### CALIFORNIA AIR RESOURCES BOARD

NOTICE OF PUBLIC MEETINGTO CONSIDER APPROVAL OF THE IMPERIAL COUNTY 2009 1997 8-HOUR OZONE MODIFIED AIR QUALITY MANAGEMENT PLAN AND 2009 REASONABLY AVAILABLE CONTROL TECHNONOLGY STATE IMPLEMENTATION PLAN The Air Resources Board (ARB or Board) will conduct a public meeting at the time and place noted below to consider the approval of the proposed lmperial County 2009 1997 8-Hour Ozone ModifiedAir Quality Management Plan (2009 Ozone Plan) and 2009 Reasonably Available Control Technology State Implementation Plan (2009 RACT SIP) for the lmperial County NonattainmentArea. If approved by the Board,ARB will submit the 2009 Ozone Plan and 2009 RACT SIP to the United States Environmental Protection Agency (U.S. EPA) for approval as a revisionto the California State Implementation Plan (SIP). DATE: November 18,2010 TIME: 9:00 a.m. PLACE: California Environmental ProtectionAgency



### . Air Resources Board Byron Sher Auditorium 1001 

### 1 Street Sacramento, California 95814 This item may be considered at a two-day Board meeting, which will commence at 9:00 a.m., November 18, 2010, and may continue at 8:30 a.m., on November 19,2010. This item may not be considered until November 19, 2010. Please consult the agenda for the meeting, which will be available at least ten days before Noverr~ber 18, 2010, to determine the day on which this item will be considered. 

### Backaround The federal Clean Air Act (CAA) establishes planning requirements for areas that exceed the health-based NationalAmbient Air Quality Standards (NAAQS)and have been designated as nonattainment based on monitored exceedancesof the NAAQS. Nonattainment areas must develop and implement SIPSthat demonstrate how they will attain the NAAQS by specified dates. In 2004 U.S. EPA identified lmperial County as a "marginal" nonattainment area for the 8-hour ozone IVAAQS promulgated in 1997. On February 13,2008, U.S. EPA found that lmperial County had not attained the 19978-hour ozone NAAQS by the marginal area attainment deadline of June 15, 2007, and reclassified it as a "moderate" nonattainment area. Underthe CAA, this action requires Californiato submit as a SIPrevision a moderate area ozone planfor lmperial County, demonstrating attainment of the 8-hour ozone NAAQS by June 15,2010. On February 19, 2009, ARB submitted a clean data finding request for lmperial County to U.S. EPA. The requestwas based on certified air monitoringdata recorded from 2006 through 2008 that indicated attainmentof the 19978-hour ozone NAAQS. In response to ARB'Srequest, on December3, 2009, U.S. EPA published inthe Federal Register its determination that lmperial County attained the 1997 8-hour ozone standard. This action suspended some CAA nonattair~ment area plan requirements. However, California is still required to submit revisions to the SIP to address remaining elements requiredfor moderate ozone nonattainmentareas, including rule review and adoption relative to the reasonably available control technology (RACT) requirements, emission inventories, and new source review requirements. On July 30, 2010, the lmperial County Air Pollution Control District adopted the 2009 Ozone Plan and 2009 RACT SIPto address the CAA moderate area plan requirements.
Proposed Action ARB staff has reviewed the lmperial County2009 Ozone Plan and 2009 RACT SIP, and consulted with District staff during its review. ARB staff finds that the lmperial County 2009 Ozone Plan and 2009 RACT SIP meet all applicable CAA requirements for a moderate nonattainment area. Staff recommends that the Board approve the lmperial County 2009 Ozone Plan and 2009 RACT SIP and direct the Executive Officer to submit them to U.S. EPA as revisionsto the California SIP. Availabilityof Documents Copies of staffs written report may be obtainedfrom ARB's Public InformationOffice, 1001 

### 1 street, First Floor, EnvironmentalServices Center, Sacramento, California, 95814, (916) 322-2990, beginning October 19, 2010. The report may also be obtained from ARB's website at http://www.arb.ca.qov/plannin~/sip/sip.htm. Submittal of Comments Interested members of the public may present comments orally or in writing at the meeting and may be submitted by postal mail or by electronic submittal before the meeting. To be considered by the Board, written comments submissions not physically submitted at the meeting must be received no later than 12:OO noon, November 17,2010, and addressed to the following: Postal mail: Clerk of the Board,Air Resources Board 1001 

