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# T echnical S upport D ocument

Proposed Approval of PM 10 

## Maintenance Plan for Truckee Meadows and Redesignation of Truckee Meadows to Attainment for the PM 10 

## Standard



# Additional Supporting Information

for Notice of Proposed Rulemaking

USEPA, Region 9

September 11 , 201 5

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## Table of Contents

I. Best Available Control Measure de minimis demonstration

II. PM 10 

### from Secondary Particulates

III. Evaluation of the Motor Vehicle Emissions Budgets

IV. Explanation of 2011 Inventory Updates

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## I. de minimis Analysis for Best Available Control Measures (BACM)

Demonstration

Table 1. de minimis Analysis of Design Day Contribution

-- All Categories

Source Categorie s 1999

Seasonal Inventory (lbs/day) 1999

Peak Season Inventory Percentage 1 Design Day

Percentage 2 Design day

contribution 3 μg/m3 BACM measure

implemented

Paved streets/reentrained dust 12,031 42.7 66.3 142.5 040.031, 040.032

Street sanding 1,894 6.7 040.031

Residential wood combustion 6,804 24.1 16.9 36.2 040.051

Fugitive dust from construction

activities 2,860 10.1 7.0 15.1 040.030

Other Stationary/Industrial Processes 4 1,256 4.5

9.8 21.1 5.8 040.030 5

Concrete production 616 2.2 2.8 below de minimis

Charbroilers 214 0.8 1.0 below de minimis

Mobile on

- road 824 2.9 3.7 below de minimis

Mobile off

- road 653 2.3 3.0 below de minimis

Unpaved roads 515 1.8 2.3 040.030

Other Fuel Combustion and Misc Area 519 2.0 2.3 below de minimis

Totals 28,188 100.1 100.0 215.0 20.8

Notes:

1 Particulate Matter (PM10) State Implementation Plan for the Truckee Meadows Air Basin (Reno Planning Area) (“Serious Area Plan”), August 2002, Appendix B, Tables 1

- 2 and 1

- 3

2 Serious Area Plan, August 2002, Table 4 (see "Percent Contribution on Exceed ance Day")

3 215 μg/m 3 is the 1st high in 1999; Serious Area Plan, August 2002, Table 4 (see 24

- hour μg/m 3 )

4 Categories in “Other Stationary/Industrial Processes” include: Asphalt Production, Incinerators, Sand and Gravel Pits, Sand Blasting, Gold Mini ng/Assay Labs, Gypsum Wallboard M anufacturing , Miscellaneous.

5 Because the provisions of rule 040.030 apply to, but are not limited to: dismantling or demolition of buildings; public or pr ivate construction; mining; processing of sand, gravel, rock or d irt; and operation of machines or equipment, some of the source categories within Other Stationary/Industrial Processes would be regulated by rule 040.030. Totals affected by rounding convention.



### Explanation and Summary

The Truckee Meadows Serious Area PM 10 

### Plan provides a design day percentage for four categories: wood burning, re

- entrained road dust, construction, and industrial/vehicle exhaust/other combustion. See Table 4. To determine the source categories above and below the de minimis cutoff, we r elied on the 9.8 design day percentage for industrial/vehicle exhaust/other combustion (I/VE/OC) group to then determine the μg/m 3 

### contribution from the largest emitting sources within I/VE/OC group. To do this we used the percentage of the inventory (e.g ., 1999 Charbroilers inventory divided by the total 1999 inventory ) and

then multiplied the result times 9.8 μg/m 3 

### (i.e., the design day percentage for I/VE/OC ) . This provided an estimate of the μg/m 3 

### from the largest remaining I/VE/OC emitters to determin e if any were above the 5 μg/m 3 

### or greater threshold requiring BACM. Based on the analysis, all source categories contributing 5 μg/m 3 

### or greater on the design day have EPA

- approved, BACM

- level rules.

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## II. PM 10 

## from Secondary Particulates

The table below provides data comparing total PM 10 

### , ammonium nitrate, and ammonium sulfate measured at the Reno3 monitor (AQS

site # 32

- 031

- 0016). Comparing the data provides an estimate of the amount and fraction of PM 10 

### precursors in relation to total PM 10



### . The EPA choose 2011, 2013, and 2014 as representative years, and then selected the five highest PM 10 

### days with secondary particulate

data available. Because we are concerned primarily with the highest PM 10 

### days, o nly the five highest values above 50 μg/m 3 

### were

selected for each year. PM 10 

### values less than 50 μg/m 3 

### would have a disproportionate percentage of the PM 10 

### from secondaries.

. 

