### ATTACHMENTS

Attachment 1: Evidence the state has adopted the revision

1.1 Staff Report, Agenda Item I of the December 9

- 10 , 201 5 EQC meeting

Also see the Certificate and Order for Filing Permanent Administrative Rules in Attachment 4 .2

Attachment 2: Evidence that the state has the necessary legal authority

For the legal authority, see page 5 of Attachment 1.1

Attachment 3 : Provisions submitted for approval

3.1 Amended rules submitted to Secretary of State e ffective December 1 0
, 2015 : O AR 340

- 200

- 0040 *

3.2 Redline strikeout version of amended rules submitted to Secretary of State e ffective December 1 0 , 2015: OAR 340

- 200

- 0040 *

3.3 Medford Limited Maintencance Plan for CO incorporated into Oregon’s State Implementation Plan with the submitt al of amended OAR 340

- 200

- 0040* to Secretary of State effective December 10, 2015

*Denotes rules that are not included in the State of Oregon Clean Air Act State Implementation Plan but are being submitted to show a complete account of the rulemaking package.

Attachment 4 : Evidence that the state followed the Administrative Procedures Act

4 .1 Public notice in the Secretary of State's Oregon Bulletin, September 1, 2015 , publication

4 .2 Certificate and Order for Filing Permanent Administrative Rules, filed and effective December 1 0 , 201 5

Attachment 5 : Evidence of adequate public notice
5.1 Affidavit s of Publication August 1 4 , 201 5 :
Th e Oregonian Medford Mail TribuneAttachment 6 : Certification of public hearing For certification of the public hearing, see the cover let ter and page 10 of Attachment 1.1

Attachment 7 : Compilation of public comment and department's response For the Presiding Officer's record for rulemaking hearings, see page 1 0 of Attachment 1.1 For the Summary of comments and DEQ responses, see page 1 2 of Attachment 1.1

### Attachment 1

Evidence the state has adopted the revision

1.1 Staff Report, Agenda Item I of the December 9

- 1 0 , 201 5 EQC meeting

Also see the Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2Staff Report page | 1 

### Oregon Department of Environmental Quality Dec. 9, 2015 Oregon Environmental Quality Commission Meeting Rulemaking Action Item I

Medford Carbon Monoxide Limited Maintenance Plan



### DEQ recommendation to the EQC

DEQ recommends that the Environmental Quality Commission:

1. Approve the limited maintenance plan for Medford, included with this staff repo rt as attachment B, as part of c hapter 340 of the Oregon Administrative Rules. 2. Adopt the proposed rules in Attachment A as part of chapter 340 of t he Oregon Administrative Rules; 3. Approve incorporating these rule amendments into the Oregon Clean Air Act State Implementat ion Plan under OAR 340

- 200

- 0040; 4. Direct DEQ to submit the SIP revision to the U.S. Environmental Protection Agency for approval.Staff Report page | 2 

### Overview

In the 1970s and 1980s the Medford area violated the national air quality standard for carbon monoxide (CO). State and federal regulations applied measures that reduced CO concentrations and in 2002 the EPA redesignated Medford as meeting the CO standard. The redesignation included approval of the first Medford CO Maintenance Plan which demonstrated how the area would continue to meet the standard in the coming decade. EPA required the plan to include a budget for the amount of CO that vehicles operating on the future highway system could emit in coming decades. Each time a new transporta tion plan is adopted, planners must show that estimated CO emissions from the new highway system will remain within the budgeted amount.

A second CO maintenance plan is now due under the Clean Air Act to address how the area will
cont inue to meet the CO standard through September 23, 2022, the final maintenance plan period. In addition, DEQ recently discovered that the instructions by EPA’s consultant for calculating the motor vehicle emissions budget in the original plan were incorrect and the budget was set too low

. When future vehicle emissions are estimated and compared to the emissions budget, they exceed the allowable amount. This error prevents Medford from adopting a new transportation plan under the original maintenance plan . The situation can be corrected by revising the budget in the original plan or by adopting a new CO maintenance plan. Since a second CO maintenance plan is already due , a new plan is the preferred way of correcting the error.

CO monitoring was disconti nued in Medford in 2009 because CO levels were well below the federal CO health standard , which is 27 percent of the federal CO limit. 1 This low level of CO allows Medford to use the streamlined requirements of a “limited maintenance plan.” Under these
str eamlined requirements, a vehicle emissions budget is no longer required when preparing future transportation plans.

DEQ, in consultation with EPA and the Rouge Valley Metropolitan Planning Organization ( RVMPO ) , proposes this new limited maintenance plan as the most efficient way to ensure continued compliance with the CO standard while support ing Medford’s transportation planning process and schedule. A significant benefit of the proposed limited maintenance plan is that an

e missions budget is no longer needed and the RV MPO can demonstrate conformity without a regional analysis. DEQ estimates this change will save the Rogue Valley MPO approximately $10,000 in unnecessary analysis costs every two years.

Under this plan Medford will continue to meet the federal CO standard, while eliminating administrative requirements that are no longer needed to protect air quality. The proposed limited maintenance plan updates Medford’s existing air quality plan, imposes no new control measur es and saves the cost of emissions analyses that are no longer useful.

1 DEQ tracks trends in area wide CO levels through periodic emission inventory updates. DEQ will reinstate monitoring if CO emissions rise significantly. This is unlikely to occur given the federal an d state emission reduction strategies in place.Staff Report page | 3 Regulated parties

The proposed Medford CO Limited Maintenance Plan would be a n amendment to O regon Administrative Rule 340

- 200

- 0040 which embodies the State of Oregon Cle an Air Act Implementation Plan. This proposal would replace the existing Medford CO Maintenance Plan and Emissions Inventory. It does not change the parties regulated by the Medford Maintenance Plan as it continues to apply mostly to transportation plannin g agencies and planning departments of local jurisdictions. In addition, the plan retains existing control measures for industrial sources and therefore also applies to larger businesses in the Medford area. The proposed CO maintenance plan would not negatively affect l arge or small business es because the rules do not create new requirements for businesses.

Request for other options

DEQ requested public comment on whether to consider other options for achiev ing the rule's substantive goals while reducing the rule’s negative economic impact on business. DEQ did not receive any comments on this topic.



### Statement of Need

Proposed Rule or Topic Discussion
Incorrect Motor Vehicle Emission Budget for CO

What need would the proposed rule address? The primary purpose of this rulemaking is to correct an improperly calculated Motor Vehicle Emission Budget in the existing CO Maintenance Plan. Air quality rules require new Regional Transportation Plans to demonstrate that future vehicle emissions from a planned transportation system “conform” to the budget in the applicable air quality plan. The existing budget is incorrectly low and cannot be met. How would the proposed rule address the need ? Because the CO concentrations in Medford are very low, DEQ proposes adoption of a Limited CO Maintenance Plan. The plan removes the need for a Motor Vehicle Emissions Budget, which is now an artificial obstacle to adopting a new transportation plan.
How will DEQ know the rule addressed the need? The need will be addressed if EPA declares removing the existing emissions budget to be adequate by the end of the first quarter in 2016, and subsequently approves the new plan.Staff Report page | 4 

### Proposed Rule or Topic Discussion

Second 10

- Year Maintenance Plan

What need would the proposed rule address? After EPA confirms that an area with an approved 10

- year maintenance plan meets the CO standard, the state must submit a second maintenance plan showing how the area will continue to meet the standard until 20 years after

re

- designation to attainment. How would the proposed rule address the need ? The proposed rulemaking includes a new Medford CO Limited Maintenance Plan as the area’s second maintenance plan.
How will DEQ know the rule addressed the need? This need will be met if EPA approves the new CO maintenance plan and the Medford area continues to meet the CO standard.

Verification of Continued Attainment

What need would the proposed rule address? Because CO concentrations in Medford are very low and the chance of exceeding the CO standard in the future is unlikely, CO monitoring equipment was removed after 2009. However, Medford still needs a method to determin e if CO levels increase significantly. How would the proposed rule address the need ? The new Medford CO Limited Maintenance Plan requires the emission inventory prepared for Medford every three years to be evaluated to determine if CO emissions increase significantly. If they do, CO monitoring will be resumed.
How will DEQ know the rule addressed the need? The need will be met if EPA approves this technique in the new Medford CO plan as an appropriate way to detect a significant increase of CO in Medford.



### Rules affected, authoriti es, supporting documents

Lead division Program or activity

Environmental Solutions Air Quality Planning
Chapter 340 action

Amend OAR 340

- 200

- 0040Staff Report page | 5 Statutory authority

ORS 468.020, 468 A

Statute s implemented

ORS 468 A .0 3 5 , 468A.135

Documents relied on for rulemaking ORS 183.335(2)(b)(C)



### Document title Document location State Implementation Plan Revision for Carbon Monoxide in the Medford Urban Growth Boundary State Implementation Plan Revision for Carbon Monoxide in the Medford Urban Growth Boundary EPA guidance document: 1995 Paisie Memo: Limited Maintenance Plan Option for Nonclassifiable CO Nonattainment Areas EPA guidance document: 1995 Paisie Memo: Limited Maintenance Plan Option for Nonclassifiable CO Nonattainment Areas



### Fee Analysis

This rulemaking does not involve fees.



### Statement of fiscal and economic impact

Fiscal and Economic Impact

The proposed limited maintenance plan has a positive fiscal and economic impact. The limited maintenance plan would streamline existing requirements, require no new control measures and reduc e the need for a costly regional emissions analysis under the transportation conformity rules.

Statement of Cost of Compliance

State and federal agencies The proposed plan would not affect state or federal agencies directly

. Because the proposed rules would greatly simplify transportation conformity requirements, the rules would have a slight positive fiscal and economic effect on DEQ indi rectly. That small beneficial effect comes from reduced staff time needed to evaluate Medford’s future conformity determinations required by transportation conformity rules.

Local governmentsStaff Report page | 6 The proposed limited maintenance plan would have some positive effect on local government in the form of cost savings.

Under the federal Clean Air Act and F ederal T ransportation A ct, metropolitan planning organizations (MPO) in maintenance areas are subject to transportation conformity rules. The MPO for Medford is the Rogue Valley Metropolitan Planning O rganization.

Each time an MPO adopts a new regional transportation plan or transportation improvement program, the conformity rules require the organization to demonstrate that emissions from the fut ure transportation system will not exceed the transportation emissions anticipated in the applicable maintenance plan. The MPO demonstrates this by preparing a regional emissions analysis that combines computer modeling of the highway system and of emissio n characteristics of the area’s cars and trucks. A significant benefit of the proposed limited maintenance plan is that an emissions budget is no longer needed and the MPO can demonstrate conformity without a regional analysis. DEQ estimates that not havin g to conduct this analysis would save the Rogue Valley Metropolitan Planning Organization approximately $10,000 every two years.

Public The proposed plan would not affect the pu blic directly

. Air pollution creates pu blic health problems that have indirect negative economic effects, but the area’s CO concentration is very low and is expected to stay low indefinitely . The proposed plan w ould continue positive economic effects in public health and welfare by maintaining compliance with the CO air quality stan dard.

Large businesses

- businesses with more than 50 employees The proposed CO maintenance plan would not affect l arge business es directly because the rules would not create new requirements for businesses.

DEQ anticipates CO concentrations would remain at a very low level under the proposed plan

. However, t he proposed rules could have indirect negative fiscal or economic effects on large businesses if CO levels were to increase substantially and the Medford area were to again violate federal air q uality standards

. The CO limited maintenance plan provides a contingency plan that describes actions to be taken if CO concentrations rise significantly. In the unlikely event of a future violation of the CO standard, the plan would require more stringent requirements for new and expanding industry. A violation would trigger DEQ having to reinstate the New Source Review requirement for Lowest Achievable Emission Rate and emission offsets for new and expanding industrial sources under O regon A dmini strative R ules Chapter 340 Division 224 . DEQ does not anticipate substantial industrial growth in the Medford area, and any new or expanding emission sources that are large businesses may not be large enough to trigger New Source Review requirements. At th is time, DEQ cannot accurately estimate the possible fiscal and economic impacts should the contingency plan be triggered, beca use such impacts are case specific

.

Small businesses

– businesses with 50 or fewer employees The proposed rules would not affect small business es directly because the proposed plan would not create new requirements. The plan would likely have no indirect effects on small business es. In the unlikely event that the Medford area violates the CO standard, the contingency plan would affectStaff Report page | 7 small businesses in the same way as described for large businesses above. That is, a violation of the standard would trigger more stringent New Sour ce Review requirements for new and expanding industry. However, small businesses are unlikely to have large enough emission quantities to trigger the requirements.

a

. Estimated number of small businesses and types of businesses and industries with small b usinesses subject to proposed rule. None

b

. Projected reporting, recordkeeping and other administrative activities, including costs of professional services, required for small businesses to comply with the proposed rule. None

c. Projected equipment, s upplies, labor and increased administration required for small businesses to comply with the proposed rule. None

d. Describe how DEQ involved small businesses in developing this proposed rule. DEQ did not involve small businesses in developing the proposed rules because the rules would likely not affect small businesses.

Advisory committee

DEQ did no t convene an advisory committee because the proposed new maintenance plan w ould not create new control measures. The plan only extends the current control measures as required under the federal Clean Air Act.

DEQ consult ed with Rogue Valley Metropolitan Planning Organization and EPA staff during development of the proposed limi ted maintenance plan.

Housing cost

To comply with ORS 183.534
, DEQ determined the proposed rule s would have no effect on the development cost of a 6,000

- square

- foot parcel and construction of a 1,200

- square

- foot detached, single

- family dwelling on that parcel. The change between the existing maintenance plan and the proposed maintenance plan primarily affects the transportation process.



### Federal relationshipStaff Report page | 8 Relationship to federal requirements

This section complies with OAR 340

- 011

- 0029 and ORS 468A.327 to clearly identify the relationship between the proposed rules and applicable federal requirements

. The proposed rules are not “different from or in addition to federal requirements” and impo se stringency equivalent to federal requirements.

The proposed limited maintenance plan would ensure that DEQ continues to comply with federal requirements in the Clean Air Act. The plan must demonstrate that the Medford area will continue to meet the fed eral CO standard until September 2022. EPA policy allows areas that are at low risk of exceeding the CO standard the option of submitting a simplified limited maintenance plan. The limited maintenance plan provides streamlined requirements, adds no new con trol measures and reduc e s the

n eed for costly regional emissions analyses when new transportation or transportation improvement programs are adopted.

What alternatives did DEQ consider if any?

Because this action is necessary to comply with requirements of the Clean Air Act, DEQ has not considered other options for this proposal.



### Land Use

Land

- use considerations

In adopting new or amended rules, ORS 197.180 and OAR 340

- 018

- 0070 require DEQ to determine whether the proposed rules significantly affect land use. If so, DEQ must explain how the proposed rules comply with statewide land

- use planning goals and local acknowledged comprehensive plans.

Under OAR 660

- 030

- 0005 and OAR 340 Division 18 , DEQ considers that rules affect land use if:

• The statewide land

- use planning goals specifically refer to the rule or program, or

• The rule or program is reasonably expected to have significant effects on:

o Resources, objectives or areas identified in the statewide planning goals, or

o Present or future land uses identified in acknowledged comprehensive plans

To determine whether the proposed rules involve programs or actions that affect land use, DEQ reviewed its Statewide Agency Coordination plan, which de scribes DEQ programs that significantly affect land use. DEQ considers that its programs specifically relate to the following statewide goals :

Goal Title

5 Open Spaces, Scenic and Historic Areas, and Natural Resources 6 Air, Water and Land Resources Q uality 9 Ocean Resources 11 Public Facilities and ServicesStaff Report page | 9 16 Estuarial R esources
Statewide goals also specifically reference the following DEQ programs:

• Nonpoint source discharge water quality program

– Goal 16

• Water quality and sewage disposal sys tems

– Goal 16

• Water quality permits and oil spill regulations

– Goal 19

Determination

DEQ determined that the proposed rules listed under the Chapter 340 Action section above do not affect existing rules, programs or activities considered land

- use progra ms and actions in OAR 340

- 018

- 0030 or in the DEQ State Agency Coordination Program.



### Stakeholder and public involvement

Advisory committee

DEQ did no t convene an advisory committee because the proposed new maintenance plan w ould not create new control measures. The plan only extends the current control measures as required under the federal Clean Air Act.

DEQ consult ed with Rogue Valley Metropolitan Planning Organization staff during development of the proposed limited maintenance plan.

EQC prior involvemen t

DEQ shares general rulemaking information with the Oregon Environmental Quality Commission through the monthly Director’s Report. DEQ did not present the co mmission additional information specific to this proposed rule revision.

Public notice

DEQ notified the public of this rulemaking proposal by:

• Publishing notice in the Sept. 1, 2015 Oregon Bulletin

• Placing the rulemaking notice on the web page for this rulemaking: Medford LMP Rulemaking

• Emailing 9434 interested parties on the Agency Rulemaking List through GovDelivery

• Emailing t he following key Oregon legislators required under ORS 183.335 :Staff Report page | 10 o Senator Chris Edwards, Chair, Senate Environment and Natural Resources Committee

o Representative Jessica Vega

- Pederson, Chair, House Energy and Environment Committee

• Issuing a DEQ news release

• Posting notice about the rulemaking on Facebook and Twitter

• Emailing these additional legislators:

o Rep. Duane Stark

o Rep. Peter Buckley

o Rep. Sal Esquivel

o Sen. Baertschiger

o Sen. Alan Bates

o Sen. Doug Whitsett



### • Providing legal notices in the following newspapers:

o The Oregonian

- Publication date

- Aug. 14, 2015

o Mail Tribune (Medford)

- Pub lication date

– Aug. 14, 2015

Public hearing DEQ he ld a public hearing on this topic at DEQ’s Medford office. The table below provides information about that hearing.

Date Monday, Sept. 21, 2015 Time 7 p.m. Address Line 1 221 Stewart Ave. Address Line 2 Suite 201 City Medford Presiding Officer Tom Peterson Staff Presenter Dave Nordberg (by phone) Call

- in Phone Number 888

- 204

- 5984 Call

- in Phone ID Code 257801

DEQ’s Tom Peterson presided as Hearings Officer and DEQ’s Dave Nordberg connected to the hearing via an op en conference line. As author of the plan, Mr. Nordberg was available b efore taking public comment to s ummarize the content of the notice and respond to any questions about the rulemaking. No one attend ed the hearing and no one called to provide comments from a remote location. Shortly after 7:30 Mr. Peterson officially closed the proceeding.

Close of public comment periodStaff Report page | 11 The comment period close d Thursday, Sept. 24, 2015 at 4 p.m.

Request for other options During the public comment period, DEQ requested public comment on whether to consider other options for achieving the rules’ substantive goals while reducing the rules’ negative economic impact on busines s. No comments responded to this request.Staff Report page | 12 

### Summary of comments and DEQ responses

During the public comment period DEQ received a single comment submitted through the agency’s website

.

Comment : Stronger emissions are encouraged. Oregon’s environmental laws are lax allowing Multnomah County and the state as a whole to have high levels of diesel soot.

Commenter
Diane Hodia k, affiliated with 350 Deschutes, OR

Response The proposed Maintenance Plan addresses only carbon monoxide emissions in the Medford area. Regional diesel particulate emissions are outside the scope of this rulemaking.

DEQ did not change the propos ed rules in response to comment

.



### Implementation

Notification

The proposed rules would become effective as state regulations upon filing on approximately Dec. 9
, 2015. By approximate ly Dec. 29, 2015
, DEQ would submit the new Medford CO Maintenance Plan to EPA as a revision to the Oregon’s State Implementation Plan. EPA has committed to promptly reviewing a new CO Plan adopted by the Oregon EQC in time to issue an Adequacy Determination allowing the revised motor vehicle emissions budget of the new plan to be implemented by Mar. 31, 2016. Once approved, DEQ will immediately share that information with the Rogue Valley Metropolitan Planning Organization, Oregon Department of Transportation, Federal Highway Administr ation and Federal Transit Admin istration.

Compliance and enforcement

Compliance and enforcement of the new Maintenance Pla n will be conducted through DEQ’s air quality permitting process for industrial sources and the transportation conformity requirements of the transportation planning process

. The Federal Highway Administration and Federal Transit Administration Transportat ion administer conformity.Notice page | 13 Measuring, sampling, monitoring and reporting

In order to verify continued attainment, every three years DEQ will review the National Emissions Estimates (NEI) of Medford’s CO emissions to identify increases over the 2008 emission levels. DEQ will evaluate a ny increase in CO emissions t o verify it is not due to a change in emission calculation methodology, an exceptional event or other factor not representative of an actual emissions increase. Estimated CO emissions will be compared to 2008 emission levels to determine if Contingency Plan provisions of the CO Maintenance Plan are triggered.
Systems There are no new requirements for DEQ’s systems aside from posting the new Maintenance Plan once it is approved by EPA as a SIP revision.
Training The new Maintenance Plan continues most of the existing regulatory requirements except those applying to conducting regional emissions analyses which are removed. There is no need for training.Notice page | 14 

### Five

- year review ORS 183.405

Requirement Oregon law r equires DEQ to review new rules within five years after EQC adopts the m. The law also exempts some rules from review. DEQ determined whether the rules described in this report are subject to the five

- year review based on its analysis of the law in effect when EQC adopted these rules.
Exemption from five

- year rule review

The Administrative Procedures Act exempt s the proposed rule from the five

- year review because the proposed rule would a mend an existing rule. ORS 183.405(4).

### Attachment 2

Evidence that the state has the necessary legal authority

For the legal authority, see page 5 of Attachment 1.1

### Attachment 3

Provisions submitted for approval

3.1 Amended rules submitted to Secretary of State effective December 10, 2015: OAR 340

- 200

- 0040*

3.2 Redline strikeout version of amended rules submitted to Secretary of State effective December 10, 2015: OAR 340

- 200

- 0040*

3.3 Medford Limited Maintencance Plan for CO incorporated into Oregon’s State Implementation Plan with the submittal of amended OAR 340

- 200

- 0040* to Secretary of State effectiv e December 10, 2015

*Denotes rules that are not included in the State of Oregon Clean Air Act State Implementation Plan but are being submitted to show a complete account of the rulemaking package.

### DEPARTMENT OF ENVIRONMENTAL QUALITY

340

- 200

- 0040

State of Oregon Clean Air Act Implementation Plan

(1) This implementation plan, consisting of Volumes 2 and 3 of the State of Oregon Air Quality Control Program, contains control strategies, rules and standards prepared by DEQ and is adopted as the State Implementation Plan (SIP) of the State of Oregon pu rsuant to the FCAA, 42 U.S.C.A 7401 to 7671q.

(2) Except as provided in section (3), revisions to the SIP will be made pursuant to the EQC’s rulemaking procedures in OAR 340 division 11 of this chapter and any other requirements contained in the SIP and w ill be submitted to the EPA for approval. The SIP was last modified by the EQC on Dec. 9, 2015

. (3) Notwithstanding any other requirement contained in the SIP, DEQ may:

(a) Submit to the EPA any permit condition implementing a rule that is part of the fe derally

- approved SIP as a source

- specific SIP revision after DEQ has complied with the public hearings provisions of 40 CFR 51.102; and

(b) Approve the standards submitted by LRAPA if LRAPA adopts verbatim, other than

non

- substantive differences, any stan dard that the EQC has adopted, and submit the standards to EPA for approval as a SIP revision.

(4) Revisions to the State of Oregon Clean Air Act Implementation Plan become federally enforceable upon approval by the EPA. If any provision of the federally approved State Implementation Plan conflicts with any provision adopted by the EQC, DEQ must enforce the more stringent provision.

Stat. Auth.: ORS 468.020 & 468A Stats. Implemented: ORS 468A.035 & 468A.135 Hist.: DEQ 35, f. 2

- 3

- 72, ef. 2

- 15

- 72; DEQ 54, f. 6

- 21

- 73, ef. 7

- 1

- 73; DEQ 19

- 1979, f. & ef. 6

- 25

- 79; DEQ 21

- 1979, f. & ef. 7

- 2

- 79; DEQ 22

- 1980, f. & ef. 9

- 26

- 80; DEQ 11

- 1981, f. & ef. 3

- 26

- 81; DEQ 14

- 1982, f. & ef. 7

- 21

- 82; DEQ 21

- 1982, f. & ef. 10

- 27

- 82; DEQ 1

- 1983, f. & ef. 1

- 21

- 83; DEQ 6

- 1983, f. & ef. 4

- 18

- 83; DEQ 18

- 1984, f. & ef. 10

- 16

- 84; DEQ 25

- 1984, f. & ef. 11

- 27

- 84; DEQ 3

- 1985, f. & ef. 2

- 1

- 85; DEQ 12

- 1985, f. & ef. 9

- 30

- 85; DEQ 5

- 1986, f. & ef. 2

- 21

- 86; DEQ 10

- 1986, f. & ef. 5

- 9

- 86; DEQ 20

- 1986, f. & ef. 11

- 7

- 86; DEQ 21

- 1986, f. & ef. 11

- 7

- 86; DEQ 4

- 1987, f. & ef. 3

- 2

- 87; DEQ 5

- 1987, f. & ef. 3

- 2

- 87; DEQ 8

- 1987, f. & ef. 4

- 23

- 87; DEQ 21

- 1987, f. & ef. 12

- 16

- 87; DEQ 31

- 1988, f. 12

- 20

- 88, cert. ef. 12

- 23

- 88; DEQ 2

- 1991, f. & cert. ef. 2

- 14

- 91; DEQ 19

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 20

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 21

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 22

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 23

- 1991, f. &cert. ef. 11

- 13

- 91; DEQ 24

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 25

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 1

- 1992, f. & cert. ef. 2

- 4

- 92; DEQ 3

- 1992, f. & cert. ef. 2

- 4

- 92; DEQ 7

- 1992, f. & cert. ef. 3

- 30

- 92; DEQ 19

- 1992, f. & cert. ef. 8

- 11

- 92; DEQ 20

- 1992, f. & cert. ef. 8

- 11

- 92; DEQ 25

- 1992, f. 10

- 30

- 92, cert. ef. 11

- 1

- 92; DEQ 26

- 1992, f. & cert. ef. 11

- 2

- 92; DEQ 27

- 1992, f. & cert. ef. 11

- 12

- 92; DEQ 4

- 1993, f. & cert. ef. 3

- 10

- 93; DEQ 8

- 1993, f. & cert. ef. 5

- 11

- 93; DEQ 12

- 1993, f. & cert. ef. 9

- 24

- 93; DEQ 15

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 16

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 17

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 19

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 1

- 1994, f. & cert. ef. 1

- 3

- 94; DEQ 5

- 1994, f. & cert. ef. 3

- 21

- 94; DEQ 14

- 1994, f. & cert. ef. 5

- 31

- 94; DEQ 15

- 1994, f. 6

- 8

- 94, cert. ef. 7

- 1

- 94; DEQ 25

- 1994, f. & cert. ef. 11

- 2

- 94; DEQ 9

- 1995, f. & cert. ef. 5

- 1

- 95; DEQ 10

- 1995, f. & cert. ef. 5

- 1

- 95; DEQ 14

- 1995, f. & cert. ef. 5

- 25

- 95; DEQ 17

- 1995, f. & cert. ef. 7

- 12

- 95; DEQ 19

- 1995, f. & cert. ef. 9

- 1

- 95; DEQ 20

- 1995 (Temp), f. & cert. ef. 9

- 14

- 95; DEQ 8

- 1996(Temp), f. & cert. ef. 6

- 3

- 96; DEQ 15

- 1996, f. & cert. ef. 8

- 14

- 96; DEQ 19

- 1996, f. & cert. ef. 9

- 24

- 96; DEQ 22

- 1996, f. & cert. ef. 10

- 22

- 96; DEQ 23

- 1996, f. & cert. ef. 11

- 4

- 96; DEQ 24

- 1996, f. & cert. ef. 11

- 26

- 96; DEQ 10

- 1998, f. & cert. ef. 6

- 22

- 98; DEQ 15

- 1998, f. & cert. ef. 9

- 23

- 98; DEQ 16

- 1998, f. & cert. ef. 9

- 23

- 98; DEQ 17

- 1998, f. & cert. ef. 9

- 23

- 98; DEQ 20

- 1998, f. & cert. ef. 10

- 12

- 98; DEQ 21

- 1998, f. & cert. ef. 10

- 12

- 98; DEQ 1

- 1999, f. & cert. ef. 1

- 25

- 99; DEQ 5

- 1999, f. & cert. ef. 3

- 25

- 99; DEQ 6

- 1999, f. & cert. ef. 5

- 21

- 99; DEQ 10

- 1999, f. & cert. ef. 7

- 1

- 99; DEQ 14

- 1999 , f. & cert. ef. 10

- 14

- 99, Renumbered from 340

- 020

- 0047; DEQ 15

- 1999, f. & cert. ef. 10

- 22

- 99; DEQ 2

- 2000, f. 2

- 17

- 00, cert. ef. 6

- 1

- 01; DEQ 6

- 2000, f. & cert. ef. 5

- 22

- 00; DEQ 8

- 2000, f. & cert. ef. 6

- 6

- 00; DEQ 13

- 2000, f. & cert. ef. 7

- 28

- 00; DEQ 16

- 2000 , f. & cert. ef. 10

- 25

- 00; DEQ 17

- 2000, f. & cert. ef. 10

- 25

- 00; DEQ 20

- 2000 f. & cert. ef. 12

- 15

- 00; DEQ 21

- 2000, f. & cert. ef. 12

- 15

- 00; DEQ 2

- 2001, f. & cert. ef. 2

- 5

- 01; DEQ 4

- 2001, f. & cert. ef. 3

- 27

- 01; DEQ 6

- 2001, f. 6

- 18

- 01, cert. ef. 7

- 1

- 01; DEQ 15

- 2001, f. & cert. ef. 12

- 26

- 01; DEQ 16

- 2001, f. & cert. ef. 12

- 26

- 01; DEQ 17

- 2001, f. & cert. ef. 12

- 28

- 01; DEQ 4

- 2002, f. & cert. ef. 3

- 14

- 02; DEQ 5

- 2002, f. & cert. ef. 5

- 3

- 02; DEQ 11

- 2002, f. & cert. ef. 10

- 8

- 02; DEQ 5

- 2003, f. & cert. ef. 2

- 6

- 03; DE Q 14

- 2003, f. & cert. ef. 10

- 24

- 03; DEQ 19

- 2003, f. & cert. ef. 12

- 12

- 03; DEQ 1

- 2004, f. & cert. ef. 4

- 14

- 04; DEQ 10

- 2004, f. & cert. ef. 12

- 15

- 04; DEQ 1

- 2005, f. & cert. ef. 1

- 4

- 05; DEQ 2

- 2005, f. & cert. ef. 2

- 10

- 05; DEQ 4

- 2005, f. 5

- 13

- 05, cert. ef. 6

- 1

- 05; DEQ 7

- 2005, f. & cert. ef. 7

- 12

- 05; DEQ 9

- 2005, f. & cert. ef. 9

- 9

- 05; DEQ 2

- 2006, f. & cert. ef. 3

- 14

- 06; DEQ 4

- 2006, f. 3

- 29

- 06, cert. ef. 3

- 31

- 06; DEQ 3

- 2007, f. & cert. ef. 4

- 12

- 07; DEQ 4

- 2007, f. & cert. ef. 6

- 28

- 07; DEQ 8

- 2007, f. & cert. ef. 11

- 8

- 07; DEQ 5

- 2008, f. & cert. ef. 3

- 20

- 08; DEQ 11

- 2008, f. & cert. ef. 8

- 29

- 08; DEQ 12

- 2008, f. & cert. ef. 9

- 17

- 08; DEQ 14

- 2008, f. & cert. ef. 11

- 10

- 08; DEQ 15

- 2008, f. & cert. ef 12

- 31

- 08; DEQ 3

- 2009, f. & cert. ef. 6

- 30

- 09; DEQ 8

- 2009, f. & cert. ef. 1 2

- 16

- 09; DEQ 2

- 2010, f. & cert. ef. 3

- 5

- 10; DEQ 5

- 2010, f. & cert. ef. 5

- 21

- 10; DEQ 14

- 2010, f. & cert. ef. 12

- 10

- 10; DEQ 1

- 2011, f. & cert. ef. 2

- 24

- 11; DEQ 2

- 2011, f. 3

- 10

- 11, cert. ef. 3

- 15

- 11; DEQ 5

- 2011, f. 4

- 29

- 11, cert. ef. 5

- 1

- 11; DEQ 18

- 2011, f. & cert. ef. 12

- 21

- 11; DEQ 1

- 2012, f. & cert. ef. 5

- 17

- 12; DEQ 7

- 2012, f. & cert.ef 12

- 10

- 12; DEQ 10

- 2012, f. & cert. ef. 12

- 11

- 12; DEQ 4

- 2013, f. & cert. ef. 3

- 27

- 13; DEQ 11

- 2013, f. & cert. ef. 11

- 7

- 13; DEQ 12

- 2013, f. & cert. ef. 12

- 19

- 13; DEQ 1

- 2014, f. & cert. ef. 1

- 6

- 14; DEQ 4

- 2014, f. & cert. ef. 3

- 31

- 14; DEQ 5

- 2014, f. & cert. ef. 3

- 31

- 14; DEQ 6

- 2014, f. & cert. ef. 3

- 31

- 14; DEQ 7

- 2014, f. & cert. ef. 6

- 26

- 14; DEQ 6

- 2015, f. & cert. ef. 4

- 16

- 15; DEQ 7

- 2015, f. & cert. ef. 4

- 16

- 15

### DEPARTMENT OF ENVIRONMENTAL QUALITY

340

- 200

- 0040

State of Oregon Clean Air Act Implementation Plan

(1) This implementation plan, consisting of Volumes 2 and 3 of the State of Oregon Air Quality Control Program, contains control strategies, rules and standards prepared by DEQ and is adopted as the State Implementation Plan (SIP) of the State of Oregon pu rsuant to the FCAA, 42 U.S.C.A 7401 to 7671q.