### 1 Street, Sacramento, California 95814 Electronic submittal: http://www.arb.ca.qovllispub/comm/bclist.~hp

### Please note that under the California Public Records Act (Government Code section 6250 et seq.), your written and oral comments, attachments, and associated contact information (e.g., your address, phone, email, etc.) become part of the public record and can be released to the public upon request. Additionally, this information may become available via Google,Yahoo, and any other search engines. The Board requests, but does not require 20 copies of any written submission. Also, ARB requests that written and email statements befiled at least ten days prior to the meeting so that ARB staff and Board members have time to fully consider each comment. Further inquiries regarding this matter should be directed to Mr. Dmitri Smith, Air Pollution Specialist, at (916) 323-1537. Special Accommodation Request Special accommodation or language needs can be provided for any of the following: An interpreter to be available at the hearing; Documents made available in an alternate format (i.e., Braille, large print, etc.) or another language; A disability-related reasonable accommodation. To request these special accommodations or language needs, please contact the Clerk of the Board at (916) 322-5594 or by facsirr~ile at 916) 322-3928 as soon as possible, but no later than 10 business days before the scheduled Board hearing. TTYrTDDlSpeech to Speech users may dial 711for the California Relay Service. Comodidad especial o necesidad de otro idioma puede ser proveido para alguna de las siguientes: Un interprete que este disponible en la audiencia Documentos disponibles en unformato alterno (por decir, sistema Braille, o en impresion grande) u otro idioma. Una acomodacion razonable relacionados con una incapacidad. Para solicitar estas comodidades especiales o necesidades de otro idioma, por favor llame a la oficina del Consejo al (916) 322-5594 o envie unfax a (916) 322-3928 lo mas pronto posible, per0 no menos de 10dias de trabajo antes del dia programado para la audiencia del Consejo. TNITDDlPersonas que necesiten este servicio pueden marcar el 711 para el Servicio de Retransmision de Mensajes de California. CALIFORNIAAIR RESOURCES BOARD

James N. Goldstene Executive Officer Date: October 13,2010

### STAFF REPORT



## Analysis of the Imperial County 2009 1997 8-Hour Ozone Modified Air Quality Management Plan and Reasonably Available Control Technology Plan State of California AIR RESOURCES BOARD



### Date of Release: Scheduled for Consideration: Noverr~ber 

### 18, 2010 

## California Environmental Protection Acrencv Air Resources BoardThis report has been reviewed by the staff of the California Air Resources Board and approved for publication. Approval does not signify that the contents necessarily reflect the views and policies of the Air Resources Board, nor does mention of trade names or corr~mercial products constitute endorsement or recommendation for use.

