STATE IMPLEMENTATION PLAN REVISION 

TO AMEND 401 KAR 59:174

STAGE II CONTROLS AT GASOLINE DISPENCING

FACILITIES 

BOONE, CAMPBELL, & KENTON COUNTIES, KENTUCKY 

Prepared by the 

Kentucky Division for Air Quality 

Submitted by 

Kentucky Energy and Environment Cabinet 

May 2016 
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TABLE OF CONTENTS

INTRODUCTION ........................................................................................................................................................ 1 

BACKGROUND .......................................................................................................................................................... 1 

STAGE II VAPOR RECOVERY RULE AND ORVR CONTROLS .......................................................................... 2 

WIDESPREAD USE .................................................................................................................................................... 2 

CLEAN AIR ACT PROVISIONS ................................................................................................................................ 3

EMISSIONS CALCULATIONS .................................................................................................................................. 4 

DECOMISSIONING PROVISIONS ........................................................................................................................... 5 

CONCLUSION ............................................................................................................................................................ 6

PUBLIC PARTICIPATION ......................................................................................................................................... 6 

TABLES

TABLE 1. INCREMENTAL BENEFIT OF MAINTAINING STAGE II VRS IN THE NORTHERN 

KENTUCKY, CINCINNATI- HAMILTON MSA WITH ORVR PHASE-IN ........................................ 5 

TABLE 2. NORTHERN KENTUCKY PORTION OF NATIONAL GASOLINE CONSUMPTION ...................... 5 

TABLE 3. PROJECTED GASOLINE CONSUMPTION OF THE NORTHERN KENTUCKY AREA ................... 5

TABLE 4. VOC EMISSIONS INVENTORY WITH STAGE II VRS COMPARED TO VOC EMISSIONS 

INVENTORY WITH ONLY ORVR ......................................................................................................... 6

APPENDICES

Appendix A – Federal Registers 

Appendix B – Emissions Calculations 

Appendix C – 401 KAR 59:174 as Amended 

Appendix D – Notice of Public Hearing & Response to Comments
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INTRODUCTION

This document contains technical support for the Kentucky Division for Air Quality’s (Division) 

request to revise Kentucky’s State Implementation Plan (SIP) by amending 401 KAR 59:174 to 

remove Stage II controls from gasoline dispensing facilities (GDF). This submittal demonstrates 

that removing Stage II equipment from GDF’s in Northern Kentucky will not deteriorate the 

area’s air quality and that over time, the removal of Stage II will prevent an increase in volatile 

organic compound (VOC) emissions due to the incompatibility of Stage II equipment and OnBoard Refueling Vapor Recovery (ORVR) systems. This plan focuses on VOC emissions, a 

precursor in ozone formation, from facilities in the Cincinnati-Hamilton, OH-KY-IN, 

Metropolitan Statistical Area (MSA) which was previously designated as Moderate 

Nonattainment for the 1-hour Ozone National Ambient Air Quality Standards (NAAQS). 

BACKGROUND

On November 6, 1991, the Environmental Protection Agency (EPA) designated the CincinnatiHamilton OH-KY-IN, MSA as Moderate nonattainment for the 1-hour Ozone National Ambient 

Air Quality Standards (NAAQS). This nonattainment area included the Kentucky counties of 

Boone, Kenton and Campbell. Section 172(a)(2) of the Clean Air Act (CAA) requires each state 

with areas failing to meet the NAAQS to develop SIPs to expeditiously attain and maintain the 

standard. For areas that are designated as a moderate, serious, or severe nonattainment for the 

ozone NAAQS, states are required to submit revisions to the SIP that include a plan for reducing 

emissions of VOCs by 15 percent from the 1990 Adjusted Base Year Emissions Inventory. 

States that were moderate nonattainment for the 1-hour Ozone NAAQS were required to attain 

the ozone NAAQS by 1999. 

Kentucky submitted a 15 Percent Plan to EPA on March 21, 1994 however, by the end of the 

1994 ozone season, the monitoring data for the entire Cincinnati area indicated attainment of the 

ozone NAAQS. Subsequently Kentucky submitted a request to redesignate the area to 

attainment. EPA determined that the 15 Percent Plan was not necessary at that time since the 

area had attained the standard. Therefore, Kentucky requested that EPA take no further action 

on the proposed reduction plan. The Cincinnati area monitoring data recorded a violation during 

the 1995 ozone season which prompted EPA to deny Kentucky’s request to redesignate the area 

to attainment, thereby making the 15 percent plan an applicable requirement for the area. 