### For
2014, no days above 50 μg/m 3 

### occurred when speciation data was also collected. The results support EPA’s proposed determination that

PM 10 

### precursors do not contribute significantly to PM 10 

### levels which exceed the standard in the area.

Date Total PM 10 

### on Highest Days (November 1

– February 28 )

(μg/m 3 ) 

### Ammonium

Nitrate
(μg/m 3 ) 

### Ammonium

Sulfate
(μg/m 3 ) 

### Percent of

PM 10 

### from secondary particulates

Monitor Reno3 Monitor Galletti Plumbkit Sparks Reno3 South Reno Toll

1/12/2011 NA NA NA 64 NA NA 3.4 0.2 5.7%

12/26/2011 NA 71 NA 57 42 33 4.5 0.4 8.6%

1/21/2011 113 63 60 52 54 38 2.7 0.2 5.6%

1/6/2011 NA NA NA 51 NA NA 7.9 0.7 16.7%

1/15/2011 74 61 62 50 32 24 2.9 0.2 6.3%

12/18/2013 110 113 65 86 80 56 11.5 0.7 14.1%

12/13/2013 90 96 57 85 66 45 2.6 0.3 3.4%

12/17/2013 103 90 69 78 65 49 NA NA NA

12/27/2013 107 91 58 75 66 40 7.4 0.4 10.4%

12/31/2013 116 97 75 72 63 37 NA NA NA

1/7/2013 83 84 61 70 60 40 8.1 0.7 12.5%

1/8/2013 81 83 51 68 57 33 NA NA NA

1/22/2013 77 75 37 68 62 41 9.4 0.7 14.9%

NA: not available 

### Average (10 samples) 6.0 0.4 9.8%

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## III. Evaluation of the Motor Vehicle Emissions Budgets

Table 2

. Evaluation of the Motor Vehicle Emissions Budgets in Redesignation Request and Maintenance Plan for the Truckee

Meadows 24

- Hour PM 10 

### Non

- Attainment Area

, August 28, 2014 (“2014 PM 10 

### Plan” or “Plan”)

.

Adequacy Review Criteria (40 CFR part 93) Is Criterion

Satisfied? Reference in SIP Document/Comments

Sec. 93.118(e)(4)(i) The plan was endorsed by the

Governor (or designee) and was subject to a public hearing. Y The Redesignation Request and Maintenance Plan for the Truckee Meadows 24

- Hour PM

10 Non

- Attainment Area , August 28, 2014 (“2014 PM 10 Plan” or “Plan”) was noticed on July 25, August 11, and August 22, 2014 for public hearings on August 28, 2014 by the Washoe County District Board of Health (WCDBH). See

Reno Gazette

- Journal Proof of Publication (received by Washoe County

Controller on Au gust 27, 2014). The 2014 PM 10 Plan includes motor vehicle emissions budgets (MVEBs) for 2015, 2020, 2025, and 2030. WCDBH provided an opportunity for public comment prior to and during its August 28, 2014 hearing. The MVEBs were adopted as part of the 2014 PM 10 Plan by WCDBH on August 28, 2014. See Certificate of Adoption, WCDBH, dated August 28, 2014.

The 2014 PM 10 Plan was then submitted by the Nevada Division of Environmental Protection (NDEP) to EPA. See letter, Colleen Cripps, Administrator, NDEP, to J ared Blumenfeld, Regional Administrator, EPA Region 9, dated November 7, 2014, with enclosures, submitting the 2014 PM 10 Plan.

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Sec.
93.118(e)(4)(ii) The plan was developed through

consultation with federal, state and local agencies; full implementation plan documentation was provided and EPA’s stated concerns, if any,

were addressed. Y The 2014 PM 10 Plan and MVEBs were developed through consultation with federal, state and local agencies which participated in the Interagency Consultation Group. Members of the consultation group include: EPA, Regional Transportation Commission of Washoe County (the Me tropolitan Planning Organization for the area), Federal Highway Administration, NDEP, Nevada Department of Transportation, and Truckee Meadows Regional Planning Agency. Written and verbal comments provided by the EPA during the development of the

draft 201 4 PM 10 Plan and prior to the official public comment period immediately before adoption have been adequately addressed by the WCDBH. The EPA did not formally comment during the public comment period for the 2014 PM 10 Plan.

Sec.
93.118(e)(4)(iii) The motor vehicle emission budgets

are clearly identified and precisely quantified. Y The 2015, 2020, 2025, and 2030 budgets are clearly identified and precisely quantified in 2014 PM 10 Plan ( see p. 28).

Sec.
93.118(e)(4)(iv) The motor vehicle emissions

budget(s), when considered together
with all other emission sources, is consistent with applicable requirements for reasonable further

progress
, attainment , or maintenance (whichever is relevant to the given implementation plan submission)

. Y The EPA has d etermined that the MVEBs, when considered together with all other emission sources, are consistent with applicable requirements for

maintenance of the PM 10 National Ambient Air Quality Standard. The MVEBs include a safety margin which is explained on page 28 of the Plan. The safety margins were included in the emissions estimates used in the maintenance demonstration. Also see page 28 of the Plan.