### Table of Contents

1



### . Introduction



### .................................................................................................... 1 II



### . Background



### ................................................................................................... -2 Ill



### . ModerateArea Requirements



### ........................................................................4 IV



### . Evaluationof the Imperial County Modified Plan



### ...........................................6

A



### . Attainment of the 1997 &Hour Ozone Standard



### .................................................. 6 B



### . Moderate Nonattainment Area Requirements



### ...................................................... 8



### ........................................................................................... V



### . 2009RACTSIP 

### I1 VI



### . Staff Recommendations



### .............................................................................. I I

### This staff report reviews plans adopted by the lmperial County Air Pollution Control Districtto address federal Clean Air Act (CAA) nonattainment area plan requirements applicable to moderate ozone nonattainment areas. With the promulgation of the 1997 8-hour ozone National Ambient Air Quality Standard (NAAQS) inApril 2004, the United States Environmental Protection Agency (U.S. EPA) classified lmperial County as a marginal nonattainment area. On February 13, 2008, U.S. EPA found that lmperial County had not attained the 1997 8-hour ozone NAAQS by the marginal area deadline of June 2007, and reclassified the County as a moderate nonattainment area. U.S. EPA'saction also required the State to submit a moderate area SIP for the lmperial County nonattainment area, by December 31, 2008, that demonstrates attainment of the 8-hour ozone standard by June 15,2010. On February 19, 2009, ARB requested that U.S. EPA make a "clean data" finding for lmperial County. The request demonstrated that the area's 2008 design value for the 8-hour ozone NAAQS, which was based on monitoring data collected from 2006 through 2008, showed attainment of the standard. U.S. EPA issued its clean data finding on December 3, 2009. A clean data finding does not constitute a redesignation to attainment under the national CAA, so lmperial County remains a moderate nonattainment area. The clean data finding suspended some CAA nonattainmentarea plan requirements. However, the State is still requiredto subrr~it revisionsto the SIP to address remaining elements required for moderate ozone nonattainment areas, including rule review and adoption relative to the reasonably available control technology (RACT) requirements, emission inventories, and new source review requirements. On July 30, 2010, the lmperial County Air Pollution Control District adopted the 2009 1997 &Hour Ozone Modified Air Quality Management Plan (2009 Ozone Plan) and 2009 Reasonably Available Control Technology State Implementation Plan (2009 RACT SIP) to address the CAA moderate area plan requirements. ARB staff reviewed the lmperial County 2009 Ozone Plan and RACT SIP and find that both plans meet all applicable CAA requirements for a moderate nonattainment area. Staff recommends that the Air Resources Board adopt the lmperial County 2009 Ozone Plan and the 2009 RACT SIP and direct the Executive Officer to submit the plans to U.S. EPA as proposed revisions to the California SIP.

## II. Background

Profileof lmperial County lmperial County is part of the Salton Sea Air Basin. The lmperial County Ozone NonattainmentArea consists of the entire county, and is under the jurisdiction of the lmperial CountyAir Pollution Control District (District). lmperial County covers 4,482 square miles of mostly arid lands inthe southeastern corner of California. It is bordered by Mexico to the south, Arizona on the east, San Diego County on the west, and Riverside County on the north. lmperial County's elevation ranges from more than 2,800 feet on the mountain summits to the east to 230 feet below sea level inthe Salton Sea. Winters are mild and dry with daily average temperature ranges between 65 and 75OF, although daily high terr~peratures of up to 80°F are not uncommon. Summers are extremely hot with daily average temperature ranges between 104 and 11 5OF and daily high temperatures of up to 120°F. The County has an annual rainfall of approximately 3 inches, occurring mostly from late summer to midwinter. lmperial County has a population of approximately 180,000 people. The County's major population centers include the cities of El Centro (25 percent of the county population), Calexico (22 percent), and Brawley (I 5 percent). Approximately 22 percent of the population resides in unincorporated areas. Mexicali, Mexico 

### - a city of approximately 900,000 people -spreads southward from the CaliforniaIMexico border at lmperial County. Mexicali's residential and industrial centers begin less than 5 miles from Calexico and 15 and 25 miles, respectively, from El Centro and Brawley. Because the New River is the only geographical feature separating lmperial County from Mexicali, air pollution transport between the two areas is possible. ARB'SJune, 1993 transport assessment report identified Mexico as the source of emissions that caused or contributed to some of the exceedances of the state ozone standard recorded in Imperial County from 1989to 1991

# '.

Air Quality History Ozone air quality has improved significantly in lmperial County in recent years as shown by both the number of days inwhich ozone values exceed the 8-hour ozone NAAQS (exceedance days) and the recorded daily high ozone concentrations. In 1997, lmperial County exceeded the 1997 8-hour ozone NAAQS of 0.085 parts per million (0.085 ppm), also expressed as 85 parts per billion (85 ppb), on 50 days. In 2009, the number of exceedance days declined to 2. Table 1 shows the progressive decrease in exceedance days at each routine monitoring site in lmperial County.


