Reply to Attn of: AWT-107

MEMORANDUM

DATE: February 19, 2010

SUBJECT: Technical Support Document for:

1. The Portland Portion of the Portla nd-Vancouver (Pdx/Van) Air Quality Maintenance Area, 8-hour ozone Secti on 110(a)(1) Maintenance Plan, and the

Salem-Keizer Air 8-hour ozone Sect ion 110(a)(1) Maintenance Plan, and

2. Oregon’s phase out of the Vehicle In spection Program's (VIP) enhanced BAR-31 test by January 1, 2007 for 1981-95 model year vehicles and elimination of the Gas Cap Pressure Test and the Evaporative Purge Test.

FROM: Krishna Viswanathan, Environmental Scientist

TO: Docket EPA-R10-OAR-2008-0155

TABLE OF CONTENTS

1. The Portland Portion of the Portland-Van couver (Pdx/Van) Air Quality Maintenance Area, 8-hour ozone Section 110(a)(1) Mainte nance Plan, and the Salem-Keizer Air 8- hour ozone Section 110(a )(1) Maintenance Plan.

I. Purpose

II. Background

III. Review of the Maintenance Plan

IV. Evaluation

V. Conclusion

VI. Recommended Agency Action

2. Oregon’s phase out of the Ve hicle Inspection Program's (V IP) enhanced BAR-31 test by January 1, 2007 for 1981-95 model year vehicles and elimination of the Gas Cap Pressure Test and the Evaporative Purge Test.

I. Purpose

II. Background

III. Review of the Proposed Revisions

IV. Evaluation

V. Conclusion2 VI. Recommended Agency Action

The Portland Portion of the Portland-Vancouver (Pdx/Van) Air Quality Maintenance Area, 8-hour ozone Section 110(a)(1) Maintenance Plan, and the Salem-Keizer Air 8-hour ozone Section 110(a)(1 ) Maintenance Plan

.

I. Purpose

This technical support document (TSD) provide s information supporting EPA’s proposed action to approve the State of Ore gon’s May 22, 2007 request to approve the Section 110(a)(1) Ozone Maintenance Plans for the Portland portion of the Pdx/Van AQMA, the Salem-Keizer Area Transportation Study Air Quality Area (SKATS) , and supporting New Source Review and Vehicle Inspection Program rules. The Section 110(a)(1) maintenance plans for these areas demonstrated how the State of Oregon will maintain compliance the 1997 8 hour Ozone National Ambient Air Quality Standards (NAAQS). The 110( a)(1) Maintenance Plans for both these areas meets the Clean Air Act (CAA) requirements and de monstrates that the Portland portion of the Pdx/Van AQMQ and the SKATS Air Quality Area will be able to remain in attainment for 1997 Ozone NAAQS through 2015. Based on my review , I am recommending full approval of the maintenance plan and supporting rules.

On January 17, 2007, EPA received a request from the Washington State Department of Ecology (Ecology) to approve under se ction 110 of the CAA, a SI P revision pertaining to the

Maintenance Plan for the Vancouver Portion of the Pdx/Van AQMA. EPA intends to propose a corollary action on Ecology’s submission concurrently with this action as th ey both pertain to the Pdx/Van Air Quality Maintenance Area.

II. Background

The CAA establishes a process for air quality management through the attainment and maintenance of the NAAQS. Ground-level ozone is not emitted directly by sources. Rather, emissions of volatile organic compounds (VOC s) and nitrogen oxides (NOx) react in the presence of sunlight to form ground-level ozone . The air pollutants, VOCs and NOx, are referred to as precursors of ozone.

A. Pdx/Van AQMA

On March 3, 1978 (43 FR 8961), the Pdx/Van Inte rstate Area consisting of the southern portions of Clark County, Washington and portions of Multnomah, Clackamas, and Washington Counties in Oregon, was designa ted an Ozone nonattainment area under the 1977 Clean Air Act. The Interstate designa tion was warranted as the Portland, OregonVancouver, Washington Interstate Urban Area shares a common air shed and common air quality problems 1 . On November 15, 1990, the CAA was amended (42 U.S.C 7401- 7671(q) and Section 107(d)(1)(C) provided th at designations occu rred by operation of

1 Letter from Clark L. Gaulding, Chief Air Programs Branch, US EPA Region 10 to Pete r Hildebrandt, Assistant Director, Office of Air Programs, State of Wa shington, dated June 12, 1978.3 law for areas that had been designated nonattainment before enactment of the amendments. In 1990, the Pdx/Van Interstate nonattainment area was classified as a marginal 1-hour ozone nonattainment ar ea (Section 181(a)(1) of the CAA).

In May 1997, EPA redesignated the Pdx/Van Inte rstate Nonattainment Area to attainment for the 1-hour ozone NAAQS and approved a Maintenance Plan (62 FR 27204). In July 1997, EPA revised the Ozone NAAQS and esta blished a new standard of 0.08 ppm averaged over eight hours and temporarily vaca ted the 1-hour standard. No violations of

the 1997 8-hour ozone standards have been reported in this nonattainment area.

In 2002, EPA began the process to designate areas under the 1997 8-hour ozone standard. On April 30, 2004 (69 FR 23858), EPA designate d and classified areas for the 8-hour ozone NAAQS. The PDX/Van Interstate Nona ttainment Area was designated as an attainment area for the 1997 8 hour ozone NAAQS. Since then and through December 31, 2008, the highest ozone reading in the area has been at the Carus Site, with a 2005 design value of 0.069 ppm. This value is below the 1997 and 2008 ozone NAAQS. Therefore, the area remains in attainment with the 1997 and 2008 8-hour ozone NAAQS.

B. Salem-Keizer Area Transportati on Study Air Quality Area (SKATS)

The SKATS air quality area marginally violated the federal air quality standard for ozone in the 1970s and was designated an oz one nonattainment area on March 3, 1978, under the 1977 Clean Air Act Amendments (43 FR 8961). The Mid-Willamette Valley Council

of Governments recommended the nonattainme nt area as the area within the SalemKeizer Area Transportati on Study boundary (SKATS) (see Figure 2 in Section 4.50.1.2 of the Oregon State Implementation Plan). This includes portions of Marion and Polk County, including the cities of Salem and Keizer. With the 1990 amendments to the CAA, the SKATS air quality area was de signated “nonattainment/insufficient data.”

