# reg on

John A. Kitzhaber, MD, Governor



### December 12,2012
Dennis J. McLerran, Regional Administrator U.S. Enviromnenta1 Protection Agency, Region 10 1200 Sixth Avenue Mail Code: RA-140 Seattle, WA 98101 - Department of Environmental Quality Headquarters 811 SW Sixth Avenue Portland, OR 97204-1390 (503) 229-5696 FAX (503) 229-6124 TTY: 711



### RE: Revision to the Oregon State Implementation Plan- Oakridge- Westfir PM 2 _s 

### attaimnent plan
Dear Mr. McLerran:
The Oregon Department ofEnviromnental Quality (DEQ) requests approval of revisions to the Oregon State Implementation Plan (SIP) from the Office of Air, Waste, and Toxics, State and Tribal Air Programs Unit 'of the U.S. EPA, Region 10. Enclosed for your review is one hard copy of the amendments and one electronic copy of the amendments are saved on the disk included.
The Enviromnental Quality Commission adopted the revisions to the SIP under OAR 340-200-0040 on December 6, 2012. DEQ submits these revisions to EPA as part of the SIP and pursuant to 40 CPR 51.104.
I certify that public notices were published in newspapers of general circulation on August 20 and 23, 2012 and in the Secretary of State's Oregon Bulletin on September 1, 2012. The notices included a statement that adoption of the rules would revise the SIP. I further certify a public hearing was held on September 18 and 20,2012 in Oakridge, Oregon.
Thank you for your assistance with these revisions to Oregon's SIP. The staff contact for this submittal is Nicole Vick, SIP Coordinator at (503) 229-5946.

# :i~ Deputy Director
Enclosures

cc Andrew Ginsburg, DEQ AQ Administrator Paul Koprowski, EPA Oregon Operations office Justin Spenillo, EPA, Region 10 Claudia Vaupel, EPA, Region 10 Nicole Vick, DEQ AQ SIP CoordinatorIncluded Attachment Title X 1 Evidence the state has adopted the revision

X 1.1 Staff Report, Agenda Item I of the December 6-7, 2012, EQC meeting Also see Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2 X 1.2a Agenda Item 6, Lane Regional Air Protection Agency (LRAPA) Board of Directors Meeting, October 18, 2012 X 1.2b Agenda Item 8, LRAPA Board of Directors Meeting, November 15, 2012 X 1.3a Minutes, LRAPA Board of Directors Meeting, October 18, 2012 X 1.3b Minutes, LRAPA Board of Directors Meeting, November 15, 2012 X 2 Evidence that the state has the necessary legal authority

X 2.1 See Attachment 1.1 "Commission Authority" (page #3 of Staff Report, Agenda Item I, December 6-7, 2012, EQC meeting) X 3 Provisions submitted for approval X 3.1 Adopted and amended rules submitted for approval X 3.1a General Air Pollution Procedures and Definitions: OAR 340-200- : 0040. Filed and effective December 10, 2012 X 3.1b Designation of Air Quality Areas: LRAPA Title 29 . LRAPA Board adopted on October 18, 2012 X 3.2 Redline/strikeout version of adopted and amended rules submitted for approval X 3.2a General Air Pollution Procedures and Definitions: OAR 340-200- : 0040. Filed and effective December 10, 2012 X 3.1b Designation of Air Quality Areas: LRAPA Title 29 . LRAPA Board adopted on October 18, 2012 X 3.3 Attainment plan and appendices submitted for approval X 3.3 Oakridge-Westfir PM 2.5 attainment plan X 3.3a Appendix A - UMAA X 3.3a1 Appendix A1 - Oakridge PM Saturation Study October 2003 X 3.3b Appendix B - Meterology X 3.3c1 Appendix C1 - 2010 SF1 Cites M-P (no header attached) X 3.3c2 Appendix C2 - Household and employment growth projections X 3.3c3 Appendix C3 - Oakridge VMT Projections 2002-2025 by LCOG X 3.3d Oakridge emission inventory with attachments X 3.3e 1 SANDWICH X 3.3e 2 Oakridge PMF report July 30, 2012 X 3.3f1 Oakridge ordinance X 3.3f2 Smoke management directive X 3.3f3 Title 38 New Source Review X 3.3f4 Woodstove changeout list X 3.3f5 Recommended strategies December 31, 2011 X 3.3g Design value X 3.3h Rollback modeling X 3.3i Transportation analysis of Oakridge by LCOG X 3.3j RACT - RACM analysis X 4 Evidence that the state followed the Administrative Procedures Act X 4.1 Public notice in the Secretary of State's Oregon Bulletin , September 1, 2012, publication

X 4.2 Certificate and Order for Filing Permanent Administrative Rules, filed December 10, 2012 and effective December 10, 2012 X 4.3 DEQ authorization for LRAPA to conduct a hearing on EQC's behalf and stringency review, dated August 15, 2012 X 5 Evidence of adequate public notice X 5.1 Affidavit of Publication: Dead Mountain Echo , Notice of August 23, 2012 publication X 5.2 Affidavit of Publication: Register Guard , Notice of August 20, 2012 publication X 6 Certification of public hearing SIP Submittal ChecklistX 6.1 See paragraph #3 of cover letter and Attachment 7.1 X 7 Compilation of public comment and department's response X 7.1 Presiding Officer's report for rulemaking hearings on September 18 and 20, 2012, dated October 26,2012 X 7.2 Summary of public comment and agency response, dated October 18, 2012

## ATTACHMENTS
Attachment 1: Evidence the s tate has adop te d the r evision 1.1 Staff Report, Agenda Item I of the December 6

- 7, 2012 , EQC meeting 1.2 a Agenda Item 6, L ane Regional Air Protection Agency (L RAPA ) Board of Directors Meeting, October 18, 2012 1.2b Agenda Item 8, LRAPA Board of Directors Meeting, November 15, 2012 1.3 a Minutes, LRAPA Board of Directors Meeting, October 18, 2012 1.3b Minutes, LRAPA Board of Directors Meeting, November 15, 2012 Also see Certificate and Order for Filing Permanent A dministrative Rules in Attachment 4.2
Attachment 2 : Evidence that the state has the necessary legal a uthority See Attachment 1.1 “Commission Authority” (pag e # 3 of Staff Report, Agenda Item I , December 6