## ' Air Resources Board, Assessment and Mitigation ofthe Im~acts ofTransported Pollutants on Ozone Concentrations in California, June 1993 -2-

### Table 1 lmperial County Exceedance Days, 8-Hour Ozone NAAQS 2001

# - 2009

Westmorland 1 0 0 0 10 5 5 2 1

Figure 1 shows the federal design value trend in lmperial County from 2001 to 2009 and the respective 1997 8-hour ozone standard. The SIP design value is based on the fourth highest value recorded each year, averaged over three consecutive years. lmperial County's 8-hour ozone design value has decreased by ten percent since 2001, and now meets the 1997 federal NAAQS. When compared to other indicators such as peak concentrations, the design value is a more stable indicator for evaluatingyear to year changes resulting from emission control programs, and isthe only indicator that can be used to determine compliance with the NAAQS. Peak concentrations measure the severity of ozone exposure but not the frequency, and can be influenced by year to year weather variations. The U.S. EPA is in the process of revisingthe 8-hour ozone NAAQS, and is expected to promulgate its revised standard in late 2010. The range of values the agency is considering for the new NAAQS -from 0.070 ppm to 0.060 ppm (70 ppb to 60 ppb) 

### - is from 29 percentto 17 percent more stringent than the current 8-hour ozone NAAQS of 0.085 ppm. Recent monitoring data suggests that lmperial County will be designated as nonattainment for the new standard.Figure 

### 1 Imperial County Design Value

- s.-8-HourOzone Design Value
8-Hour Ozone Standard

Year



## Ill. Moderate Area Requirements

On December 

### 3, 2009, U.S. EPA published its finding that Imperial County attained the 1997 8-hour ozone standard. U.S. EPA's "clean data finding" suspends certain SIP elements including the attainment demonstration, reasonable further progress demonstration, and contingency measures requirements. However, some SIP requirements remain, and some were added when U.S. EPA reclassified Imperial County from marginal to moderate. Table 2 shows SIP elements required for marginal and moderate area plans, and identify the SIP elements suspended by the clean data finding.Table 2 Marginal and Moderate Ozone Nonattainment Area SIP Requirements and 

## - Clean Data Finding Elements requirementsuspended with clean data finding 

### .-- x

x

x

x
Note: N/A in Imperial County becauseof population(<200,000) moderate area

x

x

x

x

x Ozone Part 

### D SIP Requirement marginal area

Note: Stage 2 GVR no longer required in moderateozone areas per Onboard Refueling Vapor Recovery rule. CAA 202(a)(6); 59 FR16262 (April 6, 1994). x

x

x x

x

x
1.15to 1 Stage 2 Gasoline Vapor Recovery (1 82(b)(3))
Emissions Inventory (172(c)(3), 182(a)(l) New Source Review (172(c)(4)and (5); 182(a)(2)(C)) InfrastructureSIP (1 72(c)(7)) Subpart 2 Reasonably Available Control Technology for VOCs and NOx (1 82(b)(2), 182(f)) Periodic Inventory (1

82(a)(3)(A)) Emissions Statement Rule (1

82(a)(3)(B)) Offset Ratio (1 82(a)(4); 182(b)(5)) x

x

x

x

x
1.1 to 1 Attainment demonstration (1

82(b)(l)) Subpart 1 Reasonably Available Control Measures (172(c)(l)) Reasonable Further Progress (172(c)(2), 182(b)(l)) Contingency measures (1

72(c)(9)) Vehicle InspectionIMaintenance (1

82(a)(2)(B), (b)(4)) x

x

## IV. Evaluation of the lmperial County Modified Plan ARB staff has reviewed the lrnperial County 2009 Ozone Plan and the District's supporting technical analysis, and determined that the plan meets CAA SIP requirementsfor moderate ozone nonattainment areas. The following sections describe the major elements of the plan.