(2) Except as provided in section (3), revisions to the SIP will be made pursuant to the EQC’s rulemaking procedures in OAR 340 division 11 of this chapter and any other requirements contained in the SIP and w ill be submitted to the EPA for approval. The SIP was last modified by the EQC on April 16, 2015 Dec. 9, 2015

. (3) Notwithstanding any other requirement contained in the SIP, DEQ may:

(a) Submit to the EPA any permit condition implementing a rule that is part of the federally

- approved SIP as a source

- specific SIP revision after DEQ has complied with the public hearings provisions of 40 CFR 51.102; and

(b) Approve the standards submitted by LRAPA if LRAPA adopts verbatim, other than

non

- substantive differ ences, any standard that the EQC has adopted, and submit the standards to EPA for approval as a SIP revision.

(4) Revisions to the State of Oregon Clean Air Act Implementation Plan become federally enforceable upon approval by the EPA. If any provision of the federally approved State Implementation Plan conflicts with any provision adopted by the EQC, DEQ must enforce the more stringent provision.

Stat. Auth.: ORS 468.020 & 468A Stats. Implemented: ORS 468A.035 & 468A.135 Hist.: DEQ 35, f. 2

- 3

- 72, ef. 2

- 15

- 72; DEQ 54, f. 6

- 21

- 73, ef. 7

- 1

- 73; DEQ 19

- 1979, f. & ef. 6

- 25

- 79; DEQ 21

- 1979, f. & ef. 7

- 2

- 79; DEQ 22

- 1980, f. & ef. 9

- 26

- 80; DEQ 11

- 1981, f. & ef. 3

- 26

- 81; DEQ 14

- 1982, f. & ef. 7

- 21

- 82; DEQ 21

- 1982, f. & ef. 10

- 27

- 82; DEQ 1

- 1983, f. & ef. 1

- 21

- 83; D EQ 6

- 1983, f. & ef. 4

- 18

- 83; DEQ 18

- 1984, f. & ef. 10

- 16

- 84; DEQ 25

- 1984, f. & ef. 11

- 27

- 84; DEQ 3

- 1985, f. & ef. 2

- 1

- 85; DEQ 12

- 1985, f. & ef. 9

- 30

- 85; DEQ 5

- 1986, f. & ef. 2

- 21

- 86; DEQ 10

- 1986, f. & ef. 5

- 9

- 86; DEQ 20

- 1986, f. & ef. 11

- 7

- 86; DEQ 21

- 1986, f. & ef. 11

- 7

- 86; DEQ 4

- 1987, f. & ef. 3

- 2

- 87; DEQ 5

- 1987, f. & ef. 3

- 2

- 87; DEQ 8

- 1987, f. & ef. 4

- 23

- 87; DEQ 21

- 1987, f. & ef. 12

- 16

- 87; DEQ 31

- 1988, f. 12

- 20

- 88, cert. ef. 12

- 23

- 88; DEQ 2

- 1991, f. & cert. ef. 2

- 14

- 91; DEQ 19

- 1991, f. & cert. ef. 11

- 13

- 9 1; DEQ 20

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 21

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 22

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 23

- 1991, f. &cert. ef. 11

- 13

- 91; DEQ 24

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 25

- 1991, f. & cert. ef. 11

- 13

- 91; DEQ 1

- 1992, f. & cert. ef . 2

- 4

- 92; DEQ 3

- 1992, f. & cert. ef. 2

- 4

- 92; DEQ 7

- 1992, f. & cert. ef. 3

- 30

- 92; DEQ 19

- 1992, f. & cert. ef. 8

- 11

- 92; DEQ 20

- 1992, f. & cert. ef. 8

- 11

- 92; DEQ 25

- 1992, f. 10

- 30

- 92, cert. ef. 11

- 1

- 92; DEQ 26

- 1992, f. & cert. ef. 11

- 2

- 92; DEQ 27

- 1992, f. & c ert. ef. 11

- 12

- 92; DEQ 4

- 1993, f. & cert. ef. 3

- 10

- 93; DEQ 8

- 1993, f. & cert. ef. 5

- 11

- 93; DEQ 12

- 1993, f. & cert. ef. 9

- 24

- 93; DEQ 15

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 16

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 17

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 19

- 1993, f. & cert. ef. 11

- 4

- 93; DEQ 1

- 1994, f. & cert. ef. 1

- 3

- 94; DEQ 5

- 1994, f. & cert. ef. 3

- 21

- 94; DEQ 14

- 1994, f. & cert. ef. 5

- 31

- 94; DEQ 15

- 1994, f. 6

- 8

- 94, cert. ef. 7

- 1

- 94; DEQ 25

- 1994, f. & cert. ef. 11

- 2

- 94; DEQ 9

- 1995, f. & cert. ef. 5

- 1

- 95; DEQ 10

- 1995, f . & cert. ef. 5

- 1

- 95; DEQ 14

- 1995, f. & cert. ef. 5

- 25

- 95; DEQ 17

- 1995, f. & cert. ef. 7

- 12

- 95; DEQ 19

- 1995, f. & cert. ef. 9

- 1

- 95; DEQ 20

- 1995 (Temp), f. & cert. ef. 9

- 14

- 95; DEQ 8

- 1996(Temp), f. & cert. ef. 6

- 3

- 96; DEQ 15

- 1996, f. & cert. ef. 8

- 14

- 96; DE Q 19

- 1996, f. & cert. ef. 9

- 24

- 96; DEQ 22

- 1996, f. & cert. ef. 10

- 22

- 96; DEQ 23

- 1996, f. & cert. ef. 11

- 4

- 96; DEQ 24

- 1996, f. & cert. ef. 11

- 26

- 96; DEQ 10

- 1998, f. & cert. ef. 6

- 22

- 98; DEQ 15

- 1998, f. & cert. ef. 9

- 23

- 98; DEQ 16

- 1998, f. & cert. ef. 9

- 23

- 9 8; DEQ 17

- 1998, f. & cert. ef. 9

- 23

- 98; DEQ 20

- 1998, f. & cert. ef. 10

- 12

- 98; DEQ 21

- 1998, f. & cert. ef. 10

- 12

- 98; DEQ 1

- 1999, f. & cert. ef. 1

- 25

- 99; DEQ 5

- 1999, f. & cert. ef. 3

- 25

- 99; DEQ 6

- 1999, f. & cert. ef. 5

- 21

- 99; DEQ 10

- 1999, f. & cert. ef. 7

- 1

- 99; DEQ 14

- 1999, f. & cert. ef. 10

- 14

- 99, Renumbered from 340

- 020

- 0047; DEQ 15

- 1999, f. & cert. ef. 10

- 22

- 99; DEQ 2

- 2000, f. 2

- 17

- 00, cert. ef. 6

- 1

- 01; DEQ 6

- 2000, f. & cert. ef. 5

- 22

- 00; DEQ 8

- 2000, f. & cert. ef. 6

- 6

- 00; DEQ 13

- 2000, f. & cert. ef. 7

- 28

- 00; DEQ 16

- 2000, f. & cert. ef. 10

- 25

- 00; DEQ 17

- 2000, f. & cert. ef. 10

- 25

- 00; DEQ 20

- 2000 f. & cert. ef. 12

- 15

- 00; DEQ 21

- 2000, f. & cert. ef. 12

- 15

- 00; DEQ 2

- 2001, f. & cert. ef. 2

- 5

- 01; DEQ 4

- 2001, f. & cert. ef. 3

- 27

- 01; DEQ 6

- 2001, f. 6

- 18

- 01, cert. ef. 7

- 1

- 01; DEQ 15

- 2001, f. & cert. ef. 12

- 26

- 01; DEQ 16

- 2001, f. & cert. ef. 12

- 26

- 01; DEQ 17

- 2001, f. & cert. ef. 12

- 28

- 01; DEQ 4

- 2002, f. & cert. ef. 3

- 14

- 02; DEQ 5

- 2002, f. & cert. ef. 5

- 3

- 02; DEQ 11

- 2002, f. & cert. ef. 10

- 8

- 02; DEQ 5

- 2003, f. & cert. ef. 2

- 6

- 03; DEQ 14

- 2003, f. & cert. ef. 10

- 24

- 03; DEQ 19

- 2003, f. & cert. ef. 12

- 12

- 03; DEQ 1

- 2004, f. & cert. ef. 4

- 14

- 04; DEQ 10

- 2004, f. & cert. ef. 12

- 15

- 04; DEQ 1

- 2005, f. & cert. ef. 1

- 4

- 05; DEQ 2

- 2005, f. & cert. ef. 2

- 10

- 05; DEQ 4

- 2005, f. 5

- 13

- 05 , cert. ef. 6

- 1

- 05; DEQ 7

- 2005, f. & cert. ef. 7

- 12

- 05; DEQ 9

- 2005, f. & cert. ef. 9

- 9

- 05; DEQ 2

- 2006, f. & cert. ef. 3

- 14

- 06; DEQ 4

- 2006, f. 3

- 29

- 06, cert. ef. 3

- 31

- 06; DEQ 3

- 2007, f. & cert. ef. 4

- 12

- 07; DEQ 4

- 2007, f. & cert. ef. 6

- 28

- 07; DEQ 8

- 2007, f. & cert. ef. 11

- 8

- 07; DEQ 5

- 2008, f. & cert. ef. 3

- 20

- 08; DEQ 11

- 2008, f. & cert. ef. 8

- 29

- 08; DEQ 12

- 2008, f. & cert. ef. 9

- 17

- 08; DEQ 14

- 2008, f. & cert. ef. 11

- 10

- 08; DEQ 15

- 2008, f. & cert. ef 12

- 31

- 08; DEQ 3

- 2009, f. & cert. ef. 6

- 30

- 09; DEQ 8

- 2009, f . & cert. ef. 12

- 16

- 09; DEQ 2

- 2010, f. & cert. ef. 3

- 5

- 10; DEQ 5

- 2010, f. & cert. ef. 5

- 21

- 10; DEQ 14

- 2010, f. & cert. ef. 12

- 10

- 10; DEQ 1

- 2011, f. & cert. ef. 2

- 24

- 11; DEQ 2

- 2011, f. 3

- 10

- 11, cert. ef. 3

- 15

- 11; DEQ 5

- 2011, f. 4

- 29

- 11, cert. ef. 5

- 1

- 11; DE Q 18

- 2011, f. & cert. ef. 12

- 21

- 11; DEQ 1

- 2012, f. & cert. ef. 5

- 17

- 12; DEQ 7

- 2012, f. & cert.ef 12

- 10

- 12; DEQ 10

- 2012, f. & cert. ef. 12

- 11

- 12; DEQ 4

- 2013, f. & cert. ef. 3

- 27

- 13; DEQ 11

- 2013, f. & cert. ef. 11

- 7

- 13; DEQ 12

- 2013, f. & cert. ef. 12

- 19

- 13; DEQ 1

- 2014, f. & cert. ef. 1

- 6

- 14; DEQ 4

- 2014, f. & cert. ef. 3

- 31

- 14; DEQ 5

- 2014, f. & cert. ef. 3

- 31

- 14; DEQ 6

- 2014, f. & cert. ef. 3

- 31

- 14; DEQ 7

- 2014, f. & cert. ef. 6

- 26

- 14; DEQ 6

- 2015, f. & cert. ef. 4

- 16

- 15; DEQ 7

- 2015, f. & cert. ef. 4

- 16

- 15

# Medford Carbon Monoxide Limited Maintenance Plan

By: Oregon Department of Environmental Quality

December , 2015

DEQ Environmental Solutions Air Quality Program 811 SW 6th Avenue Portland, OR 97204 Phone: (503) 229

- 5519 (800) 452

- 4011 Fax: (503) 229

- 5675 Conta ct: Dave Nordberg www.oregon.gov/DEQ

DEQ is a leader in restoring, maintaining and enhancing the quality of Oregon’s air, land and
water.

# State Implementation Plan Revision
Medford Carbon Monoxide Limited Maintenance Plan

A Limited Maintenance Plan
for Carbon Monoxide

T he Medford Urban Growth Boundary

State of Oregon Clean Air Act Implementation Plan

Opened for public comment August 14 , 2015

State of Oregon Department of Environmental Quality 811 SW Sixth Avenue Portland, OR 97204

- 13902015 Medford CO LMP

Page i 

### Table of Contents

Acknowledgments

................................ ................................ ................................ ........................... ii Executive Summary

................................ ................................ ................................ ....................... iii
Plan Structure

................................ ................................ ................................ ................................ . iv
1. Introducti on

................................ ................................ ................................ ................................ . 1 2. Geographic Area

................................ ................................ ................................ ......................... 1 3. History of CO Problem in Medford

................................ ................................ ............................ 2 4. Limited Maintenance Plan Option

................................ ................................ .............................. 5 5. Emission Inventory

................................ ................................ ................................ ..................... 6
6. Co ntinuing Control Measures

................................ ................................ ................................ ... 10
7. Verification of Continued Attainment

................................ ................................ ...................... 12 8. Contingency Plan

................................ ................................ ................................ ...................... 12



### Table of Figures

Figure 1. Medford Urban Growth Boundary

................................ ................................ ................. 2 Figure 2. Medford Carbon Monoxide Trend 2nd highest 8

- hour average, 1977

- 2009

................. 5 Figure 3. Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008

................................ ....... 7 Figure 4. Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008

................................ 8 Figure 5. 2008 Medford Annual CO Em issions

................................ ................................ .............. 9 Figure 6. 2008 Medford Seasonal CO Emissions

................................ ................................ ............ 9



### Table of Tables

Table 1. Medford Carbon Monoxide Concentrations 1977

- 2009

................................ .................... 4
Table 2 Medford UGB 2008 CO Annual and Seasonal Emissions Inventory

................................ 6



### Appendices

Appendix 1 : EPA 1995 Paisie Memo Appendix 2 : Medford 2008 Emission Inventory Appendix 3 : EPA 2012 Approval Letter for removal of the CO monitor and Justification for Discontinuation of Monitoring in Carbon Monoxide and PM 10 Maintenance Areas Appendix 4 : Inventory Preparation and Quality Assurance Plan2015 Medford CO LMP

Page ii 

### A cknowledgments

Principal Author: Dave Nordberg , DEQ Air Quality Planning

Principal Contributors:

Oregon Department of Environmental Quality

David Collier Air Quality Planning Manager Brian Finner an Air Quality Planning Anthony Barnack Air Quality Planning Jeffrey Stocum Air Quality Technical Services Manager Wes Risher Air Quality Technical Services Chris Swab Air Quality Technical Services Brandy Albertson Air Quality Technical Services Tom Carlson Sierra Research, Inc

Environmental Protection Agency

Claudia Vaupel EPA Region X Bob Kotchenruther EPA Region X

Medford

Dan Moore Rogue Valley Council of Governments Jonathan David Rogue Valley Council of Governments2015 Medford CO LMP

Page iii 

### Executive Summary

Medford , Oregon violated the national air quality standard for carbon mon oxide in the 1970s and 1980s. Conditions have progressively improved and Medford has not violated the carbon monoxide (CO) standard since 1 991

. In 2001 Oregon submitted a ten

- year CO Maintenance Plan to EPA and requested that Medford be redesignated t o attainment. EPA appro ved the request as a revisi o n to th e State Implementation Plan (SIP) September 23, 20 0 2

. Oregon DEQ has now prepared this second ten

- year CO Maintenance Plan that indicates how Medford will continue to maintain the CO standard through September 23, 2022

-- the end of the second maintenance plan period. Once adopted by the Oregon Environmental Quality Commission this plan will be submitted to the EPA as a further revision of the SIP.

High levels of CO have been traditionally caused by motor vehicles emissions. The improvemen t of CO concentrations over previous decades is largely due to modern vehicle emission control systems which have reduced CO emissions dramatically. Because CO is so low this plan qualifies
to use a Limited Maintenance Plan (LMP ) which streamlines requirements for SIP approval. This technique is available to maintenance areas that have a design value of no higher than 7.65 ppm which is 85 percent of the 8

- hour CO stan dard

. By comparison Medford has a design value of 2.4 ppm or 27 percent of the standard.

All maintenance plans including LMPs need to establish the rel a tionship between CO emissions and measured ambient CO concentrations. To speed development of this pl an , the Rogue Valley Council of Governments contracted with Sierra Research to do assemable much of the Medford CO Emissions Inventory. DEQ and Sierra Research began with the EPA’s 2008 National Emission Inventory (NE I ) to quantify CO emissions in the Medfor d area

. This plan retains the control and contingency measures from the first CO maintenance plan. The primary control measure has been the emission standards for new motor vehicles under the Federal Motor Vehicle Control Program. Another signific nat measure that continues is the New Source Review Program with Best Available Control Technology (BACT).

Another requirement for a LMP is to maintain a method of determining if an area’s air quality degrades to the point where a violation could occur. A mbient CO concentrations in Medford declined to such low levels that the CO measurement equipment was removed in 2010

. Because the Medford CO monitor h as been removed

, DEQ use s an alternate method to verify that the

area continue s to attain the CO standard

. This alternate method of tracking CO emissions will be revised in the proposed limited maintenance plan. DEQ calculates Medford’s CO emissions every three years through the Statewide Emission Inventory, which is submitted to EPA for inclusion in the National Emission Inventory

. Under the new plan DEQ will evaluate any increase of Medford’s CO emissions to determine if that would trigger the Conti ngency Plan. Control measures in the Contingency Plan include resuming testing CO concentrations in Medford ’s air , and if needed, forming an advisory committee to develop new st rategies to prevent or correct any violation of the CO standard

.2015 Medford CO LMP

Page iv 

### Plan Structure

This SIP revision includes the compliance history for Medford and describes how the area met and will continue to meet the standard. This document is organized as follows:

Section 1

– Introduction

. D escribes the purpose of this second maintenance plan , and summary on the CO standard

.

Section 2

– Geographic Area. Describes the geographic area covered by the maintenance plan,

Section 3

– H istory of the C arbon Monoxide Problem. Summarizes Medford CO compliance history and past CO monitoring data and trends

.

Section 4

– Limited Maintenance Plan Option

. D escribes the criteria an area must meet to qualify for this option and how Medford qualifies.

Section 5

– Emission Inventory

. I ncludes historical information on the most significant CO emission categories from the original maintenance plan and an updated inventory on these categories

.

Section 6

– Continuing Control Measures . L ists the measures that were in the original CO maintenance plan

, and how these measures will be continued under th is LMP.

Section 7

– Verification of Continued Attainment . D escribes how compliance will be tracked and confirmed

.

Section 8

– Contingency Plan. Describes the contingency measures that apply should a violation occur in the future.

Appendices

– Supporting documentation for this LMP.2015 Medford CO LMP

Page 1 

### 1. Introduction

This State Impl ementation Plan revision documents that the area within the Medford Urban Growth boundary w ill continue to meet the National Ambient Air Quality Standard (NAAQS) for CO through 202 2

. This plan also describes steps that must be taken if the are a ’s c arbon monoxide concentrations deteriorate to an to an actionable level. This plan is a “limited maintenance plan ” developed in accordance with the federal Clean Air Act and the policies of the U.S. Environmental Protection Agency (EPA) . S ee the 1995 “Paisie Memo ” provided in Appendix 1

. The Clean Air Act requires EPA to set air quality standards to protect public health for six common air pollutants, including carbon monoxide

. In 1971 EPA set the national ambient air quality standard for carbon monoxide. Carbon monoxide is a colorless, odorless gas that decreases the oxygen carrying capacity of the blood. High concentrations can severely impair the function of oxygen

- dependent tissues, including the brain, heart, and muscle. Prolonged exposure to even low levels can aggravate existing conditions in people with heart dis ease or circulatory disorders. Motor vehicles are the primary source of CO in Oregon.

EPA established the national ambient air quality standard for CO at 35 parts per million (ppm) for a 1

- hour average and 9 ppm for an 8

- hour average. Two exceedances within one calendar year constitute a vio lation. Like most areas of the country that failed to meet the CO standard, Medford failed to meet the 8

- hour portion of the standard 1

.


### 2. Geographic Area

The C ity of Medford is located in southwes tern Oregon, West of the Cascade Mountains in the Rogue River Valley . The city is approximately 26 square miles in area, and the population in 2013 was 77,677

. The surrounding hills can trap air pollution under stable meteorol ogical conditions (inversions). These conditions exist most frequently durin g the winter and we re associated with the majority of past carbon monoxide violations.

Figure 1 shows the Medford Urban Growth Boundary which is also the geographic area subject to this limited maintenance plan.

1 40CFR part 50.8 states that standards defined in parts per million should be compared “in terms of integers with fractional parts of 0.5 or greater rounding.” This led to an interpretation by EPA that any 8

- hour CO concentration of less than 9.5 ppm would be equivalent to attainment. Therefore, concentrations at or above 9.5 ppm represent an exceedance of the standard. Two exceedances in one calendar year constitute a violation.2015 Medford CO LMP

Page 2 Figure 1

. Medford U rban Growth Bo undary



### 3

. History of CO Problem in Medford
History of CO in Medford Area/Design Values

The Medford area was designated by the Environmental Protection Agency (EPA) as a nonattainment area for carbon monoxide (CO) on March 3, 1978. On June 20, 1979 DEQ submitted a CO Control Strategy and requested an extension beyond 1 982 to attain the CO standard. At that time the design value was 13.8 parts per million ( ppm ) . EPA approved the 1979 plan and the extension, giving D EQ2015 Medford CO LMP

Page 3 until December 31, 1987 to bring the Medford area into compliance. An updated control strategy was submitted in 1982 which was revised in 1985 to include a state

- operated vehicle inspection program.

Following ado ption of the 1990 Clean Air Act Amendments, EPA classified Medford as a moderate CO nonattainment area with a design v alue of 12.1 p pm. The CO nonattainment boundary was defined as the Medford, Oregon Urban Growth Boundary (UGB) used for comprehensive land use planning under state law. In 2001, DEQ demonstrated that Medfo rd had attained the 8

- hour CO standard with a design value of 7.5 ppm and submitted a maintenance plan showing how the area would continue to meet the CO standard into the future. EPA approved the maintenance plan and redesignated Medford to attainment for CO effective September 23, 2002.

Since then, CO concentrations continued to im prove and CO monitoring was ended in 2010 followed by EPA’s approval of an alternate approach for tracking CO as shown in Appendix 3. Now DEQ is submitting a s econd CO maintenance plan with a design value of 2.4 ppm CO based on ambient monitoring from 2008 and 2009. This second C O plan is based on EPA guidance for limited maintenance plans as detailed by a memo from Joe Paisie dated October 6, 1995 and an email from Meg Patulski dated October 4, 2005.

H istorically, several carbon monoxide monitoring sites in the Medford nonattainment area exc eeded the 8

- hour NAAQS for CO. Exceedances were recorded for approximately half of the year in the late 19 70s. However, because the control measures in the State Implementation Plan (SIP) were effective at reducing CO emissions, Medford air quality has met the CO standard since 1992. This is consistent with CO emission inventories from 1993 and 2008 which show that CO emissions in Medford continue d to decline.2015 Medford CO LMP

Page 4 

### Table 1. Medford Carbon Monoxide Concentrations 1977

- 2009

8

- hour CO Averages Year Maximum 2 nd Highest 1977 21.8 17.3 1978 19.8 18.3 1979 16.2 13.8 198 0 19.2 15.7 198 1 14.9 14.5 198 2 14.3 13.2 198 3 15.8 12.6 198 4 15.2 12.4 198 5 16.9 16.3 198 6 12.7 12.6 1987 12.9 9.7 1988 12.2 10.8 1989 12.2 12.1 1990 9.2 9.0 1991 11.9 10.5 1992 7.4 7.4 1993 8.5 7.5 1994 7.4 6.7 1995 6.1 6.0 1996 6.7 6.6 1997 7.3 5.7 1998 5.5 5.3 1999 6.8 6.1 2000 4.8 4.7 2001 4.8 4.6 2002 5.9 5.5 2003 5.0 4.7 2004 4.0 4.0 2005 4.4 3.8 2006 2.9 2.8 2007 3.1 2.7 2008 2.6 2.4 2009 2.4 2.4

(When multiple monitors operated in a given year

, values shown are from the CO monitor with the highest second

- high measurement .)2015 Medford CO LMP

Page 5 Figure 2

. Medford Carbon Monoxide Trend 2nd h ighest 8

- hour a verage, 1977

- 200 9



### 4

. Limited Maintenance Plan Option

EPA developed the Limited Maintenance Plan (LMP) option for areas with little risk of re

- violating the carbon monoxide standard ( see 1995 Paisie Memo, Appendix 1 ) . EPA allows states to use this policy to prepare the required second 10

- year maintenance plans, if the monitoring data show the design value is at or below 85 percent of the 8

- hour CO standard, or 7.65 p pm

. Dete rmining the design value in this case is based on the higher of the two annual second highs in a two year calendar period. The Medford 8

- hour design value is 2.4 ppm , based on the two most recent years of data (200 8 and 2009 ) . This is 27 percent of the t he 8

- hour standard and far below the 85 percent level at which an area is eligible for the LMP option.

The LMP approach does not require future year emission projections or a maintenance demonstration. A LMP must include an attainment inventory, provisions for verification of continued attainment, a contingency plan and a statement regarding conformity determinations. Due t o the low measured CO values in Medford over the past 22 years, DEQ does not anticipate that CO levels will approach levels2015 Medford CO LMP

Page 6 th at would exceed or violate the 8

- hour CO standard , and as noted above, the Medford area has never exceeded the 1

- hour CO standard

. 

### 5

. Attainment Emission Inventory

The Medford a rea has met the National Ambient Air Quality Standards (NAAQS) for carbon monoxide (CO) since 1991

. In 2001 DEQ submitted the first Medford CO Maintenance Plan and requested that the area be redesignated to attainment. EPA approved that first Medford CO Maintenance Plan and redesignated the to attainment September 23, 2002

. The current Emissions Inventory describes emissions for 2008, and is part of this proposed second limited maintenance plan show ing that the area will continue to compl y with EPA requirements. The principal components addressed in this inventory include station ary point sources, stationary area sources, non

- road sources,

on

- road mobile sources, quality assurance implementation, and emissions summaries. The geographic focus for this 2008 emission inventory is the Medford CO Maintenance Area, which is defined as t he Medford Urban Growth Boundary (UGB) plus emissions from industrial sources within 25 miles

. The following table summarizes contributions by source category

. Emissions are reported for two time periods: annual emissions (in units of tons per year) and se asonal emissions (in units of pounds per day). A detailed breakdown of the 2008 CO emission inventory is provided in Appendix 2

.


### Table 2

. Medford UGB 2008 CO Annual and Seasonal Emissions Inventory

Annual CO Season Source Type tpy % of Category lbs /day % of Category Stationary Point Sources 2,376.1 15% 13,159 16% Stationary Area Sources 3,333.1 21% 30,399 37%

Non

- Road Mobile Sources 4,488.2 28% 10,061 12%
On

- Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%

Using the MOVES 2010b emission factor model for an average CO season 2008 day, on

- road mobile sources contribute 35% of the total CO air emissions in the Medford UGB. Gasoline vehicles contribute 97% of the CO emissions within the on

- road mobile category, whereas diesel vehicles contribute 3% of the on

- road mobile category.