On September 11, 1998, Kentucky submitted a 15 Percent Plan to EPA for the Northern 

Kentucky area. The submittal not only established the necessary reductions required to meet the 

1999 target level, it also provided control strategies that would be implemented to assure that 

progress towards the target level would be effective. Stage II requirements were established as 

one of the provisions used to meet the required 15 percent reduction. Kentucky adopted 401 

KAR 59:174, Stage II Controls at Gasoline Dispensing Facilities on January 12, 1998 and the 

regulations became part of Kentucky’s SIP on February 8, 1999 (63 FR 67586). The regulation 

applies to 140 facilities in Northern Kentucky that have an average monthly throughput of more 

than 10,000 gallons/month. The vast majority of Northern Kentucky facilities (138/140) are 

equipped with vacuum assist Stage II VRS controls. The Cincinnati-Hamilton, OH-KY-IN 
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nonattainment area was redesignated to attainment for the 1-hour ozone standard on July 5, 2000 

(65 FR 37879). 

STAGE II VAPOR RECOVERY RULE AND ORVR CONTROLS

VOCs are emitted from the refueling of gasoline vehicles and trucks at gasoline dispensing 

facilities (GDF). When gasoline is pumped into a vehicle, the empty space in the tank has 

gasoline vapors that are forced out of the tank. With Stage II vapor recovery systems (VRS), 

instead of being emitted into the air, those vapors are directed into the underground storage tank 

(UST). 

There are two types of Stage II VRS controls. The first is a balance type of Stage II system. A 

balance system has a rubber boot around the gasoline nozzle spout that fits snugly up to a 

vehicle’s fill pipe. When the gasoline is pumped into the vehicle, an increase in pressure in the 

vacant space of the vehicle gas tank, combined with a slight decrease in pressure in the UST 

from emptying fuel, forces the gasoline vapors from the tank, through the fill pipe into the UST. 

The second is a vacuum assist system that uses a vacuum pump on the vapor return line to help 

draw the vapors from the vehicle fill pipe into the UST. 

ORVR is a vehicle emission control system that captures fuel vapors from the vehicle gas tank 

during refueling on the vehicle itself. With ORVR, the gas tank and fill pipe are designed so that 

when refueling the vehicle, fuel vapors in the gas tank travel to an activated carbon packed 

canister, which adsorbs the vapor. To prevent vapors from escaping through the fill pipe 

opening, a seal in the fill pipe allows liquid gasoline to enter, but blocks the vapors from 

escaping. When the engine is in operation, it draws the gasoline vapors into the engine intake 

manifold to be used as fuel. 

ORVR was first required for all passenger cars starting with model year 2000. Since 2006, all 

light-duty trucks, sports utility vehicles, and medium-duty vehicles are required to be equipped 

with ORVR. 

According to the federal register promulgated on May 16, 2012, “Stage II and ORVR emission 

control systems are redundant, and the EPA has determined that emission reductions from 

ORVR are essentially equal to and will soon surpass the emission reductions achieved by Stage 

II alone” (77 FR 28772). Where ORVR has been demonstrated to be in “widespread use,” Stage 

II is unnecessary and even incompatible. Incompatibility refers to excess emissions resulting 

from Stage II VRS and ORVR being used together because the two emission controls together 

result in extra venting of VOCs from the underground storage tank into the ambient air. This can 

lead to an increase in emissions. Studies, including one conducted by the California Air 

Resources Board (CARB), further indicate that incompatibility between the vacuum assist 

version of the Stage II VRS and ORVR degrade the benefit of keeping the Stage II VRS (CARB, 

June 1999). This incompatibility is especially important in Kentucky, given the high proportion 

of facilities with vacuum assist versions of the Stage II VRS controls. 
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WIDESPREAD USE 

Section 202(a)(6) of the CAA details that the EPA can revise or waive the Section 182(b)(3) 

Stage II vapor recovery requirement for applicable ozone nonattainment areas after the 

Administrator determines widespread use of ORVR has been demonstrated throughout the motor 

vehicle fleet. EPA has considered demonstration of widespread use of ORVR in motor vehicle 

fleets to include: 

1) Determining the percentage of ORVR-equipped vehicles in service, and 

2) Determining when VOC emissions resulting from the application of ORVR 

controls alone equal the VOC emissions when both Stage II vapor recovery 

systems (VRS) and ORVR controls are used. 