### A. Attainment of the 

### 1997 8-Hour Ozone Standard On February 19, 2009, ARB requested that U.S. EPA make a "clean data" finding for lmperial County. The request demonstrated that the area's 2008 design value for the 8-hour ozone NAAQS,which was based on monitoring data collected from 2006 through 2008, show attainment of the 1997 8-hour ozone NAAQS. On December

### 3, 2009, U.S. EPA published a clean data finding for lmperial County. Subsequent monitoring data show that the County continues to meet the 1997 8-hour ozone standard. Figure 2 illustrates the lmperial County ozone nonattainment area and monitoring locations. Figure2 shows the location 

### of routine ozone monitoring stations in lmperial County. The number of routine ozone monitoring sites in lmperial County exceeds the monitoring density required infederal regulations for a county of approximately 180,000 residents (40 CFR Part 58, Appendix D).Finure

### 2 Map of Imperial County and Monitoring Stations

6- Calexim East

Table 3 shows the Imperial County air monitoring stations design values for 2006 through 2009, representing 2004 through 2009 monitoring data. The design values for all of the monitoring sites are at or belowthe mandated 0.085 ppm threshold. The El Centro gthStreet and Westmorland started with the highest design values; both show a trend of improving air quality. The design values for the Niland and Calexico-East sites show slight upward trends, but in both cases are still well below the 19978-hour ozone standard. On the map above, a dot represents an air monitoring station.Table 3 Imperial Monitoring Station County Design Values (PP~)

Calexico East

Design values impacted by the deletionof June 2007 through October 2007 data due to monitoring irregularities. Pollution transport from Mexico contributed to high readings in some ozone exceedance days in Calexico, and possibly in some other Imperial County sites. The CAA allows the exclusion of concentrations caused by transport from another country inthe development of attainment demonstration plans. This plan does not utilize international transport exclusion since the clean data finding does not rely on the transport argument.



### B. Moderate NonattainmentArea Requirements As discussed earlier, U.S. EPA's clean data finding suspends certain SIP requirements. This section reviews the elements that the District submitted to fulfill the remaining moderate area nonattainment requirements. New Source Review and Offset Ratio Federal New Source Review (NSR) regulations are applied to the siting and modification of sources that are located in areas designated as federal nonattainment for NAAQS. The purpose of federal NSR is to ensure that ambient air quality does not deteriorate any further in nonattainment areas. Imperial's SIP-approved NSR rule, Rule 207, was adopted by the Imperial County Air Pollution Control Boardon November 10, 1980. The CAA requires moderate nonattair~ment areas to have offsets ratios of 1.I 

### 5 to 1. Rule 207 has a 1

### .I 5 to 1 offset ratio for ozone precursors. This rule and the offset ratio fulfill the requirements of the CAA.

### RACT Analysis The District completed its RACT analysis in a separate document (please refer to Section V). The Imperial CountyAir Pollution Control Board adopted the 2009 RACT SIP at the July 13, 2010, Board meeting.


### Emissions Inventory The precursors of ozone are oxides of nitrogen (NOx) and reactive organic gases (ROG). Mobile sources contribute the bulk of Imperial County's NOx emissions with heavy duty trucks clearly leading locomotives, and passenger vehicles as the top source (Table 4). Livestock waste, passenger vehicles, and pesticides constitute the top sourcesfor ROG emissions (Table 5). ROG and NOx emissions decreased significantly in these categories between 2002 and 2009, as did total emissions, as shown in Tables 4 and 5. The Emission Statement Rule requiresthe owner or operator of each stationary source that emits NOx or ROGto provide a statement for classes or categories of sources showing the actual emissions. The Imperial County Air Pollution Control Board adopted an Emissions Statement and Certification Rule on February 23, 2010. 

### Air Quality Planning Indeveloping this plan, the District held regularly scheduled SIP working group meetings that included various community representatives, health, environmental, and industry and military representatives, local and county governments, and state and federal agencies. The meetingswere initiated in March 2008 and ended in June 2009. The District also posted drafts of the 2009 Ozone Plan on their website throughout the process.Table 

### 4 ImperialCounty NOx Sources


### 11 lmnerial Countv

### - Ton Sourcesof NOx (tons ner davl 

### 11 

# 1) Rank (2002) 

## I Source Category 

## I 2002 

## 1 2009
I 1 

## I HEAVY DUTY DIESEL TRUCKS 

# 11 2 

### I LOCOMOTIVES 7 5

7 8 9



### 11 TOP 10 CATEGORIES PERCENTOFTOTAL 

### 1 96% 

### 1 95% 

### 11 10 

## I AGRICULTURAL IRRIGATION PUMPS TOP 10 CATEGORIESTOTAL TOTAL EMISSIONS

Numbers may notadd due to rounding "Top 10"categoriesare prioritized by2002 emissions MANUFACTURINGAND INDUSTRIAL (BOILERS, IC ENGINES) MANAGED BURNING AND DISPOSAL AIRCRAFT