Salem’s ozone concentrations are influenced by emissions of ozone precursors in the Portland area. In 1979, the Salem area was desi gnated under EPA guidelines as a “rural”

ozone nonattainment area and an Attainme nt Plan was approved by EPA on April 12, 1982 (47 FR 15587). Salem’s attainment plan under the rural ozone policy consists of

three elements:

I. Controls on major existing sources of volatile organic compounds under Reasonably Available Contro l Technology (RACT) rules;

II. Controls on major new VOC sources unde r Lowest Achievable Emission Rate (LAER) rules, and

III. An approved plan for the Portland- Vancouver AQMA, which is the major urban area upwind of Salem.

All of these program elements remain in place. Although the Salem/Turner ozone monitoring site has no reported violations of the 1 hour standard since 1996, Oregon Department of Environmental Quality (ODEQ) did not submit a redesignation request or4 a maintenance plan for this area. Therefore, SKATS remains a nonattainment area for the

1 hour Ozone standard.

In 2002, EPA began the process to designate areas under the 1997 8-hour ozone standard. On April 30, 2004 (69 FR 23858), the EPA designate d and classified areas for the 8-hour ozone NAAQS. The Salem area was designated as an attainment area for the 8-hour ozone NAAQS. The Salem/Turner ozone monitor shows a 2005 design value of 0.065 ppm. Based on ozone data since 1998, the area re mains in remains in attainment with the 1997 8-hour ozone NAAQS.

C. All Areas

As of April 30, 2004 (69 FR 23951), EPA speci fied that even though the 1-hour ozone standard had been revoked, the 1-hour oz one NAAQS designations and classification

statuses were retained as of the effectiv e date of designation for the 8-hour NAAQS for purposes of anti-backsliding regulati ons (40 CFR 51.905). Consequently, antibacksliding regulations apply even afte r revocation of the 1-hour ozone NAAQS.

EPA’s Phase 1 Implementation Rule for the 8-hour ozone standard was published on April 30, 2004 (69 FR 23951, 23998). 40 CFR 51.905 sets forth requirements for antibacksliding purposes for areas designated attainment for the 8- hour standard. These provisions require such areas to submit a 10 year maintenance plan under section 110(a)(1) of the CAA if they were also a nona ttainment or an atta inment/unclassifiable area with a section 175A maintenance plan under the ozone standard. The maintenance plan needs to demonstrate that the area w ill maintain the standard for 10 years after designation in accordance with section 110(a)(1) of the CAA.

On December 22, 2006, the U.S. Court of Appeal s for the District of Columbia Circuit vacated EPA’s Phase 1 Implementation Rule for the 8-hour Ozone Standard (69 FR 23951, April 30, 2004). On June 8, 2007, in South Coast Air Quality Management Dist. v.
EPA, Docket No. 04-1201, in response to several petitions for rehearing, the DC Circuit clarified that the Phase 1 Rule was vacated only with regard to those parts of the rule that had been successfully challenged – the Phase 1 Rule provisions relate d to classifications for areas currently classified under subpart 2 of Title I, Part D of the CAA. The June 8 decision reaffirmed the December 22, 2006, deci sion that EPA had improperly failed to retain measures required for areas that were previously designated nonattainment for the 1-hour standard and the anti-backsliding provi sions of the regulations. That decision does not affect EPA’s ability to take this action.

On May 22, 2007, EPA received a request from the ODEQ to approve a SIP revision pertaining to the Maintenance Plan for the Portland Porti on of the Portland-Vancouver

Interstate Maintenance Area and a Maintena nce Plan for the SKATS air quality area, under section 110 of the CAA. This plan demonstrates how the ODEQ intends to maintain the 8-hour ozone NAAQS. This ma intenance plan contains a base-year inventory for 2002, projected emissions to 2015, and results of computer modeling that

demonstrates that the 8-hour Ozone standards will not be violated in 2015. The plan also5 indicates how maintenance plan progress will be tracked and identifies measures that would be available to promptly correct any NAAQS violation. ODEQ’s SIP submittal meets the CAA requirements for SIP submittals under Section 110(a)(1), Section 110(l)

and Section 193.

III. Review of the Maintenance Plan

A. What are the components of a section 110(a)(1) 8-hour ozone maintenance plan?

CAA Section 110(a)(1) requires states to s ubmit plans to EPA which provide for the implementation, maintenance and enforcement of NAAQS standards in each air quality control region with the state. On May 20, 2005, EPA issued guidance that applie s to areas that are designated as unclassifiable/a ttainment for the 8-hour ozone standard. The purpose of that document is to address the maintenance requir ements in section 110(a)(1) of the CAA, and provide guidance to the states in the development of a SIP.

Both the Pdx/Van AQMA and the SKATS AQA are eligible to submit maintenance plans under section 110(a)(1) according to this guidance. Th e Pdx/Van AQMA qualifies as an area that is designated unclassifiable/attainment for the 8 hour ozone NAAQS and is designated attainment for the 1-hour ozone NAAQS with an approved maintenance plan. SKATS qualifies as an area that is designated unclassifia ble/attainment for the 8 hour ozone NAAQS and is designated nonattainment for the 1-hour ozone NAAQS. The maintenance plan for these areas should include the following five components:

1. Attainment Inventory – The attainment inventory should be based on actual “typical summer day” emissions of volatile organic compounds ( VOCs) and nitrogen oxides (NOx) for a 10-year maintenance period. For purposes of an attainme nt emissions inventory, the state must choose any of the three years on which the 8-hour oz one attainment designation was based. As many areas are already required to develop an inventory for the 2002 under EPA’s Consolidated Emissions Reporting Rule (CERR; 40 CFR Pa rt 51, Subpart A, 67 FR 39602, June 10, 2002), EPA recommends that areas use that year as the attainment emission inventory base year for the section 110(a)(1) maintenance plan.

2. Maintenance Demonstration – The area must demonstrate how it will remain in compliance with the 8-hour ozone standard for a period of 10 years following the effective date of designation as unclassifiable/attainment. If the ef fective date of the ar eas’ designation for the 8- hour NAAQS was June 15, 2004, the maintenance plan must project attainment for 2014 or beyond.

A typical method that areas have used to dem onstrate that an area will maintain the 1-hour

standard has been to use the attainment inventor y and to show that future emissions of ozone precursors will not exceed those levels. Howeve r, in areas where transport of precursor emissions from an area outside a jurisdiction is a factor to ozone levels, more sophisticated analysis using air quality models may be required to demonstrate maintenance of the standard.6 3. Ambient Air Quality Monitoring - The state should continue to operate air quality monitors in accordance with 40 CFR Part 58 to verify maintenance of the 8-hour ozone standard.

4. Contingency Plan – The state must develop measures so th at in the event of a violation of the 8-hour ozone NAAQS, the measures can be implemen ted as expeditiously as practicable after the

violation.