Stage II VRS control efficiency is assumed by EPA to be 86 percent from the MOVES 2010b 

default database (77 FR 28772). The percentage of gasoline pumped into vehicles from GDFs 

with Stage II control is estimated by EPA to be 90 percent as per EPA guidance. By multiplying 

these two numbers, the expected area-wide control efficiency of Stage II VRS is 77.4 percent. 

A policy memorandum published by EPA entitled, “Removal of a Stage II Vapor Recovery in 

Situations Where Widespread Use of Onboard Refueling Vapor Recovery is Demonstrated,” 

determined that if at least 95% of the vehicles in a fleet have ORVR, then widespread use will 

likely have been demonstrated. Because the percentage of vehicles without ORVR is decreasing 

on a yearly basis and the amount of gasoline pumped to these vehicles is decreasing as well, EPA 

could predict a date for ORVR widespread use. EPA considered two different approaches. They 

first looked at the assumed 98 percent control efficiency of ORVR (77 FR 28775 and EPA 

guidance), and then used the Motor Vehicle Emissions Simulator (MOVES) 2010 motor vehicle 

emissions model to determine the number of vehicles with ORVR projected out to the year 2020. 

EPA’s table “Projected Penetration of ORVR in the National Vehicle Fleet by Year – Based on 

MOVES 2010” is located in Appendix A (77 FR 28776). Overall ORVR efficiency was 

determined by multiplying the fraction of gasoline dispensed into vehicles with ORVR by the 

assumed 98 percent average in-use control efficiency. Using this approach, ORVR control 

efficiency reached the equivalent Stage II VRS control efficiency of 77.4 percent by May 2013 

(77 FR 28778). The second approach used observations from the first approach to determine that 

by the end of the calendar year 2012; more than 75 percent of gasoline will be dispensed into 

vehicles with ORVR, resulting in an overall ORVR control efficiency close to the Stage II VRS 

control efficiency and allowing for a phased-in approach to ORVR. Further information on 

EPA’s approach for determining widespread use can be found in EPA’s determination (77 FR 

28772) and its proposal published in the Federal Register on July 15, 2011 (76 FR 41731). 

 

CLEAN AIR ACT PROVISIONS

EPA can only propose approval of a SIP revision seeking to discontinue an existing SIPapproved Stage II control program if the SIP revision meets the following CAA provisions: 

 The requirements of 110(l), 

 The requirements of CAA, Section 193 for any current nonattainment area that adopted a 

Stage II control program into its SIP prior to November 15, 1990, and 
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 The requirements of CAA, Section 184(b)(2) which applies to any area of the northeast 

ozone transport region (OTR). 

Kentucky is not a part of the northeast OTR and, therefore, CAA Section 184(b)(2) does not 

apply. Additionally, since Kentucky adopted its Stage II Vapor Recovery Program into its SIP 

on December 9, 1998 (63 FR 67586), CAA, Section 193 also does not apply. Therefore, the 

remainder of this section includes a detailed description of the requirements of CAA, Section 

110(l). 

110(l) 

Section 110(l) of the CAA, governs EPA’s ability to approve all SIP revisions. Specifically, 

Section 110(l) states: 

Each revision to an implementation plan submitted by a State under this chapter shall be 

adopted by such State after reasonable notice and public hearing. The Administrator shall not 

approve a revision of a plan if the revision would interfere with any applicable requirement 

concerning attainment and reasonable further progress (as defined in Section 171 of this title), 

or any other applicable requirement of this chapter. 

This SIP revision uses the analysis provided by EPA’s “Guidance on Removing Stage II 

Gasoline Vapor Control Programs from State Implementation Plans and Assessing Comparable 

Measures” to demonstrate that removing Stage II vapor recovery controls by amending 401 KAR 

59:174 will not interfere with attainment, reasonable further progress or any other requirement of 

the Clean Air Act. 

EMISSIONS CALCULATIONS

This section summarizes the results of the emissions calculations located in Appendix B. Using 

methods described in EPA’s Guidance Document, this submittal demonstrates that the emission 

control gain, identified in the guidance as the “increment” (or incremental benefits), of Stage II 

VRS controls decreases as ORVR controls are phased-in. The calculations provided in 

Appendix B show that the incremental benefit of keeping Stage II VRS controls as ORVR 

controls are phased-in is an ever decreasing benefit, which eventually becomes a disbenefit. 