Stationary area sources comprise 37% of the total CO air emissions in the Medford UGB on a CO season day. Within the area source category, residential wood combustion a ccounts for 49% of the emissions. Wood combustion in non

- certified woodstoves and inserts accounts for 28% of the total2015 Medford CO LMP

Page 7 area source emissions. Prescribed burning accounts for 47% of the total area source emissions on a CO season day.

Non

- road mobile sourc es contribute 12% of the total CO on an average CO season day. Within this category, 4

- cycle engines comprise 79% of the total emissions.

Permitted stationary point sources comprise 16% of the CO air emissions in the Medford UGB on an average CO season da y. This category includes permitted stationary sources with both federal T itle V and state A ir C ontaminant D ischarge Permits. There are 37 point sources within the Medford UGB and a 25

- mile buffer zone around the UGB.

Emissions summaries for CO have decr eased for both annual and season day as compared to the 1993 attainment year EI. Annual e missions have decreased 24%, and seasonal emissions have decreased 27% compared to the 1993 attainment year EI.

Figure 3. Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008

4
, 835

2
, 376 2
, 168

3
, 333 2
, 651 4
, 488 11,435

5
, 730

0 5
, 000 10
, 000 15
, 000 20
, 000 25
, 000

1993 2008Emissions (tpy) On

- road Mobile

Nonroad Sources

Area Sources

Permitted Point Sources2015 Medford CO LMP

Page 8 Figure 4. Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008

Details of the Oregon 2008 Medford UGB CO Limited Maintenance Plan Emission Inventory from point, area, non

- road, and on

- road mobile sources are presented in the full emission inventory included as Appendix 2 . The amount of annual and seasonal CO emission s from stationary point, stationary area, non

- road mobile, and on

- road mobile sources are shown in Figures 3 and 4

. 28
, 516

13
, 159 19,748

30
, 399 6
, 536 10
, 061 57
, 342

28
, 731

0 20
, 000 40
, 000 60
, 000 80,000 100
, 000 120
, 000

1993 2008Emissions (lbs/day) On

- road Mobile

Nonroad Sources

Area Sources

Permitted Point Sources2015 Medford CO LMP

Page 9 Figure 5

. 2008 Medford Annual CO Emissions

Figure 6

. 2008 Medford Season al CO Emissions 0 2
, 000 4
, 000 6
, 000

Stationary Point Sources Stationary Area Sources Non

- Road Mobile Sources On

- Road Mobile SourcesCO Emissions, tpy



### 0 15
, 000 30
, 000 45
, 000

Stationary Point Sources Stationary Area Sources Non

- Road Mobile Sources On

- Road Mobile SourcesCO Emissions, lbs/day2015 Medford CO LMP

Page 10 

### 6

. Continuing Control Measures

To qualify for the LMP option, the plan must include all control measures that were relied on to demonstrate attainment of the NAAQS

. The primary control measure has been the emission standards for new motor vehicles under the Federal Motor Vehicle Control Program. Other control measures have been the Motor Vehicle Inspection program, New Source Review program and a Woodstove Curtailment program.

Federal Motor Vehicle Emission Control Program

This limited maintenance plan continues to rely on federal emission sta ndards for new motor vehicles. These requirements include the federal Tier II emission standards for new light and medium duty cars and trucks as well as standards for heavy duty on

- road and non

- road vehicles.

As noted in Table 2 above, o n

- r oad m obile s ources are responsible for the highest annual CO concentrations in Medford

. That is because cars and trucks moving through an area can assemble in significant numb ers at areas of heavy traffic. The h igh est CO con centrations typically occur in a small region near a congested intersection as CO dissipates quickly as it moves away from its point of emission.

Emission reductions mandated by the Federal Motor Vehicle Emission Control Program have been primarily responsible for the large decrease in ambient CO concentrations in the past. Before CO emissions were regulated, a typical car of the 1950s emitted approxim ately 87 grams of CO per mile. Since then, federal rules have lowered CO emissions to the point where today’s federal Tier II requiremen ts limit cars to no more than 3.4 grams CO per mile

- a 95% reduction of CO. This program will continue to be an effective control for o n

- r oad m obile s ource emissions in the future.

Major New Source Review

Under this limited maintenance plan, the e mission control requirement for new or expanding major industry in Medford area will continue to require Best Available Control Technology (BACT). BACT technology provides a high level of control while allowing some flexibility and consideration of the

cos t effectiveness of different control options.

Motor Vehicle Inspection Program

Oregon’s Vehicle Inspection Program (VIP) will continue to operate in the Medford area. Gasoline and light duty diesel vehicles up to 20 years old that are registered in the Medford

- Ashland Air Quality Maintenance Area will continue to be subject to emissions testing and inspection when vehicle registrations are renewed. This p rogram has operated since 1986 and has effectively reduced CO emissions by promoting proper vehicle maintenance.2015 Medford CO LMP

Page 11 Wood smoke Curtailment

As noted in the previous section, residential wood combustion is a leading source of CO emissions from stationary area sources

. However these sources of DO emissions are distributed widely and do
not concentrate as on

- road CO emissions can. These emission sources do not mov e and therefore contribute to a diffuse, low

- level background concentration of CO. A s shown in Tabl e 2, stationary

area sources represent 2 1 percent of the total annual and 37 percent of season al CO emissions in Medford

. W oodsmoke emission control efforts have significantly reduced emissions through emission certification standards for new stoves, woodstove change

- out programs to encourage removal of non

certified stoves, and a local voluntary curtailment program to reduce wood burning during stagnant weather periods. These efforts will be continued under this limited maintenance plan, and are expec ted to provide modest reductions in CO emissions in Medford

. Conformity requirements

F ederal t ransportation c onformity rules (4 0 CFR 51 .390 and 93 .100 et. seq. ) and g eneral c onformity rules (40 CFR 51.851 and 93.150 et. seq. ) continue to apply under a limited maintenance plan

. However, as noted in the Paisie Memo these requirements are greatly simplified. U nder a LMP vehicle emissions are not considered to be constraining so a Motor Vehicle E missions B udget is not required . During future transportation conformity determinations, regional emissions analyses are not required (including modeling) as vehicle emissions are assumed to comply. 2

2 See Paise Memo in Appendix 1 for additional information on conformity requi rements

.2015 Medford CO LMP

Page 12 

### 7. Verification of Continued Attainment

As described in this plan, CO levels in the Medford UGB have declined progressively since 1991. CO concentrations a re not expected to increase significantly or threaten compliance with the CO standard. Because the Medford CO monitor was removed after 2009, DEQ implemented an alternate method of verifying conti nued attainmen t with the CO standard

. The proposed limited maintenance plan will change the way Medford’s continued attainment is verified. DEQ will calculate CO emissions every three years as part of the Statewide Emission Inventory, which is submitted to EPA for inclusion in the National Emission Inventory (NEI). DEQ will review the NEI estimates to identify increases over the 2008 emission levels and report on them in the annual network plan for the appl icable year. Because on

- road motor vehicles and stationary

are a sources emit the most CO in Medford, th ese categor ies will be the focus of this review. Any increase in CO emissions will be evaluated by DEQ to verify it is not due to a change in emission

ca lculation methodology, an exceptional event, or other factor not representative of an actual emissions increase. DEQ will consider a 10 percent increase over 2008 emission levels to be a “significant” emission increase for the purpose of triggering the Con tingency Plan described in Section 8. Emission categories to be assessed for a significant increase are the total annual emissions, total seasonal emissions, annual or seasonal on

- road emissions plus annual or seasonal area source emissions.



### 8

. Conti n gency Plan

Section 175(A) of the Clean Air Act requires a maintenance plan to include contingency measures necessary to ensure prompt correction of any future violation of the the air quality standard. The first Medford maintenance plan contained continge ncy measures that would be implemented based on monitoring data

-- i f CO concentrations exceeded 90 percent of the 8

- hour standard (8.1 ppm) or if a violation of t he standard were to occur. After the Medford CO monitor was removed in 2009
, an alternate method of triggering the contingency measures was implemented.

Under the proposed limited maintenance plan a different Contingency Plan will apply. The new plan has three levels of action depending on the severity of the circumstances :

Phase 1. I f DEQ ’s three

- year periodic review of CO emissions s hows a significant increase in emissions, as described in Section 7 of this plan

, DEQ will re sume monitoring ambient CO in Medford

.

Phase 2. If the highest measured 8

- hour CO concentration in a given year in Medford e xceeds 7.65 pp m ( the level at which an area is eligible for a Limite d Maintenance plan)

, DEQ will evaluate the cause of the CO increase, and consider forming an advisory committee to recommend corrective strategies

. Within 6 months of the validated 7.65 pp m or higher CO concentration, DEQ will prepare2015 Medford CO LMP

Page 13 a list of strategies to prevent or correct a violation of the 8

- hour CO standard. This list is to facilitate a choice of strategies that might be implemented to reduce ambient CO concentrations

. The contingency strategies that will be considered include, but are not limited to:

• Improvements to parking and traffic circulation

• Aggressive signal retiming program

• Increased transit f unding

• More stringent vehicle Inspection/Maintenance requirements, and

• Accelerated bicycle and pedestrian improvements.

DEQ (and the advisory group if needed) may also choose to conduct further evaluation, to determine if other strategies are necessary, or to take no further action i f the problem was caused by an exceptional event.

Phase 3. If a violation of the CO standard occurs , and is validated by DEQ, in addition to Phase 2 above, DEQ will replace the requirement for new and expanding industry to apply Best Achievable Control Technlogy ( BACT ) with the requirement to apply Lowest Achievable Emission Rate ( LAER ) technology . In addition

, DEQ will reinstate the requirement for new and ex panding industry t o offset any new CO emissions. More CO emission reduction measures identified in the evaluation of contingency Phase 2 may also be considered. Committing to further study in this way gives DEQ flexibility in choosing an appropriate approach should the need arise.

## Appendix 1 - EPA 1995 Paisie MemoAppendix 2

- 2015 Medford CO LMP

Page i (DRAFT) 

## Appendix 2 To Medford 2015 CO Limited Maintenance Plan

2008 Year Emission Inventory For Carbon Monoxide (CO)

Medford Urban Growth Boundary

June 2015

Oregon Department of Environmental Quality Environmental Solutions Division Air Quality Technical Services Section 811 SW 6 th Avenue Portland, Oregon 97204Appendix 2

- 2015 Medford CO LMP

Page ii 

## Table of Contents
Table of Contents

................................ ................................ ................................ .................. ii Table of Figures

................................ ................................ ................................ ..................... v Table of Tables

................................ ................................ ................................ ...................... vi 1 Executive Summary

................................ ................................ ................................ ......... 2 2 Introduction

................................ ................................ ................................ .................... 6 2.1 Purpose of the Report

................................ ................................ ................................ ..... 6

2.2 Inventory Time Frame and Area Covered

................................ ................................ ....... 6

2.3 Report Contents

................................ ................................ ................................ .............. 9

2.4 Automated Systems

................................ ................................ ................................ ...... 10

2.5 So urces Not Inventoried

................................ ................................ ............................... 10

2.6 Guidance Documents

................................ ................................ ................................ .... 10

2.7 Contact Personnel

................................ ................................ ................................ ......... 11

3 Medf ord Carbon Monoxide Attainment Area Inventory

................................ ................. 13 3.1 Inventory Area Maps and Descriptions

................................ ................................ ........ 13

3.1.1 Inventory Area Maps

................................ ................................ .............................. 13

3. 1.2 Legal Descriptions

................................ ................................ ................................ ... 17

3.1.2.1 Legal Description of Medford Urban Growth Boundary / CO Inventory Area 17

3.1.2.2 Legal Description of Open Burning Control Areas

................................ ........ 18

3.1.2.3 Legal Description of Medford Area Woodstove Curtailment Ordinance / Critical PM10 Control Area

................................ ................................ ............................... 19

3.1.2.4 Legal Description of the Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary

................................ ................................ ............. 19

3.2 Summary of Emissions Data

................................ ................................ .......................... 20

3.3 Stationary Permitted Point Sources

................................ ................................ .............. 23

3.3.1 Introduction

................................ ................................ ................................ ............ 23

3.3.2 Geographic Area and Sources Included

................................ ................................ .. 23

3.3.3 Point Source Determination

................................ ................................ ................... 23

3.3.3.1 2008 Point Source Determination

................................ ................................ 24

3.3.4 Methodology and Approach

................................ ................................ ................... 25

3.3.4.1 Data Collection

................................ ................................ .............................. 25

3.3.4.2 Emission Basis

................................ ................................ ............................... 25

3.3.4. 3 Activity Data

................................ ................................ ................................ .. 25Appendix 2

- 2015 Medford CO LMP

Page iii 3.3.4.4 Plant Site Emission Limits (PSELs)

................................ ................................ . 26

3.3.4.5 Annual Emissons Calculations

................................ ................................ ....... 26

3.3.4.5.1 Emissions Estimation Methodologies for TV Sources

................................ . 26

3.3.4.5.2 Emissions Estimation Methodlogies for ACDP Sources

.............................. 26

3.3.4.6 Seasonal Emissions Calculations

................................ ................................ ... 27

3.3.4.6.1 Seasonal Adjustment Factors

................................ ................................ ...... 27

3.3.4.6.2 Season Day Emissions Calculations

................................ ............................. 27

3.3.5 Summary of Stationary Point Source Emissions

................................ ..................... 29

3.3.6 Control Efficiency (CE) and Rule Effectiveness (RE)

................................ ................ 30

3.4 Stationary Nonpoint (Area) Sources

................................ ................................ ............. 31

3.4.1 Introduction and Scope

................................ ................................ ........................... 31

3.4.2 Methodology and Approach

................................ ................................ ................... 31

3.4.2.1 Source Category Identification and General Methodology Overview

......... 31

3.4.2.2 Reconciliation with Point Source Emissions (double count prevention)

...... 32

3.4.3 Discussion of Area Source Categories

................................ ................................ ..... 32

3.4.3.1 Waste Disposal, Treatment and Recovery

................................ .................... 32

3.4.3.1.1 Incineration

................................ ................................ ................................ . 32

3.4.3. 1.1.1 Industrial Incineration

................................ ................................ ........................ 32

3.4.3.1.1.2 Commercial/Institutional Incineration

................................ .............................. 33

3.4.3.1.1.3 Residential Incineration

................................ ................................ ..................... 33

3.4.3.1.2 Open Burning

................................ ................................ .............................. 33

3.4.3.1.2.1 Industrial Open Burning

................................ ................................ ..................... 33

3.4.3.1.2.2 Commercial/Institutional Open Burning

................................ ............................ 33

3.4.3.1.2.3 Residential Open Burning (back yard burning)

................................ .................. 34

3.4.3.2 Small Stationary Fossil Fuel and Wood Use

................................ .................. 35

3.4.3.2.1 Fuel Oil Combustion

................................ ................................ .................... 35

3.4.3.2.2 Natural Gas (NG) and Liquified Petroleum Gas (LPG)

................................ . 36

3.4.3.2.3 Coal and Biomass C ombustion

................................ ................................ .... 37

3.4.3.3 Residential Wood Combustion

................................ ................................ ..... 38

3.4.3.4 Miscellaneous Area Sources

................................ ................................ ......... 38

3.4.3.4.1 Forest Wildfires

................................ ................................ ........................... 38Appendix 2

- 2015 Medford CO LMP

Page iv 3.4.3.4.2 Prescribed Burning

................................ ................................ ...................... 38

3.4.3.4.3 Structure Fires

................................ ................................ ............................. 39

3. 5 Nonroad Vehicles and Equipment

................................ ................................ ................ 55

3.5.1 Introduction and Scope

................................ ................................ ........................... 55

3.5.2 Nonroad Vehicles and Equipment

................................ ................................ .......... 55

3.5.2.1 Vehicle Categories

................................ ................................ ........................ 55

3. 5.2.2 Methodology

................................ ................................ ................................ . 55

3.5.3 Aircraft and Airport Operations Emissions

................................ ............................. 56

3.5.4 Waterborne Vessels

................................ ................................ ................................ 56

3.5. 5 Rail

................................ ................................ ................................ ........................... 56

3.6 On

- Road Mobile Sources

................................ ................................ .............................. 72

3.6.1 Introduction and Scope

................................ ................................ ........................... 72

3.6.2 Spatial and Temporal Allocation of 2008 NEI Data

................................ ................. 72

3.6.2.1 Spatial Allocation

................................ ................................ .......................... 72

3.6.2.2 Temporal Allocation

................................ ................................ ...................... 72

3.6.3 Summary of On

- Road Mobile Source Emissions

................................ .................... 72

4 Quality Assurance and Quality Control

................................ ................................ .......... 78 4.1 Introduction

................................ ................................ ................................ .................. 78

4.2 Organization and Personnel

................................ ................................ .......................... 78

4.3 Data Collection and Analysis

................................ ................................ ......................... 79

4.3.1 Data Collection and Analysis

................................ ................................ ................... 79

4.4 DATA HANDLING

................................ ................................ ................................ ........... 79

4.5 Data Coding and Recording

................................ ................................ .......................... 79

4.6 Data Tracking

................................ ................................ ................................ ................ 79

4.7 QA/QC Procedures

- Checking and Correcting

................................ ............................. 80

4.7.1 Checking Data

................................ ................................ ................................ ......... 80

4.7.1.1 Inventory Completeness

................................ ................................ ............... 80

4.7.1.2 Missing Data

................................ ................................ ................................ .. 80

4.7.1.3 Incorrect Calculations

................................ ................................ ................... 80

4.7.1.4 Incorrect Information

................................ ................................ ................... 81

4.7.1.5 Reasonableness

................................ ................................ ............................. 81

4.7.1. 6 Emissions Summary Reasonableness

................................ ........................... 81Appendix 2

- 2015 Medford CO LMP

Page v 4.8 Data Reporting

................................ ................................ ................................ .............. 81

5 Referenc es
................................ ................................ ................................ .................... 82 6 Appendices to the Emission Inventory

................................ ................................ ........... 84



## Table of Figures Executive Summary, Figure 1: 2008 Medford UGB annual CO emissions, percentage by source catego ry 3 Executive Summary, Figure 2: 2008 Medford UGB CO season day emissions, percentage by source category

................................ ................................ ................................ ................................ ........................ 3 Executive Summary, Figure 3: Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008

.................... 4 Executive Summary, Figure 4: Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008

............. 5

Figure 1: Medford Urban Growth Boundary

................................ ................................ ................................ 7 Figure 2: 2008 Medford CO LMP, 25

- mile buffer and permitted point source locations

............................. 8 Figure 3: Open Burning Control Areas and Rog ue Basin Open Burning Control Area

................................ 14 Figure 4: Woodstove Curtailment Ordinance Area / Critical PM 10 Control Area

................................ ....... 15 Figure 5: Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary

........ 16 Figure 6: Distribution of 2008 Annual CO Emissions

................................ ................................ .................. 20 Figure 7: Annual CO Emissions by Percentage

................................ ............... Error! Bookmark not defined. Figure 8: Distribution of 2008 Season Day CO Emissions

................................ ................................ ........... 21 Figure 9: Season Day CO Emissi ons by Percentage

................................ ................................ ..................... 21 Figure 10: 2008 Commercial Open Burning Locations

................................ ................................ ................ 34 Figure 11: 2008 Residential Open Burning Locations

................................ ................................ ................. 35 Figure 12: Area Source Annual Emissions by Percentage

................................ ................................ ........... 40 Figure 13: Area Source Season Day Emission s By Percentage

................................ ................................ .... 40 Figure 14: Distribution of Medford UGB Annual Nonroad Source CO Emissions, 2008

............................. 58 Figure 15: Percentage of Medford Annual Nonroad CO Source Emissions, 2008

................................ ...... 58 Figure 16: Distribution of Medford CO Season Day Nonroad Source Emissions, 2008

.............................. 59 Figure 17: Percentage of Medford UGB CO Season Day Nonroad Source Emission, 2008

........................ 59

Appendix A, Figure A

- 1: 2008 Medford CO LMP Permitted Point Source Locations

................................ . 86

Append ix B, Figure B

- 1: Wildfire and Prescribed Burn Location and Date

................................ ................ 92Appendix 2

- 2015 Medford CO LMP

Page vi 

## Table of Tables Executive Summary, Table 1 Medford UGB 2008 Estimated CO Emissions Contribution by Source Category.

................................ ................................ ................................ ................................ ....................... 2

Table 2.1: Summary of 2008 CO Emissions Data

................................ ................................ ........................ 22

Table 2.3. 1: 1993 Attainment Year Inventory List of Permitted Point Sources

................................ ......... 24 Table 2.3. 2: Medford UGB CO Season: Summary of Point Source Emissio ns by SIC

................................ . 29 Table 2.3. 3: Medford UGB CO Season, Summary of Top 5 :Point Source Emitters

................................ ... 30

Table 2.4. 1: Medford 2008 CO EI Summary of Estimation Procedures for Area Sources

......................... 41 Table 2.4. 2: Medford 2008 CO EI Summary of Emissions Estimates for Area Sources

............................. 41 Table 2.4. 3: Area Source Emissions From Fuel Oil Use

................................ ................................ .............. 42 Table 2.4. 4: Area Source Emissions From Natural Gas (NG) Use

................................ ............................... 43 Table 2.4. 5: Area Source Emissions From Liquified Petroleum Gas (LPG) Use

................................ .......... 45 Table 2.4. 6: Area Source Emissions From Residential Wood Combustion

................................ ................ 47 Table 2.4. 7 : Area Source Emissions From Wildfires

................................ ................................ ................... 48 Table 2.4. 8: Area Source Emissions From Prescribed (RX) Burning

................................ ........................... 49 Table 2.4. 9: Area Source Emissions From Structure Fires

................................ ................................ ......... 50 Table 2.4. 10: Area Source Emissions From Residential Open Burning

................................ ...................... 51 Table 2.4. 11: Area Source Emissions From Industrial Open Burning

................................ ......................... 52 Table 2.4. 12: Area Source Emissions From Commercial/Institutional Open BUrning

............................... 52 Table 2.4. 13: Area Source Emissions From Coal Use

................................ ................................ ................. 53 Table 2.4. 14: Area Source Emissions From Biomass Burning

................................ ................................ ... 54

Table 2.5. 1: Medford UGB 2008 CO Summary of Emissions from Nonroad Sources

................................ 60 Table 2.5. 2: Medford UGB 2008 CO, Summary of Emissions from Nonroad Gasoline Vehicles * Equipment, 2

- Cycle

................................ ................................ ................................ ................................ ..... 61 Table 2. 5. 3. 2008 Medford UGB CO: Summary of Emissions from Nonroad Gasoline Vehicles and Equipment, 4

- Cycle

................................ ................................ ................................ ................................ ..... 63 Tabl e 2. 5. 4. 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG/LPG Vehicles and Equipment

................................ ................................ ................................ ................................ ................... 65 Table 2. 5. 5. 2008 Medford UG B CO: Summary of Emissions from Nonroad Diesel Vehicles and Equipment

................................ ................................ ................................ ................................ ................... 67 Table 2.5. 6. 2008 Medford UGB CO: Summary of Emissions from Aircraft and Airport GSE

.................... 69 Table 2.5. 7. 2008 Medford UGB CO: Summary of Emissions from Railroads

................................ ............ 71

Table 2.6. 1. 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Vehicle Type

.............. 75 Table 2.6. 2. 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Road Type

.................. 77

Appendix A, Table A

- 1: Stationary Point Source Determination for 2008 CO Inventory

.......................... 87 Appendix A, Table A

- 2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory

........... 87 Appendix A, Table A

- 3: Stationary Point Source Emission Estimation Details

................................ ........... 89

Appendix B, Table B

- 1: GIS Allocation Results: Josephine County Zones, County

- Wide and by UGB

...... 93Appendix 2

- 2015 Medford CO LMP

Page ii 

## 1 Executive Summary
The Medford Carbon Monoxide (CO) Maintenance Area has met the National Ambient Air Quality Standards (NAAQS) for carbon monoxide. In accordance with the 1990 Federal Clean Air Act Amendments, the area has been redesignated to attainment status through the development of a Redesignation Request / Maintenance Plan. Th is limited maintenance plan inventory is for 2008, and is provided as part of the maintenance plan package to show compliance with published EPA requirements. The principal components for development and documentation that have been addressed in this inventory include stationary point sources, stationary area sources, non

- road sources, on

- road mobile sources, quality assurance implementation, and emissions summaries. The geographic focus for this 2008 emission inventory is the Medford CO Maintenance A rea, which is defined as the Medford Urban Growth Boundary (UGB).

The following table summarizes contributions by source category for annual and seasonal CO emissions within the Medford UGB for 2008.

Executive Summary, Table 1 Medford UGB 2008 Estimated CO Emissions Contribution by Source Category.


### Annual CO Season Source Type tpy % of Category lbs/day % of Category Stationary Point Sources 2,376.1 15% 13,159 16% Stationary Area Sources 3,333.1 21% 30,399 37%

Non

- Road Mobile Sources 4,488.2 28% 10,061 12%
On

- Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%

During the average CO season 2008 day, on

- road mobile sources contribute 35% of the total carbon monoxide (CO) air emissions in the Medford UGB. Gasoline vehicles contribute 97% of the CO emissions within the on

- road mobile category, whereas diesel vehicles contribute 3% of the on

- road mobile category.

Stationary area sources comprise 37% of the total CO air emissions in the Medford UGB on a CO season day. Within the area source category, residential wood combustion accounts for 49% of the emissions. Wood combustion in non

- certified woodstoves and inserts accounts for 28% ofAppendix 2

- 2015 Medford CO LMP

Page 2 the total area source emissions. Prescribed burning accounts for 47% of the total area source emissions on a CO season day. Non

- road mobile sources contribute 12% of the total CO on an average winter day. Within this category, 4

- cycle engines comprise 79 % of the total emissions.

Permitted stationary point sources comprise 16% of the CO air emissions in the Medford UGB on an average CO season day. This category includes permitted stationary sources with both federal TV and state ACDP permits. There are 37 point sources within the Medford UGB and a 25

- mile buffer zone around the UGB.

Emissions summaries for CO have decreased for both annual and season day as compared to the 1993 attainment year EI. Emissions have decreased 24% annually, and 27% for a se ason day as compared to the 1993 attainment year EI.

Details of the Oregon 2008 Medford UGB CO Limited Maintenance Plan Emission Inventory from point, area, non

- road, and on

- road mobile sources are presented in the following document. The relative percen tage of annual and seasonal CO emissions from stationary point, stationary area, non

- road mobile, and on

- road mobile sources are shown in the Ex ecutive Summary Figures 1 through 4Appendix 2

- 2015 Medford CO LMP

Page 3 Executive Summary, Figure 1 : 2008 Medford UGB annual CO emissions, percentage by source category

Executive Summary, Figure 2 : 2008 Medford UGB CO season day emissions, percentage by source category Stationary Point Sources 14 %

Stationary Area Sources 26 %

Non

- Road

Mobile Sources

26 % On

- Road

Mobile Sources

34 %

Stationary Point Sources 16 %
Stationary Area Sources 37 %

Non

- Road

Mobile Sources

12 % On

- Road Mobile Sources

35 %Appendix 2

- 2015 Medford CO LMP

Page 4 Executive Summary, Figure 3 : Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008 4
, 835

2
, 376 2
, 168

3
, 333 2
, 651 4
, 488 11,435

5
, 730



### 0 5
, 000 10
, 000 15
, 000 20
, 000 25
, 000

1993 2008Emissions (tpy) 

### On

- road Mobile

Nonroad Sources

Area Sources

Permitted Point SourcesAppendix 2

- 2015 Medford CO LMP

Page 5 Executive Summary, Figure 4 : Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008 28
, 516

13
, 159 19,748

30
, 399 6
, 536 10
, 061 57
, 342

28
, 731

0 20
, 000 40
, 000 60
, 000 80,000 100
, 000 120
, 000

1993 2008Emissions (lbs/day) 

### On

- road Mobile

Nonroad Sources

Area Sources

Permitted Point SourcesAppendix 2

– 2015 Medford CO LMP 6 

## 2 Introduction

2.1 Purp ose of the Report The Clean Air Act Amendments (CAAA) of 1990 authorized the U.S. Environmental Protection Agency (EPA) to designate nonattainment areas with respect to the National Ambient Air Quality Standards (NAAQS). Under the 1990 CAAA, pre

- enactment carbon monoxide nonattainment areas were classified according to the severity of nonattainment. Each state was required to submit a list designating nonattainment areas within the state.

Oregon submitted a list of areas that were in nonattainment to EPA on 15 March 1991. The area within the Medford Urban Growth Boundary was listed as nonattainment for carbon monoxide (Medford UGB / NAA). The nonattainment area had a design value of 7.5 parts per million (ppm) for carbon monoxide, and exceeded the NAAQS in the period 1977 through 1991. The NAAQS limit is 9 ppm, but it must reach 9.5 ppm to be considered an exceedance. The highest recorded CO value measured in Medford was 21.8 ppm at the Brophy building site in 1977. Previous nonattainment boundaries in cluded the entire Medford Air Quality Maintenance Area (AQMA) under former Governor Straub in 1978. Due to hot spot problems within the downtown region of Medford in 1982, the nonattainment area was revised to include only the central business district. The nonattainment area was again modified in 1992 when the Federal Register promulgated the designation of the Medford UGB / NAA as nonattainment for CO on November 30, 1992 by letter from Governor Roberts.

The emission inventory area for the Medford CO n onattainment area was delineated as the Medford UGB in the Inventory Preparation Plan (IPP) submitted September 15, 1997. The Oregon CO IPP was approved by EPA Region X on June, 10, 1998 by letter from Joan Cabreza. This document fulfills the EPA require ments for preparing the limited maintenance plan 2008
y ear emission inventory, specified in the provisions of the 1990 CAAA, and EPA guidance documents.