5. Verification of Continued Attainment – The state must indicate how it intends to track the progress of the maintenance plan. This is necessary because emissions projections for the maintenance demonstration depend on assumptions of point, area, and mobile source growth.

B. How has the state addressed the componen ts of a section 110(a)(1) 8-hour ozone maintenance plan?

1. Attainment Inventory - This maintenance plan contains a base-year inventory for 2002 and projects emissions to 2015. The effective year of the 8-hour ozone ini tial designation was 2004; ODEQ projected emissions for 10 years or beyon d from the effective date of the initial designation. Consequently, ODEQ de veloped an emissions invent ory for ozone precursors for the year 2002 and 2015. In this projection is a bu ilt-in growth allowance for point sources of

5000 tons of VOC and 5000 tons of NOx. S ection 4.50.4.1.2 Industrial Emission Management Rules and Growth Allowance Program Procedures explain how the 5000 tons will be allocated to

industrial facilities.

ODEQ used a comprehensive emissions invent ory for VOCs, NOx and CO for the 2002 BaseYear in order to project emissions. DEQ develope d an attainment emission inventory for the year 2002. The emission inventory reflects detailed estim ates of emissions from all sources, grouped into four major categories:

۞ Industrial Point Sources (sources with a DEQ air quality permit), ۞ On-Road Mobile Sources (e.g. mo tor vehicles and trucks), ۞ Non-Road Mobile Sources (e.g. lawnmowers, construction equipment and other engines),

and ۞ Area Sources (e.g. household products, print shops, degreasing a nd surface coating operations, pesticide applicati on, open burning and wildfires).

The 2002 Consolidated Emissions Reporting Rule (CERR) emissions data submitted by DEQ

and SWCAA to EPA’s National Emission Inventor y (NEI) were used as the basis for the 2002 attainment year inventory. This 2002 count y-by-county annual inve ntory was developed following the currently accepted methodologies for the National Emission Inventory. The Technical Appendices submitted with ODEQ’s ma intenance plan contain more detailed

information for each sector of the emission inventories.7 Table 1

Figure 1

Table 28 Figure 2

Emissions for all source categories were calcu lated following EPA guidance and are properly documented in the Appendix D of the Maintenan ce Plans. This component of the Maintenance Plans meets the requirements for attainment inventories under Sec tion 110(a)(1) and EPA guidance.

2. Maintenance Demonstration – Since 2004 is the effective date of designations for this area for the 8 hour NAAQS, the maintenance plan mu st demonstrate maintenance to 2014 or beyond. This maintenance plan projects emissions to 2015. The ODEQ developed two different growth scenarios for major industrial (point) sources . The first growth scenario (called “2015 Projection”) reflects the 2002 estimate of actua l industrial emissions, increased by regional employment projections for that sector. The s econd growth scenario (called “2015 Maintenance Demonstration”) represents a very conservative estimate of possibl e future year emissions and is

used in maintenance demonstration for the maintenance plan. The 2015 Maintenance

Demonstration reflects maximum “legally allowable” emission levels currently permitted for existing industry, plus the emissions growth a llowance reestablished for new industry growth. For the Portland, OR side of the Pdx/Van AQMA the growth allowance is 5,000 tons per year

each of NOx and VOCs.

Portland Area 2105 Emissions projections used for Maintenance Demonstration in lbs/day9 Table 3

The submission from ODEQ depicts on-road emi ssions decreasing significantly (61% less VOC

emissions and 68% less NO X emissions) due to the implementation of federal motor vehicle emission and fuel standards and continuing impl ementation of the vehicle inspection program.

Non-road emissions also show a 30% decrease in NO X emissions due to the phase-in of federal

emission and fuel standards. Area source emissions are expected to increase due to increases in population that affect categories such as architect ural surface coating and consumer solvent use.

Point source “actual” emissions are inflated by the growth allowance to derive the 2015

Maintenance Demonstration amount.

For the Portland area, this summarizes to 2015 VOCs increasing by about 5% from 2002 actual emissions, and 2015 NO X emissions decreasing by about 30% with point sources showing the greatest increase and on-road mobiles s ources showing the greatest decrease.

Figure 410 Table 4

ODEQ submitted information to verify that on-road emissions for the Salem area decrease significantly (71% less VOC emissions and 69% less NO X emissions) due to the implementation

of federal motor vehicle emission and fuel standa rds. The Salem area will also benefit from the phase in of on-board canister systems in motor vehicles that control gasoline vapors while refueling. Non-road emissions also show a 42% decrease in NOx emissions due to the phase-in

of federal emission and fuel standards. Area sour ces in the Salem area are projected to increase slightly due to increases in population.

Point source “actual” emissions are not expected to change significantly although the table above

describes the difference between “actual” emissi ons in the 2002 attainment inventory and the “allowable” emissions and growth allowance in the 2015 Maintenance Demonstration. The 2015

Maintenance Demonstration include s one proposed energy facility that has withdrawn its permit application making the invent ory very conservative.

For the Salem area, this summarizes to 2015 VOCs decreasing by about 8% from 2002 actual emissions, and 2015 NO X emissions decreasing by about 51% with point sources showing the greatest increase and on-road mobiles s ources showing the greatest decrease.

As the tables above indicate, 2015 emissions s how an overall decrease fo r both the Pdx/Van and the SKATS areas during the 10-ye ar maintenance period. However, it is important to note that the formation of ozone is dependent on a numbe r of variables, which cannot be estimated by emissions projections alone. As the Pdx/Van In terstate Urban Area shar es a common airshed and common air quality problems 2 , examining the effects of transp ort of ozone precursors from the Vancouver, WA side of the AQMA is necessar y. Other variables include, weather and the transport of ozone precursors from areas outside of the State of Oregon. In order to demonstrate continued maintenance, a state may utilize more sophisticated tools such as air quality or dispersion modeling.

2 Letter from Clark L. Gaulding, Chief Air Programs Branch, US EPA Region 10 to Peter Hildebrandt, Assistant Director, Office of Air Programs, State of Washington, dated June 12, 1978.11 In section 4.40.5.4 of their maintenance plan, ODEQ summarizes the re sults of dispersion modeling study performed for the Pdx/Van Maintenance Area in 2004 by the Washington State University (WSU) (see table and chart below). Fo r further details of the study see Appendix D – of the ODEQ SIP submittal.