Additionally, Section 110(l) of the CAA requires that a SIP revision does not interfere with any 

applicable requirement concerning attainment, and reasonable further progress (as defined in 

CAA, Section 171). Kentucky regulation 401 KAR 59:174 became effective March 4, 2016. 

Table 1 below demonstrates that the decommissioning of Stage II VRS at GDF in 2016 will not 

create an emissions increase. The impact on the area-wide VOC inventory has been calculated 

and evaluated to show that it is consistent with Section 110 (l). 

Table 1 demonstrates the Stage II in-use control efficiency at 67.5%. The table includes the year 

with the latest available data, 2014, along with each subsequent year projected out to 2020. For 

2016, the far right column, “% increase when Stage II removed,” has a negative percentage. 

This suggests the operation of the Stage II systems would start resulting in a negative impact on 

emissions for that particular year due to the increased ORVR vehicle fleet population in the area. 
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By keeping the area’s overall Stage II program in operation, it would make the air quality worse. 

Therefore, the year in which this negative percentage first appears would be the year to start the 

decommissioning of Stage II systems in northern Kentucky. Further explanation of the terms 

and calculations can be found in Appendix B. 

Table 1 Incremental benefit of maintaining Stage II VRS in the Northern Kentucky, CincinnatiHamilton MSA with ORVR phase-in. 

Years QSII QORVRi ηiuSII

* QSIIva CFi ηORVR i % Increase when 

Stage II removed 

2014 0.875 0.8293 0.675 0.986 0.0644 0.98 0.0373 3.73% 

2015 0.875 0.8650 0.675 0.986 0.0672 0.98 0.0135 1.35% 

2016 0.875 0.8860 0.675 0.986 0.0688 0.98 -0.0005 -0.05% 

2017 0.875 0.9030 0.675 0.986 0.0702 0.98 -0.0119 -1.19% 

2018 0.875 0.9190 0.675 0.986 0.0714 0.98 -0.0225 -2.25% 

2019 0.875 0.9320 0.675 0.986 0.0724 0.98 -0.0312 -3.12% 

2020 0.875 0.9430 0.675 0.986 0.0733 0.98 -0.0386 -3.86% 

 *ηiuSII = 67.5% Stage II In-Use Control Efficiency

Table 2 below shows the Northern Kentucky area’s consumption of gasoline. The data was 

compiled using EPA’s guidance document and the Federal Highway Administration website. 

Table 2 Northern Kentucky Portion of National Gasoline Consumption 

Year 

NKY Portion of Total 

National Gasoline 

Consumption 

Total National Gasoline 

Consumption 

May – September (gallons) 

NKY Consumption 

May – September 

(gallons) 

2014 0.001299 59,345,592,000 77,089,924 

Table 3 Projected Gasoline Consumption of the Northern Kentucky Area 

Year 

NKY Consumption 

May – September 2014 

(gallons) 

Projected Ratio for 

Gasoline Consumption 

Growth 

Projected Gasoline 

Consumption of NKY 

Nonattainment Area 

(gallons/season) 

2014 77,089,924 N/A N/A 

2017 77,089,924 1.0404 80,204,357 

2020 77,089,924 0.9710 74,854,316 

Table 4 shows the gasoline consumption for the Northern Kentucky area for the years 2014, 

2017 and 2020. The data was established by using a projected ratio for gasoline consumption 

from the Department of Energy’s EIA Annual Outlook – Liquid Fuels Supply and Disposition. 
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Table 4 VOC Emissions Inventory with Stage II VRS Compared to VOC Emissions Inventory 

with only ORVR 

Year 

VOC Base Year 

Emissions in (tpd) 

(2011 Base Year) 

VOC Emissions 

with Stage II VRS 

Controls in Place 

(tpd) 

VOC Emissions 

with Stage II 

VRS Removed 

(tpd) 

VOC Emissions 

Difference Between 

Stage II VRS In 

Place and Removed 

Incremental Benefit 

(tpd) 

2011 8.47 8.47 N/A N/A 

2014 8.47 6.50 6.29 -0.21 

2017 8.47 5.03 4.88 -0.15 

2020 8.47 3.54 3.44 -0.10 

Table 4 above compares VOC emissions with continued implementation of Stage II VRS to 

VOC emissions with only ORVR controls in place when projected to 2020 using the 2011 base 

year inventory. The 8.47 tpd is representative of the on-road mobile source emissions only. This 

table determines that the removal of Stage II VRS requirements will result in a decrease in motor 

vehicle VOC emissions and therefore satisfies the requirement in section 110(l), not to interfere 

with any applicable requirement concerning attainment and reasonable further progress or any 

other applicable requirement. 