### 2.2 Inventory Time Frame and Area Covered The 2008 limited maintenance plan inventory covers carbon monoxide emissions for the Medford Urban Growth Boundary (UGB) maintenance area. 2008 was chosen as the bse year because it is the most recent National Emission Inventory (NEI) year for which the DEQ has PM2.5 monitoring data for the Medford area. Emissions are reported in this inventory for two representative time periods: Annual Emissions (in units of “tons per year”) and Seasonal Emissions (in units of “pounds per day”). Annual emissions represent CO e missions generated over th e 2008 Maintenance Year. Seasonal emissions represent CO emissions generated on an

avera ge day in a three

- month period

- called the CO season

- when ambient CO accumulations are typically the highest. For the Medford UGB, the CO Season is defined as the pe riod of three consecutive months: December through February

.Appendix 2

– 2015 Medford CO LMP Page 7 The ge ographic area of the Medford UGB is shown in Figure 1

. Figure 2 shows boundaries used for the permitted point source section of the 2008 emission inventory

. As in the 1993 attainment ye ar inventory, a 25

- mile buffer zone is the starting point for point source boundary definition. The 25

- mile extension to the UGB area includes incorporated and unincorporated Jackson County and a part of Josephine County. Populated areas within the 25 mi le buffer included in this inventory are Medford, Rogue River, Grants Pass, and White City.

Figure 1 : Medford Urban Growth BoundaryAppendix 2

– 2015 Medford CO LMP Page 8 Figure 2 : 2008 Medford CO LMP, 25

- mile buffer and permitted point source locationsAppendix 2

– 2015 Medford CO LMP Page 9 

### 2.3 Report Contents The Report is divided into the following components :

Part 1: Introduction to the Report
Part 2: Medford CO 2008 Limited Maintenance Plan Emission Inventory
Part 3: Quality Assurance and Quality Control
Part 4: References
Part 5: Appendices

 Part 1 provides an introduction to this Report and its purpose. Contents of the Report are briefly described. Information concerning automated systems is included. Sources not inventoried for the inventory are described along with a rationale for the exclusio ns. EPA procedure and guidance documents used in preparing the inventory are described. Finally, information on the personnel responsible for the preparation of the inventory is outlined.  Part 2 describes in detail the methodologies and approaches taken to estimate emissions in the Medford UGB for the 2008 Limited Maintenance Plan inventory. Part 2 is divided into sections describing the inventory process and the types of emission sources that are addressed in the inventory, as follows:  Section 1.0 p rovi des maps of open burning control areas and the Medford

Ashland Air Quality Maintenance Area / Vehicle Inspection Boundary. These maps are included for consistency with the 1993 Medford CO Attainment Year I nventory . This section also provides legal descri ptions of the inventory and open burning control areas, as well as the AQMA/VIP boundary.

 Section 2.0 contains summary tables for stationary point, stationary area,

non

- road mobile, and on

- road mo bile sources in the Medford UGB.

 Section 3.0 contains a di scussion of the stationary point source emission category methodology and emissions estimate approach. Tables summarizing point source emissions estimates follow the discussion.

 Section 4.0 addresses stationary area sources and contains a discussion of
t he approaches used in estimating emissions. Each area source category inventoried is described in detail, including the methodology used in making the calculations. Tables summarizing stationary area source emissions estimates follow the discussion.

 Section 5.0 provides a discussion of the approach and methodology used in evaluating emissions from non

- road mobile sources. Tables summarizing

non

- road mobile source emissions estimates follow the discussion.Appendix 2

– 2015 Medford CO LMP Page 10  Section 6.0 provides a description of the app roach and methodology used in evaluating emissions from on

- road mobile sources. Tables summarizing on

road mobile source emissions estimates follow the discussion.  Part 3 describes the quality assurance procedure s utilized in preparing the 2008 inventory.  Part 4 contains an extensive list of referen ces utilized for the Medford CO emission inventory.  Part 5 contains A ppendices with supplemental data used to estimate emissions.

Tables and figures for each emission category are located at the end of the discussion section for that category. For example, summary emission tables for all stationary point source types in the Medford UGB are located at the end of Part 2, Section 3. Please note that some references listed in the tables are numbered as ‘DEQ ma ster references’ (See Part 5 for this classification at the end of each entry).



### 2.4 Automated Systems The inventory has been assembled by the staff of the Technical Services Section, Air Quality Division of the Oregon Department of Environmental Quality (DEQ) , and by Sierra Research, a consulting firm specializing in air quality and pollution control . The point source emissions are specifically drawn from the DEQ Tracking Reporting and Administration of Air Contaminant Sources (TRAACS) database. The TRAACS d ata is used for tracking compliance with plant site emission limits and for reporting compliance status to the EPA EIS system. TRAACS is also used to store actual emi ssion data also reported to EIS. TRAACS contains annual emission levels for each permitt ed point source as well as, emission factors, and annual activity levels (fuel use and production levels). Nonpoint emissions, except where indicated, were extracted from the EPA Emission Inventory System (EIS) EIS Gateway. The EPA EIS database houses Nati onal Emissions Inventory (NEI) data that includes submittals from states.



### 2.5 Sources Not Inventoried For consistency, the 1993 attainment year emission inventory was used as a reference, and all sources in the 1993 inventory are addressed in the 2008 inventor y. Calculations and methodology for sources emitting 0 emissions during a typical CO season day are included in the 2008 inventory as well.



### 2.6 Guidance Documents For consistency, DEQ and Sierra followed the format and outline of the 1993 Medford UGB CO Attai nment Year Emission Inventory 1

. For those sources inventoried by DEQ, inventory methodology followed applicable EPA procedure and guidance documents. Two primary documents utilized were Procedures for the Preparation of Emission Inventories for Carbon Mon oxide and Precursors of Ozone, Volume I 3 , and Emission Inventory Requirements for Carbon Monoxide State Implementation Plans 2

.Appendix 2

– 2015 Medford CO LMP Page 11 

### 2.7 Contact Personnel Due to existing workload and staffing commitments, DEQ entered into an agreement with the Rogue Valley Council of Governments (RVCOG) and Sierra Research for assistance with the Medford CO LMP emission inventory ( please see Appendix C for the work proposal from Sierra ).

The work breakdown was as follows:

• DEQ

o Permitted point sources

o Open burning

o Wildfires and prescribed burning

• RVCOG/Sierra Research

o Small, stationary fuel combustion (non

- permitted)

o Residential wood combustion

o Structure fires

o Aircraft and airport related

o Locomotives

o Recreational marine

o Nonroad vehicles & equipment

o On

- road mobile (exhaust)

The a bbreviated list of those conducting this Medford 2008 Limited Maintenance Plan emission inventory is shown below:

DEQ Wendy Wiles Environmental Solutions Division Administrator

Jeffrey Stocum
, Air Quality Technical Services Manager Emission Inventory Christopher Swab, Senior Emission Inventory Analyst Brandy Albertson , Emission Inventory Analyst Miyoung Park , Emission Inventory Specialist Wayne Kauzlarich, ACDP Permit Writer Dana Bailey, Permit Coordinator Quality Assurance Wesley Risher, Emission Inventory Analyst David Collier
, Air Quality Planning Manager Dave Nordberg
, Air Quality Planner

Sierra Research Tom Carlson, Principal ScientistAppendix 2

– 2015 Medford CO LMP Page 12 Wenxian Zhang, Associate Engineer

Starcrest Consulting Group, LLC Wayne Elson, Air Quality Planner and Mobile Source Emissions Expert

Rogue Valley Council of Governments Dan Moore, Planning Coordinator, AICPAppendix 2

– 2015 Medford CO LMP Page 13 

## 3 Medford Carbon Monoxide Attainment Area Inventory

3.1 Inventory Area Maps and Descriptions

3.1.1 Inventory Area Maps The following maps are presented here for consistency with the Medford CO 1993 Attainment Year SIP Emissions Inventory 1 :

• Figure 1 (previous): Medford UGB Carbon Monoxide Attainment Area

• Figure 2 (previous): Medford UGB with 25

- mile point source buffer zo ne

• Figure 3: Open Burning Control Areas as defined in (OAR) 340

- 264

- 0078(1) and Rogue Basin Open Burning Control Area as defined in 340

- 264

- 0078(3)

• Figure 4: Woodstove Curtailment Ordinance Area / Critical PM 10 Control Area

• Figure 5: Medford

- Ashland Air Qu ality Maintenance Area / Vehicle Inspection Program BoundaryAppendix 2

– 2015 Medford CO LMP Page 14 Figure 3 : Open Burning Control Areas and Rogue Basin Open Burning Control AreaAppendix 2

– 2015 Medford CO LMP Page 15 Figure 4 : Woodstove Curtailment Ordinance Area / Critical PM 10 Control AreaAppendix 2

– 2015 Medford CO LMP Page 16 Figure 5 : Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program BoundaryAppendix 2

– 2015 Medford CO LMP Page 17 

### 3.1.2 Legal Descriptions

3.1.2.1 Legal Description of Medford Urban Growth Boundary / CO Inventory Area Lega l description of the Medford Urban Growth Boundary Attainment Area as adopted by Oregon DEQ define the boundaries as shown in Figure 1 and can be found in the Oregon Administrat ive Rules (OAR) 340

- 204

- 0010(12):

(12) “Medford UGB” means the area beginning at the line separating Range 1 West and Range 2 West at a point approximately 1/4 mile south of the northwest corner of Section 31, T36S, R1W; thence west approximately 1/2 mile; thence south to the north bank of Bear Creek; thence west to the south bank o f Bear Creek; thence south to the intersection with the Medford Corporate Boundary; thence following the Medford Corporate Boundary west and southwesterly to the intersection with Merriman Road; thence northwesterly along Merriman Road to the intersection with the eastern boundary of Section 10, T36S, R2W; thence south along said boundary line approximately 3/4 mile; thence west approximately 1/3 mile; thence south to the intersection with the Hopkins Canal; thence east along the Hopkins Canal approximately 200 feet; thence south to Rossanely Drive; thence east along Rossanely Drive approximately 200 feet; thence south approximately 1200 feet; thence west approximately 700 feet; thence south approximately 1400 feet; thence east approximately 1400 feet; thenc e north approximately 100 feet; thence east approximately 700 feet; thence south to Finley Lane; thence west to the end of Finley Lane; thence approximately 1200 feet; thence west approximately 1300 feet; thence north approximately 150 feet; thence west ap proximately 500 feet; thence south to Highway 238; thence west along Highway 238 approximately 250 feet; thence south approximately 1250 feet to a point even with the end of Renault Avenue to the east; thence east approximately 2200 feet; thence south
appr oximately 1100 feet to a point even with Sunset Court to the east; thence east to and along Sunset Court to the first (nameless) road to the south; thence approximately 850 feet; thence west approximately 600 feet; thence south to Stewart Avenue; thence we st along Stewart Avenue approximately 750 feet; thence south approximately 1100 feet; thence west approximately 100 feet; thence south approximately 800 feet; thence east approximately 800 feet; thence south approximately 1000 feet; thence west approximate ly 350 feet to a point even with the north

- south connector street between Sunset Drive and South Stage Road; thence south to and along said connecting road and continuing along South Stage Road to Fairlane Road; thence south to the end of Fairlane Road and extending beyond it approximately 250 feet; thence east approximately 250 feet; thence south approximately 250 feet to the intersection with Judy Way; thence east on Judy Way to Griffin Creek Road; thence north on Griffin Creek Road to South Stage Road; t hence east on South Stage Road to Orchard Home Drive; thence north on Orchard Home Drive approximately 800 feet; thence east to Columbus Avenue; thence south along Columbus Avenue to South Stage Road; thence east along South Stage Road to the first road to the north after Sunnyview Lane; thence north approximately 300 feet; thence east approximately 300 feet; thence north approximately 700 feet; thence east to King’s Highway; thence north along King’s Highway to Experiment Station Road; thence east along Ex periment Station Road to Marsh Lane; thence east along Marsh Lane to the northern boundary of Section 6, T38S, R1W; thence east along said boundary approximately 1100 feet; thence north approximately 1200 feet; thence east approximately 1/3 mile; thence no rth approximately 400 feet; thence east approximately 1000 feet to a drainage ditch; thence following the drainage ditch southeasterly approximately 500 feet; thence east to the eastern boundary of Section 31, T37S, R1W; thence south along said boundary ap proximately 1900 feet; thence east to and along the loop off of Rogue Valley Boulevard, following that loop to the Southern Pacific Railroad Line (SPRR); thence following SPRR approximately 500 feet; thence south to South Stage Road; thence east along Sout h Stage Road to SPRR; thence southeasterly along SPRR to the intersection with the west fork of Bear Creek; thence northeasterly along the west fork of Bear Creek to the intersection with U.S. Highway 99; thence southeasterly along U.S. Highway 99 approxim ately 250 feet; thence east approximately 1600 feet; thence south to East Glenwood Road; thence east along East Glenwood Road approximately 1250 feet; thence north approximately 1/2 mile; thence west approximately 250 feet; thence north approximately 1/2 m ile to the Medford City Limits; thence east along the city limits to Phoenix Road; thence south along Phoenix Road to Coal Mine Road; thence east along Coal Mine Road approximately 9/10 mile to the western boundary of Section 35, T37S, R1W; thence north to the midpoint of the western boundary of Section 35, T37S, R1W; thence west approximately 800 feet; thence north approximately 1700 feet to the intersection with Barnett Road; thence easterly along Barnett Road to the southeast corner of Section 27, T37S, R1W; thence northAppendix 2

– 2015 Medford CO LMP Page 18 along the eastern boundary line of said section approximately 1/2 mile to the intersection with the 1800 foot contour line; thence east to the intersection with Cherry Lane; thence following Cherry Lane southeasterly and then northerly to the intersection with Hillcrest Road; thence east along Hillcrest Road to the southeast corner of Section 23, T37S, R1W; thence north to the northeast corner of Section 23, T37S, R1W; thence west to the midpoint of the northern boundary of Section 22; T37 S, R1W; thence north to the midpoint of Section 15, T37S, R1W; thence west to the midpoint of the western boundary of Section 15, T37S, R1W; thence south along said boundary approximately 600 feet; thence west approximately 1200 feet; thence north approxim ately 600 feet; thence west to Foothill Road; thence north along Foothill Road to a point approximately 500 feet north of Butte Road; thence west approximately 300 feet; thence south approximately 250 feet; thence west on a line parallel to and approximate ly 250 feet north of Butte Road to the eastern boundary of Section 8, T37S, R1W; thence north approximately 2200 feet; thence west approximately 1800 feet; thence north approximately 2000 feet; thence west approximately 500 feet; thence north to Coker Butt e Road; thence east along Coker Butte Road approximately 550 feet; thence north approximately 1250 feet; thence west to U.S. Highway 62; thence north approximately 3000 feet; thence east approximately 400 feet to the 1340 foot contour line; thence north
ap proximately 800 feet; thence west approximately 200 feet; thence north approximately 250 feet to East Vilas Road; thence east along East Vilas Road approximately 450 feet; thence north approximately 2000 feet to a point approximately 150 feet north of Swan son Creek; thence east approximately 600 feet; thence north approximately 850 feet; thence west approximately 750 feet; thence north approximately 650 feet; thence west approximately 2100 feet; thence on a line southeast approximately 600 feet; thence east approximately 450 feet; thence south approximately 1600 feet; thence west approximately 2000 feet to the continuance of the private logging road north of East Vilas Road; thence south along said logging road approximately 850 feet; thence west approximate ly 750 feet; thence south approximately 150 feet; thence west approximately 550 feet to Peace Lane; thence north along Peace Lane approximately 100 feet; thence west approximately 350 feet; thence north approximately 950 feet; thence west approximately 100 0 feet to the western boundary of Section 31, T36S, R1W; thence north approximately 1300 feet along said boundary to the point of beginning.

3.1.2.2 Legal Description of Open Burning Control Areas In addition to the UGB, DEQ has specific rule s that address commercial, demolition, construction an d industrial open burning. The rules are identified for densely pop ulated locations in the state, including cities over 4,000 people in population and within three miles of the corporate city limits of these cities

. The boundaries defined by the rules are termed O pen Burning Control Areas. The rules pertaining to the Medford area may be found in the Oregon Administrative Rules (OAR) 340

- 264

- 0078, summarized below.

Generally, areas around the more densely populated l ocations in the state and valleys or basins that restrict atmospheric ventilation are designated "Open Burning Control Areas". The practice of open burning may be more restrictive in open burning control areas than in other areas of the state. The specific open burning restrictions associated with these open burning control areas are listed in OAR 340

- 264

- 0100 through 340

- 264

- 0170 by county. The open burning control areas of the state are defined as follows:

(1) All areas in or within three miles of the in corporated city limit of all cities with a population of 4,000 or more.

(3) The Rogue Basin Open Burning Control Area is located in Jackson and Josephine Counties with boundaries as generally depicted in Figure 4 Rogue Basin Open Burning Control Area. The area is enclosed by a line beginning at a point approximately 4

- 1/2 miles NE of the City of Shady Cove at the NE corner of T34S, R1W, Willamette Meridian, thence south along the Willamette Meridian to the SW corner of T37S, R1W; thence east to the NE corn er of T38S, R1E; thence south to the SE corner of T38S, R1E; thence east to the NE corner of T39S, R2E; thence south to the SE corner of T39S, R2E; thence west to the SW corner of T39S, R1E; thence NW along a line to the NW corner of T39S, R1W; thence west to the SW corner of T38S, R2W; thence north to the SW corner of T36S, R2W; thence west to the SW corner of T36S, R4W; thence south to the SE corner of T37S, R5W; thence west to the SW corner of T37S, R6W; thence north to the NW corner of T36S, R6W; thence east to the SW corner of T35S, R1W; thence north to the NW corner of T34S, R1W; thence east to the point of beginning

.Appendix 2

– 2015 Medford CO LMP Page 19 3.1.2.3 Legal Description of Medford Area Woodstove Curtailment Ordinance / Critical PM10 Control Area In order to strengthen overall woodstove strategies in the Medford AQMA, local ordinances in the Medford area were unified in 1998, resulting in a Woodstove Curtailment Ordinance Area, also known as the Critical PM 10 Control Area. The unified ordinance applies in Jackson County, as well as the c ities of Ashland, Central Point, Jacksonville, Medford, Phoenix, and Talent. The legal description is as follows:

Beginning on I

- 5 and Tolo Road, crossover north on Tolo Road to Old Hwy 99. East on Old Hwy 99 to Kirtland Road. Northeasterly on Kirtland Road to Tablerock Road. North on Tablerock Road to the Rogue River. Northeasterly along the southern bank of the Rogue River to the mouth of Little Butte Creek. Northeasterly along Little Butte Creek to Antelope Creek. Southeasterly along Antelope Cre ek to Dry Creek. Southeasterly on Dry Creek to Hwy 140. Southwesterly on Hwy 140 to Kershaw Road. South on Kershaw Road to Corey Road. West on Corey Road to Foothill Road. South on Foothill Road to Medford Urban Growth Boundary (UGB) (near Delta Water s Road). Follow eastern UGB south to North Phoenix Road. South on North Phoenix Road to Phoenix UGB. Follow eastern UGB south to I

- 5. Southeasterly on I

- 5 to Talent UGB. Follow the eastern, southern, and western UGB until intersection with Southern Pa cific Railroad Track (which became Union Pacific / Central Oregon & Pacific Railroad in 1994). Southern Pacific Railroad track north to Hartley Lane (Road). West on Hartley Lane (Road) to Talent

- Phoenix Road (Colver Road). North on Talent

- Phoenix Road ( Colver Road) to Phoenix UGB. West along southern boundary of Phoenix UGB to Camp Baker Road. West on Camp Baker Road to Coleman Creek Road. North on Coleman Creek Road to Carpenter Hill Road. West on Carpenter Hill Road to Pioneer Road. Northwest on P ioneer Road to Griffin Creek Road. North on Griffin Creek Road to Medford UGB. North along Medford UGB to South Stage Road. West on South Stage Road to Arnold Lane. North on Arnold Lane to Jacksonville Hwy. West on Jacksonville Hwy to Hanley Road. No rtheast on Hanley Road to Ross Lane. West on Ross Lane to Redwood Drive. South on Redwood Drive to LaPine Avenue (which becomes Wendt Road). West on LaPine Avenue (Wendt Road) to Old Stage Road. North on Old Stage Road to Old Military Road. North on O ld Military Road to Old Stage Road. Northwest on Old Stage Road to Scenic Avenue. Northwest on Scenic Avenue to Tolo Road. North on Tolo Road to Willow Springs Road. East on Willow Springs Road to Ventura Lane. North on Ventura Lane to I

- 5. Northwest on I

- 5 to crossover of Tolo Road.

3.1.2.4 Legal Description of the Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary Vehicle owners residing within the Medford

- Ashland Air Quality Maintenance Area are subject to DEQ vehicle inspec tion per OAR 340

- 256

- 0300(2) and (3). The legal description of the Medford

– Ashland air quality maintenance area is as follows:

340

- 204

- 0010(10) “Medford

- Ashland Air Quality Maintenance Area” (AQMA) means the area defined as beginning at a point approxi mately two and quarter miles northeast of the town of Eagle Point, Jackson County, Oregon at the northeast corner of Section 36, Township 35 South, Range 1 West (T35S, R1W); thence South along the Willamette Meridian to the southeast corner of Section 25, T37S, R1W; thence southeast along a line to the southeast corner of Section 9, T39S, R2E; thence south

- southeast along line to the southeast corner of Section 22, T39S, R2E; thence South to the southeast corner of Section 27, T39S, R2E; thence southwest al ong a line to the southeast corner of Section 33, T39S, R2E; thence West to the southwest corner of Section 31, T39S, R2E; thence northwest along a line to the northwest corner of Section 36, T39S, R1E; thence West to the southwest corner of Section 26, T3 9S, R1E; thence northwest along a line to the southeast corner of Section 7, T39S, R1E; thence West to the southwest corner of Section 12, T39S, R1W, T39S, R1W; thence northwest along a line to southwest corner of Section 20, T38S, R1W; thence West to the southwest corner of Section 24, T38S, R2W; thence northwest along a line to the southwest corner of Section 4, T38S, R2W; thence West to the southwest corner of Section 6, T38S, R2W; thence northwest along a line to the southwest corner of Section 31, T37S
, R2W; thence North and East along the Rogue River to the north boundary of Section 32, T35S, R1W; thence East along a line to the point of beginning.Appendix 2

– 2015 Medford CO LMP Page 20 

### 3.2 Summary of Emissions Data Summary tables of emission data that are presented here include stationary point sources, stationary
area sources, non

- road mobile sources, and on

- road mobile sources. Summary emissions are expressed as charts in Figures 6 through 8

. Table 2.1 provides a summary of the 2008 emissions estimates.

Figure 6 : Distribution of 2008 Annual CO Emissions

Figure 7 : Annual CO Emissions by Percentage 0 2
, 000 4
, 000 6
, 000

Stationary Point Sources Stationary Area Sources Non

- Road Mobile Sources On

- Road Mobile SourcesCO Emissions, tpy



### Stationary Point Sources 14 %

Stationary Area Sources 26 %

Non

- Road

Mobile Sources 26 % On

- Road

Mobile Sources 34 %Appendix 2

– 2015 Medford CO LMP Page 21 Figure 8 : Distribution of 2008 Season Day CO Emissions

Figure 9 : Season Day CO Emissions by Percentage 

### 0 15
, 000 30
, 000 45
, 000

Stationary Point Sources Stationary Area Sources Non

- Road Mobile Sources On

- Road Mobile SourcesCO Emissions, lbs/day



### Stationary Point Sources 16 %

Stationary Area Sources 37 %

Non

- Road

Mobile Sources 12 % On

- Road

Mobile Sources 35 %Appendix 2

– 2015 Medford CO LMP Page 22 Table 3

. 1 : Summary of 2008 CO Emissions Data



### Annual CO Season Source Type tpy % of Category lbs/day % of Category Stationary Point Sources 2,376.1 15% 13,159 16% Stationary Area Sources 3,333.1 21% 30,399 37%

Non

- Road Mobile Sources 4,488.2 28% 10,061 12%
On

- Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%Appendix 2

– 2015 Medford CO LMP Page 23 

### 3.3 Stationary Permitted Point Sources

3.3.1 Introduction The following section is an overview and summary of the 2008 CO Point Source Emission Inventory developed for the Medford CO Limited Maintenance Plan (LMP) due in 2015. The 2008 CO inventory is an update to the original 1993 Attainment Year inventor y 1 . However , 1993 and 2008 emission results were not compared because of discrepancies caused by a significant lapse in time between inventories and the change in point source determination methodology. This inventory includes both annual and seasonal emission estimates that establish both short and long term CO trends from industrial sources during 200 8. This write up details the step s used to develop the 2008 Medford Point Source Emission Inventory and is a discussion of the results.



### 3.3.2 Geographic Area and Sources Included The geographic focus for this inventory is the former Medford CO nonattainment area which is the Urban Growth Boundary (UGB) for the city. The UGB is represented by the red outline above in Section 1, Figure 1 . A 25

- mile buffer zone was also added to Medford’s UGB to include industrial sources from other cities such as White City, Central Point, Ashland, Grants Pass, and Rogue River. Section 1, Figure 2 shows the UGB and 25

- mile buffer zo ne as the inventory boundary.

Grants Pass industrial sources were not included in the Medford 1993 inventory because they were already inventoried for the 1993 Grants Pass State Implementation Plan 9 . The 1993 inventory for the Grants Pass SIP was updated in July 2014. Industrial sources from Grants Pass will be included in the 2008 CO inventory for Medford.



### 3.3.3 Point Source Determination Point sources within the Medford UGB and 25

- mile buffer zone include both industrial and non

- industrial sources. Industri al sources are included under Part 2.3 Stationary Point Sources of this inventory and non

industrial sources are covered under Part 2.4 Stationary AREA Sources . This is a discussion on the point source determination for industrial sources included in both the 1993 Attainment Year Inventory and the 2008 Point Source CO Inventory for Medford.

Point sources for the 1993 Attainment Year Inventory were defined as stationary industrial sources that emitted more than 100 tons CO within the Medford UGB and a 25

- mile buffer zone. Smaller stationary industrial sources that emitted less than 100 tons we re included with non

- industrial sources under Part 2.4 Stationary AREA Sources in the 1993 inventory.

Table 2.3.1 is the original list of large stationary industrial sources included in the 1993 inventory. See Reference 618 , Appendix A, P oint Source Dat a and Table A

- 1 Individual Stationary Point Source Determinations.Appendix 2

– 2015 Medford CO LMP Page 24 Table 2.3. 1 : 1993 Attainment Year Inventory List of Permitted Point Sources

Source Number Source Name Permit Type CO PSEL Current Operating Status SIC

15

- 0004 Boise Cascade Corporation TV 2974 Active 2436 15

- 0012 U.S. Forest Industries ACDP 99 Active 2435 15

- 0014 Medite Corporation ACDP 99 Active 2436 15

- 0020 Boise Cascade Corporation TV 796 Active 2436 15

- 0025 Timber Products Company TV 237 Active 2436 15

- 0041 Dyno Polymers Incorporated ACDP 1900 Closed 2861 15

- 0048 Medford Corporation ACDP 947 Closed 2493 15

- 0058 Royal Oak Enterprises, Inc. ACDP 613 Closed 2861 15

- 0073 Medford Corporation TV 235 Active 2493 15

- 0159 Biomass One, L.P. TV 570 Active 4961

Three facilities have since closed and the other seven operated in 2008 so they were added to the 2008 Medford CO EI.

3.3.3.1 2008 Point Source Determination Point sources included in the 2008 CO Inventory are defined as stationary industrial sources that have a state or federal air operating permit and are located within the UGB and 25

- mile buffer for Medford. These stationary industrial sources would fall under one of two permit programs that DEQ administers:

• Air Contaminant Discharge Permit (ACDP) : a state operating permit for small industrial sources that emit 99 tons or less per year of any criteria pollutant, or

• Title V Permit (TV): a federal operating permit for large industrial sources that emit 100 tons or greater per year of any criteria pol lutant.

One major change for the 2008 inventory was to include ACDP sources, reported as Area Sources in 1993, with the TV sources. DEQ has better data now to estimate CO emissions from ACDP sources.

The conditions used in 1993 for point source determ ination no longer apply and so the new conditions for inclusion in the 2008 inventory are as follows:

• Sources are located within the UGB and 25

- mile buffer,

• Sources had an active ACDP or Title V permit in 2008

• Sources operated in 2008,

• Sources actually emit CO emissions

All ACDP and TV sources in Jackson and Josephine Counties were mapped using ArcGIS 10 in order to eliminate sources located outside the UGB and 25

- mile buffer zone. The remaining ACDP and TV sources that fell within the inventory boundary were compared against the other conditions listed above to determine if they would be included in the 2008 CO EI for Medford. The list was narrowed down to 28 ACDP and 9 TV sources that met all the conditions above. Table A

- 1 is the final list of 37 sources by source number, name, site location, permit types, operating status, CO PSEL, and standard industrial classification codes (SIC) included in the 2008 inventory. Section 1 , Figu re 2 provides the geographical locations for the Medford sources included in 2008 CO inventory.Appendix 2

– 2015 Medford CO LMP Page 25 Appendix A, Table A

- 1.1 provides a list of 37 sources that were excluded from the 2008 inventory because they did not meet one or more of the conditions listed above. Ten sources were not included because, although they had a CO PSEL in their permit, they did not actually operate equipment that emits CO. This is fairly common with General ACDPs because they list all possible emission units and processes based o n a source category and assign a facility based on the type of business they operate. An example of this is when a source is assigned to a General permit for millwork and the emission units/processes identified in the permit are boilers, veneer dryers, ki lns, cyclones, target boxes, etc. The source may only operate cyclones and target boxes and nothing else in the list that may emit CO emissions.

27 sources were closed sometime between 1993 and 2008; therefore, they were not included in the 2008 CO EI fo r Medford



### 3.3.4 Methodology and Approach The Medford inventory was developed using existing TV emissions data submitted by DEQ to EPA ’s 200 8 National Emission Inventory (NEl) and by putting together estimates for ACDP sources where no data was readily available. Since ACDP sources are typically reported to the NEI as Area Sources by county and source classification, CO emission estimates needed to be calculated down to individual source levels. The following is the methodology and approach used to develop the 200 8 Medford Point Source CO Emission inventory.

3.3.4.1 Data Collection Data collection is necessary to gather information used to calculate both annual and seasonal e missions. Information s uch as a source’s emission basis, activity/throughput data, operating schedu les, and P lant Site Emission Limits (P SELs ) were collected for the inventory. This data w as collected from 2008 annual reports, permits, or retrieved electronically from a permitting database. Most emissions and compliance information for TV sources is alr eady stored in DEQ’s Tracking Reporting and Administration of Air Contaminant Sources (TRAACS) permitting database. However, some information for ACDP sources such as emission basis and emission estimates are stored in an external database.