- 7, 2012 , EQC meeting)
Attachment 3 : Provisions su bmitted for a pproval 3.1 Adopted and amended rules submitted for approval 3.1a General Air Pollution Procedures and Definitions: OAR 340
- 200
- : 0040. Filed and e ffective December 10, 2012 3.1b Designation of Air Quality Areas: LRAPA Title 29 . LRAPA Board adopted on October 18, 2012
3.2 Redlin e/strikeout version of adopted and amended rules submitted for approval 3.2a General Air Pollution Procedures and Definitions: OAR 340
- 200
- : 0040. Effective December 10, 2012 3.2 b Designation of Air Quality Areas: LRAPA Title 29 . LRAPA Board adopted on October 18, 2012
3.3 Attainment plan and appendices submitted for approval 3.3 Oakridge

- Westfir PM 2.5 

### a ttainment p lan 3.3a Appendix A

- UMAA 3.3a1 Appendix A1

- Oakridg e PM Saturation Study October 2003 3.3b Appendix B

- Meterology 3.3c1 Appendix C1

- 2010 SF1 Cites M

- P (no header attached) 3.3c2 Appendix C2

- Household and employment growth projections 3.3c3 Appendix C3

- Oakridge VMT Projections 2002

- 2025 by LCOG 3.3d Oakridge emission inventory with attachments 3.3e1 SANDWICH 3.3e2 Oakridge PMF report July 30, 2012 3.3f1 Oakridge ordinance 3.3f2 Smoke management directive 3.3f3 Title 38 New Source Review

### 3.3f4 Woodstove changeout list 3.3f5 Recommended strategies December 31, 2011 3.3g Design value 3.3h Rollback modeling 3.3i Transportation analysis of Oakridge by LCOG 3.3j RACT

- RACM analysis

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, 2012 publication 4.2 Certificate and Order for Filing Permanent Administrative Rules, filed and effectiv e December 10, 2012 4.3 DEQ a uthorization for LRAPA to conduct a hearing on EQC’s behalf and stringency review , dated August 15, 2012
Attachment 5: Evidence of adequate public notice 5.1 Affidavit of Publication: Dead Mountain Echo, Notice of August 23, 2012 publication 5.2 Affidavit of Publication: The Register Guard , Notice of August 20, 2012
Attachment 6: Certification of public hearing See paragraph #3 of cover letter and Attachment 7.1
Attachment 7: Compilation of public comment and department’s response 7.1 Presiding Officer ’s r eport for rule making hearing s o n September 18 and 20 , 201 2 , dated October 26, 2012 7.2 Summary of public comment and agency response, dated October 18, 2012

## Attachment 1
Evidence the s tate has adopted the r evision

1.1 Staff Report , Agenda Item I of the December 6

- 7 , 2012 , EQC m eeting 1.2a Agenda Item 6, Lane Regional Air Protection Agency (LRAPA) Board of Directors Meeting, October 18, 2012 1.2b Age nda Item 8, LRAPA Board of Directors Meeting, November 15, 2012 1.3a Minutes, LRAPA Board of Directors Meeting, October 18, 2012 1.3b Minutes, LRAPA Board of Directors Meeting, November 15, 2012
Also see Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2

### State of Oregon 

## Department of Environmental Quality Memorandum

Date: Nov. 16,2012


### To:

From: Environmental Quality Cor1issiop-UL.-------- · Dick Pedersen, Director

# Y~ Subject: Agenda item I, Action item, Rule proposal: Oakridge- Westfir PM 25 Attainment Plan Dec. 6-7,2012, EQC meeting Why this is important

DEQ recommendation and EQC motion

Background and need for rulemaldng This proposed rulemaking adopts an attainment plan that will reduce fine particulate matter, or PM 2
. 5 , in order to protect the health of the residents in the city of Oakridge and neighboring Westfir community. LRAPA, the Lane Regional Air Protection Agency, is the designated agency for air quality in Lane County, as delegated by DEQ. The plan and associated rules are designed to bring this area into compliance with National Ambient Air Quality Standards for PM 25 by the federal deadline of December 2014. DEQ recommends that the Oregon Environmental Quality Commission adopt the proposed rule amendments as presented in attachment A, approve Oakridge-Westfir 

### PM 25 Attaimnent Plan as presented in attachment A and direct DEQ to submit the Oakridge-Westfir 

### PM 25 Attainment Plan to the Environmental Protection Agency as a revision to the Oregon Clean Air Act State hnplementation Plan. History of particulate pollution in Oakridge During the winter months, Oakridge air quality is often threatened by high concentrations of smoke fi·om wood stoves settling on the valley floor. Local climate and topography make the city of Oakridge prone to wintertime temperature inversions, low wind speeds and poor atmospheric dispersion.
As a result, Oakridge has struggled to meet air quality standards. Oakridge was designated a PM 10 nonattainment area Jan. 20, 1994. The city has not violated the PM 10 standard since this designation. Voluntary measures to reduce wood smoke emissions adopted in 1999 continue to reduce measured particulate levels.
In 1997, EPA revised the particulate standard to include smaller particulate, PM 2
. 5 , and established a daily standard of 65 micrograms per cubic meter. The original PM 10 strategies were so successful that Oakridge met the 1997 

### PM 25 standard. However, in 2006, EPA

Item I 000001Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan Dec. 6-7, 2012, EQC meeting Page 2 of 5

Effect of rule lowered the daily PM2.s standard based on the latest health effects research, from 65 [tg/m 3 to 35 [Ig/m 3