Table 5

2015 Maintenance Demonstration for the Pdx/Van/SKATS Maintenance Area (ppm)
1997 8-hour ozone standard = 0.08 ppm

Exceedance ≥ 0.085 ppm maximum

Violation > 0.085 ppm Predicted Design Value

Monitoring Site 1998 Predicted

Maximum 2015 Predicted

Maximum 2015 Predicted Design Value*, ppm

Portland/Carus 0.098 0.094 0.072

Portland/Milwaukie 0.092 0.096 0.062

Portland/Sauvie Island 0.082 0.076 0.054

Vancouver/Mountain View 0.083 0.081 0.061

Salem/Turner 0.088 0.075 0.060

*Predicted Design Value is calculated using the EP A statistical procedure called the Relative Reduction Factor described in Appendix 6 of the ODEQ’s s ubmittal and in EPA’s 8-hour ozone modeling guidance. Predicted design value is compared to the 8-h our ozone standard to determine compliance.

Figure 512 These results in Table 5 and Figure 5 illustra te that the Pdx/Van AQMA and the SKATS will maintain compliance with the 8-hour ozone st andard through 2015. The Carus monitoring site, downwind of Portland, has historically been the site with the highest ozone readings in the region. The model predicted that the Milwaukie site would produ ce a slightly higher maximum value under worst case meteorological conditions, and the maximum values at both Milwaukie

and Carus would exceed but not violate the standa rd. However, the Carus site is expected to remain the highest and most important site for determining compliance with the ozone standard. The design value at Carus and all other sites demonstrate continued compliance with the 1997 and 2008 ozone NAAQS.

Supplemental Review for Compliance with section 110(l) of the CAA

Does ODEQ’s Section 110(a)(1) 8- hour ozone maintenance plan co mply with all aspects of the

Clean Air Act?

Before a modification to the Portland Ozone Ma intenance Plan can be approved by EPA, the Agency must determine that the submission meets the requirements of CAA Section 110(l) of the

CAA which states “....The Administrator shall no t approve a revision of a plan if the revision would interfere with any applicable requirement concerning attainment and reasonable further progress (as defined in section 171), or any other applicable requirement of this Act.”

The Ozone NAAQS has changed from 1997 to 2008. The 2008 8-hour Ozone NAAQS was promulgated in March 2008 with primary a nd secondary standards at 0.075 ppm or 75 ppb. These are the currently applicable NAAQS and th e attainment demonstration has to show that the 2008 NAAQS is also not being vi olated into the future due to the changes proposed by the State of Oregon. As seen from the table and chart above the 2015 predic ted design values are below the 2008 NAAQS. Therefore this plan demons trates compliance with all applicable Ozone NAAQS, from 1997 and 2008.

We applied the same standard of review for a ll criteria pollutant NAAQS. The Portland area is currently designated as an attainment area for a ll criteria pollutants, a nd historical monitoring data affirms that this area is in comp liance with other criteria air pollutants NAAQS 3

. Additionally, EPA’s evaluation of the impacts of the changes proposed in this Plan has determined that these changes will not cause an in crease in direct or precursor emissions that will

interfere with the attainment or maintenance of any other NAAQS.

Therefore the proposed approval of this plan will not interfere w ith any applicable requirement concerning attainment or maintenance of any applicable NAAQS in the Portland area.

Based on monitoring in the area, SKATS is in compliance with the remaining NAAQS 4

. Additionally, the actions proposed for approval in this Plan will not cau se an increase of direct or precursor emissions of any criter ia pollutant such as to inte rfere with the attainment or maintenance of any other criteria pollutant NAAQS.

3 EPA’s AirData database at http://www.epa.gov/oar/data/reports.html

4 EPA’s AirData Database - http://www.epa.gov/oar/data/reports.html13 Therefore, this plan demonstrates compliance wi th all applicable ozone NAAQS in Pdx/Van and SKATS and the proposed approval of this plan will not interfere with the attainment or maintenance of any other NAAQS for these areas.

Control Strategies for the Portland and Sa lem Area, Applicable Rules and Changes:

The following strategies are supported by the rule s that are in the currently approved SIP and

will continue to will remain in the Portland Ozone Maintenance Plan as they currently apply to

sources in the Portland area:

۞ Motor Vehicle Inspection Progr am (OAR 340-256-0300 through 0470); ۞ Emission Standards for VOC Point Sources (R easonably Available Control Technology) for existing major industrial faci lities (OAR 340-232-0010 through 0230); ۞ New Source Review Program for new and e xpanding major industrial facilities (OAR 340-224-0010 through 0100 and 340-225-0010 through 0090); ۞ Voluntary Parking Ratio Ru les (OAR 340-242-0300 through 0390); ۞ Barge Loading Rules and Stage I vapor recovery systems that control VOCs from gasoline delivery operations (included within OAR 340-232); ۞ Aerosol Paint Rules that lower VOC content fr om spray paints sold in the Portland area (OAR 340-242-0700 through 0750); ۞ Motor Vehicle Refinishing Rules that requir e low-emitting painting methods at auto body shops (OAR 340-242-0600 through 0630); and ۞ Public education and outreach that encour ages people to voluntarily reduce emissions, such as not mowing lawns and driving less on Clean Air Action Days (now called Air Pollution Advisories).

The following strategies in the Portland-Vancou ver Ozone Maintenance Plan (Oregon portion) have been modified and were submitted for approval by EPA. More details are discussed with each rule submitted for approval, as needed. Base d on EPA review and determination that these modifications are acceptable under the CAA, thes e modifications are proposed for approval and incorporation in the federally approved SIP for Oregon.

۞ General Air Pollution Procedures and Definition: OAR 340-200; ۞ Ambient Air Quality Standards and PSD Increments: OAR 340-202

o OAR 340-202-0090 Ozone: OAR 340-202 includes Oregon’s ambient air quality

standards and section 202-0090 was revise d to update the oz one standard to

reflect revisions to the national ambi ent air quality st andards (NAAQS). Specifically, this revision replaces the 1-hour standard of 0.12 ppm with the new 8-hour standard of 0.08 ppm and adopts by reference 40 CFR 50, Appendix I as the appropriate method for determining compliance with the standard. This

revision is consistent with EPA revi sions to the ozone NAAQS and should be approved. ۞ Designation of Air Quality Areas: OAR 340-204 ۞ Major New Source Review: OAR 340-224

o OAR-340-224-050 : OAR-340-224 includes ODEQ’s Major New Source Review regulations for both nonattainment ar eas (section 224-0050) and maintenance14 areas (section 224-0060). Since Salem is be ing re-designated from nonattainment to maintenance, the special exemp tion provisions for the Salem Ozone Nonattainment Area included in paragr aph 224-0050(4) of the nonattainment area provisions are being moved to the maintenance area provisions in a new paragraph 224-0060(2)(e). The proposed re vision is consistent with the redesignation of the Salem nonattainment area to maintenance and should be approved. ۞ Air Quality Analysis Re quirements: OAR 340-225