3.3.4.2 Emission Basis Emission basis details the emission units and processes permitted at a source. The basis is developed by using information from emission detail sheets found in permits or permit review reports. For TV sources emission basis is organized in a workbook, a d elivery mechanism for importing data into TRAACS. The workbook contains emission source and process descriptions, activity data, emission factors or other data used in estimating emissions, and potential to emit emissions used to develop Plant Site Emissio n Limits (PSELs). The workbook imports the emission basis into TRAACS where this information is used in preparing emission inventories. Further, the emission basis and emissions are submitted to EPA’s EIS database annually.

ACDP emission basis is col lected and stored by inventory project in an MS Access database, known as Final ACDP EI database . This database stores the same type of information as TRAACS such as the emission units/process descriptions, emission factors, and other data necessary for ca lculating emissions. The information is obtained from ACDP permits and/or annual reports.

3.3.4.3 Activity Data Activity data , also called throughput, w as collected from 2008 annual reports for Title V a nd ACDP sources

. Activity data consists of fuel use, p roduction activity, or other annual throughput types used to estimate emissions. Sources must fulfill permit conditions for annual reporting by submitting annual activity information, emissions factors, and emission estimates for criteria air pollutants. T he activity data is used toAppendix 2

– 2015 Medford CO LMP Page 26 verify existing emissions estimates from the reports as well as to calculate emissions not typically reported by the sources themselves

3.3.4.4 Plant Site Emission Limits (PSELs) PSELs were found in the DEQ TRAACS database (see Section 1.4) or permits

3.3.4.5 Annual Emissons Calculations Point source annual emissions were estimated at the process level for each source. Emission basis and activity data used to estimate process level emissions were collected from ACDP and TV permits and 2008 annu al reports. Below are the estimation methodologies used to prepare TV source annual emissions for the 2008 NEI and ACDP source emissions for the Medford inventory.

3.3.4.5.1 Emissions Estimation Methodologies for TV Sources Emissions for this inventory were estim ated 1 of 2 ways using:

• emission factors, or

• Continuous Emissions Monitoring System (CEMS)

Emission factors, the most common methodology, are derived by the source and permit writer to determine PSELs and compliance. Emission factors are developed using such resources as AP

- 42, industry standards, or by source testing. Emission factors relate the quantity of a pollutant to its activity such as lb of pollutant per
g allon of fuel oil. Emission factors may be based on assumptions or conversions not likely defined in the permit or emission detail sheets. These assumptions include capture efficiencies, control efficiencies, conversion constants, %LEL (lower explosive l imit), and transfer efficiency.

Most of the CO emission estimates were developed using emission factors from permits and activity from 2008 annual reports. The following formula was used to estimate annual CO emissions: 2008 Annual CO Emissions (tpy) = (2008 Activity * Emission Factor)/2000 lbs/ton

Some CO emission estimates were derived via C EMS which is the most accurate representation of emissions at

a source. Permit conditions may require direct measurement of stack emissions and recordkeeping for reporting hourly or daily CO em itted at a facility. Emission factors and CEMS are the most common estimation methodologies used to develop large industrial point source emissions for the 2008 CO inventory.

3.3.4.5.2 Emissions Estimation Methodlogies for ACDP Source s Emissions from ACDP sources are generally not reported as point sources to the NEI but as AREA sources at the county

- level and source classification code (SCC). Since ACDP sources were reported on a county

- level to the 2008 NEI, emission estimates had t o be developed for each individual source for this inventory. CO emission estimates were developed using emission factors from permits and activity from 2008 annual reports. The following formula was used to estimate annual CO emissions: 2008 Annual CO E missions (tpy) = (2008 Activity * Emission Factor)/2000 lbs/ton

See Appendix A, Table A

- 2 Stationary Point Source Emission Estimation Details. The table provides annual emission details down to process

- level for both ACDP and TV sources. This table inclu des emission unit level information such as annual activity, emission factors, and operating details. The 2008 annual emissions for both ACDP and TV sources were used next to calculate seasonal emissions.Appendix 2

– 2015 Medford CO LMP Page 27 3.3.4.6 Seasonal Emissions Calculations Emissions are gener ally not static and fluctuate during different times of the year for various reasons such as changes in source activity or temperature. For example, CO emissions may peak during winter months in urban areas due to incomplete combustion of carbon

- based fue ls (i.e. automobiles, woodstove, open

- burning, fuel combustion of industrial boilers, etc.). The winter months of December through February is defined as the CO season, the period for which emissions are more likely to peak. The reason for this is cooler temperatures during these months prevent complete combustion of the fuel which may result in excess CO emissions trapped near the ground by atmospheric inversions.

2008 annual CO emissions were temporally allocated from annual to seasonal emissions for the CO season. Typical Season Day (TSD) emissions are average daily CO emissions calculated over the CO season and recorded in pounds per day (lbs/day). To complete seasonal emission estimates data components such as annual emissions (tpy), seasonal adjus tment factors, and annual activity days are required. The following is the allo cation and development methods and data comp onents needed to calculate seasonal emissions.

3.3.4.6.1 Seasonal Adjustment Factors Seasonal Adjustment Factors ( SAF ) were calculated using te mporal files of peak season activity by source classification code (SCC) from EPA’s Sparse Matrix Operator Kernal Emissions (SMOKE) modeling program. The data components from these files are used in the following equation to calculate SAF: SAF = ((Sum of Peak Season Activity) (12 months)) / ((Annual Activity) (Peak Season Activity Months))

An example of how this calculation works is: Use SCC 10200502, Determine the peak season months and % activity for the peak season months :

Peak Season Activity Months: % Activity During Peak Season Months December 83 January 83 February 83 Total Annual Activity: 996 Insert information into pertinent components of SAF calculation : SAF = ((83+83+83) (12 months)) / ((996) (3 months)) = 1.00

Both ACDP and TV sources required SAFs to complete seasonal calculations

. See Appendix B, Table B

- 1 : Seasonal Adjustment Factors by SCC Used for 2008 CO Inventory.

3.3.4.6.2 Season Day Emissions Calculations Typical Season Day (TSD) emissions are average daily CO emissions calculate d over the CO season (i.e. December 1 st through end of February the following year). The following data components are needed to calculate TSD emissions:

• 2008 Annual CO Emissions (AE)

• SAF

• Activity Days (AD) TSD emissions = (AE*SAF*2000 lb/ton) / (AD)Appendix 2

– 2015 Medford CO LMP Page 28 The following is an example calculation for natural gas fuel combusted in a veneer dryer. In order to complete the TSD calculation 2008 annual CO emissions, seasonal adjustment factor by SCC and annual activity days are needed. This formula breaks the an nual emissions down to lbs/day over the CO season.

Dryer Emissions (SCC 30700716):

• AE = 140 tons

• SAF = 1.00

• AD = 365 days/yr TSD Emissions = (140*1.00*2000) / (365) = 767 lbs/day

TSD emission calculations were performed for all 37 ACDP and TV sources. T SD emission estimates for TV and ACDP sources cannot be calculated nor stored in TRAACS. TV and ACDP seasonal emissions were calculated and housed in MS Access Final _SIP_MP_PSD_EITool database. Appendix A, Table A

- 2 Stationary Point Source Emission Estim ation Details also provides TSD emission estimates down to the process

- level for both ACDP and TV sources.Appendix 2

– 2015 Medford CO LMP Page 29 

### 3.3.5 Summary of Stationary Point Source Emissions Inventory results were organized into tables summarizing 2008 annual and seasonal CO emissions by sour ce industrial classification (SIC) and at source and process levels. Appendix C, Tables 2.3.1, 2.3.2, and 2.3.3 summarize stationary point source CO emissions for the 2008 Medford inventory. See Figures 8 through 11 for how stationary point source annual and season day emissions are distribut ed amongst the other source categories of the inventory

.

Total 2008 annual and seasonal CO emissions for industrial sources located within the Medford UGB and 25

- mile buffer are 2,376.1 tons per year and 13,159 lbs pe r day, respectively. The major industries permitted in Medford and the surrounding cities are wood products manufacturing, concrete production, steam supply for operating processes or heating dwellings, sewer systems, crematories, and landfills.

Table 2.3. 2 summarizes 2008 CO annual and seasonal emissions by SIC for the Medford UGB and 25

- mile buffer area. The table reveals three industrial classifications that contribute over 96% of total point source CO emissions in 2008.

Table 2.3. 2 : Medford UGB CO Season: Summary of Point Source Emissions by SIC (1) (2) CO Emissions

SIC Code SIC Name Annual and TSD Emissions
tpy lbs/day
2048 OTHER PREPARED FEEDS 0.1 1 2421 SAWMILLS AND PLANING MILLS 2.4 20 2431 MILLWORK 1.2 9 2434 WOOD KITCHEN CABINETS 0.2 1 2435 HARDWOOD VENEER AND PLYWOOD 22.4 123 2436 SOFTWOOD VENEER AND PLYWOOD 1803.6 9943 2439 STRUCTURAL WOOD MEMBERS 0.3 2 2493 RECONSTITUTED WOOD PRODUCTS 36.3 207 2951 PAVING MIXTURES AND BLOCKS 12.3 74 3272 OTHER CONCRETE PRODUCTS 5.2 37 3861 PHOTOGRAPHIC EQUIPMENT & SUPPLY 3.8 21 4952 SEWERAGE SYSTEMS 10.7 59 4953 REFUSE SYSTEMS 211.1 1160 4961 STEAM SUPPLY 266.6 1501 Pollutant Total 2376.1 13159

Softwood veneer and plywood (SIC 2436) contributes 75.9% while steam supply (SIC 4961) and refuse systems (SIC 4953) only emit 11.2% and 8% of total CO emissions, respectively. This leaves a wide margin between softwood veneer and plywood products manufact uring and other industrial classifications.

Further evaluation required identification of sources in each SIC. Table 2.3.3 in Appendix C, is a list of sources with annual and seasonal CO emissions for each SIC

. This table reveals which sources are cont ributingAppendix 2

– 2015 Medford CO LMP Page 30 significantly to CO emissions in the three primary SIC’s listed above. A 100 tpy annual emissions cut

- off was applied to these sources to determine the top emitters of CO emissions for this inventory.

Table 2.3.3 list s five sources that contribu te the most CO emissions within the Medford UGB and 25

- mile buffer . These five sources emit together 88% of the total annual and seasonal CO emissions. Boise Cascade Wood Products, L.L.C. (15

- 0004) produces over half the 2008 CO emissions out of the five sources. CO emissions for these sources occur because of fuel combustion activities such as the operation of boilers, landfill engines, and veneer dryers. All other source contributions to 2008 annual and seasonal CO emissions are considered minimal.

T able 2.3. 3 : Medford UGB CO Season, Summary of Top 5 :Point Source Emitters (1) (2) CO Emissions

Emission Year SIC Code Source Number Source Name Annual Emissions Typical Season Day tpy lbs/day
2008 2436 15

- 0004 Boise Cascade Wood Products, L.L.C. 1087.6 5943 2008 2436 15

- 0020 Boise Cascade Wood Products, L.L.C. 513.1 2812 2008 4961 15

- 0159 Biomass One, L.P. 232.7 1278 2008 4953 15

- 0026 Dry Creek Landfill, Inc. 162.6 891 2008 2436 17

- 0030 TP Grants Pass, LLC 111.4 598 Pollutant Total 2,107.4 11,521 (1) And (2), see Appendix A, Table A

- 2

In summation, wood product companies (Boise Cascade (15

- 0004) and (15

- 0020)) and TP Grants Pass L.L.C (17

- 0030) account for 81% of total CO emissions during 2008. Biomass One, L.P. (15

- 0159) and Dry Creek Landfill (15

- 0026) only account for 19% of t he industrial source CO emissions in 2008. These sources contributed 2107.4 tpy out of 2376.1 tpy and 11521 lbs/day out of 13159 lbs/day over the CO season. All these sources are still in operation today.



### 3.3.6 Control Efficiency (CE) and Rule Effectiveness (RE) EPA requires control efficiency and rule effectiveness to be calculated for SIPs. According to EPA’s Air Emissions Reporting Requirements (AERR) rule (40 CFR Part 51) these concepts are defined as:

• Control Efficiency (CE): the capture and reduction efficiency of primary control devices

• Rule effectiveness (RE): a generic term for identifying and estimating the uncertainties in emission control programs. Rule effectiveness adjusts the control efficiency from what could be realized under ideal conditions to what is actually emitted in practice due to less than ideal conditions. It is a measure of the extent to which a rule actually achieves its desired em ission reductions.

The 1993 baseline control efficiencies were zero and rule effectiveness did not apply because no CO controls were installed back then for any source. No controls for CO have been installed since 1993 for any source; therefore, contro l efficiency and rule effectiveness also do not apply in the 2008 inventory.Appendix 2

– 2015 Medford CO LMP Page 31 

### 3.4 Stationary Nonpoint (Area) Sources

3.4.1 Introduction and Scope This section describes the development of the emissions inventory for carbon monoxide for stationary area sources lo cated in the Medford UGB in 2008. Area sources included in this inventory are stationary and collectively represent relatively small and numerous individual sources within the inventory area. Included in
t he area source category are three groups of distin ct area source emission contributors: Waste disposal, treatment and recovery (including residential, industrial, and commercial open burning); Small stationary fuel and wood use (including residential, industrial, and commercial combustion); and Miscellane ous (forest fires, structural fires, and slash burning). A fourth group of sources, small permitted point sources, originally included in the 1993 attainment year inventory, are included in the permitted point source inventory (Section 2.3) for this emiss ion inventory.

All tables referred to in this section of the report are shown at the end of the section.

Table 2.4.1 lists the procedures used to develop the emission estimates for the various categories of area source CO emissions included in the Medfor d UGB inventory. Estimated area source emissions represented in this inventory occur on an average weekday during the three

- month CO season of January 1 through February 28, and Dec ember 1through December 31, 2008.

Stationary area sources are currently re ferred to as nonpoint sources by EPA, however the term area sources is used in this document for consistency with the 1993 attainment year EI.



### 3.4.2 Methodology and Approach

3.4.2.1 Source Category Identification and General Methodology Overview Discussion of guidance d ocuments and broad methodology used to calculate stationary area source emissions can be found in Part I. The list of stationary area sources included in the inventory was based on the EPA Procedures Document 3 and the Emissions Inventory Requirements for CO 1 . These area sources were compared to sources evaluated in the 1993 Attainment Year CO SIP Emission Inventory 618 , and the annual inventory of point source categories.

The starting point for emissions estimates for many area source categories was the E PA 2008 National Emission Inventory All data from the 2008 NEI was retrieved from the EPA EIS Gateway (See Part 1, Section 1.4 of this report). The 2008 NEI CO emissions estimates consist of data generated by both DEQ and EPA, depending upon source categ ory. The DEQ data for specific categories, such as Residential Wood Combustion, were submitted to EPA through the EIS CERS XML process as required by the Air Emissions Reporting Rule (AERR). Data and documentation for the 2008 NEI may be found at the fol lowing website: http://www.epa.gov/ttnchie1/net/2008inventory.html

For DEQ generated emission estimates, emission factors were taken from the EPA Procedures Document 2 , the FIRE Version 5 S CC’s and Emission Factors 10 , the Compilation of Air Pollution Emission Factors (AP

- 42) 11

, various EPA Surveys, and local studies conducted by the Oregon Department of Environmental Quality or environmental consulting firms. Errors in estimated emissions c ould occur in the multiplier values used, in the accuracy of calculations, or in mistakes in the construction of equations. Therefore, estimated emissions were checked for reasonableness by a number of approaches: 1) using alternative multiplier values wh en possible;Appendix 2

– 2015 Medford CO LMP Page 32 2) comparing estimates with the results of earlier area source inventories; and 3) performing independent checks on the accuracy of the multiplier values, the methodologies, and the emission calculations.

Seasonal activity factors were taken from the EPA Procedures Document 2 or were derived by DEQ and based upon season specific activity levels following guidelines in the Procedures Document

. All sources were considered to be uncontrolled with the exception of open burning; for details on how controls were incorporated into the open burning categories, please see Section 2.4.3.1.2 and associated tables.

3.4.2.2 Reconciliation with Point Source Emissions (double count prevention) Double counted emissions were removed from area source fuel combustion emi ssions by subtracting emissions from point source fuel burning processes, broken down by the specific type of fuel, as shown in Appendix A, Table A

- 2. However, point source emissions to be removed were selected with the following two parameters:

• ACDP sourc e emissions only, since the 2008 TV source double

- count was resolved by the DEQ for the 2008 NEI submittal.

• Jackson County sources only, excluding those sources inventoried in the Grants Pass area, since area sources inventoried were for the Medford UGB on ly



### 3.4.3 Discussion of Area Source Categories Each of the major area source categories is comprised of area source types. Detailed descriptions of the emission estimation met hodology for each source type are included in Tables 2.4.3 through 2.4.14 and in Appendix B . The applicable appendix table number is included in the annotations, which accompany the summary table. Discussion of data sources, emission factors, seasonal adjustment factors, and activity levels which affect the area source are included f or each area source type. Applicable state regulations affecting a specific area source emission category are included in the notes on each category summary table. If specific area source type emissions were affected by state regulations during the invent ory year, control efficiency, rule effectiveness, and rule penetration have been applied 1,3 . Example calculations for emissions estimates are included on individual spreadsheets. The following sections describe these major categories; subsections
corresp onding to individual area source types are included.

Summary charts and tables, along with emissions estimates tables by category, are shown following this section.

3.4.3.1 Waste Disposal, Treatment and Recovery This category includes disposal, treatment, recover y and clean up of solid and liquid wastes by incineration and open burning.

3.4.3.1.1 Incineration This category consists of the disposal of solid waste, infectious waste, or crematory incinerator waste from industrial and commercial/institutional sources by combust ion. Combustion occurs in a structure or furnace for the purpose of reduction in volume or weight of the waste material.

3.4.3.1.1.1 Industrial Incineration The Medford UGB does not contain any industrial incineration sources and as such this category has not been in ventoriedAppendix 2

– 2015 Medford CO LMP Page 33 3.4.3.1.1.2 Commercial/Institutional Incineration The 1993 attainment year emission inventory considered this category (given as “Commercial/Instititional On

Site Incineration) as an Area source

. In 2008 this category was treated under point sources; Please see Part 2.3 of this document for point source methodology.

3.4.3.1.1.3 Residential Incineration Residential on

- site solid waste incineration activity is assumed to be zero. DEQ rules outlining structural requirements, source tests, and continuous emission monitoring , as well as associated permit costs, preclude individual residential construction of incineration devices. Destruction of solid waste and yard debris at residential sites is included in residential open burning calculations.

3.4.3.1.2 Open Burning This category in cludes waste material disposal from industrial, commercial / institutional, and residential sources in open outdoor fires, burn barrels or incinerators which do not meet DEQ emission limits, or burn in a manner in which combustion air is not effectively co ntrolled and combustion products do not vent through a stack or chimney.

3.4.3.1.2.1 Industrial Open Burning Industrial open burning is prohibited in the Medford UGB except by special letter permit issued by DEQ’s Western Region Office. No industrial open burning was permitted within the Medford UGB in 200 8 945, 946

. Industrial Open Burning emissions estimates are detailed in Table 2

. 4.11

.
3.4.3.1.2.2 Commercial/Institutional Open Burning This category is specific to the clearing of land for new construction and the burning of organic material (i.e. trees, shrubs and other vegetation). Jackson County Commercial and Institutional Open Burning emissions are from the EPA 2008 Nat ional Emissio ns Inventory (NEI) database. Using Jackson County land use zoning acreage, GIS allocations were created to approximate both the location and magnitude of emissions, see Appendix B, Table B

- 1. Annual CO Medford UGB Emissions were estimated by multiplying t he county emissions by the GIS allocation (%) for the appropriate land use zoning classification (ID #8: Commercial Lawn & Garden: Commercial Zones).

Burn permits and complaints were provided by the DEQ Medford office 12,14 and City of Medford Fire Distri ct 13,15 , and b urn days and type of burn were based on the information. L atitude and longitude data obtain from the permits were used in Google earth to determine which burn locations were inside the UGB area. Figure 10 shows all commercial open burning location from permits and complaints within Medford UGB area.Appendix 2

– 2015 Medford CO LMP Page 34 Figure 10 : 2008 Commercial Open Burning Locations

There were no CO emission in the CO season because there were no permitted com mercial burns and no record of illegal burns.

3.4.3.1.2.3 Residential Open Burning (back yard burning) Residential open burning includes the outdoor burning of wood, leaves, land clearing debris, and household
waste. Household waste often referred to as residential m unicipal solid waste (MSW), is a term for nonhazardous refuse produced by households (e.g. paper, plastics, metals, wood, glass, rubber, leather, textiles, and food wastes).

Jackson County residential open burning emissions are from the EPA 20 08 Nat ional Emissions Inventory (NEI) database. Using J ackson County land use zoning acreage, GIS allocations were created to approximate both the location and magnitude of emissions, see Appendix B , Table B

- 1

. Annual CO Medford UGB emissions were estimated by multiplying the county emissions by the GIS a llocation (%) for the appropriate land use zoning classification ( ID # 9 : Residential Lawn & Garden: Residential Zoning )

.
Burn permits and complaints were provided by the DEQ Medford office 12,14 and City of Medford Fire District 13,15 , and b urn days and type of burn were based on the information. L atitude and longitude data obtain from the permits were used in Google earth to determine which burn locations were inside the UGB area. Figure 11 shows all residen tial open burning location from permits and complaints within Medford UGB area.Appendix 2

– 2015 Medford CO LMP Page 35 Figure 11 : 2008 Residential Open Burning Locations

Weekly activity values use based on EPA’s document 16

. Open burning can be expected to take place seven days a week. Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by the Seasonal Adjustment Factor (SAF)
, which include s burning complain ts (violations record) and permitted burning during peak Season and total burning days annual activity , divided by activity days per week, multiplied by 52 weeks per year using the following formula:
CO Typical Season Day (lbs/day) = (Annual UGB Emissions (tons/year) *2000 (lb/ton)* SAF)/ (Activity (days/wk) * 52 (wk/year))

Residential Open Burning emissions estimates are detailed in Table 2.4. 10

3.4.3.2 Small Stationary Fossil Fuel and Wood Use This category includes small furnaces, heaters, heating units, and cooking devices that emit fewer than 100
tons of CO per year. Four main types of fuel are used within the Medford UGB by industrial, commercial/institutional, and residential sources: fuel oils, natural gas, liquefied petroleum gas (LPG), and wood. Wood fuel use is evaluated only for residential sources
, where wood use is primarily in fireplaces, wood stoves, furnaces , and for cooking; fossil fuel use by residential sources is evaluated for space heating or cooking purposes only. U se of these fuels by industrial and commercial sources for other purposes is included in the point source inventory.

3.4.3.2.1 Fuel Oil Combustion F uel oil emissions from industrial/commercial/institutional sources are from fuel consumption in large or small boilers, furnaces, heaters , and other heating devices. Residential fuel oil emission sources are primarily from fuel consumption in furnaces, heaters, and other heating devices

. For this inventory, industr ial andAppendix 2

– 2015 Medford CO LMP Page 36 commercial fuel oil use includes residual oil, distillate oil, and kerosene use; residential fuel oil consumption includes distillate and kerosene use only.

Jackson County emissions for fuel oil combustion a re from the EPA 2008 NEI database . Since industrial and commercial fuel use emissions were not inventoried in the 2008 NEI, the respective 2011 NEI emissions were used. EPA county

- wide industrial and commercial emissions were allocated to the Medford UGB using the 2008 employee population data from the US Census Bureau and developing a ratio of UGB employees to
count y employees

. The 2008 US Census employee population was downloaded from the following location: http://www.census.gov/econ/cbp/index.html

. Two zip codes were used to represent the Medford UGB: 9 7501 and 97504

. The residential emissions were allocated to the UGB by a ratio of the 2010 Medford UGB population to the county

- wide population

. The Medford UGB population was determined by mapping the census blocks with population and housing unit coun ts to the Medford UGB boundary using the GIS spatial analysis tool. The census block data with population and housing unit counts are from the 2010 Tiger/Line shapefiles. This type of shapefile is released every 10 years, so the 2010 shapefile was select ed as the closest to year 2008. The following formula was used for spatial allocation :

Annual UGB emissions, tpy = Annual Jackson County Emissio ns (tons/year) * (UGB employee or population / Jackson County employee or population )

The employee data were used to allocate industrial and commercial fuel use, and the population data were used to allocate residential fuel use. Weekly activity and the SAF were taken from the 1993 EI

. 3 Typical Season Day emissions were calculated by multi plying the UGB annual emissions tons by the SAF, divided by activity days per week, multiplied by 52 weeks per year, using the following formula.

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (Activi ty (days/wk) *52 ( weeks/yr))

Area source fuel combustion emissions were reconciled with permitted point source emissions by subtracting emissions from point source fuel burning processes, broken down by the specific type of fuel, as shown in Appendix A, T able A

- 2. However, point source emissions to be removed were selected with the following two parameters:

• ACDP source emissions only, since the 2008 TV source double

- count was resolved by the DEQ for the 2008 NEI submittal.

• Jackson County sources only, excl uding those sources inventoried in the Grants Pass area, since area sources inventoried were for the Medford UGB only

Fuel Oil Combustion emissions estimates are detailed in Table 2.4.3.

3.4.3.2.2 Natural Gas (NG) and Liquified Petroleum Gas (LPG) Natural Gas (NG) and Liquefied Petroleum Gas (LPG) emissions from industrial and commercial sources are from fuel consumption in large or small boilers, furnaces, heaters, and other heating devices. Residential NG/LPG emission sources are primarily from fuel consumption i n furnaces, heaters, and other heating devices.

Jackson County emissions for NG and LPG were first extracted from the EPA 2008 NEI database . Since industrial and commercial NG/LPG use emissions were not inventoried in the 2008 NEI, the respective 2011 NEI emissions were used. EPA county

- wide industrial and commercial emissions were allocated to the Medford UGB using the 2008 employee popula tion data from the US Census Bureau and developing a ratio ofAppendix 2

– 2015 Medford CO LMP Page 37 UGB employees to county employees

. The residential emissions were allocated to the UGB by the ratio of the 2010 Medford UGB population data divided by the county

- wide population

. The UGB popul ation was determined using the same method and data described in section 2.4.3.3.1

. The following formula was used for spatial allocation:

Annual UGB emissions, tpy = (Annual Jackson County Emissions (tons/year)) * (UGB employee or population / Jackson County employee or population )

The employee data were used to allocate industrial and commercial NG/LPG use, and the population data were used to allocate residential NG/LPG use. Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF , divided by activity days per week, and multiplied by 52 weeks per year. Weekly activity and SAFs were taken from the 1993 EI

. 3

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/t on) *SAF)/ (Activity (days/wk) *52 ( weeks/yr))

Area source fuel combustion emissions were reconciled with permitted point source emissions by subtracting emissions from point source fuel burning processes, broken down by the specific type of fuel, as show n in Appendix A, Table A

- 2. However, point source emissions to be removed were selected with the following two parameters:

• ACDP source emissions only, since the 2008 TV source double

- count was resolved by the DEQ for the 2008 NEI submittal.

• Jackson County sources only, excluding those sources inventoried in the Grants Pass area, since area sources inventoried were for the Medford UGB only

NG and LPG emission estimates are detailed in Table 2.4.4 and Table 2.4.5

.
3.4.3.2.3 Coal and Biomass Combustion Jackson County emissions for coal and biomass were extracted from the EPA 2011 NEI since they were not inventoried in the 2008 NEI. EPA county

- wide industrial and commercial emissions were allocated to the Medford UGB using the 2008 employee population data from the US Census Bureau and developing a ratio of UGB employees to county employees

. The following formula was used for spatial allocation:

Annual UGB emissions, tpy = (Annual Jackson County Emissions (tons/year)) * (UGB employee / Jackson County employee )

The employee data were used to allocate industrial and commercial coal and biomass use. Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF , divided by activity days per week, and multiplied by 52 weeks per year. Weekly activity and SAFs were not provided in the 1993 EI 3 , so the same values as the fuel oil use were used.

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (Activity (days/wk) *52 ( weeks/yr))

Coal and biomass emission estimates are detailed in Table 2.4. 1 4 and Table 2.4. 1 5

.Appendix 2

– 2015 Medford CO LMP Page 38 3.4.3.3 Residential Wood Combustion Wood is an important residential space

- heating source in Oregon. As a heating source, wood contributes a significant percentage of pollutants to an airshed when compared to fuel oil and NG/LPG. Because the CO season in Medford occurs during the winter months when residential wood combustion is at its height, emissions from residential wood burning are considered , and have been estimated, to be significant in the U GB

.
Jackson County emissions for Residential Wood Combustion were extracted from the EPA 2008 NEI database. Annual UGB emissions were estimated by multiplying county

- wide emissions by the ratio of the UGB population to county populati on

. The UGB population was determined using the same method and data described in section 2.4.3.3.1

. The following formula is used for spatial allocation:

Annual UGB emissions, tpy = Annual Jackson County Emissions (tons/year) * (UGB population / Jackso n County population)

Typical season day emissions were calculated by multiplying the UGB annual emissions tons by the SAF
, divided by activity days per week, and multiplied by 52 weeks per year. The SAFs were obtained from the 1993 EI

. 1 Weekly activity is 7 days per week based on the need for heating from this fuel source, which is consistent with the 1993 EI

. 1

Residential Wood Combustion emissions estimates are detailed in Table 2.4.6

.
3.4.3.4 Miscellaneous Area Sources The area sources descri bed in this section are combustion sources and include forest wildfires, prescribed burning, and structural fires.

3.4.3.4.1 Forest Wildfires DEQ staff analyzed EPA 2008 NEI fire event data 17
, to determine wildfire emissions for the Medford UGB and a 10

- mile buffer around the UGB. The 10

- mile buffer was chosen because it captured most of the northern valleys in the area that might drain towards Medford. Since EPA NEI fire event emission data is specific to date, direct estimation of annual and seasonal emissions is possible without relying on an SAF from other reference sources. Seasonal emissions were determined to be 0 lbs/day. Forest wild fire emissions estimates and references are detailed in Table 2.4.7.

3.4.3.4.2 Prescribed Burning By definition, “prescribed burning ” means forest debris or woody vegetation to be burned under the Oregon Smoke Management Plan administered by the Oregon Department of Forestry pursuant to OAR 477.515. To estimate prescribed burning emissions, DEQ staff analyzed EPA 2008 NEI fire event dat a 17
, for the Medford UGB and a 10

- mile buffer around the UGB. The 10

- mile buffer was chosen because it captured most of the northern valleys in the area that might drain towards Medford . Since EPA NEI fire event emission data is specific to date, direct e stimation of annual and seasonal emissions is possible without relying on an SAF from other reference sources.