, causing Oakridge to go back into nonattainment. The area designated as nonattainment for Pl\'hs
was expanded to include the nearby small city of Westfir and the surrounding area. The federal Clean Air Act requires OakridgeWestfir to reduce its particulate levels to comply with the PM 25 standard by December 2014.
The Oakridge PM 25 Advisory Committee LRAP A and the City of Oakridge convened the Oakridge Advisory Committee in 20 II to help develop and recommend strategies to bring Oakridge into attainment with the standard. The committee included residents fi·om both Oakridge and Westfir. From July to December 20 II, the committee met to evaluate pollution reduction strategies with the highest chance of success in meeting the PM 2
. 5 standard and developed recommendations for emission reduction
measures. These recommendations formed the groundwork for the city to adopt emission reduction measures in local ordinances, and for LRAPA to develop an attainment plan for the Oakridge- Westfir area.
State hnplementation Plan The attainment plan, developed in accordance with EPA's guidance, is a comprehensive document that identifies the emission sources of PM2 5 and estimates the current and future year concentrations based
on the emission inventory and measurements. The plan contains emission reduction strategies consisting of local ordinances, LRAP A regulations and non-regulatory elements including incentives and education. If the community fails to reduce pmiiculate emissions by the 2014 deadline, the plan's contingency measures would take effect automatically and are designed to achieve rapid compliance with the PM2.s standard. The contingency measures are a backstop until the plan can be reevaluated and corrected. The proposed attainment plan will help LRAP A and the community control emissions to ensure clean air and protect public health in Oakridge-Westfir.
Since residential woodstove emissions comprise the majority of the fine particulate emissions in Oakridge- Westfir, most of the proposed pmiiculate reductions will come fi·om enhancements to the community's woodstove curtailment program, implemented through local ordinances. Other related strategies include continuing the program of replacing polluting uncertified woodstoves and a public
awareness and education program.
If the attainment plan fails to achieve the federal standard by December 2014, additional measures and regulations in the contingency plan would increase the number of"red no-bum days"

Item I 000002Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan Dec. 6-7, 2012, EQC meeting Page 3 of 5

Commission authority Key issues under the woodstove program fi·om 20 to 30 days per year, increase the percentage of cmtailment effectiveness and decrease the allowed opacity for wood stove emissions from 40 percent to 20 percent during the winter woodstove season.
The emission reduction measures in the attainment plan are designed to meet the daily 

### PM 25 standard by lowering PM 2
. 5 levels on worst days during the winter heating season to approximately 28 j.tg/m 3

, below the 24-hour health standard of35 j.tg/m 3 • Since the woodstove curtailment program achieves the vast majority of emission reductions, the effectiveness of the program is critical to meet the 

### PM 25 standard in Oakridge-Westfir.
The commission has authority to take this action under ORS 468.020, 468A.025 and 468A.460.
Economic impacts During plan development and the public comment period, LRAP A received comments expressing concern that the attainment plan could harm the local economy and hinder its recovery. LRAPA, the Oakridge Advisory Committee and the City of Oakridge focused on strategies with the lowest fiscal impact on local businesses and the economy.
One benefit of the plan meeting the health standards on schedule is that it would allow more opportunity for future economic development.
When an area is designated as nonattainment, federal requirements for industrial sources require use of the most stringent control equipment for new or expanding sources and reasonably available control technology for existing sources. While these federal restrictions may prevent some industries from expanding or moving into the OakridgeWestfir area, they are designed to reduce pollution and ensure the health of all residents. LRAP A expects the attainment plan will achieve timely compliance with the standard, which will enable LRAP A to begin the steps needed to lift the more stringent industrial restrictions. If the area meets the standard by 2014, LRAPA can begin development of a maintenance plan that can be submitted to EPA, with a request to re-designate the area to attail111lent. The maintenance plan can include provisions to ease the restrictions on industrial growth, depending on the implementation success of the existing attainment plan. This will have a positive economic impact on the community.

Item I 000003Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan Dec. 6-7, 2012, EQC meeting Page 4 of 5

Public outreach Evaluating compliance with the standard Some community members raised questions on the technical accuracy of monitoring data showing Oakridge- Westfir is above the PM 25 standard. They stated that the Willamette Activity Center monitor in southwest Oakridge should not be used to determine compliance because it is located in a pati of town that has the poorest air quality and is not representative of the entire city. However, EPA monitoring requirements dictate that monitoring take place in the area with the highest pollution levels in order to ensure the entire community meets health standards and is protected. Over the last 20 years, LRAP A has conducted numerous monitoring studies where patticulate samples have been taken throughout the Oakridge area, and more recently in the Westfir area. These studies show that patticulate levels are consistently high at Willamette Activity Center.
LRAP A also received comments questioning the validity of the PM 25 standard. EPA sets this standard based on the latest scientific and health effect research. EPA reviews the standard every five years. LRAP A expects that the proposed attainment plan will have a positive effect on the health of Oakridge- Westfir residents. There are a number of studies linking PM 25 exposure with respiratory problems and cardiac diseases. U.S. and Canadian studies report statistically significant relationships between an increase in PM 25 and an increase in hospitalizations for all respiratory causes, including chronic obstructive pulmonary disease, pneumonia and asthma. ill addition to the greatly expanded body of evidence on hospitalization or emergency depattment visits for cardiovascular diseases, new epidemiologic studies have also reported associations between more subtle physiological changes in the cardiovascular system and shortterm exposures to PM 2
. 5 concentrations. These impacts could result in days of missed work and have economic impacts that would affect the economy.
Woodstove emissions The enforcement of the woodstove cmtailment program is the key strategy to help Oakridge- Westfir comply with the standard. This includes a focus on habitually violating offenders, increased patrols on red days and increased awareness and public outreach regarding the curtailment program. Since the curtailment program already exists, effective enforcement is essential for success of the plan.
LRAPA held a public information meeting in Oakridge on Sept. 18, 2012, with residents fi·om Oakridge and Westfir in attendance, and a public hearing was held before the LRAP A Board of Directors in Springfield on Sept. 20, 2012. A summary of the public comments is provided in attachment C.