The Plan does not include MVEBs for NO

x and VOC because the District demonstrated, based on information in the Desert Research Institute’s February 1988 report, PM 10 Source Apportionment the Truckee Meadows, Nevada, for State Implementation Plan Development, Volume I: Modeling Methods and Results, Final Report, and recent air quality data showing secondary particulates comprise a small fraction of the total PM 10 that secondary particulates formed by precursor emissions are an insignificant contributor to PM 10 levels. The EPA

concludes that PM 10 precursor emissio ns do not contribute significantly to PM 10 levels which exceed the standard in the Truckee Meadows area.

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Sec.
93.118(e)(4)(v) The plan shows a clear relationship

among the emissions budget(s),

control measures and the total emissions inventory. Y The emission inventories for all point, non

- point, on

- road mobile, and non

- road

mobile sources of direct PM 2.5 are described in Appendix C of the 2014 PM 10 Plan. Adopted control measures are described in Chapter 4, Appendix A, and Appendix B of the 2014 PM 10 P lan. The budgets are described in Chapter 6 of the

2014 PM 10 Plan. The budgets are consistent with the inventories in Appendix C that is relied on for the maintenance demonstration in Chapter 6 of the 2014 PM 10 Plan.

Sec.
93.118(e)(4)(vi) Revisions to previously submitted

control strategy or maintenance plans explain and document any changes to any previous submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins (see §93.101 for defin ition), and reasons for the changes (including the basis for any changes to emission

factors or estimates of vehicle miles traveled). Y On July 13, 2009, the NDEP submitted the Redesignation Request and Maintenance Plan for the Truckee Meadows 24

- Hour PM 10 Non

- Attainment Area (“2009 PM 10 Plan”) to EPA as a revision to the Nevada SIP. The 2009 PM 10 Plan

established MVEBs f

o r 2009, 2013, 2018, and 2020 , and the budgets included safety margins

. The EPA found the MVEBs in the 2009 PM 10 Plan adequate , 75

FR 27776 (May 18, 2010), but did not take action on the plan.

The 2014 PM 10 Plan supersedes the 2009 P M 10 Plan and includes amended

emissions inventories

, maintenance demonstration, and MVEBs (including amended safety margins)

. . The Washoe County Air Qualit y Management Division (WCAQMD) provides documentation for the amended emissions inventories, maintenance demonstration, and MVEBs (and safety margins) in chapter 6 and appendi ces A

, B , and C of the 2014 PM 10 plan and in the 2011 Periodic Emissions Inventory. Among other changes, t he MVEBs in the 2014

PM 10 Plan reflect updated vehicle activity forecasts prepared by the Regional Transportation Commission, an updated emissions factor model (MOVES), updated paved road fugitive dust emissions factors published by EPA (in AP

- 42, section 13.2.1.3 (dated January 2011), and a locally

- developed silt content value (instead of using a default value) for use in calculating PM 10 from vehicle travel on unpaved roads.

Sec.
93.118(e)(5) EPA has reviewed the State’s

compilation of public comments and response to comments that are required to be submitted with any implementation plan. Y Prior to and during the hearing on the 2014 PM 10 Plan, WCDBH received only one public comment, and it was supportive of adoption of the Plan. The comment, from the Regional T ransportation Commission, was included in the Plan submittal. No issues that might have affected our approval of the budgets

were raised by the public.

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## IV. Explanation of 2011 Inventory Updates

The table below explains the reasons for changes to 2011 emissions inventory when comparing the 2011 Periodic Emissions Inventory (dated November 2012) with the 2011 Emissions Inventory in the Appendix C of the Redesignation Request and Maintenance Plan for

the Truckee Meadows 24

- Hour PM 10 

### Non

- Attainment Area (“2014 Plan”) (dated August 28,

2014 ).

Source Category 

### 2011 Emissions
(lbs/day)


### Explanation 3

2014

Plan 1 2012 NEI

submittal 2 Difference

Paved Road Fugitive

Emissions 1,453 3,820 2,367 Predictive Emission Factor equations from

AP

- 42, section 13.2.1.3, updated January

2011.

Unpaved Road Fugitive

Emissions 2,623 13,540 10,917 Recalculated using updated silt loading factors (comparing states/local agencies with similar climate/geography) and applied extra control measures (projected road paving),

based on guidance/direction from Karina O'Connor during the SIP development

process.

On

- Road Mobile 1,183 1,568 385 The Regional Transportation

Commission updated VMT (e.g., from economic impacts)

, used new traffic demand

model (i.e., TransCAD instead of EMMA)

, and then ran new forecast.



### Notes:

1 

### 2014 Plan

, Appendix C

, August 28, 2014

.

2 

### 2011 Periodic Emissions Inventory

, Washoe County, Nevada

, November 2012

.

3 

### For paved road fugitive emissions, see 2014 Plan, Appendix B.2. For unpaved road fugitive and on

- road mobile emissions, see September 2, 2015, email from Yann Ling

- Barnes, Washoe County Health District to John Ungvarsky, USEPA Region 9.