Use of the EPA data resulted in a significant increase in prescribed burning emissions estimates

- two orders of magnitude larger than the est imate for the 1993 attainment year plan. However, emission inventory staff for the attainment year plan did not have access to the considerably more exact prescribed burning data currently available from EPA for 2008. Prescribed burning emission estimate s and details are found in Table 2.4.8

.Appendix 2

– 2015 Medford CO LMP Page 39 3.4.3.4.3 Structure Fires Josephine County s tructure f ires emissions are from DEQ’s 2008 county

- wide emissions submitted to the EPA National Emissions Inventory (NEI).

Annual CO Medford UGB e missions are estimated by multiplying county

- wide emissions by the ratio of the 2008 UGB population to county population ( population data taken from the US Census Bureau ) using the following formula:

Annual UGB emissions, tpy = UGB Emissions (tons/year) * (UGB population / Josephine county population) The Seasonal Adjustment Factors (SAF) was estimated from Oregon Fire Marshal data specific to Medford. Weekly activity are taken from the EPA procedures document 2

. Typical Season Day emissions were calculated by m ultiplying the UGB annual emission tons by the SAF, divided by activity days per week, multiplied by 52 weeks per year using the following formula:

CO Typical Day Emissions (lb/day) = (Annual UGB Emissions (tons/year) *2000 ( lb/ton ) * SAF)/ (Activity (days/wk) * 52 (wk/year))

Structure Fires emissions estimates are detailed in Table 2.4.9

.Appendix 2

– 2015 Medford CO LMP Page 40 

## Area Source Emissions Summaries and Estimates

Figure 12 : Area Source Annual Emissions by Percentage

Figure 13 : Area Source Season Day Emissions By Percentage Prescribed

Burning

46 %

RWC: Non

Certified Devices

29 % RWC: Certified Devices

12 % RWC: Fireplaces 6 % All other

sources 7 %

Prescribed Burning

47 %

RWC: Non

Certified Devices

29 % RWC: Certified Devices

12 % RWC: Fireplaces 7 % All other

sources 5 %Appendix 2

– 2015 Medford CO LMP Page 41 Table 2.4. 1 : Medford 2008 CO EI Summary of Estimation Procedures for Area Sources

Table 2.4. 2 : Medford 2008 CO EI Summary of Emissions Estimates for Area SourcesAppendix 2

– 2015 Medford CO LMP Page 42 Table 2.4. 3 : Area Source Emissions From Fuel Oil UseAppendix 2

– 2015 Medford CO LMP Page 43 Table 2.4. 4 : Area Source Emissions From Natural Gas (NG) UseAppendix 2

– 2015 Medford CO LMP Page 44 (1) (2) (3) (4) (5) (6)

SCC and Category Description County Emissions Spatial factor Annual UGB
Emissions Activity Seasonal Adjustment

Factor CO Typical Season Day
Emissions
(tons/year (%) (tons/year) (days/week) (SAF) (lbs/day)
SCC 21-02-006-000 69.70 31% 21.6 6 1.0 139
Industrial: NG

------- ------- ACDP Emissions (7) 29.5 219

------- ------- Reconciled Emissions Estimate (8) 0 0

SCC 21-03-006-000 55.10 79% 43.5 6 1.4 391 Comm/Inst. NG

------- ------- ACDP Emissions (7) 18.7 104

------- ------- Reconciled Emissions Estimate (8) 24.8 287
SCC 21-04-006-000 45.56 38% 17.3 7 1.7 162
Residential: NG

-------- --------

42.1 448 Total CO UGB Emissions (tpy): Total CO UGB Typical Season Day Emissions (lbs/day):Appendix 2

– 2015 Medford CO LMP Page 45 Table 2.4. 5 : Area Source Emissions From Liquified Petroleum Gas (LPG) UseAppendix 2

– 2015 Medford CO LMP Page 46Appendix 2

– 2015 Medford CO LMP Page 47 Table 2.4. 6 : Area Source Emissions From Residential Wood CombustionAppendix 2

– 2015 Medford CO LMP Page 48 Table 2.4. 7 : Area Source Emissions From WildfiresAppendix 2

– 2015 Medford CO LMP Page 49 Table 2 .4. 8 : Area Source Emissions From Prescribed (RX) BurningAppendix 2

– 2015 Medford CO LMP Page 50 Table 2.4. 9 : Area Source Emissions From Structure FiresAppendix 2

– 2015 Medford CO LMP Page 51 Table 2.4. 10 : Area Source Emissions From Residential Open BurningAppendix 2

– 2015 Medford CO LMP Page 52 Table 2.4. 11 : Area Source Emissions From Industrial Open Burning

Table 2.4. 12 : Area Source Emissions From Commercial/Institutional Open BUrning

(1) (2) (3) (4) (5) (6)
SCC and Category Description County Emission Spatial factor Annual UGB
Emissions Activity Seasonal Adjustment

Factor CO Typical Season Day

Emission (tons/year) (%) (tons/year) (days/week) (SAF) (lbs/day) Legal Burning - Permitted
SCC: 26-10-000-500 Commercial / Institutional Open Burning 166 50.3% 84 5 0 0

Notes: (1). The MS Access application used to query both databases is located at : \\deqhq1\EI_FILES\2008_Medford_Second_LMP_CO\Final_EI\2008_NEI\Final_Data_ForBrian.accdb
(2) Spatial Factor (%), using Josephine County land use zoning acreage GIS Allocation Results were created to approximate both the location and magnitude of emissions. County-Wide emission estimates were allocated by UGB percentage taken from Appendix X, Table C-X, (ID 8 = Commercial Lawn & Garden: Commercial Zones) GIS Allocation Results: Josephine County Zones, County-Wide and by UGB. Spatial surrogates are typically used to approximate emissions inside smaller boundaries from larger boundaries.
(3) Annual UGB Emissions: (tons/year)= County Emissions (tons/year)*Spatial Factor (%)
(4) Activity values used in the 1993 EI : Activity is based on the assumption that an individual commercial employee works 5 days per week even if the commercial source's operation runs 7 days per week. This employee activity is important because the emissions are based on employee population numbers.

(5) Seasonal Adjustment Factor (SAF)= (0 peak season activity * 12 months)/(173 annual activity * 3 months) 0 Burn days include complaint(illegal) burn data and permitted burns (DEQ Ref.951, 952 and 946)

(6) CO Typical Season Day Emissions [lb/day] = ((Annual Emissions [tons/year]) * (2000 [lb./ton]) * (SAF))/ ((Activity [days/wk]) * (52 [wk./year]))Appendix 2

– 2015 Medford CO LMP Page 53 Table 2.4. 13 : Area Source Emissions From Coal UseAppendix 2

– 2015 Medford CO LMP Page 54 Table 2.4. 14 : Area Source Emissions From Biomass BurningAppendix 2

– 2015 Medford CO LMP Page 55 

### 3.5 Nonroad Vehicles and Equipment

3.5.1 Introduction and Scope This section describes the develop ment of the emission inventory for carbon monoxide for nonroad mobile

sources located in the Medford UGB in the 2008 CO Limited Maintenance Plan year

. Sources inventoried within the nonroad mobile sector include off

- road gasoline and diesel

- powered vehicles and equipment, aircraft, and railroads as well as recreational and commercial waterborne vessels.

As with most of the area source categories, emissions within the Medford UGB were developed by applying SCC

- specific spa tial and temporal scaling factors to county

- wide estimates of annual emissions for Jackson County from the 2008 NEI pursuant to the methodology outlined in the IPP.

Table 2.5.1 summarizes the nonroad mobile source emission inventory for the major nonroad source categories in terms of both a nnual and daily emissions (adjusted for activity during the CO season). Figure s 2

- 1 through 2

- 4 compare emissions of the nonroad emission subcategories.



### 3.5.2 Nonroad Vehicles and Equipment This category encompasses 2

- stroke gasoline, 4

- stroke gasoline, Compressed Natural Gas (CNG) / Liquefied Petroleum Gas (LPG), and diesel vehicles and equipment. Each of the sub

- categories include s the following vehicle categories: Recreational Equipment, Construction Equipm ent, Industrial Equipment, Lawn/ Garden Equipment, Agricultural Equipment, Light Commercial Equipment, and Logging Equipment

.
3.5.2.1 Vehicle Categories The nonroad vehicles and equipment category include s the following gasoline, CNG/LPG, and diesel sources: SCC: 22

- xx

- 001

- xxx: Recreational Equipment SCC: 22

- xx

- 002

- xxx: Construction Equipment SCC: 22

- xx

- 003

- xxx: Industrial Equipment SCC: 22

- xx

- 004

- xxx: Lawn / Garden Equipment SCC: 22

- xx

- 005

- xxx: Agricultura l Equipment SCC: 22

- xx

- 006

- xxx: Light Commercial Equipment SCC: 22

- xx

- 007

- xxx: Logging Equipment

3.5.2.2 Methodology The starting point for emissions estimates for sources in this category was the county

- wide, annual CO emissions from the EPA 2008 NEI

. Using Jack son county land use zoning acreage
, 7 GIS

- based spatial allocation factors were created to estimate the fraction of county

- wide emissions from each of the vehicle types (Appendix A, Table A

- 1 ) occurring within the Medford UGB

. Annual Medford UGB emissions were estimated by multiplying the county

- wide emissions by the spatial factor (%) for the appropriate zoning ID. The following formula was used for spatial allocation:

Annual UGB emissions [tpy] = Annual Jackson County Emissions (tons/year) * Spatial All ocation Factor

Typical CO Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF) divided by 365 days per year. SAFs were taken from the 1993 EI

. 3 The activity is assumed to be 7 days per week across all vehicle typ es to be consistent with the 1993 EI

. 3

CO Typical Season Day Emission [lbs/day] = (Annual UGB Emissions (t/yr) * 2000(lb/ton) *SAF)/ (365 days/yr))Appendix 2

– 2015 Medford CO LMP Page 56 Nonroad vehicle and equipment emissions are detailed in Tables 2.5.2 through 2.5.5.



### 3.5.3 Aircraft and Airport O perations Emissions The aircraft and airport operation emission source categories inventoried include commercial and military aircraft, general aviation, air taxi, airport auxiliary power unit, and airport ground service equipment (GSE). Annual Jackson Co unty CO emissions from aircraft and airport operation were obtained from the 2008 NEI

. * Annual Medford UGB CO emissions were estimated by multiplying the county

- wide emissions by appropriate spatial allocation factors. Spatial factors for general aviatio n and air taxi were calculated b y dividing the total aircraft

- related emissions by those of the Jackson County. The military and commercial aircraft, auxiliary power unit, and GSE were assigned a 100% spatial allocation factor since all these sources occu r at the Rouge Valley International Medford Airport located within the UGB, which is the sole commercial airport operating in Jackson County. The details of these calculations and a summary of aircraft and airport emissions are given in Table 2.5.6.



### 3.5.4 Water borne Vessels Waterborne vessels fall under two categories: commercial/military marine vessels and recreational pleasure craft. Although pleasure craft emissions occur in other areas of Jackson County, neither category of waterborne vessel has any activi ty within the Medford UGB due to lack of sufficient water bodies and inland location to support such activity. As such, waterborne vessel e missions within the Medford UGB w ere set to

zero.



### 3.5.5 Rail Railroad emissions encompass both locomotive operation and railway maintenance as shown b y individual SCC category below.

SCC: 22

- 85

- 002

- 007 : Locomotives: Line

- Haul SCC: 22

- 85

- 002

- 010 : Locomotives: Yard

County

- wide annual emissions for railroads were taken from the EPA 2008 NEI database

. † Jackson County annual emission estimates for locomotive emissions were allocated using only active track miles within the Medford UGB and locating railroad yard activity within the Medford UGB using the railway GIS shapefiles in the 2008 NEI supporting d ata.

The 2008 NEI had no railway maintenance e missions for Jackson County; therefore, emissions for these SCC categories were set to zero for the Medford UGB.

Typical Season Day e missions were calculated by multiplying the UGB annual emissions tons by the SAF
, divided by 365 days per year. To be consistent with the 1993 EI
, 3 seasonal activity is assumed to be uniform and the SAF is equal to 1.0

.

* Aircraft and airport operations have traditionally been classified within the Nonroad Mobile Source sector. Although their S CC classifications have not changed, EPA grouped them within the Point Source sector beginning with the 2008 NEI. To maintain

con sistency with previous Medford air quality plans and emission inventories, these emissions continue to be reported within the Nonroad sector.

† Railroad have traditionally been classified within the Nonroad Mobile Source sector. Although their SCC classif ications have not changed, EPA grouped them within the Non

- Point (Area) Source sector beginning with the 2008 NEI. To maintain consistency with previous Medford air quality plans and emission inventories, these emissions continue to be reported within the Nonroad sector.Appendix 2

– 2015 Medford CO LMP Page 57 CO Typical Season Day Emission [lbs/day] = (Annual UGB Emissions (t/yr) * 2000(lb/ton) *SAF)/ (365 days/y r))

Railroad emission estimates are detailed in Table 2.5.7.Appendix 2

– 2015 Medford CO LMP Page 58 Figure 14 : Distribution of Medford UGB Annual Nonroad Source CO Emissions, 2008

Figure 15 : Percentage of Medford Annual Nonroad CO Sourc e Emissions, 2008Appendix 2

– 2015 Medford CO LMP Page 59 Figure 16 : Distribution of Medford CO Season Day Nonroad Source Emissions, 2008

Figure 17 : Percentage of Medford UGB CO Season Day Nonroad Source Emission, 2008Appendix 2

– 2015 Medford CO LMP Page 60 Table 2.5. 1 : Medford UGB 2008 CO Summary of Emissions from Nonroad Sources

CO Annual UGB

Emissions (tons/yr) CO Typical Season Day Emissions (lbs/day)

GAS, 2-Cycle
Recreational Equipment 2.5.2 22-60-001-xxx 0.0 0.0 Construction Equipment 2.5.2 22-60-002-xxx 12.2 36.2 Industrial Equipment 2.5.2 22-60-003-xxx 0.1 0.3 Lawn / Garden Equipment 2.5.2 22-60-004-xxx 225 12 Agricultural Equipment 2.5.2 22-60-005-035 0 0 Light Commercial Equipment 2.5.2 22-60-006-xxx 17 93 Logging Equipment 2.5.2 22-60-007-005 0 0 Category Subtotal 254 142
GAS, 4-Cycle
Recreational Equipment 2.5.3 22-65-001-xxx 0 0 Construction Equipment 2.5.3 22-65-002-xxx 63 138 Industrial Equipment 2.5.3 22-65-003-xxx 32 172 Lawn / Garden Equipment 2.5.3 22-65-004-xxx 2,322 127 Agricultural Equipment 2.5.3 22-65-005-xxx 0 0 Light Commercial Equipment 2.5.3 22-65-006-xxx 1,378 7,476 Logging Equipment 2.5.3 22-65-007-xxx 0 0 Category Subtotal 3,795 7,914
CNG/LPG
Recreational Equipment 2.5.4 22-67,68-xxx-xxx 0 0 Construction Equipment 2.5.4 22-67,68-xxx-xxx 2 4 Industrial Equipment 2.5.4 22-67,68-xxx-xxx 190 1,031 Lawn / Garden Equipment 2.5.4 22-67,68-xxx-xxx 2 0 Agricultural Equipment 2.5.4 22-67,68-xxx-xxx 0 0 Light Commercial Equipment 2.5.4 22-67,68-xxx-xxx 0 0 Logging Equipment 2.5.4 22-67,68-xxx-xxx 0 0 Category Subtotal 194 1,036

Diesel
Recreational Equipment 2.5.5 22-70-001-xxx 0 0 Construction Equipment 2.5.5 22-70-002-xxx 65 146 Industrial Equipment 2.5.5 22-70-003-xxx 12 60 Lawn / Garden Equipment 2.5.5 22-70-004-xxx 4 0 Agricultural Equipment 2.5.5 22-70-005-xxx 0 0 Light Commercial Equipment 2.5.5 22-70-006-xxx 20 123 Logging Equipment 2.5.5 22-70-007-xxx 2 0 Category Subtotal 104 329

VEHICLE SUBTOTAL Category Subtotal 4,348 9,421

AIRCRAFT
Military Aircraft 2.5.6 22-75-001-000 2 4 Aircraft: Commercial Aircraft 2.5.6 22-75-020-000 17 86 Aircraft: General Aviation 2.5.6 22-75-050-xxx 48 155 Aircraft: Air Taxi 2.5.6 22-75-060-xxx 7 37 Aircraft Auxillary Power Unit 2.5.6 22-75-070-000 2 12 Airport GSE 2.5.6 22-xx-008-005 61 330 Category Subtotal 138 624

RAILROADS

Locomotives: Line-Haul 2.5.7 22-85-002-007 0 1 Locomotives: Yard 2.5.7 22-85-002-010 3 15 Category Subtotal 3 16

MARINE VESSELS

Commercial Marine Vessels 2.5.8 22-80-004-000 0 0 Pleasure Craft-Diesel-Inboard/Stern 2.5.8 22-82-020-005 0 0 Pleasure Craft-Diesel-Outboard 2.5.8 22-82-020-010 0 0 Pleasure Craft-Gasoline 2-Stroke-Ou 2.5.8 22-82-005-010 0 0 Pleasure Craft-Gasoline 2-Stroke-Per 2.5.8 22-82-005-015 0 0 Pleasure Craft-Gasoline 4-Stroke-Inb 2.5.8 22-82-010-005 0 0 Category Subtotal 0 0 (tons/yr) (lbs/day)
TOTAL NON-ROAD 4,488 10,061 2008 EI

Source Description Table # SCC CodeAppendix 2

– 2015 Medford CO LMP Page 61 Table 2.5. 2 : Medford UGB 2008 CO, Summary of Emissions from Nonroad Gasoline Vehicles * Equipment, 2

- CycleAppendix 2

– 2015 Medford CO LMP Page 62Appendix 2

– 2015 Medford CO LMP Page 63 Table 2. 5. 3 . 2008 Medford UGB CO: Summary of Emissions from Nonroad Gasoline Vehicles and Equipment, 4

- CycleAppendix 2

– 2015 Medford CO LMP Page 64Appendix 2

– 2015 Medford CO LMP Page 65 Table 2. 5. 4 . 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG /LPG Vehicles and EquipmentAppendix 2

– 2015 Medford CO LMP Page 66Appendix 2

– 2015 Medford CO LMP Page 67 Table 2. 5. 5 . 2008 Medford UGB CO: Summary of Emissions from Nonroad Diesel Vehicles and EquipmentAppendix 2

– 2015 Medford CO LMP Page 68Appendix 2

– 2015 Medford CO LMP Page 69 Table 2.5. 6 . 2008 Medford UGB CO: Summary of Emissions from Aircraft and Airport GSEAppendix 2

– 2015 Medford CO LMP Page 70Appendix 2

– 2015 Medford CO LMP Page 71 Table 2.5. 7 . 2008 Medford UGB CO: Summary of Emissions from Railroads
(1) (2) (3) (5)

SCC and Category Description County Emission Spatial factor Annual UGB
Emissions CO Typical Season Day
Emissions (tons/year) (%) (tons/year) (lbs/day)

SCC 22-85-002-007 6.66 3% 0.22 1.21
Locomotives: Line-Haul

SCC 22-85-002-010 8.01 33% 2.67 14.63
Locomotives: Yard

-------- -------- Total CO UGB Emissions (tpy) : 3 16

Notes for Table 2.5.7
(1) The data are from the 2008 NEI, summarized in the file "MedfordCOLMP_2008NEI_Jackson_County.xlsx." (References 5 and 18)

https://gis.odot.state.or.us/transGIS/
Jackson County Medford UGB Spatial Factor

Line-haul 138.3 4.6 3.33%

Yard 3 1 33.33% (3) Annual UGB CO Emissions (tons/year) = County Emissions (tons/year)*Spatial Factor (%).
(4) Seasonal Adjustment Factor (SAF) is obtained from Table 2.5.6 of Oregon 1993 Medford UGB Carbon Monoxide Attainment year SIP Emission Inventory (5) CO Typical Season Day Emissions [lbs/day] = ((Annual Emissions [tons/yr] * 2000 [lbs/ton]) * SAF) / (365 [days]) Total CO UGB Season Typical Day Emissions (lbs/day):

(2) Spatial factor (%) allocates county-wide emissions to UGB. The spatial surrogates for line-haul and yard emissions are track miles and yard locations, respectively. Track miles were obtained from 2008 NEI railway shapfile, and yard locations were identified by using ODET TransGIS: (4)

Seasonal Adjustment Factor

(SAF)

1

1Appendix 2

– 2015 Medford CO LMP Page 72 

### 3.6 On

- Road Mobile Sources

3.6.1 Introduction and Scope This section describes the development of t he emission inventory for CO from on

- road mobile sources in the Medford UGB for the 2008 CO L MP analysis year. On

- road emission estimates from Version 3 of the 2008 NEI database were used to represent countywide emissions. (The

on

- road emission estimates in Version 3 of the 2008 NEI were developed using EPA’s MOVES2010b vehicle emissions model.) On

- road sources included in this inventory were grouped by both vehicle type and road type . Separate sets of on

- road CO emissions categorized by vehicle type and by road type were estimated and reported

.


### 3.6.2 Spatial and Temporal Allocation of 2008 NEI Data

3.6.2.1 Spatial Allocation County

- wide 2008 on

- road exhaust emissions from the 2008 NEI w ere allocated to the Medford UGB using spatial surrogate s based on vehicle miles tr aveled (VMT). The spatial factor was calculated by dividing the Medford UGB ann ual VMT by the Jackson County annual VMT in 2008. Medford UGB annual VMT w as calculated from the model output of the RVMPO “ Models Version 3. 0 ” travel demand model. 8 Jackson County annual VMT w as calculated from the monthly VMT provided in the 2008 NEI supporting “4c” archive file 3 database for transportation activity . Table 2.6.1 and Table 2.6.2 detail spatial allocation of data for on

- road mobile sources. The foll owing formula was used for spatial allocation:

Annual UGB emissions, tpy = Annual Jackson County Emissions (tons/year) * (UGB Annual VMT / Jackson County Annual VMT)

3.6.2.2 Temporal Allocation Typical Season Day CO emissions were calculated by multiplying the UGB annual emissions tons by the SAF , divided by 365 days per year. The SAFs for on

- road emissions grouped by vehicle type were calculated using the values in Table 2.6.5 in the 1993 EI

. 1 The SAFs for on

- road emissions grouped by road type were taken from Table 2.6.3 in the 1993 EI
, 1 and the weekly adjustment factors were taken from Table 2.6.4 in the 1993 EI 1 . The following formula was used for temporal allocation:

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (365 days/year)



### 3.6.3 Summary of On

- Road Mobile Source Emissions
On

- road mobile emissions have been summarized by vehicle type and roadway type for annual and season day emissions in F igures 19 through 21 , and Tables 2.6.1 and 2.6.2 respectively.

The CO Season daily emissions are nominally different in Tables 2.6.1 and 2.6.2 because of the SAFs, which were taken from the 1993 Attainment Year EI 1 . A lthough these SAFs gave the same

3 ftp://ftp.epa.gov/EmisInventory/2008v3/doc

.Appendix 2

– 2015 Medford CO LMP Page 73 CO Season daily emissions in respective tables in the 1993 EI, they result in slightly different CO season daily emissions when applied to the 2008 NEI

.

Figure 18 : Percentage of 2008 Medford Annual Onroad CO Source Emissions, by Vehicle Type

Figure 19 : Percentage of 2008 Medford Season Day Onroad CO Source Emissions, by Vehicle Type LDGV 32 %

LDGT 2

36 % LDGT 4

19 % HDDV 3 % ALL OTHER TYPES

10 %

LDGV 32 %

LDGT 2

36 % LDGT 4

19 % HDDV 3 % ALL OTHER TYPES

10 %Appendix 2

– 2015 Medford CO LMP Page 74 Figure 20 : Percentage of 2008 Medford Annual Onroad CO Source Emissions, by Roadway Type

Figure 21 : Percentage of 2008 Medford Season Day Onroad CO Source Emissions, by Roadway Type 

### Interstate 14 %

Arterial 17 % Collector
7 % Local

5 % Parking Area 57 %

Interstate 16 %

Arterial 17 % Collector 6 % Local

5 % Parking Area 56 %Appendix 2

– 2015 Medford CO LMP Page 75 Table 2.6. 1 . 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Vehicle TypeAppendix 2

– 2015 Medford CO LMP Page 76Appendix 2

– 2015 Medford CO LMP Page 77 Table 2.6. 2 . 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Road TypeAppendix 2

– 2015 Medford CO LMP Page 78 

## 4 Quality Assurance and Quality Control

4.1 Introduction The Oregon DEQ is responsible for overall quality and accuracy of this inventory of Carbon Monoxide (CO) sources and emissions for the Medford urban growth boundary (UGB) for the 2008 Limited Maintenance Plan

. As presented in the IPP delivered to EPA in N ovember 2014, DEQ used existing data that has already been quality checked. DEQ staff performed quality assurance for accuracy, completeness, and representativeness on the spatial and temporal allocation of emissions from the existing inventory. DEQ and Sierra Research used EPA county database estimates from the 200 8 NEI v.3 generated using MOVES 2010b modeled emissions rates

. 5,18



### 4.2 Organization and Personnel Wesley Risher, an emission inventory analyst at the DEQ , was appointed Quality Assurance Coordinator

. DEQ staff Brandy Albertson, Christopher Swab, and Miyoung Park, along with Wenxian Zhang at Sierra Research, performed the bulk of the required source calculations. The abbreviated organizational hierarchy for carrying out the Quality Assurance Program is shown below.

Oregon Department of Environmental Quality Air Quality Division

Wendy Wiles , Administrator

– Environmental Solutions Division Jeffrey Stocum, Manager

– Air Quality Technical Services Section Emission Inventory Christopher Swab, Senior Emission Inventory Analyst Brandy Albertson , Emission Inventory Analyst Miyoung Park , Emission Inventory Specialist Quality Assurance Wesley Risher, Emission Inventory Analyst

David Collier
, Air Quality Planning Manager Dave Nordbe rg , Air Quality Planner

Sierra Research Tom Carlson, Principal Scientist Wenxian Zhang, Associate EngineerAppendix 2

– 2015 Medford CO LMP Page 79 

### 4.3 Data Collection and Analysis

4.3.1 Data Collection and Analysis To ensure the comprehensive nature of the emission inventory, a source listing from the 1993 attainment year inventory was used as a starting point 1 . The listing of sources in the 1993 inventory was generated using EPA's Quality Assurance Plan guidance document 1 and EPA’s Procedures for the Preparation of Emissions for Carbon Monoxide And Precursors Of Ozone 2 were used. The inventoried sources are marked under the appropriate pollutant categor y. Only those sources that had been determined to operate in the inventory areas were included

Inventory source categories were divided into Station ary Point Sources, Stationary Area Sources, Non

- Road Mobile and On

- Road Mobile Sources , the details of which are discussed in Parts 2.3 through 2.6 of this report

. Permitted s tationary point source information is maintained by DEQ for sources with annual emissions of at least 5 tons per year, so a questionnaire/survey was not necessary to identify stationary area and point sources. Emissions from permitted point sources

were calculated on the basis of 2008 production levels and the best available emission factors (from TV source tests or from the permits). Point sources considered in this inventory are listed in Appendix A, Table A

- 1

.
The majority of the area and nonroad source emissions data a t annual, county

- wide levels were taken from previously comp iled EPA and DEQ estimates that were subjected to QA/QC protocols 5

. Many of the stationary area sources and non

- road mobile sources were allocated to UGB by
ap plying a spatial surrogate developed using ArcGIS and zoning shapefiles . Zoning and railway line GIS work was reviewed for completeness and accuracy by DEQ staff familiar with the Medford UGB region and activity. Population, fuel use, and employee data was reviewed by DEQ staff as part of the QA/QC protocols outlined here. Additionally, i n all cases, the source of the information and validation for its use was documented in the calculation spreadsheets and checked at the time of QC for reliability and appropriateness.



### 4.4 DATA HANDLING Data handling by DEQ staff included: 1) data tracking, and 2 ) Q A/QC (which included data checking, data correcting, and handling corrected data). Specific additional procedures included checking data after conversion to the inventory format, checking for missing data, and reviewing the estimates.



### 4.5 Data Coding and Reco rding No air dispersion modeling was performed for this SIP so coding the source emissions for entry into the model was not necessary.



### 4.6 Data Tracking Information obtained from source files, other divisions of the DEQ, other State, Federal, and local agencie s, and private companies used in compiling the emission inventories were recorded in reference files, in appendices, and documented on the calculation spreadsheets. The appendices and calculation spreadsheets were also stored electronically. All emissionAppendix 2

– 2015 Medford CO LMP Page 80 factors, throughputs, seasonal adjustment factors, and activities were documented on the calculation spreadsheets in both hard copy and electronic copy. All of the above mentioned information is kept at DEQ Headquarters.



### 4.7 QA/QC Procedures

- Checking and Cor recting The QC of all source category emissions include d : 1. Checking input data for inventory completeness, missing data, incorrect calculations, incorrect information, and reasonableness, and 2. Correcting the calculation sheets, summary sheets, and Appendic es where needed.

The QA of the emission estimates include: 1. Reviewing the emission summary for reasonableness, and 2. Ensuring that the data transferred betw een agencies and consultants was intact.



### 4.7.1 Checking Data

4.7.1.1 Inventory Completeness Completeness of the inventory was determined by checking against the EPA QA Plan guidance source listings and the 1993 attainment year inventory . Double counting of sources was reviewed to ensure that source categories included in stationary point source category were not al so included in area or non

- road mobile categories. Double

- count removal is detailed in Tables 2.4.3 and 2.4.4 of this document.

4.7.1.2 Missing Data In order to ensure that all the necessary data was submitted for each stationary point source, forms were created t o identify all the data elements required by EPA to be reported for each stationary point source. Any parameter left blank during the initial completion of the form was considered a missing data element. Further review of the source files and, as necessa ry, contact with facility personnel were procedures used to obtain the missing information. If these steps did not result in supplying a missing data element, estimates were made based on similar point sources or from information contained in EPA publicat ions. Written documentation of the source of the data were recorded in the Emission Inventory notebook on the Data Error Report and Correction form as well as in the Audit Trail notebook.