Item I 000004Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan Dec. 6-7, 2012, EQC meeting Page 5 of 5

Next steps

Attachments

Available upon request If approved, DEQ must submit this PM 2 .s attainment plan to EPA as a revision to the Oregon Clean Air Act State Implementation Plan. LRAPA must continue to provide real-time air monitoring and daily woodburning advisories and work closely with the city of Oakridge to ensure effective implementation of the curtailment strategies and the success of the attainment plan. LRAP A must continue to assist the city in designing public education materials. Finally, LRAP A staff must continue to collaborate with the city of Oakridge and the public to track progress in reducing PM 2 .s levels to meet the standard.
A. Proposed rule revisions 1. Revisions to Division 200 2. Revisions to LRAPA's Title 29 3. Oakridge- Westfir PM 2 .s Attaimnent Plan B. Summary of public comments and agency responses C. Presiding Officer's Repmt on public hearings D. Relationship to Federal Requirements questions E. Statement ofNeed and Fiscal and Economic Impact F. Land Use Evaluation statement
I. DEQ proposed rulemaking announcement 2. Oakridge PlYh.s_Advisory Committee Recommendations 3. Legal Notice of Hearing 4. Written comments received 5. LRAP A minutes fi·om public hearing

Approved:

Report prepared by: Brian Finneran

Item I 000005

### A G E N D A

LANE REGIONAL AIR PROTECTION AGENCY MONTHLY BOARD OF DIRECTORS MEETING THURSDAY , OCTOBER 18, 2012

12:15 P.M. LRAPA MEETING ROOM 1010 MAIN STREET SPRINGFIELD, OREGON

(Note: Start times for agenda items are approximate.)
1. (12:15 p.m.) CALL TO ORDER
2. (12:15 p.m.) ADJUSTMENTS TO AGENDA
3. (12:20 p.m.) PUBLIC PARTICIPATION ( time limited to three minutes per speaker) 

### A. Comments On an Item On Today’s Agenda B. Comments On a Topic Not Included On Today’s Agenda (Note: This is an opportunity for the public to bring up unscheduled items. The board may not act at this time but may, if it deems necessary, place such items on future agendas. Issues brought up under t his agenda item are to be limited to three minutes’ speaking time by the person raising the issue. If additional time is necessary, the item may be placed on a future agenda.) 

### 4. (12:30 p.m.) ACTION ITEM: Consent Calendar A. Approval of Minutes of September 20 , 2012 Board of Directors Meeting View Material 

### B. Approval of Expense Reports Through September 30 , 2012 View Material 

### 5. (12:40 p.m.) Advisory Committee View Material


### 6

. (12:50 p.m.) ACTION ITEM: Proposed Adoption of Oakridge PM2.5 Attainment Plan View Material 

### REPORTS
7

. (1:50 p.m.) Director’s Report of Agency Activities in the Month of September, 2012 View Material 

### WORK SESSION
8

. (2 :0 0 p.m.) Old Business A. Personnel Policy Review Committee

– Status Report B. Revenue Resources Committee

– Status Report Review Committee Efforts (joint meeting with Revenue Resources Committee, including updates from Springfield, Lane County, or other IGA partners) View Material 

### C. Strategic Priorities

Updated LRAPA High Priorities (review and discussion of attached July 26, 2012 staff report) View Material 

### D. Handbook for Board Members (as approved on May 17, 2012) View MaterialA G E N D A October 18, 2012

LRAPA BOARD OF DIRECTORS MEETING -2-


### 9

. (2:30 p.m.) New Business

1 0

. (3 :10 p.m.) Adjournment

If you have questions regarding items on this agenda, would like to request a copy of backup material for an agenda item, or would like to be added to the mailing list to receive the agendas for the monthly LRAPA Board of Directors meetings, please contact Debby Wineinger at (541) 736

- 1056 Ext. 219

– email

– debby@lrapa.org
Location is wheelchair accessible (WCS). American Sign Language (ASL) interpretation is available with 48 hours notice. Please call contact Debby Wineinger at (541) 736

- 1056 Ext. 219

– email

– debby@lrapa.org

### A G E N D A

LANE REGIONAL AIR PROTECTION AGENCY MONTHLY BOARD OF DIRECTORS MEETING THURSDAY , NOVEMBER 15, 2012

12:15 P.M. LRAPA MEETING ROOM 1010 MAIN STREET SPRINGFIELD, OREGON

(Note: Start times for agenda items are approximate.)
1. (12:15 p.m.) CALL TO ORDER
2. (12:15 p.m.) ADJUSTMENTS TO AGENDA
3. (12:20 p.m.) PUBLIC PARTICIPATION ( time limited to three minutes per speaker) 

### A. Comments On an Item On Today’s Agenda B. Comments On a Topic Not Included On Today’s Agenda (Note: This is an opportunity for the public to bring up unscheduled items. The board may not act at this time but may, if it deems necessary, place such items on future agendas. Issues brought up under this agenda item are to be limited to three minutes’ speaking time by the person raising the issue. If additional time is necessary, the item may be placed on a future agenda.) 

### 4. (12:30 p.m.) ACTION ITEM: Consent Calendar A. Approval of Minutes of October 18 , 2012 Board of Directors Meeting view material 

### B. Approval of Expense Reports Through October 31 , 2012 view material


### 5. (12:40 p.m.) Advisory Committee view material 

### REPORTS
6

. (1:00 p.m.) FY’12 (July 1, 2011 – June 30, 2012) Audit of Financial Statement

Presentation (Isler, CPA) view material


### 7

. (1: 2 0 p.m.) Director’s Report of Agency Activities in the Month of October , 2012 view material


### 8. (1:30 p.m.) Oakridge PM2.5 Attainment Plan Follow

- up view material 

### WORK SESSION
9

. (2 :0 0 p.m.) Old Business A. Revenue Resources-Ongoing Discussion B. Preparation for Work Session with Lane County Board of Commissioners C. Personnel Policy Review Committee

– Status ReportA G E N D A November 15, 2012

LRAPA BOARD OF DIRECTORS MEETING -2-



### 10

. (2:50 p.m.) New Business
1 1

. (3 :00 p.m.) Adjournment

If you have questions regarding items on this agenda, would like to request a copy of backup material for an agenda item, or would like to be added to the mailing list to receive the agendas for the monthly LRAPA Board of Directors m eetings, please contact Debby Wineinger at (541) 736