o OAR 340-225-0090 : OAR 340 225 includes ODEQ’s Air Quality Analysis Requirements and minor edits are made to paragraph 225.0090(2)(e) reflecting the re-designation of Salem from a nonattainment to maintenance area. ۞ Emission Standards for VOC Point Sources: OAR 340-232 ۞ Rules Applicable to the Portland Area: OAR 340-242 ۞ Employee Commute Options Program (OAR 340-242-0010 through 0290):

o Program requirements now focus on larg er employers (100 or more employees) and reduce the survey requirements from annual to every two years. Section 4.50.4.1.1 Changes to the Employee Commute Options Rule discusses the changes to the rule in detail. EPA review ed this proposal and concludes that 90% of the trip and emission reductions are maintained by focusing on larger employers. Therefore, this change in focu s retains substantial benefits of the ECO program making it easier to administer. ۞ Industrial Emission Management Pr ogram (OAR 340-242-0400 through 0440):

o Reestablish the industr ial growth allowance for new and modified major industrial

sources to ensure that the ozone stan dard will not be violated even under conservative growth assumptions. Section 4.50.4.1.2 Industrial Emission Management Rules of the maintenance plan describes this program in great detail. This maintenance plan reestablishes th e existing growth allowance for new and expanding major VOC and NO X industrial sources, creates an administrative and public process for releasing the growth a llowance in increments, and retains the emission offset requirement as a safe guard. The growth allowance has been

included in the modeled 2015 ozone maintenance demonstration.

Sections 4.50.4.1.3 ODEQ’s 110(a)(1) submission mentions that al though according to EPA’s 2004 ozone implementation rules (40 CFR 51.900), ne ither general conformity nor transportation conformity is required for areas attaining the 8- hour ozone standard, the ODEQ and the Portland Metropolitan Service District or Metro (Metro is a Portland metropolitan area elected regional government chartered as primarily responsible for regional land-use planning 5 ) will informally track VOC, NOx, air toxics and greenhouse gas em issions when Metro assesses conformity for the purposes of the Portland Carbon Monoxide Ma intenance Plan as a voluntary program to assess impacts of transportation emissions on ai r quality over time. This will help the state

understand and track the trends of these emissions w ith respect to the growth projections in this maintenance plan and its relation to air quality in the area.

ODEQ commits to retaining strategies in the S KATS Attainment Plan that was adopted in 1980 and revised in 1982, including Emission Standa rds for VOC Point Sources (OAR 340-232-0010

5 http://www.oregonmetro.gov/index.cfm/go/by.web/id=211 – accessed on Sept, 04, 2009.15 through 0230) and continued reliance on the cont rol strategies in the Portland-Vancouver AQMA

Ozone Maintenance Plan.

All these controls were incorporated in the maintenance demonstration inventory and modeling performed for the Pdx/Van AQMA and the SKATS ar ea. Even with these po licies represented by these rule incorporated in the technical analysis , the results indicate that both these areas will

maintain the 1997 and the 2008 8 hour ozone standards through 2015.

3. Ambient Air Quality Monitoring – ODEQ commits to operate an ozone air quality monitoring network in accordance with 40 CFR 58 to verify maintenance of the 8-hour ozone

standard in Portland and Salem (see Appendix D10-1 of ODEQ’s submittal). The agency further commits that any modification to the ambient air monitoring network, such as removal of duplicative or unnecessary monitors, will be acco mplished through close consultation with the EPA Regional office. Proposed network modifi cations would be accompanied by technical and statistical analysis sufficient to document th at a given monitor may be removed because:

a. it is unnecessary or duplicative in the case of network reductions, or b. to justify the value of investing in monitoring network enhancements.

In accordance with 40 CFR 58, the final network desi gn will be subject to the approval of the EPA Regional Administrator.

4. Contingency Plan – Section 110(a)(1) of the CAA requires that the state develop a contingency plan which will ensure that any vi olation of a NAAQS is promptly corrected. The purpose of the contingency plan is to adopt meas ures, outlined in the main tenance plan, in order

to assure continued attainment in the event of a violation of the 8-hour ozone NAAQS. The maintenance plan should identify the even ts that would “trigg er” the adoption and implementation of a contingency measure(s), the contingency measure(s) that would be adopted and implemented, and the schedul e indicating the time frame by wh ich the state would adopt and implement the measure(s).

The provisions specified under Part A of the Contingency Plan for the Portland-Vancouver AQMA are linked to ambient concentrations of oz one and would be triggered if measured ozone levels at any of the ozone monitoring sites (Mou ntain View, Sauvie Island, Milwaukie, or Carus) exceed the early-warning thresholds specified be low, or if a violation of the 8-hour ozone

standard occurs.

The provisions specified under Part B of the Contingency Plan are linked to increases in the average amount of vehicle use per person in the Portland metropolitan area, and would only affect the Oregon portion of the Portland-Va ncouver AQMA. The following are the specific steps that ODEQ will take the based on monitored values of ambient ozone:

Part A of the Contingency Plan Based On Ambient Concentrations in Portland or

Vancouver

PHASE 1: ELEVATED OZONE LEVELS16 If the air quality index (AQI) is forecast to be within the “orange” range for ozone air quality (unhealthy for sensitive populations), or 8-hour daily maximum ozone values approach 0.100 ppm or greater, and meteorologi cal conditions conducive to ozone formation are expected to persist, SWCAA will coordinate to issue an advisory to inform the public of air quality levels and voluntary actions they can take to limit expos ure to unhealthy air pollution levels and reduce

emissions.

PHASE 2: RISK OF VIOLATION

If monitored 8-hour ozone levels at any site within the Portla nd-Vancouver area registers an annual fourth highest monitored value of 0.085 pp m or greater within a single ozone season or 0.080 ppm or greater averaged over two years, ODEQ and SWCAA and will assess the likely

sources of emissions and meteor ological events contributing to elevated ozone levels. ODEQ may form a planning group to assist ODEQ in its review. Th e ODEQ could recommend that no

action be taken if it is determined that:

1. elevated ozone levels were caused by an ev ent that is unlikely to occur again, or

2. high ozone levels were caused by an uncontro llable event, such as a severe wildfire,

or 3. federal regulations that will reduce ozone precursor emissions are scheduled to be implemented within two years.

If it is determined that the event did not meet the criteria above, DEQ will evaluate options for appropriate action, including the option for additi onal emission reduction strategies to prevent

future exceedances or a violati on of the 8-hour ozone standard.