DECOMMISSIONING PROVISIONS

Included in the amendment of the regulation is the process of decommissioning the Stage II VRS 

controls in such a way that it is done in a safe and environmentally appropriate manner. The 

owner/operator will follow the decommissioning process as amended in 401 KAR 59:174. 

These decommissioning procedures follow PEI/RP300-09 recommended practices related to 

capping and sealing vapor recovery underground piping and vapor recovery dispenser piping, 

and the associated tests in recommended practices. 

Facilities can begin decommissioning January 1, 2016. There is no schedule for facility 

decommissioning, only the requirement that all facilities must have decommissioning completed 

by December 31, 2018. 

401 KAR 59:174 has been amended to include these requirements pertaining to the 

decommissioning of the Stage II VRS equipment and can be found in Appendix C. 

CONCLUSION

The Energy and Environment Cabinet is requesting the approval of the SIP revision to 

implement the amended regulation 401 KAR 59:174, decommissioning and removal of 

requirements for Stage II vapor recovery systems. The SIP demonstrates that the removal of 

Stage II VRS controls at gasoline dispensing facilities in Northern Kentucky will result in VOC 
7 

emission reductions beginning in 2016. This request to remove Kentucky’s Stage II VRS 

controls is based on EPA’s August 7, 2012 Guidance Document, “Guidance on Removing Stage 

II Gasoline Vapor Control Programs from State Implementation Plans and Assessing 

Comparable Measures”. Section 202(a)(6) of the CAA gives EPA discretionary authority to 

revise or waive the Section 182(b)(3) Stage II requirement by rule after the Administrator 

determines that ORVR is in widespread use throughout the motor vehicle fleet. EPA can 

propose approval of a SIP revision seeking to discontinue an existing SIP-approved Stage II 

control program if Kentucky’s SIP revision meets the requirements of 110(l). The Division 

demonstrates in this SIP revision that removal of Stage II controls by amendment of 401 KAR 

59:174 in Kentucky’s SIP is consistent with Section 110(l) of the Clean Air Act (CAA) and will 

not interfere with the attainment of the NAAQS, reasonable further progress towards attainment, 

or any other applicable requirements. 

PUBLIC PARTICIPATION

In accordance with 40 CFR 51.102, a public hearing was held at the Division for Air Quality 

offices located at 200 Fair Oaks Lane, Frankfort, KY on April 29, 2016. The only comments 

received during the public comment period were from EPA. A copy of the public hearing notice 

and response to comments can be found in Appendix D. 
COMPLETENESS CRITERIA FOR SIP SUBMITTALS – 

40 CFR PART 51 APPENDIX V

To ensure completeness of this SIP revision submittal, the following elements detailed in 40 

CFR Part 51, Appendix V are listed: 

A. ADMINISTRATIVE MATERIALS: 

1. A formal letter of submittal from the Governor or his designee, requesting EPA 

approval of the plan or revision. 

The cover letter dated May 3, 2015 signed by Secretary Charles G. Snavely, the Governor’s 

designee requests EPA’s approval of the SIP revision to amend 401 KAR 59:174 Stage II 

Controls at Gasoline Dispensing Facilities. 

2. Evidence that the State has adopted the plan in the State code or body of regulations; or 

issued the permit, order, consent agreement in final form. That evidence shall include 

the date of adoption or final issuance as well as the effective date of the plan, if different 

from the adoption/issuance date. 

The Commonwealth of Kentucky is submitting this document to request 401 KAR 59:174 be 

amended to the SIP. The regulation became effective on March 4, 2016. The effective date of 

the plan should be the date of the SIP revision submittal, May 3, 2016. 

3. Evidence that the State has the necessary legal authority under State law to adopt and 

implement the plan. 

The powers and duties of the Cabinet established in KRS 224.10-100 provide the Energy and 

Environment Cabinet with the statutory authority to prepare and develop a comprehensive plan 

or plans related to the environment of the Commonwealth. Additionally, KRS 224.10-100 

requires the cabinet to administer and enforce all rules, regulations and orders promulgated 

under Chapter 224, Environmental Protection, including those regulations that provide for the 

prevention, abatement, and control of all air pollution. 