- 1056 Ext. 219

– email

– debby@lrapa.org
Location is wheelchair accessible (WCS). American Sign Language (ASL) interpretation is available with 48 hours notice. Please call contact Debby Wineinger at (541) 736

- 1056 Ext. 219

– email

– debby@lrapa.org

### M I N U T E S LANE REGIONAL AIR PROTECTION AGENCY BOARD OF DIRECTORS MEETING THURSDAY

– OCTOBER 18, 2012 LRAPA MEETING ROOM 1010 MAIN STREET SPRINGFIELD, OREGON

ATTENDANCE

Board: Bill Brommelsiek, Chair

– At -Large (Springfield Area) ; Mike Fleck , Vice-Chair

– Cottage Grove/Oakridge; Joseph Gonzales

– Eugene; Jeannine Parisi

– Eugene; Jay Bozievich

– Lane County; Scott Lucas

– Eugene; Brian Forge

– At -Large General; Dave Ralston

– Springfield
ABSENT: Andrea Ortiz

– Eugene
Staff: Merlyn Hough

– Director; Robbye Lanier; Debby Wineinger ; Nasser Mirhosseyni
Others: LRAPA Advisory Committee Members Jim Daniels ; John Tamulonis ; and Chuck Gottfried ; Ben P. Sapping ton- Eugene Area Chamber of Commerce

1. OPENING: Brommelsiek called the meeting to order at 12:15 p.m.
2. ADJUSTMENTS TO AGENDA: No adjustments were made to the agenda.
3. PUBLIC PARTICIPATION: No public participation.
4. CONSENT CALENDAR: Approval of Minutes of September 20, 2012 Board of Directors Meeting MOTION: Lucas MOVED to approve Minutes as presented. Ralston SECONDED THE MOTION. VOTE ON MOTION: 8-0 Approval of Expense Reports Through September 30, 2012
Fleck commented that the general fund balance was down about $100,000.00, and the cash flow chart shows a higher amount. He asked if that was reflecting the loss of dues. Mirhosseyni explained that on the federal side we are up. And we receive federal payments monthly and the states payments are quarterly.
Brommelsiek

asked if LRAPA had received anything from the partners in dollars or in -kind services. Mirhosseyni said we have not and we are still waiting for the signed MOU from the county.

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 2 -

MOTION: Ralston MOVED to approve the Expense Reports as presented. Gonzales SECONDED THE MOTION. VOTE ON MOTION: 8-0
5 . ADVISORY COMMITTEE: Maurie Denner and Earl Koenig were not present at today’s meeting . Merlyn gave updates from the last meeting. Chuck Gottfried, who was present today, g a ve an overview on a field burning report from last summer. He had recapped the changes since the phase-out of field burning. Gottfried said if anyone is hearing discussions about field burning; it is probably not related to field burning. It is other sources of smoke. Burning in the south valley is history, and burning i n the north valley is not likely to impact us. There may be misunderstandings on sources of smoke.
Lucas asked about the economic impacts on the grass growers. Gottfried said there has been a shift in techniques with the increased use of pesticides and herbicides. The end results are always up and down. There is always a new bug or fungus but then there are also new chemicals.
Ralston added that there are tradeoffs; they may use a different technique such as pesticides which shifts the burden to other environmental impacts.
Bozievich mentioned two recent burns but they were not field burning. They were for wildlife management. One completely smoked out the city of Veneta during the harvest festival. He wanted to know if LRAPA received calls or complaints about it. Hough said there is an annual joint permit application submitted by The Nature Conservancy, BLM, Corps of Engineers, and the City of Eugene. It outlines their plan for ecological burning in the wetlands area. There was also some burning in Southern Benton County on the Wildlife Refuge. And that did impact the Elmira area. Bozievich said the fire danger level was high on the day of the burn. And he was shocked that they were burning on that day. Hough said there were fire districts directly involved with them, and they have fire suppression equipment on site. Brommelsiek said he would hope they would check with the local communities about events prior to burning. Hough agreed, and said they do have a prescription that they follow; it requires certain wind vectors, and wind speed ranges to try and minimize impact on populated areas. He said LRAPA staff also has its own criticisms that the burning hasn’t been ideally handled. Hough said the CAC welcomed the request to look into the Coal Train issue. There has been a lot of information complied on both sides of the issue. They formed a subcommittee and that group will be meeting within the next week.
Brommelsiek

asked Jay Bozievich about information he received from over at the coast, and did it make sense to continue to work on the coal train issue at this time or put in on hold. Bozievich said he did think it made sense to continue to work on it. They put off taking any action on the resolution but the issue will still be around. With the forty some people that testified he heard a lot of repeated information received off the internet that he had verified was inaccurate. He didn’t think it would hurt to be prepared, also he didn’t think the issue was going away.
Gonzales asked if LRAPA was going to make a statement, he asked what the board’s directive
was
. Brommelsiek

said the board has asked the CAC to look into the issue and get back to the board with some technical information, on both the diesel engines and the coal dust issues. And d epending on what we learn from the CAC we may take further action.

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 3 -

6. ACTION ITEM: HEARING ON PROPOSED ADOPTION OF OAKRIDGE PM2.5 ATTAINMENT PLAN
Brommelsiek

reminded everyone that the public hearing was held at the last meeting. We received several comments, and many were received at the last minute. We postponed final decision at the meeting to give staff time to summarize the comments. Hough told everyone that in the packet today were the revised attainment plan, comments/responses, and rule changes. He gave a brief overview of the comments and responses. Discussion during the overview:
Brommelsiek

said in California they were able to argue successfully there was no contribution from one area to another. And suspected that the same argument could be made here, that Westfir couldn’t contribute to Oakridge’s problems. Parisi said it sounded like EPA Region 10 was supportive of the change but it was hung-up in Washington DC. Hough said they were not in a position to override; they were understanding and supportive of our arguments