PHASE 3: ACTUAL VIOLATION

If a violation of the 8-hour ozone standard occurs, ODEQ SWCAA will determine the emissions and meteorological events contri buting to the violation. If the violation is not due to an

uncontrollable event or other criteria in Phase 2, ODEQ will identify new strategies necessary to ensure compliance with the 8-hour ozone standard within 18 months of the conclusion of the ozone season that prompted the contingency plan, and revise the maintenance plan as needed to correct the violation. A revised maintenance pl an would be submitted to EPA for approval.

Measures that would be considered fo r implementation include the following:

o Reinstatement of applicable measures as defined in 40 CFR 51.900, which includes the Enhanced Inspection/Main tenance Test for certai n model year vehicles;

o Contingency Plan Requirements described in OAR 340-224-0060(5) that reinstate the LAER and offset requirements and eliminat e the growth allowance until a revised maintenance plan is adopted by the EQC and approved by EPA;

o Other measures as appropriate.

Part B of the Contingency Plan Based on Sign ificant Increase in Vehicle Miles Traveled in the Oregon portion of the Portland-Vancouver AQMA17 Although EPA’s 8-hour ozone implementation rule (69 FR 23987-88, April 30, 2004) does not allow states to implement conformity for attainme nt areas as a matter of federal law, the rule states that states can work with their metropo litan planning organizations to develop a voluntary program to address motor vehicle emissions growt h. Metro has agreed to informally track motor

vehicle VOC and NOx emissions at the same time as they are demonstrating conformity with the

Portland Carbon Monoxide Maintenance Plan emissi ons budget. In addition, Metro has agreed to the following contingency measures for the Po rtland Carbon Monoxide Ma intenance Plan that are also appropriate as voluntary measures for addressing ozone precursor emissions within the Portland metropolitan area. Although transportation control measures cannot be enforced and are removed from the Portland AQMA Ozone Maintena nce Plan, other measures to reduce vehicle miles traveled (VMT) such as the Employee Co mmute Option program and public education and outreach remain in the ozone maintenance plan . In addition, DEQ par ticipates in Metro’s Regional Transportation Options program which includes many efforts in the Portland area designed to reduce single-o ccupancy vehicle trips.

PHASE 1: 5% VMT INCREASE

Metro will review and verify the local av erage vehicle miles traveled per capita (VMT/capita) for the Oregon portion of the Portland-Vancouver Air Quality Maintenance

Area derived from the most recent estimat es of population and daily vehicle miles

traveled from federal and state sources.

If daily VMT/capita exceeds a 5 % increase above the 2002 rate for two successive years, the Standing Committee [TPAC, as defined at OAR 340-252-0060(2)(b)(A)(iii)] shall be

convened to:

1. determine whether there is a data problem with the trigger;

2. if there is not a data problem with the trigger, identify and analyze the

effectiveness of those local actions that could reduce air pollutant emissions; and,

3. determine whether a recommendation should be made to JPACT to initiate local action to reduce VMT/capita until th e 2002 level is once again attained.

PHASE 2: 10% VMT INCREASE

Metro will review and verify local VMT/capit a values derived from the most recent estimates of population and daily vehicle miles traveled from federal and state sources.

If average daily VMT/capita exceeds a 10 pe rcent increase above the 2002 rate for the Oregon portion of the Portland-Vancouver Air Quality Maintenance Area for two successive years, the following measures wi ll become required Transportation Control Measures for the region (as determined by the programming of funds for specified projects) under the Portland Ca rbon Monoxide Maintenance Plan:

1. Washington County Commuter Rail within six years after exceeding the 10% increase above the 2002 VMT/capita rate,18 2. Interstate 205 Light Rail Transit (I-205 LR T) within six years after exceeding the

10% increase above th e 2002 VMT/capita rate;

3. An increase of efforts for the Regional Travel Options Program sufficient to increase the number of empl oyers reached by the program by at least 5 % per year the number of employers currently s ubject to the DEQ Employee Commute Options program.

4. Alternatively, specific projects from the Regional Transportation Options program could be substituted.

5. An increase of funding of at least 5% per year greate r than current funding for Transit Oriented Development projects.

6. Other programs or projects consistent w ith state and federal law as may be determined by the Metro Council after consultation with the Joint Policy Advisory Committee on Transportation.

Salem SKATS 8-Hour Ozone Contingency Plan

PHASE 1: ELEVATED OZONE LEVELS

If the air quality inde x (AQI) is forecast to be within the “orange” range for ozone air quality (unhealthy for sensitive populations), or 8-hour daily maximum ozone values reach 0.100 ppm or greater, and meteorological conditions conducive to ozone formation are expected to persist, DEQ will issue an a dvisory to inform the public of air quality levels and actions they can take to limit exposure to unhealthy air pollution levels and

reduce emissions.

PHASE 2: RISK OF VIOLATION

If monitored 8-hour ozone levels at any site within the Sa lem/Turner area registers an annual fourth high monitored value of 0.085 ppm or greater within a single ozone season, or 0.080 ppm or greater averaged over two years, DEQ will assess the likely emissions and meteorological events c ontributing to elevated ozone levels. DEQ may form a planning group to assist DEQ in its review . The DEQ could recommend that no action be

taken if it is determined that:

(a) elevated ozone levels were caused by an ev ent that is unlikely to occur again, or (b) high ozone levels were caused by an uncont rollable event, such as a severe wildfire,

or (c) federal regulations that will reduce ozone precursor emissions are scheduled to be implemented within two years.

If it is determined that the event did not meet the criteria above, DEQ will evaluate options for appropriate action, including th e option for additional emission reduction strategies to prevent future exceedances or a violation of the 8-hour ozone standard.

PHASE 3: ACTUAL VIOLATION19 If a violation of the 8-hour ozone standa rd occurs, DEQ will determine the probable emissions and meteorological even ts contributing to the viola tion. If the violation is not due to an uncontrollable event or other criteria in Phase 2, DEQ will identify new strategies necessary to ensure compliance with the 8-hour ozone standard within 18

months of the conclusion of the ozone seas on that prompted the contingency plan, and revise the maintenance plan as needed to correct the violati on. Contingency plan requirements described in OAR 340-224-0060(5) that reinstate the LAER requirement would also apply until a revised maintenan ce plan is adopted by the EQC and approved by EPA.

5. Verification of Continued Attainment – ODEQ will continue to monitor ambient air quality ozone levels in the Portland-Vancouver AQMA as described in Contingency Plan. ODEQ will update countywide emission inventories every three years as required by the Consolidated Emission and Reporting Rule (CERR) to update the National Emissions Inventory. If ambient ozone levels increase, ODEQ will compare CERR updates with the 2002 and 2015 emissions inventories and evaluate the assumptions used in the 2015 emissions projections to determine whether emissions are increasing at a rate not anticipated in the maintenance plan.