Missing data for stationary area sources and non

- road mobile sources can usually be identified by the inability to calculate emissions. If the appropriate data was missing, a reasonable effort was made to acquire it. If this was unsuccessful, estimates were made based on data of recent years or on information cont ained in EPA documents. Missing data were recorded on the QC area and non

- road mobile correction forms.

4.7.1.3 Incorrect Calculations In order to ensure that all the calculations were done correctly, the calculations were first reviewed to ensure that the y were used correctly, followed by review of ele ctronic equations inAppendix 2

– 2015 Medford CO LMP Page 81 order to make sure that they were entered correctly. Any improperly used or incorrect calculations were noted on the calculation sheet

.
4.7.1.4 Incorrect Information In order to ensure that the informa tion on summary s heets, calculations sheets, and Appendices for this report are correct, all the explanations, titles, and reference were checked for accuracy and clarity. Any changes were documented either directly on the sheet.

4.7.1.5 Reasonableness A reasonab leness check was performed on the estimated emissions, activity levels, and emission factors using the 1993 Medford Attainment Year CO SIP emission inventory 1 as a background comparison.

Stationary point source estimated emissions associated with the Air Contaminant Discharge Permit, Title V Permit, or Title V draft for each identified point source were reviewed in relation to similar sources. In addition, the stationary point source production levels source tests, and permitted emission factors were rech ecked. The source’s current operational status was also reviewed using notices of construction, permit addendums, and DEQ source inspector information. Stationary area source and non

- road mobile estimated emissions were compared, when possible to the 199 3 Medford Attainment Year CO SIP emission inventory 1

. The references from which the emission factors and activity levels were taken were confirmed for the appropriateness of their use. Any reasonableness errors were documented in the correction forms.

4.7.1.6 Emi ssions Summary Reasonableness Emissions summaries were reviewed against the 1993 attainment year, as shown in Executive Summary Figures 3 and 4 of this document.



### 4.8 Data Reporting An electronic copy of this report will be provided to EPA Region X in June 20 15. Electronic copies of the summary and calculations spreadsheets will be made available to EPA upon request.Appendix 2

– 2015 Medford CO LMP Page 82 

## 5 References

1. State of Oregon 1993 Attainment Year SIP Emission Inventory: Medford UGB Carbon Monoxide, Appendix D3

- 4 . Air Quality Division, Oregon Department of Environmental Qual ity, Portland, OR, March 9, 2001

. (DEQ AQ

- TS Ref. 618)

2. Procedures Document for National Emission Inventory, Criteria Air Pollutants 1985

- 1999
, EPA

- 454/R

- 01

- 006, U.S. EPA, Research Triangle Park, NC. March 2001. (DEQ AQ

- TS Ref. 2)

3. Emission Inventory Requirements for Carbon Monoxide State Implementation Plans , EPA

450/4

- 91

- 01 1 , U.S. EPA, Research Triangle Park, NC. March 1991. (DEQ AQ

- TS Ref. 1a)

4. Inventory Preparation Plan/Quality Assurance Plan for the Medford Urba n Growth Boundary 2008 Carbon Monoxide (CO) Limited Maintenance Plan , Oregon Department of Envir onmental Quality, February 2015: Please see Appendix C

.

5. http://www.epa.gov/ttnchie1/net/2008inventory.html

.

6. 2008 National Emissions Inventory, Version 3, Technical Support Document, Draft
, U.S. EPA, Research Triangle Park, Sep 2013.

7. The Jackson County zoning data were downloaded from http://gis.jacksoncounty.org/Portal/gis

- data.aspx

.

8. Technical Memorandum: Modeling to Support the RVMPO 2015

- 2018 TIP Air Quality Conformity Determination (AQCD) , prepared by Jin Ren with ODOT/TPAU, June 2014.

9. Grants Pass SIP Appendices for Carbon Monoxide. Appendix D4

- 4: Grants Pass UGB and CO NAA: 1993 Base Year and 2015 Forecast Year Emission Inventory and Forecast. Oregon DEQ. September 13, 2002. (DEQ AQ

- TS Ref. 933)

10. Internet: http://www.epa.gov/ttnchie1/software/fire/index.html

11. Compilation of Air Pollutant Emission Factors , Fifth Edition and Supplements, AP

- 42, U.S. EPA, Research Triangle Park, NC. January 1995. (DEQ AQ

- TS Ref. 8)

.

12. E mail from Wayne Kauzlarich, DEQ WR Medford, AQ Permit Writer/Inspector to Miyoung Park. City of Medford burn information (2008year). November 28, 2014 (DEQ AQ

- TS Ref. 945)

.Appendix 2

– 2015 Medford CO LMP Page 83 13. Email from Greg G. Kleinberg, City of Medford , Deputy Chief

- Fire Marshal, Medford Fire

Rescue to Miyoung Park. City of Medford burn Information (2008 year). November 25, 2014 (DEQ AQ

- TS Ref. 946).

14. Email from Meghan Fagundes, DEQ WR Medford, AQ Permit Writer/Inspector to Miyoung Park. Complaint open burning locations for Jacks on County in 2008. March 12, 2015 (DEQ AQ

- TS Ref. 951).

15. Email from Greg G. Kleinberg, City of Medford , Deputy Chief

- Fire Marshal, Medford Fire

Rescue to Miyoung Park. City of Medford, illegal burn information (2008 year). March 12, 2015 (DEQ AQ

- TS R ef. 952).

16. Open Burning Emission factor: Emission Inventory Improvement Program (EIIP), EPA, Office of Air Quality Planning and Standards, Emission Factor and Inventory Group, Research Triangle Park, NC. Volume III: Chapter 16 (DEQ AQ

- TS Ref. 947)

17. E

- mail f rom Venkatesh Rao (EPA) to C. Swab. EPA 2008 Oregon/California prescribed burning and wildfire emissions estimates, EIS event format. August 3, 2011. (DEQ AQ

TS Ref. 762)

18. E

- mail from Wenxian Zhang to C. Swab. Medford UGB 2008 CO LMP

- Draft Emissio n Inventory. April 27, 2015. (DEQ AQ

- TS Ref. 961).Appendix 2

– 2015 Medford CO LMP Page 84 

## 6 Appendices to the Emission InventoryAppendix 2

– 2015 Medford CO LMP Page 85 

## APPENDIX A: STATIONARY PERMITTED POINT SOURCES

• Figure A

- 1: Point Source Locations

• Table A

- 1: Stationary Point Source Determination for 2008 CO Inventory Determination

• Table A

- 2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory

• Table A

- 3: Stationary Point Source Emission Estimation DetailsAppendix 2

– 2015 Medford CO LMP Page 86 Appendix A, Figure A

- 1 : 2008 Medford CO LMP Permitted Point Source LocationsAppendix 2

– 2015 Medford CO LMP Page 87 Appendix A, Table A

- 1 : Stationary Point Source Determination for 2008 CO Inventory

Appendix A, Table A

- 2 : Exclusion of 1993 and some 2008 Facilities from CO Emission InventoryAppendix 2

– 2015 Medford CO LMP Page 88Appendix 2

– 2015 Medford CO LMP Page 89 Appendix A, Table A

- 3 : Stationary Point Source Emission Estimation Details

(cont ’d on next page)Appendix 2

– 2015 Medford CO LMP Page 90 Appendix A, Table A

- 3 ContinuedAppendix 2

– 2015 Medford CO LMP Page 91 

## APPENDIX B: STATIONARY AREA SOURCES

• Figure B

- 1: Wildfire and Prescribed Burning Locations

• Table B

- 1: GIS Allocation Results: Josephine County Zones, County

- Wide and by UGBAppendix 2

– 2015 Medford CO LMP Page 92 Appendix B, Figure B

- 1 : Wildfire and Prescribed Burn Location and DateAppendix 2

– 2015 Medford CO LMP Page 93 Appendix B, Table B

- 1 : GIS Allocation Results: Josephine County Zones, County

- Wide and by UGBAppendix 2

– 2015 Medford CO LMP Page 94 Notes for Table B

- 1

## Appendix 3 - EPA Approval Letter

## Justification for Discontinuation of Monitoring in Carbon Monoxide and PM 10 

## Maintenance Areas

Submitted to: Keith Rose, EPA Region 10

By: Anthony Barnack, Oregon DEQ

October, 2011

Last Updated: 12 / 01 /11 By: Anthony Barnack 

## ReportThis report prepared by:

Oregon Department of Environmental Quality

811 SW 6 th Avenue Portland, OR 97204 1 -800 -452 -4011 www.oregon.gov/deq

Contact: Anthony Barnack (503) 229 -57133 3



## Monitoring Discontinuation Justification

Table of Contents

1. Executive Summary

................................ ................................ ................................ ..................... 1

2. Introduction

................................ ................................ ................................ ................................ .. 2

3. Pollutant Trends and Source of Emissions

................................ ................................ .................. 2 3.1 Carbon Monoxide Trends for Eugene/Springfield and Medford

................................ ................................ ........ 2 3.2 Carbon Monoxide Emission Sources in Eugene/Springfield and Medford

................................ ........................ 4 3.3 PM 10 Trends

................................ ................................ ................................ ................................ ........................ 4 3.4 PM 10 Emission Sources in Eugene/Springfiel d and Medford

................................ ................................ ............. 5
4. Fraction of PM 10 that is PM 2.5
................................ ................................ ................................ ...... 5 4.1 Klamath Falls PM 10 vs. PM 2.5 ................................ ................................ ................................ ............................ 6 4.2 Grants Pass PM 10 vs. PM 2.5 :

................................ ................................ ................................ ............................... 7 4.3 PM 10 vs. PM 2.5 Summary:

................................ ................................ ................................ ................................ .. 9
5. Emission Estimate Methods:

................................ ................................ ................................ ....... 9 5.1 The Central Lane MPO Regional Emissions Analysis

................................ ................................ ....................... 9 5.2 The Rogue Valley Regional Emissions Analysis

................................ ................................ .............................. 10
6. An alternate approach for tracking the pollutant

................................ ................................ ....... 10 6.1 Tracking Carbon Monoxide:

................................ ................................ ................................ ............................ 10 6.2 Tracking PM 10 :

................................ ................................ ................................ ................................ ................ 11
7. Alternate contingency measure trigger

................................ ................................ ...................... 11 7.1 Alternative trigger for CO for Medford UGB:

................................ ................................ ................................ . 11 7.2 Alternative trigger for CO for Eugene/Springfield AQMA:

................................ ................................ ............ 12 7.3 Alternative trigger for Klamath Falls PM 10 Urban Growth Boundary

................................ ............................. 13 7.4 Alternative trigger for Grants Pass PM 10 Urban Growth Boundary

................................ ................................ . 14
8. Conclusion

................................ ................................ ................................ ................................ . 14

9. Reference

................................ ................................ ................................ ................................ ... 15

Table of Figures Figure 1. Medford and Eugene/Springfield CO trends.

................................ ................................ . 3 Figure 2. Grants Pass and Klamath Falls PM 10 trends.

................................ ................................ .. 4 Figure 3. Klamath Falls, Peterson School PM 10 /PM 2.5 Correlation.

................................ .............. 6 Figure 4. Klamath Falls winter time PM 10 distribution of PMcoarse and PM 2.5
. .......................... 7 Figure 5. Grants Pass, Parkside School PM10/PM2.5 Correlation.

................................ ............... 8 Figure 6. Grants Pass, winter time PM 10 distribution of PMcoarse and PM 2.5
. ............................. 8

Table of Tables Table 1. Medford and Eugene/Springfield CO design values.

................................ ...................... 3 Table 2. Medford and Eugene/Springfield PM 10 design values.

................................ ................... 5 Table 3. PM 2.5 fraction of PM 10 Average and 95% confidence level.

................................ ........... 9 Table 4. 2010 CO emission estimates within the Eugene/Springfield boundary.

....................... 10 Table 5. 2010 CO emission estimates within the Medford urban growth boundary.

.................. 10 Table 6. Linear regression equations and ratios used to estimate PM 10 using PM 2.5
. .................. 14Glossary of Terms:

NAAQS

– National Ambient Air Quality Standards (EPA criteria pollutant standards) CO

– Carbon monoxide PM 10 – Particulate matter, 10 microns in diameter or smaller PM 2.5 - Particulate matter, 10 microns in diameter or smaller ODEQ

– Oregon Department of Environmental Quality LRAPA

– Lane Regional Air Protection Authority (Lane County, Oregon) SIP

– State Implementation Plan ppm

– Parts per million (concentration) μg/m 3

– micrograms per meter cubed (concentration) FRM

– Federal Reference Method MPO

– Metropolitan Planning Organization AQCD

- The Air Quality Conformity Determination1 1

1 

## Monitoring Discontinuation Justification

1 . Executive Summary

Due to budget cuts, Oregon DEQ and the Lane Regional Air Protection Authority need ed to discontinue carbon monoxide and PM 10 monitoring in maintenance areas which are now far below the National Ambient Air Quality Standard (NAAQS). The monitoring funds have either been lost or reinvested in higher priority monitoring such as PM 2.5 or ozone. These pollutants are much closer to the NAAQS and require sustained monitoring.

The CO and PM 10 maintenance plans require continued monitoring for compliance determination and as triggers for contingency plans. To remove this requirement from the plans would require resources and time that ODEQ and LRAPA cannot afford at this time. EPA Region 10 has proposed a compromise which would require the use of alternative methods to track these pollutants in maintenance areas. The alternative methods w ill be included in the next maintenance plan revisions.

The method fo r tracking CO would use th e regional emissions analysis performed in the Air Quality Transportation Conformity Determination. This is conducted every four years by the Metropolitan Planning Organizations. These analyse s will show the emission trends and will provide a trigger for the contingency plans written into the maintenance plans. As a real time measure, the Portland CO monitor will be used to track trends in general CO levels.

For PM 10 , PM 2.5 will be used as a surrogate. The percent of PM 10 that is PM 2.5 is very high in Oregon and the control strategies are the same for both pollutants.

Maintenance Plans are located at: http://www.deq.state.or.us/aq/planning/maintenance.htm2 2

2 

## Monitoring Discontinuation Justification

2

. Introduction

Beginning i n the 1970s

, and continuing through the early part of the 1990s, Oregon had several communities that violated the carbon monoxide and PM 10 NAAQS and were consequently declared out of attainment for these pollutants. Oregon DEQ and local stake holders implemented State Implementation Plans (SIPs) to bring these areas under the NAAQS. After many years of levels below the standards , maintenance plans were installed to keep the air quality below the NAAQS. The mainten ance plans included requirements to continue monitoring to determine long

- term trends and compliance . Monitoring was also required for contingency measure trigger s for additional regulatory actions.

Over the last twenty years, the CO and PM 10 concentrati ons have dropped far below the NAAQS. Monitoring continued only to meet the maintenance requirements, but had no real benefi t for public health. The maintenance plans require monitoring until 2014 for Eugene/Springfield CO, and 2022 for Medford CO, and 2 023 for Grants Pass PM 10 and Klamath Falls PM 10 . Public health benefits most from PM 2.5 , ozone, and air toxic monitoring.

In the last ten years ODEQ and LRAPA ha ve experienced repeated budget cuts as a result of diminished revenue and expanded costs. In 2010 and 2011, budget cuts were especially deep and re sulted in the elimination or reprioritization of many m onitoring activities . ODEQ and LRAPA had alre ady cut discretionary monitoring and had to now consider shutting dow n required, but low priority monitoring. CO and PM 10 sites were considered expendable as long as alternative methods were available to track general concentrations and act as contingency measure triggers.

This report shows the how alternative methods can be used to adequately track CO and PM 10 and trigger contingency measure s

.

3

. Pollutant Trends and Source of Emissions

3.1 Carbon Monoxide Trends for Eugene/Springfield and Medford The carbon monoxide levels have continuously dropped over the past 20 years and are now routinely one quarter of the NAAQS. Figure 1 show s the CO trend s for Medford and Eugene/Springfield and Table 1 provides the design values from 200 0 to 2010

. Medford has been below the NAAQS since 1993 and Eugene/Springfield has been below the NAAQS since 1983. With ever more cleaner cars on the road, the design values are not expected to increase.3 3

3 

## Monitoring Discontinuation Justification

Figure 1 . Medford and Eugene/S pringfield CO trends. Second highest 8 hour average.

Table 1 . Medford and Eugene/Springfield CO design values. Eugene Medford

(ppm) % of

NAAQS (ppm) % of

NAAQS 2000 4.3 45% 4.7 49% 2001 4.1 43% 4.6 48% 2002 4.2 44% 5.5 58% 2003 3.4 36% 4.7 49% 2004 3.4 36% 4 42% 2005 2.6 27% 3.8 40% 2006 2 21% 2.8 29% 2007 2.1 22% 2.7 28% 2008 1.7 18% 2.4 25% 2009 1.7 18% 2.4 25% 2010 1.3 14% ND ND Based on a nnual 2 nd highest, daily maximum eight hour average.4 4

4 

## Monitoring Discontinuation Justification

3. 2 Carbon Monoxide Emission Sources in E ugene/Springfield and Medford In the past, CO emissions in M edford and Eugene/Springfield wer e primarily from mobile source. In newer vehicles, catalytic converters, fuel injections, and electronic timing have greatly reduced tailpipe CO levels. As the vehicle fleet becomes newer the CO levels are expected to continue drop ping

.

Non

- mobile CO sources include industrial and area sources. Both areas have EPA Title V sources with Plant Site Emission Limits over 100 tons per year. These sources have been operating for years and are regulated. The y would have to go through P revention of Significant Deteriora tion review if they wanted to raise their CO emissions.

Both areas also have a significant population using residential wood heating

. Both were PM 10 non

- attainment area s and ha ve had program s in place for years that encourages the use of certified woodstoves. All of Oregon now has the Heat Smart Program which requires the removal of non

- certified woodstove upon sale of a home. Certified wood stoves emit far less CO than non

- certified stoves.

3. 3 PM 10 Trends Over the last 20 years PM 10 levels have dropped statewide because of permitting programs and other reduction strategies

. Figure 2 shows the PM 10 trends for Grants Pass and Klamath Falls from 1987 to 2010

. Table 2 provides the design values from 200 0 to 2010. Grants Pass has been below the NAAQS since 1988 and Klamath Falls has been bel ow the NAAQS since 1991.

Figure 2 . Grants Pass and Klamath Falls PM 10 trends.5 5

5 

## Monitoring Discontinuation Justification

Second highest 24 hour average PM 10 values.

Table 2

. G r a n t s P a s s a n d K l a m a t h F a l l s PM 10 design values. Grants Pass Klamath Falls

(μg/m3) % of

NAAQS (μg/m3) % of NAAQS 2000 40.0 27% 93.0 62% 2001 50.0 33% 62.0 41% 2002 41.0 27% 121.0* 81% 2003 49.0 33% 63.2 42% 2004 32.3 22% 70.4 47% 2005 37.5 25% 75.5 50% 2006 37.7 25% 56.3 38% 2007 39.3 26% 71.8 48% 2008 42.3 28% 71.7 48% 2009 ND ND 61.8 41% 2010 ND ND 40.8 27% Based on annual 2 nd highest, 24 hour average. * The 2002 Klamath Falls PM 10 value was from a forest fire but was not considered an exceptional event because it was below the NAAQS.

3. 4 PM 10 Emission Sources in E ugene/Springfield and Medford In the past, PM 10 emissions in Medford and Eugene/Springfield were primarily from industr ial and area sources. Both areas have EPA Title V sources with Plant Site Emission Limits over 100 tons per year. Industrial sources were regulated and now have cyclones , bag houses, and more efficient boilers to control emissions. Other methods such as Wigwam burners were outlawed. If these sources wanted to emit more PM 10 they would have to go through Prevention of Significant Deteriation review.

The primary source of PM 10 is now smoke from residential wood heating. Medford and Eugene/Springfie ld were PM 10 non

- attainment areas and have had programs in place for years that encourage the use of certified woodstoves. All of Oregon now has the Heat Smart Program which requires the removal of non

- certified woodstove upon sale of a home. Certified w ood stoves emit far less PM 10 than non

- certified stoves.

4

. Fraction of PM 10 that is PM 2.5 In Oregon, PM 10 is mostly made up of PM 2.5 . This section will show the results of years of wintertime collocated PM 10 and PM 2.5 sampl ing in Klamath Falls and Grants Pass to ascertain the PM coarse (PMc) fraction of PM 10 . In Oregon, winter weather occurs from November through February . This is when most winter inversions occur and the highest concentrations are measured.6 6

6 

## Monitoring Discontinuation Justification

4.1 Klamath Falls PM 10 vs. PM 2.5 C omparable PM 10 and PM 2.5 FRM samplers were operated in Klamath Falls from 2007 through 20 10 . Comparison of the winter PM 2.5 and PM 10 data shows a correlation with an R Squared of 0. 87 (Figure 3 ). During this period there were 17 samples greater than 1⁄4 of the NAAQS, three of which were greater than 1⁄2 the NAAQS. The highest value in the past three winters was 57% of the PM 10 NAAQS. On average, winter PM 10 is 70 % PM 2.5 by weight with a 95% confidence level of 66% to 74% (summarized in Table 3). Figure 4 shows the PM 2.5 and PMcoarse fractions for the highest winter values for 2007

- 2009.

Figure 3 . Klamath Falls, Peterson School PM 10 /PM 2.5 Correlation.7 7

7 

## Monitoring Discontinuation Justification

Figure 4

. Klamath Falls winter time PM 10 distribution of PMcoarse and PM 2.5
. Note: In Figure 4, PMc(red)+PM 2.5 (blue) = PM

10
Over the past ten years there were two years with elevated days outside of winter. In 2002, massive forest fires caused elevated levels during August; the PM 10 was mostly PM 2.5 . In 2009, a dust event caused an elevated level in early October. The dust event had a low PM 2.5 quotient but the PM 10 concentration (87μg/m 3 ) was well below the NAAQS. If that single dust event was included in t he linear regression done in Figure 2, the RSquared would change from 0.87 to 0.76 and the equation would change from y =1.4x+1.0 to y =1.4x+3.2. This is only a 2.2μg/m 3 higher PM 10 derived value if the dust event is included.

4.2 Grants Pass PM 10 vs. P M 2.5 : C omparable PM 10 and PM 2.5 samplers were co

- located in Grants Pass from 2006 through 2008. The PM 2.5 and PM 10 correlation has an R Squared of 0.94 (Figure 5).

From 2006 to 2008 there were only four samples over 1⁄4 of the NAAQS, and none over 1⁄2 the NAAQS. On average, winter PM 10 is 73% PM 2.5 by weight with a 95% confidence level of 70% to 76% (summarized in Table 3) . The highest value in the past three winters was only 29% of the PM 10 NAAQS. Figure 6 shows the PM 2.5 and PM coarse fractions for the winter values for 2006

- 2008.8 8

8 

## Monitoring Discontinuation Justification

Figure 5

. Grants Pass, Parkside School PM10/PM2.5 Correlation.

Figure 6

. Grants Pass, winter time PM 10 distribution of PMcoarse and PM 2.5
. Note: In Figure 6, PMc( red)+PM 2.5 (blue) = PM

109 9

9 

## Monitoring Discontinuation Justification

4.3 PM 10 vs. PM 2.5 Summary: T able 3 shows t he summary of the winter co

- located PM 10 and PM 2.5 samples . This percentage shows the percentage (by weight) of PM 10 that is PM 2.5
.

Table 3 . PM 2.5 fraction of PM 10 Average and 95% confidence level. Average 95% Confidence Level Klamath Falls 70% 66%

- 74% Grants Pass 73 % 70 %

- 76%

5

. Emission Estimate Methods : Modeled CO emission estimates are developed by the Metropolitan Planning Organizations (MPOs) for Eugene/Springfield and Medford as part of the transportation conformity requirements in the maintenance plans in accordance with Clean Air Act section 176(c)

. T ransportation conformity ensure s that f ede ral funding and approval are given to highway and transit projects that are consistent with ("conform to") the air quality goals established by a SIP. Conformity, to the purpose of the SIP, means that transportation activities will not cause new air qualit y violations, worsen existing violations, or delay timely attainment of the NAAQS

. A regional emissions analysis is a major component of demonstrat ing transportation conformity

. The regional emissions analysis includes emissions from all current and plan ned regionally significant projects in the entire transportation system in the maintenance area for the duration of the transportation plan or TIP

. The regional emissions analysis must use the latest planning assumptions and latest emissions mode l

.

This following section discusses the regional emissions analyses conducted in Eugene/Springfield and Medford for transportation conformity determinations.

5. 1 The Central Lane MPO Regional Emissions Analysis T he Central Lane MPO is the agency responsible for performing the regional emissions analysis in the Eugene/Springfield maintenance area

. The most recent regional emissions analysis was completed in 2010 for the “ FY10

- 13 Metropolitan Transportation Improvement Program

. ”

The 2010 CO emission s projections from the regional emissions analyses are shown in Ta ble 4 (in tons per year)

. T he first year listed, 2004, is the regional land use/transportation model base year

.10 10

10 

## Monitoring Discontinuation Justification

Table 4

. 2010 CO emission estimates within the Eugene/Springfield boundary.

Analysis Year Estimated CO Emissions ( t ons/yr)
2004 2,198
2008 1,634
2018 1,160
2028 1,056
203 1 1,059

5.2 The Rogue Valley Regional Emissions Analysis T he Rogue Valley MPO is the agency responsible for performing the regional emissions analysis in the Medford maintenance area

. The most recent regional emissions analysis was completed in 2010 “ 2010

- 2013 Metropolitan Transportation Improvement Program 2009

- 2034 Regional Transportation Plan ”

. The 2010 AQC D’s C O emissions from the regional emissions analysis are shown in Table 5 (in pounds per day)

. The first year listed, 200 5 , is the regional land use/transportation model base year used in the “ 2001

- 2023 Regional Transportation Plan and 2002

- 2005 Transportation Improvement Program ”

.

Table 5

. 2010 CO emission estimates within the Medford urban growth boundary.

Analysis Year Estimated CO Emissions ( lbs/day )
2005 33,910
2015 19,359
2020 20
, 2 80
2026 19
, 770
2034 32,640

6

. An alternate approach for tracking the pollutant CO and PM 10 maintenance plans required continued monitoring to determine NAAQS compliance. If the monitoring agency discontinues monitoring, CO and PM 10 must be tracked using alternative methods. This section outlines the specific tracking methods O DEQ and LRAPA will use for CO in Medford and Eugene/Springfield, and PM 10 in Klamath Falls and Grants Pass.

6.1 Tracking Carbon Monoxide : Carbon monoxide h as traditionally been tracked by monitoring and modeling

. Once monitoring is discontinued in the Eugene/Springfield and Medford maintenance areas, regional emissions modeling will be the primary method of tracking CO.11 11

11 

## Monitoring Discontinuation Justification

Because on-road motor vehicle emissions are the primary source of CO in the Eugene/Springfield and Medford maintenance areas, ODEQ believes the regional emissions analysis conducted for the CO maintenance area s provides an effective surrogate method for
tr acking CO emissions. The regional emissions analysis must use the latest planning assumptions (e.g., population, vehicle miles traveled, employment estimates) and the latest emissions model. The regional emissions modeling is done at least every four years and produces CO estimates based on current and planned transportation activities throughout the CO maintenance areas. If these estimates exceed the base year estimates (shown in italics in Tables 4 and 5), then the current CO concentrations may be higher than the design values for those years (3.4 ppm in Eugene in 2004 and 3.8 ppm in Medford in 2005, see Table 1). If this occurs, EPA and ODEQ or LRAPA will decide whether to conduct CO survey monitoring. If the CO survey monitoring shows levels > 1⁄2 of the NAAQS, then CO monitoring will be restarted. Survey monitoring is done with an inexpensive non-FRM monitor.

ODEQ will also continue to monitor CO in Portland. This monitoring will track general CO concentrations, because if the CO levels increase in Portland, they may also be going up in the other cities. If the Portland CO design value exceeds 1⁄2 the NAAQS, survey monitoring may be performed at the former Medford and Eugene/Springfield CO sites to determine current conditions. If the surveyed CO levels are 1⁄2 the NAAQS, CO monitoring will be restarted.

The CO estimates will be included in the annual network review.

6.2 Tracking PM 10 : PM 10 in Klamath Falls and Grants Pass will be tracked using PM 2.5 monitoring. The major source of PM 10 in these communities is smoke from wood heating. The percentage of PM 10 which is PM 2.5 is known in both of these communities and PM 10 estimates can be made using PM 2.5 monitored levels. PM 2.5 is monitored with both continuous and FRM samplers. Table 6 contains the linear regression equations used to estimate PM 10 from PM 2.5 at these sampling locations.

The PM 10 estimates will be included in the annual network review.

7 . Alternate contingency measure trigger CO and PM 10 maintenance plans contain contingency triggers which are tied to monitored levels. If the trigger concentration is reached, ODEQ or LRAPA must institute the contingency measures outlined in the maintenance plan. If the monitoring agency wants to discontinue monitoring, they need to offer an alternative method to measure air quality for comparison to the trigger level. This section outlines the specific alternative trigger methods for CO in Medford and Eugene/Springfield, and PM 10 in Klamath Falls and Grants Pass.

7.1 Alternative trigger for CO for Medford UGB: Contingency trigger requirements: On March 9 th , 2001, the Environmental Quality Commission adopted the State implementation plan revision for carbon monoxide in the Medford urban growth boundary (a12 12

12 

## Monitoring Discontinuation Justification

plan for maintaining the national ambient air quality standards for carbon monoxide). Section 4.52.3.3 of the plan requires a “Contingency Plan” to take effect if the second highest daily 8 hour average monitored values were 1) above 90% of the NAAQS (phase 1), or 2) above the NAAQS (phase 2). The “Plan” makes an exception for the Medford Old Car Rally. The problem: ODEQ had to discontinue CO monitoring due to budget cuts and very low concentrations. The contingency plan relies on continued monitoring to compare to the trigger points. ODEQ needs to adopt a trigger point based on an alternative pollutant measure.

The Solution : For Medford, two alternative contingency trigger methods will be used. Method 1 relies on estimates produced every four years. Method 2 relies on hourly, real time data.

Method 1: The first method will be to use the modeled CO emissions in the regional emissions analysis conducted every four years by the Rogue Valley MPO for the transportation conformity determination. If the modeled emissions are above the modeled baseline year emissions, CO survey monitoring will be started to determine whether the contingency requirements are triggered. Survey monitoring is done with an inexpensive non-FRM monitor.

Method 2: The Portland, SE Lafayette CO monitor will be used as a surrogate. This provides real time monitoring data. If the Portland monitor reaches 1⁄2 the NAAQS, survey sampling will be started in Medford to determine whether the contingency requirements are triggered. Survey monitoring is done with an inexpensive non-FRM monitor.

