic emissions inventory to o.

D. Summary and Recommendations:
Pursuant to 40 CFR Part 51.102 and after proper notice, the TCEQ conducted public hearings to consider the revision to the SIP. Proper notice included prominent advertisement in the areas affected at least 30 days prior to the dates of the hearings. Public hearings were held in Houston on January 14, 2014 and Arlington on January 16, 2014. Data, views, and recommendations of interested persons regarding the proposed SIP revision were submitted to the TCEQ during the comment period and were considered and incorporated by reference to the SIP revision. The TCEQ used acceptable techniques and methodologies

4 In March 2010, EPA replaced the MOBILE6.2 model with MOVES as the official emissions factor model for developing on

- road mobile s ource category EIs. Although MOVES represents a new approach to assessing on

- road emissions, the sources are the same, and the opportunity to use local inputs for meteorological conditions, control programs, and fleet character istics remains. The primary a pproach to developing an on

- road inventory is the same with either MOVES or MOBILE6.2. With both models, emission rates are produced for subsets of the on

- road fleet, and the emission rates are multiplied by the activity level of each vehicle type or sourc e use type.

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to develop the 2011

- base year emission inventories for the 2008 o zone NAAQS for the HGB and DFW nonattainment areas to satisfy the EI requirements at sections 172 and 182 of the CAA

. Ther efore we recommend approval of the Texas SIP to meet CAA emissions inventory reporting requirements for the DFW and the HGB nonattainm ent areas under the 2008 ozone NAAQS submitted by TCEQ on July16 , 2014

.