. Brommelsiek noted that LRAPA’s response on comment two, page three, first sentence, we say the tightening is more than 50%; it is actually about 46%. Lucas suggested alternate language “almost 50%” regarding the tightened standard. Hough wanted to point out on comment 8A Transportation, we thought it was straightforward that motor vehicle emissions should be considered insignificant, but we have had some pushback on it. And we may need to add a sentence to the plan that says “ there is a motor vehicle budget of this number of pounds per day which would be based on the 2014 emission inventory that Lane Council of Government prepared for us ”
. Or we may just want to make it conditional “ if EPA does not concur with this finding of insignificance than the budget for evaluating regional conformity in the future is this number of pounds per day based on the 2014 numbers. ”

The future motor vehicle emission projection is that the numbers will continue to decrease because of cleaner vehicles and fuels. We shouldn’t have a problem if there is a project that triggers the regional review. The regional review would be ODOT’s responsibility. RACT/RACM is reasonably available control technology (RACT) and reasonably available control measures (RACM)

. Brommelsiek asked about industrial sources in the community. Hough explained that RACT on industries isn’t so much the issue, the RACM part has to do with residential wood burning.
Parisi asked if there was going to be any feedback about households not conforming to the rules. Are police going to engage with folks who are burning on a no-burn day, will staff be informed what the circumstances were, such as copies of police reports. Hough said currently we are receiving the police logs. Parisi added that it would be helpful to know if they are owneroccupied or rental units. And do you target your energy to change the behavior in those households.
Fleck wanted to know how a police officer determines the opacity of the smoke coming from the chimney. Hough said excessive smoke is banned by city ordinance all the time, if someone is exceeding 40% opacity that is enforceable. It does require a calibrated eyeball. There is a

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 4 - certification program for determining the opacity in stacks. Some of the LRAPA staff is recertified every year. For industrial sources the limit is typically 20% opacity. When you see any visible smoke it is about 5 -10% opacity. At 100% you wouldn’t be able to see through it at all. So 40% is relatively heavy smoke. One of the contingency measures is if we don’t me e t standards by the deadline it would go from 40% opacity to 20%. Both would require city staff to be trained. And they have not yet had the training or certification. On the curtailment days there cannot be any visible smoke, so opacity certification would not be required for the police officers, and warnings or citations could be issued even before opacity training and certification

. Lucas asked if it was a person being recertified every year or a piece of equipment. Hough said it was a person. Lucas asked if that was a federal law, and why a person would need to be recertified every year. Hough explained that the opacity training/certification is essentially calibration of the person's ability to determine the density of the observed smoke

. The opacity certification involves a calibrated smoke generator; the operator of the smoke generator will put out 15% opacity smoke , a horn will sound, and people being certified will fill-in the reading on a scorecard. For example, the reader has to be within 5% on average , and not off by more than 10- 15% or so on any individual reading

. Gonzales said it didn’t sound like the City Coun ci l is taking ownership with this issue in terms of training. Hough said the Mayor, City Councilor Glenn Fortune, and the former City Administrator have all been very supportive. And Hough said he was attending a City Council work session tonight to reinforce the importance with all of them.
Brommelsiek

commented that on page 6, comment 2 didn’t read correc tly. He asked if someone could check and be sure the comment was stated correctly. Hough read the comment: Why have existing strategies that have been in place since 2008 - the continua tion of which are the pr imary strategy for attainment - have not yielded greater progress toward the projected 2014 design value in the last three years? Parisi commented that maybe it was verbatim. Hough said they would check on the wording in the comment. Hough noted that under “other comments” there were several minor corrections and clarific ations made in response. And regarding comment 2 on the last page, we need to add a sentence and we are still waiting to hear if EPA concurs with it. And lastly, EPA had some minor sugges ted changes.
Fleck said he heard at least one item that may need clarification. He was referring to ODOT and insignificant vs. significant. He asked about direction for adopting this, do we include the changes now, or do we have to amend if those arise? Hough and Lanier outlined alternative ways to adopt or amend the plan. Hough deferred to Robbye Lanier ’s recommendation s
. Parisi asked if you should come back to it at the end of the meeting, she would hate to postpone it if we don’t need to. She also asked if you could adopt the plan in content. So we are substantially adopting it today. If there are minor editorial changes . W e know those might happen, and we don’t have to go back and look at them again. Lucas asked if the new suggestion was to incorporate the changes and then vote on a final plan at the November meeting. Hough said he was thinking about Jeannine’s suggestion that the board take action today; substantially approve the plan with the recognition that additional details will be addressed at the November meeting. We could move it forward for EQC adoption. Lucas asked then there will be things you do with other agencies between now and November when things are amended. Hough said we

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 5 - would finalize where EPA is going to come out, we are pretty sure that they are not going to concur with the insignificance finding. We will need to put a sentence in with a specific number in the plan.
Brommelsiek

said we could have a motion to approve as presented with modifications as identified by you today. Fleck agreed

. Brommelsiek

continued to say so we can move forward and revisit in November if there are any concerns. Brommelsiek suggested a motion to approve with modifications as outlined by Merlyn at this meeting. Parisi commented that it was in everyone’s best interest that Oakridge is able to h it attainment in 2014; even if they are in attainment there are still a lot years required to get the restrictions off the books. Forge added that he thought it was also important that it had the board’s approval with Merlyn attending the work session in

Oakridge this evening. Bozievich wanted to clarify the changes that Merlyn outlined today include the change to the transportation component as being significant, and a budget based on the LCOG 2014 number. Parisi added as deemed necessary by EPA.
Ralston wanted to get a comment on the record, he still hates all or nothing propositions. And he still has a problem including Westfir in the nonattainment area and monitoring in the worst
areas. Bozievich also wanted to say for the record, that he takes issu e with EPA’s nonattainment area that they have prescribed for this plan. He thinks it is overly large and in general the standard has become really constricted, but those are battles we can’t win at this time. It is more important to pass this plan and get them in attainment so they can move forward with economic development. He agrees with Dave Ralston ’ s objections, and it really is all or nothing, we either approve the plan or we don’t. And if they don’t have a plan they actually will have more problems, even with the wrong attainment area. MOTION: Lucas MOVED to approve with modifications as outlined by Merlyn Hough at this meeting
. Fleck SECONDED THE MOTION. VOTE ON MOTION: 7-1 in favor.
7. DIRECTOR’S REPORT OF AGENCY ACTIVITIES FOR SEPTEMBER 2012 : Hough said regarding air quality in September, there were some local smoke concerns, but the bigger impact was wildfire smoke entering the area.
Gonzales had a question regarding the total number of complaints. He wanted to know the about the 17 listed for open burning, what areas they were in? Hough said more detail was given in the enforcement section. Brommelsiek commented that prior to October 1 st 

### burning wasn’t allowed. And it was also postponed for two weeks. Brommelsiek asked Merlyn if the report could be broken down into the geographic areas where the complaints were coming from on future reports. Hough said that can be provided.