III. Evaluation

The State of Oregon has met the requirements to submit a Section 110(a) (1) Maintenance Plan that presents satisfactory inform ation regarding the five elements of the Maintenance Plan and has satisfied Section 110(l) and 193 of the CAA. Therefore, appr oval of the State of Oregon’s 8-

hour Ozone Maintenance Pl an is recommended.

IV. Conclusion

This submission satisfies all require ments for an acceptable SIP revision.

V. Recommended Agency Action

The SIP revision request should be approved.

Rules Approved With this Action

۞ General Air Pollution Procedures and definition: OAR 340-200; ۞ Ambient Air Quality Standards and PSD Increments: OAR 340-202 ۞ Designation of Air Quality Areas: OAR 340-204 ۞ Major New Source Review: OAR 340-224 ۞ Air Quality Analysis Re quirements: OAR 340-225 ۞ Emission Standards for VOC Point Sources: OAR 340-232 ۞ Rules Applicable to the Portland Area: OAR 340-242 ۞ Employee Commute Options Program (OAR 340-242-0010 through 0290) ۞ Industrial Emission Management Program (OAR 340-242-0400 through 0440)20 Oregon’s phase out of the Vehicle Inspection Program's (VIP) enhanced BAR-31 test by January 1, 2007 for 1981-95 model year vehicles and elimination of the Gas Cap Pressure Test and the Evaporative Purge Test.

I. Purpose

This technical support document (TSD) provide s information supporting EPA’s proposed action to approve the State of Oregon’s August 9, 2005 request to approve revi sions to the Oregon State Implementation Plan: Volume 2 -Section 5.4.7 – Test Procedures and Standards. These pertain to phasing out the ODEQ’s Vehicle Inspection Program Enhanced Test, changing fleet testing frequency requirements and eliminating the gas cap and tank vapor recovery tests. The submitted revisions are supported by demonstration that these changes will not affect th e ability of the State of Oregon to comply with all applicable NAAQS , especially CO and Ozone. For Ozone, the submittal refers to the Section 110 (a)(1) Main tenance plans for the Portland portion of the Pdx/Van AQMA and the SKATS submitted thereafter. The Section 110(a)(1) maintenance plans

for these areas demonstrate how the State of Oregon will maintain compliance with the 1997 8 hour Ozone National Ambient Air Quality Standard s. The 110(a)(1) Maintenance Plans for both these areas meet the Clean Air Act (CAA) re quirements and demonstrate that the Portland portion of the Pdx/Van AQMQ and the SKATS Air Quality Area will be able to remain in attainment with the 1997 Ozone NAAQS through 2015. EPA further analyzed that the revisions comply with the CAA, including Section 110(l) . The applicable NAAQS for Ozone is the 2008 8-hour standard and the 110(a)(1) Maintenance Pl an includes technical information that shows the 2008 8-hour ozone NAAQS will not be violated with all the revisions and changes proposed. Based on our review, we are proposing full appr oval of the revisions to the Oregon State Implementation Plan: Volume 2 -Section 5.4.7 – Te st Procedures and Standards and supporting

rules.

II. Background

On August 9, 2005, the Oregon department of Environmental Quality (ODEQ) submitted revisions to the Oregon State Im plementation Plan: Volume 2 -S ection 5.4.7 – Test Procedures and Standards. These revisions pertain to:

1. Phasing out the ODEQ Vehicle Inspection Program (VIP) Enha nced test and using only

the Basic and On-Board Diagnostic (OBD) tests;

2. Implementing HB2546 of the 2003 Oregon Legisla tive Session (fleet testing frequency requirements), and

3. Eliminating the gas cap and gas tank va por recovery tests (Cap and Purge).

The ODEQ tests pollution from vehicles in both Medford and Portland as one of the ways to

ensure that these areas meet and do not exceed the Clean Air Act based National Ambient Air Quality Standards (NAAQS). ODEQ uses the follo wing three test methods: Basic, Enhanced, and Onboard Diagnostic (OBD). According to ODEQ, the Basic test is relatively inexpensive to operate and is the least effectiv e in reducing pollution, the Enhanced test is very expensive to operate and is moderately effective in reducing ve hicle emissions while the OBD test is the least expensive to operate, but the mo st effective in reducing emissi ons. However, the OBD test can21 only be used for 1996 and newer model year vehi cles because it relies on technology that is present on these later model vehicles. In Portlan d, ODEQ currently performs all three tests: Basic for 1975-80 model year vehicles, Enhanced fo r 1981-95 model years, and OBD for 1996 and newer model years. In Medford, ODEQ conducts the Basic and OBD tests.

OBD-ready vehicles represent a large and increasing percentage of the vehicle population with a corresponding decline in the percen tage of vehicles that receive the Enhanced test. Therefore, ODEQ can replace the Enhanced test with the Basic test for 1981-1995 model year vehicles without significantly affecting Portland's air quality. This cha nge has no effect on the Medford area vehicle inspection program as ODEQ does not conduct the Enhanced test in Medford.

III. Review of the Proposed Revisions to the SIP

Even though the Enhanced test will be phased out, ODEQ has submitted technical evidence to EPA that the air quality, specifically related to Ozone and CO will not be degraded in the Portland Air Quality Maintenance Area. This change will allow ODEQ to conduct the testing operations more quickly and with fewer employees . ODEQ is able to achieve this operational cost reduction without significantly impacting air quality due to th e effectiveness of the OBD test method. The OBD system helps keep 1996 and newer vehicles clean by precisely controlling all aspects of the vehicle operation. When the proposed Enhanced test phase-out is expected to be complete in January 2007, ODEQ forecasts that over 75 percent of the fleet will be 1996 and newer and therefore will have OBD systems.

In addition to the Enhanced test phase-out, ODE Q is proposing other rule changes that provide improved customer service at reduced costs. ODEQ has already implemented House Bill 2546, enacted by the 2003 Oregon Legislature. Hous e Bill 2546 reduced the frequency of testing required for self-testing fleets from on ce a year to once every other year.

Another proposed change is to eliminate the requirement for two elements of the vehicle inspection test operations that have been diffi cult to implement: gas cap and purge testing.

The gas cap test is designed to reduce emissi ons by ensuring that the vehicle's gas cap has an adequate seal on the vehicle's fuel tank as pa rt of the Basic and Enhanced tests. The device developed for this test had compatibility issues with some adapters in testing and has proved to be an impediment for the State of Oregon.