7.2 Alternative trigger for CO for Eugene/Springfield AQMA: Contingency trigger requirements: On February 27 th , 1992, Lane Regional Air Pollution (now Protection) Authority sent an addendum to their carbon monoxide maintenance plan title “Contingency Commitment for Amendment of Oregon’s SIP, Eugene -Springfield carbon monoxide Attainment Redesignation & Adoption of Maintenance Plan”. The letter committed LRAPA to a carbon monoxide contingency plan as part of their carbon monoxide maintenance plan. The letter stated that “Within 60 days of reporting on AIRS that a v iolation of the carbon monoxide NAAQS has occurred within the Eugene-Springfield AQMA, LRAPA and LCOG will submit to the EPA a contingency plan for attaining the standard, which will be implemented as expeditiously as practicable”. Since the carbon monoxide NAAQS was never violated following this letter, the contingency plan for attaining the standard was never required.

The problem: LRAPA had to discontinue CO monitoring due to budget cuts and low CO concentrations. The contingency plan relies on continued monitoring to compare to the trigger points. LRAPA needs to adopt a trigger point based on an alternative pollutant measure.13 13

13 

## Monitoring Discontinuation Justification

The Solution : For Eugene/Springfield, one of two alternative contingency trigger methods will be used. Method 1 relie s on estimates produced every four years. Method 2 relies on hourly, real time data.

Method 1: The first method will be to use the modeled CO emissions in the regional emissions analysis conducted every four years by the Central Lane MPO . If the modeled emissions are above the modeled baseline year emissions , CO survey monitoring will be started to determine whether the contingency requirements are triggered. Survey monitoring is done with an inexpensive non

- FRM monitor.

Method 2: T he Portland, SE Lafayette CO monitor will be used as a surrogate. This provides real time monitoring data. If the Portland monitor reaches 1⁄2 the NAAQS

, survey sampling will be started in Eugene to determine whether the contingency requirements are triggered

. Survey monitoring is done with an inexpensive non

- FRM monitor.

7.3 Alternative trigger for Klamath Falls PM 10 Urban Growth Boundary Contingency trigger requirements: I n October 2002, the Klamath Falls PM 10 maintenance plan was finalized, installing a contingency plan that said:

Phase 1: Risk of Violation The County and DEQ will reconvene a planning group to develop an action plan if ambient concentrations (actual or estimated) equal or exceed 90% of the NA AQS concentration of PM 10 (135 μg/m3 for the 24 hour average or 45μg/m3 for an annual average) at Peterson School. The planning group will prepare an action plan that includes a schedule for implementation of additional strategies as necessary to prevent a n exceedance or violation of PM 10 standards. If the high PM 10 concentration was determined to be a natural event based on EPA's policy or an exceptional event, no further action may be needed.

Phase 2: Actual Violation If a violation of the PM 10 standard occurs and is validated by DEQ, the following contingency measures will automatically be implemented:

The problem: DEQ had to discontinue PM 10 monitoring due to budget cuts and low PM 10 levels . The contingency plan relies on continued PM 10 monitoring to compare to the trigger points. O DEQ needs to adopt a trigger point based on an alternative pollutant measure.

The Solution : The PM 10 alternative pollutant measure will be to use PM 2.5 monitoring as a surrogate. The PM 2.5 relationship to P M 10 has been established in recent years with collocated PM 10 and PM 2.5 monitors. Linear regression analysis was performed on the PM 10 and PM 2.5 data14 14

14 

## Monitoring Discontinuation Justification

(Figure 3) and a linear regression equation was established (Table 6). Using this linear regression equation, ODEQ has determined the PM 2.5 concentration needed to trigger the PM 10 “Risk of Violation” and “Actual Violation” levels discussed above, also shown in Table 6

. 7.4 Alternative trigger for Grants Pass PM 10 Urban Growth Boundary Contingency trigger requirements: In October 2002, the Grants Pass PM 10 maintenance plan was finalized, installing a contingency plan that said:

“DEQ will convene a planning group if the 24 -hour PM 10 concentration as measured at the Grants Pass PM 10 monitor equals or exceeds 120μg/m 3 . The planning group will assess the probable emissions event resulting in the elevated PM 10 level and consider a range of measures with the potential to reduce emissions. However, if a violation of the 24 -hour PM 10 standard occurs, Lowest Achievable Emission Rate requirements, plus offsets, for major new industrial sources in the UGB will be restored and the exemption for offsets eliminated.”

The problem: ODEQ discontinued PM 10 monitoring due to budget cuts and low PM 10 levels. The contingency plan relies on continued PM 10 monitoring to compare to the trigger points. ODEQ needs to adopt a trigger point based on an alternative pollutant measure.

The Solution : The PM 10 alternative pollutant measure will be to use PM 2.5 monitoring as a surrogate. The PM 2.5 relationship to PM 10 has been established in recent years with collocated PM 10 and PM 2.5 monitors. Linear regression analysis was performed on the PM 10 and PM 2.5 data (Figure 3) and a linear regression equation was established (Table 6). Using this linear regression equation, DEQ has determined the PM 2.5 concentration needed to trigger the PM 10 trigger of 120μg/m 3 . This is shown in Table 6

.

Table 6

. Linear regression equations and ratios used to estimate PM 10 using PM 2.5
. Klamath Falls Grants Pass Linear Regression Equation y = 1.4 x + 3.2 y = 1.2x + 2.6 PM 2.5 trigger for “Risk of Violation” 94 μg/m 3
PM 2.5 trigger for “Actual Violation” 105 μg/m 3
PM 2.5 trigger for 120 μg/m 3 PM 10 101 μg/m 3
Y = PM 10 , X = PM 2.5

8 . Conclusion Budget cuts have forced ODEQ and LRAPA to cut CO and PM 10 monitoring where they are required by the maintenance plans for compliance determination and contingency measure triggers. Fortunately, the CO and PM 10 levels are so far below the NAAQS that there is very little probability that the monitors would trigger the contingency plans. Regardless, the maintenance plans need ambient levels for comparison, so alternative methods are needed to estimate concentrations. The alternative contingency plans described in this document will15 15

15 

## Monitoring Discontinuation Justification

allow O DEQ and LRAPA to track CO and PM 10 levels into the future. If levels start trending back up near the NAAQS, funding from other monitoring can be shifted and CO and PM 10 monito rs restarted

. This is very unlikely however.

Finally, monitoring is only required during the first 20 years of the maintenance plan. The monitoring requirement for Eugene/ Springfield CO expire s in 2014 . The monitoring requirements for Medford CO will expire in 2023 and for Grants Pass PM 10 and Klamath Falls PM 10 , the monitoring requirements will expire in 202 3

.

9

. Reference 1

. Air Quality Conformity Determination, Central Lane MPO FFY10

- 13 Metropolitan Transportation Improvement Program a nd 2007

- 2031 Regional Transportation Plan, October, 2010. 2

. Air Quality Conformity Determination for 2010

- 2013. Metropolitan Transportation Improvement Program & 2009

- 2034 Regional Transportation Plan

– Amended, Rogue Valley MPO, April, 2010.Appendix 4

– 2015 Medford CO LMP 

## Appendix 4



# Inventory Preparation and Quality Assurance Plan

for the Medford Urban Growth Boundary

2008 Carbon Monoxide (CO)

Limited Maintenance Plan O REGON 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## Q UALITY

Air Quality Division

– Technical Services SectionAppendix 4

- 2015 Medford CO LMP 

## February 201 5

Oregon Department of the Environmental Quality
Inventory Preparation Plan/Quality Assurance Plan

for the

Medford Urban Growth Boundary

2008
Carbon Monoxide (CO)

Limited Maintenance Plan

 Oregon Department of the Environmental Quality

Environmental Solutions Division, Technical Services Section

811 SW Sixth Avenue

Portland, Oregon 97204

Phone 503

- 229

- 5359 • Fax 503

- 229

- 5675Appendix 4

– 2015 Medford CO LMP

Page i 

### TABLE OF CONTENTS

1 IN TRODUCTION

................................ ................................ ................................ .................... 1 Geographic Area

................................ ................................ ................................ ................................ ........ 1 Temporal Resolution

................................ ................................ ................................ ................................ . 3
2 INVENTORY DEVELOPMENT

................................ ................................ ............................ 3

2.1 Data Categories

................................ ................................ ................................ ............................. 4

Emission Sectors

................................ ................................ ................................ ................................ ........ 4
3 SPATIAL ALLOCATION METHODS

................................ ................................ ................... 5
4 TEMPORAL ALLOCATION METHODS

................................ ................................ .............. 7

4.1 Permitted Point

................................ ................................ ................................ ............................. 7

4.2 Aircraft and Locomotives

................................ ................................ ................................ ............... 7

4.3 Nonpoint (area) and Nonroad Vehicles & Equipment

................................ ................................ ... 7

4.3.1 Open Burning

................................ ................................ ................................ ........................ 7

4.3.2 Small Stationary Fossil Fuel Combustion

................................ ................................ .............. 7

4.3.3 Residential Wood Combustion

................................ ................................ ............................. 7

4.3.4 Wildfires and Prescribed Burning

................................ ................................ ......................... 8

4.3.5 Structure Fires

................................ ................................ ................................ ....................... 8

4.3.6 Nonroad Vehicles & Equipment Excluding Aircraft and Locomotives

................................ .. 8

4.4 On

- Road Mobile: Vehicle Exhaust

................................ ................................ ................................ . 8
5 QUALITY ASSURANCE AND QUALITY CONTROL

................................ ....................... 8

6 EXTERNAL AUDITS

................................ ................................ ................................ ............. 8
7 PERSONNEL

................................ ................................ ................................ ........................... 8
8 SCHEDULE

................................ ................................ ................................ ............................. 9Appendix 4

– 2015 Medford CO LMP

Page ii 

### TABLE OF FIGURES

Figure 1

- 1. Medford UGB and CO Maintenance Area

................................ ................................ ........................... 2 Figure 1

- 2. Medford 25 Mile Buffer for CO Sources >100 tons/year

................................ ................................ ..... 3



### TABLE OF TABLES

Table 2.1. 1993 CO Season Day Emissions by Category

................................ ................................ ........................ 4 Table 2.2. 1993 CO Season Day Emissions by Source Category

................................ ................................ ............ 4 Table 3.1. Data Sources, Spatial Surrogates and Boundaries

................................ ................................ ................ 6Appendix 4

– 2015 Medford CO LMP

Page 1 

### 1 INTRODUCTION Medford Oregon was designated a nonattainment area for carbon monoxide (CO) in 1978 and classified as moderate upon enactment of the 1990 Clean Air Act Amendments (CAAA) . The highest 8

- hour carbon monoxide concentration recorded in Medford occurred in 1977 at level of 21.8 ppm. Due to hot spot problems within the downtown region of Medford in 1982 the nonattainment area was revised to include only the central business d istrict. Following the CAAA, t he nonattainment area was modified to the Medford U rban G rowth B oundary (UGB) as recommended by Governor Roberts ’s March 15, 1991 letter to the EPA (57 FR 56762, November 30, 1992) . By the late 1980’s, maximum levels were cl oser to the standard level, and the last exceedances of the standard w ere in 1990.

The area was re designated to attainment for the 8

- hour CO standard in September 23, 2002
, when EPA approved Oregon’s redesignation request and the first maintenance plan d esigned to maintain compliance with the 8

- hour CO standard through the year 2015 (67 FR 48388 , July 24, 2002)

. This plan addresses the second 10

- year maintenance period required under section 175A(b) of Act. Once approved by EPA, the second maintenance plan will fulfill the 20

- year maintenance planning requirements of Clean Air Act section 175A . This Inventory Preparation Plan is in support of the development of the required second CO maintenance plan.

The m aintenance area is the Medford UGB ( Figure 1.1 ). Similar approach is recommended for the second maintenance plan. One of two CO monitors was located at the Brophy building location in downtown Medford. Measured CO levels were so low that the monitor was removed with EPA approval at the end of 2009. Because on

- road mobile vehicle emissions are the primary source of CO in Medford (about 50%), Oregon DEQ has been tracking any increase in emissions for CO in Medford.

The Medford second maintenance plan qua lifies for the Limited Maintenance Plan (LMP) approach because it satisfies all the requirements outlined in the Limited Maintenance Plan Option for Nonclassifiable CO Nonattainment Areas (Paisie memo, 1995). For the 8

- hour CO, in the most recent two
years of data, the maximum value of 2.6 ppm was recorded on January 18 , 20 08 and the second maximum value of 2.4 ppm was recorded on December 6, 2008 . The risk to the community of exceeding the CO standard is low.

Oregon DEQ proposes using existing informatio n from the EPA 2008 National Emission Inventory (NEl) to create the emissions inventory for CO sources in Medford. This document describes the planned approach to the Medford CO LMP EI and the basis for selecting that approach.


### Geographic Area The geograph ic area of the Medford UGB is shown in Figure 1

- 1. The 25

- mile extension to the UGB area is shown in Figure 1

- 2 ; includes incorporated and unincorporated Jackson County and a part of Josephine County. Populated areas within the 25 mile buffer with large point sources included in this inventory are Medford, Rogue River and White City . The city is approximately 28 sq. miles in area, and the US Census 2008 population was 77,667. Th e elevation of the city is approximately 422 meters ( 1384 ft).Appendix 4

– 2015 Medford CO LMP

Page 2 Figure 1

- 1 . Medford UGB and CO Maintenance AreaAppendix 4

– 2015 Medford CO LMP

Page 3 Figure 1

- 2. Medford 25 Mile Buffer for CO Sources >100 tons/year



### Temporal Resolution The CO season is defined as three consecutive months, December 1 st through the end of February. As such, winter season day emissions will be included in the inventory. The unit of measure for winter season day emissions will be pounds per day (lb/day).



### 2 INVENTORY DEVELOPMENT The DEQ will develop an emission inventory u sing EPA 2008 National Emissions Inventory (NEI) data for Jackson County. We will temporally allocate the EI data to CO season, and spatially allocate the county

wide NEI data to the Medford UGB, or to buffers around the UGB, depending on emissions catego ry. All data sources and allocation methods will be documented. The emission inventory will be consistent with the 1993 inventory.Appendix 4

– 2015 Medford CO LMP

Page 4 

### 2.1 Data Categories From the base year (1993) emission inventory for the maintenance plan, the most significant categories of CO emissions in the Medford UGB are on

- road mobile vehicle exhaust, stationary area sources, permitted point sources, and nonroad vehicles and equipment. Table 2.1 shows the breakdown by category for CO Season day emissions in 1993.

Table 2

. 1 . 1993 CO Season Day Emissions by Category Emission Inventory Category Emissions per Day (lb/day) Percent of Daily

Emissions

On

- Road Mobile Sources 57,342 51%

Stationary Point Sources 28,516 25%

Stationary Area Sources 19,748 18%

Non

- Road Mobile Sources 6,536 6%

------- -------

Total 112,143 100%



### Emission Sectors

We propose 11 emission inventory source sectors be included in this LMP for the Medford UGB maintenance area. The sectors are based on a review of emission sectors listed in the 1993 maintenance plan, and an analysis of 2008 NEI data. Table 2.2 shows the breakdown by source category of average daily CO emissions in 1993 inventory; DEQ will use the same source categories as in the 1993 inventory with the exception of the small point sources which will be combined with the Permitted Point Sources category.

Table 2

. 2 . 1993 CO Season Day Emissions by Source Category Emission Source Category Emissions per Day (lb/day) Percent of Worst

Case Day Emissions

Permitted Point Sources 28,516 25.43%

Small Point Sources 13 0.01%

Open Burning 495 0.44%

Small Stationary Fossil Fuel Combustion (a) 390 0.35%

Residential Wood Combustion 18,648 16.63%Appendix 4

– 2015 Medford CO LMP

Page 5 Emission Source Category Emissions per Day (lb/day) Percent of Worst

Case Day Emissions

Wildfires & Prescribed Burning 183 0.16%

Structure Fires 19 0.02%

Aircraft & Airport Related 2,773 2.47%

Locomotives 17 0.01%

Recreational Marine 0 0.00%

Nonroad Vehicles & Equipment 3,747 3.34%

Onroad Mobile: Exhaust 57,342 51.13%

------- --------

Total 112,143 100%

(a) Non

- permitted stationary residential, industrial, commercial, and institutional fuel use 

### 3 SPATIAL ALLOCATION METHODS For emissions sources with specific coordinates, emissions will be mapped to either the UGB or other boundary, depending on emissions source category. For sources without specific coordinates, spatial surrogates will be used to approxim ate both the location and magnitude of emissions. Spatial surrogates are typically used to approximate emissions inside smaller boundaries from larger boundaries. For sources without specific coordinates, county

- wide emissions will be spatially allocated to UGB using the formula:



### E UGB 

### = E COUNTY 

### * Surrogate UGB 

### / Surrogate COUNTY

Where E UGB = emissions in UGB,

E COUNTY = county

- wide emissions

Surrogate UGB = surrogate activity in UGB

Surrogate COUNTY = surrogate activity in county

Data sources, spatial surrogates or boundaries used for each category of emissions are detailed in Table 3

- 1

.Appendix 4

– 2015 Medford CO LMP

Page 6 Table 3

. 1 . Data Sources, Spatial Surrogates and BoundariesAppendix 4

– 2015 Medford CO LMP

Page 7 

### 4 TEMPORAL ALLOCATION METHODS Annual emissions will be adjusted from tons per year to lbs per season day for each source category. Methods for each category are described below , and all methods are consistent with the 1993 EI.



### 4.1 Permitted Point Typical day emissions estimates will be calculated from annual emissions utilizing facility operating schedules taken from source permits. Seasonal adjustment may also be estimated from source annual reports, and DEQ point source emissions estimation reports.



### 4.2 Aircraft and Locomotives Aircraft and locomotive activity will be considered uniform throughout the year. Annual emissions will be divided by 365 days to estimate season day emissio ns.



### 4.3 Nonpoint (area) and Nonroad Vehicles & Equipment For nonpoint (area) and nonroad vehicles and equipment (excluding aircraft and locomotive), temporal allocation to season will follow the formula:

Annual to Typical Season Day = (Annual Emissions * SAF) / (weekly activity * 52 weeks/yr)

Where SAF = Seasonal Adjustment Factor =

= (Season Activity * 12 months) / (Annual Activity * Season Months)

(Reference: EPA

- 450/4

- 91

- 016, p. 5

- 22)



### 4.3.1 Open Burning Open burning will be temporally alloc ated using SAF values and activity in days per week; DEQ may either verify the SAF values used in the 1993 EI or develop new SAF values based on the 2008 permitting and complaint data. Regardless, the method will be consistent with the 1993 EI.



### 4.3.2 Small Stat ionary Fossil Fuel Combustion Annual emissions from small stationary fossil fuel combustion will be temporally allocated using SAF values and activity in days per week taken from the 1993 EI. SAF values for these sources in the 1993 EI were taken directly from EPA

- 450/4

- 91

- 016, Table 5.8

- 1, p. 5

- 18.



### 4.3.3 Residential Wood Combustion Annual emissions from residential wood combustion will be temporally allocated using SAF values and activity in days per week taken from the 1993 EI. SAF values for these sources in the 1993 EI were taken directly from EPA

- 450/4

- 91

- 016, Table 5.8

- 1, p. 5

- 18.Appendix 4

– 2015 Medford CO LMP

Page 8 

### 4.3.4 Wildfires and Prescribed Burning As wildfires and prescribed burning are date

- specific events, DEQ will temporally allocate emissions from these sources using fire date data, ava ilable from the EPA National Emission Inventory (NEI). SAF values will be calculated using annual and seasonal fire dates.



### 4.3.5 Structure Fires As structure fires are date

- specific events, DEQ will temporally allocate emissions from these sources using fire da te data. Fire data used by DEQ to estimate structure fire emissions for the NEI is supplied by the state fire marshal. A seasonal adjustment factor (SAF) will be estimated using annual and seasonal fire dates.



### 4.3.6 Nonroad Vehicles & Equipment Excluding Aircra ft and Locomotives Sources of emissions covered by the Nonroad model include the following categories:

 Recreational marine 

### • Railway maintenance

 Agricultural 

### • Lawn & garden

 Construction 

### • Industrial

 Light commercial 

### • Logging

 Airport Ground Support Equipment (GSE) Emissions from these categories will be temporally allocated to season using SAFs and weekly activity taken from the 1993 emission inventory.



### 4.4 On

- Road Mobile: Vehicle Exhaust EPA provides 2008 on

- road NEI data by month, allow ing for calculation of an on

- road seasonal adjustment factor for typical season day estimation.



### 5 QUALITY ASSURANCE AND QUALITY CONTROL DEQ will be using existing data that has already been quality checked. DEQ staff will perform quality assurance for accuracy, completeness, and representativeness on the spatial and temporal allocation of emissions from the existing inventory. DEQ will b e using EPA county database estimates from the 200 8 NEI v.3 generated using MOVES 2010b modeled emissions rates.



### 6 EXTERNAL AUDITS DEQ is willing to be audited by the EPA, and make changes to this inventory preparation and quality assurance plan if warranted

.



### 7 PERSONNEL DEQ personnel responsible for the Medford CO Limited Maintenance Plan inventory include:Appendix 4

– 2015 Medford CO LMP

Page 9 Wendy Wiles, DEQ Environmental Solutions Division Administrator

Jeffrey Stocum, Air Quality Technical Services Section Manager , 503

- 229

- 5506

Emission Inventory and Air Quality Information Systems

Christopher Swab, Senior Emission Inventory Analyst , 503

- 229

- 5661

Brandy Albertson, Emission Inventory Analyst , 503

- 229

- 6459

Wesley Risher, Emission Inventory Analyst , 503

- 229

- 5092

Miyoung Park, Emission Invent ory Specialist , 503

- 229

- 5178

Quality Assurance

Anthony Barnack, Air Monitoring Coordinator , 503

- 229

- 5713

David Collier, Air Quality Planning & Development Manager , 503

- 229

- 5177

Dave Nordberg, Air Quality Planner , 503

- 229

- 5519



### 8 SCHEDULE



## Medford CO 2008 Limited Maintenance Plan

Draft Inventory Preparation Plan to EPA Oct. 2014

Fast Track Checklist to EPA Feb. 20, 2015

Final IPP with Schedule to EPA Feb. 20, 2015

Draft Emissions Inventory to ODEQ May 1, 2015
Draft Maint. Plan w/o E.I. to EPA May 20, 2015

Final E.I. to ODEQ June 16, 2015

EPA Comments on Draft Maint. Plan to ODEQ June 22, 2015

Maintenance Plan with E.I. to EPA July 1, 2015Appendix 4

– 2015 Medford CO LMP

Page 10 

### EPA Comments on Plan & E.I. to ODEQ (if possible) July 22, 2015

Public Comment Perio d Begins (email notice) Aug. 17, 2015
Public Hearing (in Medford) Sept. 17, 2015

Close of Comment Period Sept. 21, 2015
Rule Adoption Staff Report to Director’s Office Oct. 29, 2015
Environmental Quality Commission Meeting Dec. 9, 2015

ODE Q Submits SIP Rule Update to SOS Dec. 14, 2015

Submit SIP Revision to EPA Dec. 22, 2015
EPA Approves Adequacy Determination Mar. 30, 2016

### Attachment 4

Evidence that the state followed the Ad ministrative Procedures Act

4.1 Public notice in the Secretary of State's Oregon Bulletin, September 1, 201 5
, publication

4.2 Certificate and Order for Filing Permanent Administrative Rules, filed and effective December 1 0 , 201 5

# OREGON BULLETIN

Supplements the 2015 Oregon Administrative Rules Compilation



### Volume 54, No. 9 September 1, 2015

For July 16, 2015–August 15, 2015

Published by JEANNE P. ATKINS Secretary of State Copyright 2015 Oregon Secretary of StateDepartment of Energy on the aggregate amount of funds that have been deferred for green energy technology.

The rules will become effective upon filing. Text of the proposed rules and hearing details can be found on the department website:http://www.oregon.gov/energy/Pages/Rulemaking-Green-EnergyTechnology.aspx. Rules Coordinator: Elizabeth Ross Address: Department of Energy, 625 Marion St. NE, Salem, OR 97301 Telephone: (503) 373-8534
Department of Energy, Energy Facility Siting Council Chapter 345
Rule Caption: Amendments to update the dates of publications, rules, codes, standards, and laws incorporated by reference. Date: Time: Location: 9-18-15 9 a.m. 2 Marine Dr. Port of Morrow Well Spring Rm. Boardman, OR 97818 Hearing Officer: Jason Sierman Stat. Auth.: ORS 469.470 & 469.501 Stats. Implemented: ORS 469.300–469.570 & 469.619. Proposed Amendments: 345-001-0005, 345-001-0010, 345-021- 0010, 345-023-0030, 345-024-0720, 345-027-0023 Last Date for Comment: 9-18-15, Close of Hearing Summary: The purpose of this rulemaking is to update identified Chapter 345 rule provisions that incorporate non-EFSC publications,rules, codes, standards and laws by reference. The proposed amendments will ensure that a more current publication, rule, code, standard or law is referenced in each identified EFSC rule.

In addition to effective dates, some of the identified Chapter 345 rule provisions that incorporate non-EFSC publications, rules, codes, standards and laws also include instructional language that fully implements the provision. Accordingly, to ensure the identified rules continue to function appropriately, some proposed amendments also include updates to the implementing language.

The Council requests public comment on these draft rules. The Council also requests public comment on whether other options should be considered for achieving the rule’s substantive goals while reducing the negative economic impact of the rule on business. Acall-in number is available for the public hearing. Please see the Oregon Department of Energy website for hearing details and othermaterials: http://www.oregon.gov/energy/Siting/Pages/councilrulemaking.aspx Rules Coordinator: Jason Sierman Address: Department of Energy, Energy Facility Siting Council, 625 Marion St. NE , Salem, OR 97301 Telephone: (503) 373-2127
Department of Environmental Quality Chapter 340
Rule Caption: Medford Limited Maintenance Plan for Carbon Monoxide Date: Time: Location: 9-21-15 7 p.m. DEQ Medford Office 221 Stewart Ave., Suite 201 Medford OR 97501 Hearing Officer: Wayne Kauzlarich Stat. Auth.: ORS 468.020 & 468A.035 Stats. Implemented: ORS 468A.025 & 468A.035 Proposed Amendments: 340-200-0040 Last Date for Comment: 9-24-15, 4 p.m. Summary: DEQ proposes this Medford Limited Maintenance Planfor carbon monoxide and associated Emissions Inventory for adoption by the Oregon Environmental Quality Commission. If adopted,DEQ will submit this Plan and Emissions Inventory to the U.S. Environmental Protection Agency (EPA) for approval as a revision to the Oregon Clean Air Act State Implementation Plan.

In the 1970s and 1980s the Medford area violated the national airquality standard for carbon monoxide (CO). State and federal regulations applied measures that reduced CO concentrations and in 2002EPA redesignated Medford as meeting the CO standard. The redesignation included approval of the first Medford CO Maintenance Plan, which demonstrated how the area would continue to meet the standard in the coming decade. EPA required the plan to include a budget for the amount of CO that vehicles operating on the future highway system could emit in coming decades. Each time a new transportation plan is adopted, planners must show that estimated COemissions from the new highway system will remain within the budgeted amount.

DEQ recently discovered the instructions for calculating the emissions budget were incorrect and set too low. When future vehicle emissions are estimated and compared to the emissions budget, they exceed the budgeted amount. This error prevents Medford from adopting a new transportation plan. The situation can be corrected by revising the budget in the original plan or by adopting a new COmaintenance plan. Since Medford is due to adopt a second CO maintenance plan, a new plan is the preferred way of correcting the error.

The measured concentration of CO in Medford is currently 27 percent of the federal CO limit. This low level of CO allows Medford to use the streamlined requirements of a “limited maintenance plan.” Under these streamlined requirements, a vehicle emissions budget is no longer required when preparing future transportation plans.

DEQ, in consultation with EPA and the Rogue Valley Metropolitan Planning Organization (RVMPO), proposes a new limited maintenance plan as the most efficient way to support Medford’s transportation planning process and schedule. Medford will continue to meet the federal CO standard, while eliminating administrativerequirements that are no longer needed to protect air quality. The limited maintenance plan updates Medford’s existing air quality plan, imposes no new control measures and saves the cost of emissions analyses that are no longer useful. Rules Coordinator: Meyer Goldstein Address: Department of Environmental Quality, 811 SW Sixth Ave., Portland, OR 97204 Telephone: (503) 229-6478

Rule Caption: Water Quality Credit Trading Date: Time: Location: 9-21-15 6 p.m. DEQ Headquarters 811 SW 6th Ave., 10th Floor, Rm. EQC A Portland, OR Hearing Officer: Evan Haas Stat. Auth.: ORS 468.020, 468B.020, 468B.030, 468B.035, 468B.550 Stats. Implemented: ORS 468B.555 Proposed Adoptions: 340-039-0001, 340-039-0003, 340-039- 0005, 340-039-0015, 340-039-0017, 340-039-0020, 340-039-0025, 340-039-0030, 340-039-0035, 340-039-0040, 340-039-0043 Last Date for Comment: 9-25-15, 4 p.m. Summary: DEQ proposes the Oregon Environmental Quality Commission adopt new rules establishing a water quality trading program. The proposed rules clarify DEQ’s authority to allow water quality trading as a voluntary compliance option in water quality permits and water quality certifications issued under the Clean Water Act (CWA). In addition, the rules establish the mechanisms and criteria throughwhich DEQ will evaluate and approve water quality trades and oversee implementation of water quality trades. The rules will provide consistency and regulatory certainty for water quality permittees, other stakeholders and the public.

Water quality trading is one compliance option among several available to meet regulatory requirements under the CWA. Throughan approved water quality trading plan, permit holders and other reg

### NOTICES OF PROPOSED RULEMAKING

Oregon Bulletin September 2015: Volume 54, No. 9 16

### Attachment 5

Evidence of adequate public notice

5.1 Affidavits of Publication August 1 4 , 201 5 : The Oregonian Medford Mail Tribune

### Attachment 6

Certification of public hearing

For certification of the public hearing, see the cover letter and page 1 0 of Attachment 1.1

### Attachment 7

Compilation of public comment and department's response

For the Presiding Officer's record for rulemaking hearings, see page 1 0 of Attachment 1.1

For the Summary of comments and DEQ responses, see page 1 2 of Attachment 1.1