8. OLD BUSINESS
A. Personnel Policy Review Committee

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 6 - Hough said he thought we were getting closer with the County MOU. We will be asking their Human Resources (HR) Director to review. Mirhosseyni added that they have a meeting with the HR Director on the 23 rd 

### of October

. B. Revenue Resources Committee
Brommelsiek

said there was to be joint meeting of the Revenue Resources Committee withthe full LRAPA Board. With the exception of Chuck Gottfried, there weren't any other nonBoard committee members present. He asked if the elected officials, Merlyn, and Nasser had any updates. Bozievich said there is a November 27 th 

### work session scheduled with the Board of County Commissioners. He has also requested that elected officials be invited to attend along with their city managers if possible, so everybody can hear the same information all at the same time. Discussion w ill cover what happens if LRAPA were gone, what activities DEQ would take over, what they couldn’t take over, and who would run the Oakridge attainment plan. And if the County no longer participates, what would happen with the various jurisdictions. He thinks it is going to be a good and important meeting.
Lucas asked if we knew if Klamath County chose to do an attainment plan or if DEQ said they had to do it. Bozievich said he knows they are doing it, but didn’t know if that was acquired or forced upon. Lucas thought it would be good to know that prior to the meeting, especially if it was forced on them. Bozievich said he was hoping Merlyn would be able to bring that information to the meeting.
Ralston said Springfield has its first mid -year budget committee meeting on Tuesday, December 4 th



### . But they won’t have anything new to report at this time. Brommelsiek asked Dave Ralston if anyone had spoke to him about possibly using the Springfield refueling center. Ralston said yes he had heard about it, and there might be other opportunities such as available space. But that is something that should be brought to the Springfield City Manager and let him bring it to the Council

. Mirhosseyni said Marcie Parker with the City of Springfield told him the re fueling issue would have to go thought the fire department to add additional users. And she said she would check on it and get back to him.
Brommelsiek

asked if anyone knew what was going on with the City of Eugene. Hough said they have finalized the MOU and they are prepared to work with us on some legal i ssues. Mirhosseyni added that there was an amendment to the MOU regarding legal support. We were informed it has to be specific because of client-attorney relationships. And the City Manager will have to approve each case. The City Manager has signed the amendment. Questions the committee asked him to follow-up on were, if LRAPA could become part of another agency , and also if LRAPA could get some clerical support. Mirhosseyni will be following up with Glenn Klein

. Mirhosseyni also reported that the equity line of credit has been approved by LRAPA's bank . It is an unsecured line of credit, and they do not need the building as collateral. But we will not be utilizing the line of credit this year. Lucas asked what is required before the line of credit is accessed , w hat is the process, does it require the Board of Directors approval be fore it accessed? Mirhosseyni said he was pretty sure it would require some legal d irective, so the City Attorney’s office will be assisting.

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 7 - Parisi wanted to know if LRAPA per the current state ordinance can be absorbed as a division of another organization. Mirhosseyni said that question has also been asked and will be explored with legal counsel

. Fleck wanted to know if the loan is unsecured will it impact the interest rate. Mirhosseyni explained because of LRAPA’s cash flow position with the bank they are going to extend it to us. But we haven’t discussed the fees and interest rate. Fleck said typically they are higher rates if unsecured

. Parisi asked Jay Bozievich at the County’s public hearing was there time to hear public comment. Bozievich explained that it was a work session and not a public hearing. Parisi asked if folks wanted to come and comment when they could do that. Bozievich said this meeting in not really set-up for that, this is informational only. Parisi said this could be taken up at future meeting and that would be the time where people could weigh in. But that would also be the time the Board of County Commissioners was making a decision. Bozievich said anytime someone wants to come for public comment, we take comments until people are done. Parisi wanted to know if there was a secondary meeting being set-up. Bozievich said not at this point. We may hear everything and look at each other and get three head nods, and just let sleeping dogs lay. There was discussion on when to schedule the next Revenue Resources Committee meeting. It was agreed that it would be after the County’s November 27 th 

### meeting. Hough said he and Nasser had talked about pulling some examples from the documents that were prepared during the budget process for the informational packet the County requested for the meeting. He didn’t envision creating something new , but just taking “ the best of ” materials. Brommelsiek believed as important as this is to the County, it was also important for the county representatives to know what the cost impacts are for the cities. If LRAPA is not around what the costs will be to implement their or dinances. So he recommended we make sure all the information included what the cities responsibilities were and what would fall to the County. Bozievich said Faye Stewart represents two those cities, we all represent portions of cities involved in this. We need to think about the impact we are creating for the cities within our districts. Also it would be good information for the elective officials that are not familiar with LRAPA. And the legal background, what part of the ORS you are created under, and how the County links the two cities together. What happens if LRAPA is not here, who takes over what portions of it? Obviously all major industry permitting would fall back on DEQ. Brommelsiek added that other permitting would also go to DEQ.