The purge test is designed to ensure that gaso line fumes from the fuel tank are captured and subsequently burned by the vehicle's engine, as part of the Enhanced test. Available test methods did not cover all makes and models, was intrusiv e and required highly qu alified personnel to correctly administer the test. These difficulties al so tended to create bot tle-necks in the testing lanes. However, presently installed OBD systems automatically monitor and ensure dependability of purge operations and evapora tive control systems to prevent evaporative emissions from escaping in to the atmosphere. This accomplishes the goal of reducing evaporative emissions from venting to ambient air. Finally, additional rule changes were made to correct grammatical errors, citations and definitions.22 IV. Evaluation

a. Compliance of the submitted changes to the CO and Ozone NAAQS

ODEQ demonstrated to EPA that the changes proposed will not affect long term

attainment of the Carbon Monoxide and Oz one clean air standards in the Portland area. NAAQS have been met for the last ten years in this area, and ODEQ has

demonstrated that it will continue to meet standards in the future.

For Carbon Monoxide, this requirement was addressed when the EQC adopted the

renewal to the Carbon Monoxide mainte nance plan in December 2004. This Portland CO 2nd 10-Year maintenance plan demonstrates continued maintenance

attainment of the Carbon Monoxide sta ndard through the year 2017, without the Enhanced test. The CO Maintenance Plan was approved by the EPA on January 24, 2006 (71 FR 3768).

For Ozone, this requirement was addressed by ODEQ when it submitted a Section 110 Ozone Maintenance Plan for the Portland AQMA. (Can you reference the earlier analysis in this doc- that is th e thing you’re referring to, correct?) The analysis in that plan confirmed that the area would not exceed the 1997 or the 2008 8-hour Ozone NAAQS with the phasing ou t of the Enhanced Test and other changes mentioned above. The plan also demonstrated that the Ozone standards will be maintained through the year 2014 and is being acted on US EPA concurrently with this action.

b. Compliance of submitted changes to section 110(l) of the CAA

A review of whether this plan revision meets all CAA requirements was done per Section 110(l) of the CAA which states “ ....The Administrator shall not approve a revision of a plan if the revision would in terfere with any applicable requirement concerning attainment and reasonable furt her progress (as defined in section 171), or any other applicable re quirement of this Act.”

With respect to these specific tests, the only pollutants that are affected are Nitrogen Oxides, VOCs, and CO. Other cr iteria pollutants such as PM, Pb, and

SO 2 , are not affected by these changes proposed by ODEQ. With respect to CO, the above section clarifies that the ap proved CO Maintenance Plan for Portland (71 FR 3768) serves to demonstrate th at the applicable CO NAAQS will be maintained with the changes propos ed because(?) these changes were incorporated into the maintenance demonstration.

VOC’s and NOx are ozone precursors and a ny increases to those precursors must be analyzed to demonstrate that they do not interfere with the attainment and reasonable further progress of any a pplicable requirement of the CAA (specifically the Ozone NAAQS). The most significant change is that of the23 Ozone NAAQS from 1997 to 2008. Th e 2008 8-hour Ozone NAAQS were promulgated in March 2008 with primar y and secondary standards at 0.075 ppm or 75 ppb. These are the currently ap plicable NAAQS and the attainment

demonstration has to show that the 2008 NAA QS is also not being violated into the future due to the changes proposed by the State of Oregon.

In section 4.40.5.4 of ODEQ’s 110 (a)(1) Maintenance Plan for the PortlandVancouver Air Quality Management Area (AQMA) and the Salem-Keizer Area Transportation Study Air Quality Area (SKATS AQA), ODEQ summarizes the results of dispersion modeling study pe rformed for the Pdx/Van Maintenance Area in 2004 by the Washington State Un iversity (WSU) (see table and chart below). This 110(a)(1) maintenance plan is being concurrently processed with this

SIP modification.

2015 Maintenance Demonstration for the Pdx/Van/SKATS Maintenance Area (ppm)

8-hour ozone standard = 0.08 ppm

Exceedance ≥ 0.085 ppm maximum

Violation > 0.085 ppm Predicted Design Value

Monitoring Site 1998

Predicted

Maximum 2015

Predicted

Maximum 2015

Predicted

Design Value*, ppm

Portland/Carus 0.098 0.094 0.072

Portland/Milwaukie 0.092 0.096 0.062

Portland/Sauvie Island 0.082 0.076 0.054

Vancouver/Mountain View 0.083 0.081 0.061

Salem/Turner 0.088 0.075 0.060

*Predicted Design Value is calculated usin g the EPA statistical procedure called the Relative Reduction Factor described in Appendix 6 of the ODEQ’s submittal and in EPA’s 8-hour ozone modeling guidance. Predicted design value is compared to the 8- hour ozone standard to determine compliance.24 These results illustrate that the Pdx/Van AQMA and the SKATS will maintain compliance with

the 1997 and the 2008 8-hour ozone standards of 0.08 and 0.075 ppm respectively, through 2015. The Carus monitoring site, downwind of Portland, has historically be en the site with the highest ozone readings in the region. The model predicted that the Milwaukie site would produce a slightly higher maximum value under worst cas e meteorological conditions, and the maximum

values at both Milwaukie and Carus would exceed but not violate the standards. However, the Carus site is expected to rema in the highest and most important site for determining compliance with the ozone standard. The design values at Carus and all other site s demonstrate continued compliance with all applicable ozone NAAQS.

IV. Conclusion

Based on our review, this plan revision meets th e requirements of Section 110(l) of the CAA.

V. Recommended Agency Action

The SIP revision request is proposed to be approved.25 Rules Approved with this Action

OREGON ADMINISTRATIVE RULES Chapte r 340, Division 256 -Department of Environmental Quality : MOTOR VEHICLES

° Definitions: 340-256-0010,

° Visible Emissions: 340-256-0100,

° Motor Vehicle Fleet Operation: 340-256-0130,

° Emission Control System Inspection: 340-256-0300,

° Government-Owned Vehicle, Permanent Flee t Vehicle and United States Government Vehicle Testing Requirements: 340-256-0310,

° Light Duty Motor Vehicle and Heavy Duty Gasoline Motor Vehicle Emission Control Test Method for Basic Program: 340-2560340,

° Light Duty Motor Vehicle Emission Contro l Test Method for Enhanced Program: 340- 256-0350,

° Light Duty Motor Vehicle Emission Control Test Criteria for Basic Program: 340-256- 0380,

° Heavy Duty Gasoline Motor Vehicle Emi ssion Control Test Criteria: 340-256-0390