Table 5 Imperial County ROG Sources 1 36 37

Imperial County -TopSources of ROG (tons per day) 

# 11 Rank l2OO2l 

### I Source Cate~orv 

### I 2002 

### 1 2009 1 1 1 1 31 32



### II 1 

### I LIVESTOCKWASTE 19 1.6 

### 11 2

2 

## I PASSENGER VEHICLES 17

## 1 

# 11 3 

### I PESTICIDES 3


### 11 6 

### I ASPHALT PAVING/ ROOFING 121211 

# 1

7 

## I CONSUMER PRODUCTS 111 

# 11 8 

### I AIRCRAFT 1112

# 11

9 

## I HEAVY DUTY DIESEL TRUCKS 111 

# 11 10 

### I RECREATIONALBOATS 1111 4



### 11 TOP 10 CATEGORIESTOTAL 

### 1 33 

### 1 27 

### 11 OFF-ROAD RECREATIONALVEHICLES 131 MANAGED BURNING AND DISPOSAL 

## I2l2

The District released the draft 2009 Ozone Plan and the 2009 RACT SIP on June 13, 2010 following several months of coordinated efforts between District staff and the SIP working group. The District released a notice of public hearing for the adoption of the 2009 Ozone Plan and associated negative declaration 30 days prior to its Board meeting, and held two public workshops to discuss both the 2009 Ozone Plan and 2009 RACT SIP. 

# 1

TOTAL EMISSIONS TOP 10 CATEGORIES PERCENTOFTOTAL Numbers may notadd due to rounding "Top I0 categoriesare prioritized by2002 emissions 3 7 87% 3 2 86%

### Air Pollution Transport Since lmperial County in effect shares an air basin with the Baja California city of Mexicali, ozone levels in southern part of the county are likely impacted by emissions from Mexico. The CAA allows states to demonstrate that an area

, would have attained the NAAQS by the applicable attainment date but for emissions emanating from outside of the United States (CAA section 179B(b)). lmperial County's 2009 Ozone Plan does not utilize the international transport provision since itwas not neededto demonstrate attainment of the 19978-hour ozone NAAQS. However, ARB has previously assessed the impacts of transported pollutants on violations of the State Ambient Air Quality Standard (SAAQS) for ozone, and determined that transport from Mexico can cause or contribute to high ozone levels in lmperial County. ARB, the local District, and U.S. EPA continue to coordinate on efforts to improve air quality and reduce transported pollutants throughout the border region. 

## V. 

## 2009 RACT SIP

Ozone non-attainment areas classified as moderate or above are required by CAA sections 182(b)(2)and 182(f)to implement RACT for sources subject to Control Techniques Guideline (CTG) documents and for all major sources of VOC and NOx that are not subject to a CTG. The 2009 RACT SIP fulfills CAA requirements for a moderate area, and ARB staff recommends that it be submitted as a SIP revision simultaneously with the 2009 Ozone Plan. The District worked closely with U.S. EPA and stakeholders as it prepared its RACT SIP. The District also released a public notice 30 days prior to its Board hearing, and held two workshops to discuss the draft 2009 RACT SIP. On July 13,2010, the lmperial County Air Pollution Control Board adopted the 2009 RACT SIP. 

## VI. Staff Recommendations
ARB staff has reviewed the lmperial County 2009 Ozone Plan for the lmperial County ozone nonattainment area, includingthe 2009 RACT SIP, and consulted with District staff during its review. ARB staff finds that the lmperial County 2009 Ozone Plan and 2009 RACT SIP meet all applicable CAA requirements for a moderate nonattainment area. Staff recommends that the Board adopt the lmperial County 2009 1997 8-Hol.~r Ozone Modified Air Quality Management Plan and 2009 Reasonably Available Cor~trol Technology State Implementation Plan, and direct the Executive Officer to submit them to U.S. EPA as proposed revisions to California's SIP.