4. A copy of the actual regulation, or document submitted for approval and incorporation 

by reference into the plan, including indication of the changes made to the existing 

approved plan, where applicable. The submittal shall be a copy of the official State 

regulation/document signed, stamped, dated by the appropriate State official indicating 

that it is fully enforceable by the State. The effective data of the regulation/document 

shall, whenever possible, be indicated in the document itself. 

A copy of 401 KAR 59:174 along with the approved changes is provided within Appendix C. 

5. Evidence that the State followed all of the procedural requirements of the State’s laws 

and constitution in conducting and completing the adoption/issuance of the plan. 

The procedural requirements associated with this plan and public comment period are 

included in the submittal to EPA. 
6. Evidence that public notice was given of the proposed change consistent with 

procedures approved by EPA, including the date of publication of such notice. 

In accordance with 40 CFR 51.102, the Cabinet provided notice for the opportunity to submit 

written comments and to allow the public the opportunity to request a public hearing. A 

copy of the public hearing notice published on the Division’s website is included in 

Appendix D. A public hearing was held at the Division for Air Quality offices located at 200 

Fair Oaks Lane, Frankfort, Kentucky on April 29, 2016. The only comments received during 

the public comment period were from EPA. The Division’s response to those comments are 

located in Appendix D. 

7. Certification that public hearing(s) were held in accordance with the information 

provided in the public notice and the State’s laws and constitutions, if applicable. 

A public hearing notice was posted on the Division’s website and sent to members of the 

community. This notice detailed that the public had 30 days to provide comment and that a 

public hearing would be held on April 29, 2016, listing the time and location. The SIP 

revision document was made available for public review on the Division’s website 

throughout the 30 day review period. 

8. Compilation of public comments and the State’s response thereto. 

All comments along with the Cabinet’s responses are available in Appendix D. 

B. TECHNICAL SUPPORT: 

1. Identification of all regulated pollutants affected by the plan. 

The appropriate pollutant(s) have been identified within the narrative consistent with EPA’s 

guidance. 

2. Identification of the locations of affected sources including the EPA 

attainment/nonattainment designations and the status of the attainment plan for the 

affected area(s). 

This plan focuses on the Cincinnati-Hamilton, OH-KY-IN, Metropolitan Statistical Area 

(MSA) which was previously designated as Moderate Nonattainment for the 1-hour Ozone 

National Ambient Air Quality Standards (NAAQS). 

3. Quantification of the changes in plan allowable emissions from the affected sources; 

estimates of changes in current actual emissions from affected sources or, where 

appropriate, quantification of changes in actual emissions from affected sources 

through calculations of the differences between certain baseline levels and allowable 

emissions anticipated as a result of the revision. 
Quantification and changes in emissions are discussed within the Emissions Calculation 

Section of this submittal. 

4. The State’s demonstration that the national ambient air quality standards, prevention 

of significant deterioration increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved and implemented. For all 

requests to redesignate an area to attainment for a national ambient air quality 

standard, under section 107 of the Act, a revision must be submitted to provide for the 

maintenance of the national primary ambient air quality standards for at least 10 years 

as required by section 175A of the Act. 

This is addressed in the Clean Air Act Provisions Section of this submittal. 

5. Modeling information required to support the proposed revision, including input data, 

output data, models used, justification of model selections, ambient monitoring data 

used, meteorological data used, justification for use of offsite data (where used), modes 

of models used, assumptions, and other information relevant to the determination of 

adequacy of the modeling analysis. 

 

6. Evidence, where necessary, that emission limitations are based on continuous emission 

reduction technology. 

This is not applicable to this submittal. 

7. Evidence that the plan contains emission limitations, work practice standards and 

recordkeeping/reporting requirements, where necessary, to ensure emission levels. 

These elements are consistent with EPA’s guidance. 

8. Compliance/enforcement strategies, including how compliance will be determined in 

practice. 

Compliance and enforcement strategies have been addressed in the regulatory changes being 

amended to the SIP. 

9. Special economic and technological justifications required by any applicable EPA 

policies, or an explanation of why such justifications are not necessary. 

Economic and technological justifications are consistent with EPA’s guidance. 
Appendix A 

Federal Registers