C. Strategic Priorities Hough said one of the key attachments is looking back at the success es in recent years , organized by the four strategic goals. And the other key attachment is looking ahead at the strategic priorities in future years

. Brommelsiek

asked if at a future board meeting someone could give an overview of the complaint process. Last year LRAPA responded to some 800 complaints. And on the “unable to do list” is has lower or medium priority complaints. If there is a matrix or

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 8 -

something that outlines the process with the lower and medium priorities. So if someone comes to them and says they didn’t get a follow -up, they would know how to respond to them. Parisi said she thought she had brought this up about two meetings ago. What gets a physical response, what just gets a call back, and what might just get logged? And she remembers hearing is that it is a case- by -case basis. She thought there was a way to prioritize , and decide where you were going to focus your resources. Lucas recalled the conversation also, and he was a little skeptical about being able to develop a workable matrix. But he would also like more information on the complaint process. Hough said complaint intake and response involves most of the agency. Lucas said he would like a few staff to sit with the board and go over the process. But he didn’t want staff to spend hours working on this as a project. Hough said we are revising our complaint policy/training with our shrinking staff. This would be added to a future agenda after the November 27 th 

### meeting with the County.
Brommelsiek

suggested to have a standing/ongoing agenda item on the revenue issues. Everyone agree that it should be a standing agenda item under “ old business. ”
Bozievich wanted to know if the sequestration goes through with the federal government, is it basically 8 1⁄2 percent reduction to all agencies? He also wanted to know if it would impact the matching grant. Hough said it would affect the federal grants to state and lcoal air agencies (State and Territorial Air Grants, or STAG grants) , and we could expect about an 8 1⁄2 percent reduction in our grant. But from what he was hearing , it would be very surprising if Congress lets that happen. Lucas wanted to know within the STAG grant what percent of it is in the overall budget. Mirhosseyni it is about 21%. Lucas said so about 8 1⁄2 percent of 21%. Hough said the federal grant is in about the $250,000.00 - $300,000.00 range so it is a significant part of our budget.
D. Handbook for Board Members
Bill Brommelsiek and Mike Fl eck signed the final document. It will be reviewed with the LRAPA Board of Directors annually.

9. NEW BUSINESS

Parisi asked if anyone knew about Councilor Ortiz’s status on the board. Ben Sappington said it was in the Register Guard that she was going to resign early. Parisi stressed that she wanted to recognize her service on the LRAPA Board. Hough explained that normally when board members complete their term s, the LRAPA Board presents them with a plaque and a letter thanking them for their service. Parisi said she would be happy to read the letter into a City Council meeting so she may be acknowledged in front of her peers. And maybe Scott Lucas would in interested in participating since he also represents Eugene. Hough added that Joe Gonzales ma y also be interested as he , too, represents Eugene. Lucas said he would be happy to participate in any way he could. And he would also contact the Mayor to see if he could get an update on the status of Councilor Ortiz or her replacement

. 1 2 . ADJOURNMEN T:

### M I N U T E S SEPTEMBER 20, 2012

LRAPA Board of Directors Meeting

- 9 - The meeting adjourned at 2:05 p.m. The next regular meeting of the LRAPA Board of Directors is scheduled for Thursday, November 15, 2012, 12:15 p.m. in the meeting room at LRAPA’s office, 1010 Main Street, in Springfield, Oregon.

Respectfully submitted,

Debby Wineinger Recording Secretary

### M I N U T E S LANE REGIONAL AIR PROTECTION AGENCY BOARD OF DIRECTORS MEETING THURSDAY –NOVEMBER 15, 2012 LRAPA MEETING ROOM 1010 MAIN STREET SPRINGFIELD, OREGON

ATTENDANCE
Board: Bill Brommelsiek , Chair– At

- Large (Springfield Area); Mike Fleck, Vice

- Chair

– Cottage Grove/Oakridge; Joseph Gonzales

– Eugene; Jay Bozievich –Lane County; Scott Lucas

– Eugene; Brian Forge

– At

- Large General
ABSENT: Jeannine Parisi

– Eugene; Andrea Ortiz

– Eugen e; Dave Ralston

– Springfield
Staff: Merlyn Hough–Director; Robbye Lanier; Debby Wineinger ; Sally Markos ; Max Hueftle; Nasser Mirhosseyni
Other s: LRAPA Advisory Committee Chair Maurie Denner ; Member Jim Daniels; Member Earl Koenig: Ben P. Sappington- Eugene Area Cha m ber of Commerce ; Paul Nielson , Isler CP A



## • Excerpts from Minutes:
REPORTS
8. Oakridge PM 2.5 

### Attainment Plan Follow- up Hough reported back to the Board that the re was a change made on page 33. W e didn’t have the specific numbers but it was something that EPA asked to be included in the plan. Another issue that came up was we went through a few iterations with EPA on their comments. There was a paragraph that was important to them to be in the plan demonstrating that we were following their 2007 implementation rule. W e acknowledged that and looked at potential secondary sources of particulate that form nitrates or sulfates in Oakridge. E PA agrees that in Oakridge (and in Oregon in general) there are minimal amounts of nitrates and sulfates that show up on the filters. It is primarily organic carbon and very heavily affected by woodstove and fireplace emi ssions. It’s not the typical situation addressed by the EPA national guidance; but, in order to be clear that we were complying they asked that we put this paragraph in . We consider this just c lar i fication as we have this in other words in the plan itself or in the appendix where we talk about RACT/RACM analysis in particular. First , we checked with DEQ to make sure this wouldn’t disrupt the EQC adoption plan for the early December meeting and we checked if some### M I N U T E S NOVEMBER 15 , 2012 LRAPA Board of Directors Meeting -2-

thing like this would require re-noticing. W e were assured on both counts we were fine. It wouldn’t require re-noticing for us or EQC and as long as we let DEQ know immediately what action the Board takes today it can still be on the December 6 th 

### EQC agenda. They are sen d ing their packet out sometime between this last Wednesday and early next week , b ut they said if we got something to them by tomorrow they could incorporate it. What Hough requested from the Board today was for them to take formal action to adopt the two clari fication changes as part of the attainment plan. Hough also spoke about the follow-up Letters from Westfir. They made comments during the public process. Their concerns were about the standards and boundary, Hough s aid those were both battles for a different place. They included DEQ in the loop on it, and DEQ responded to thecomments and indicated that they would be willing to take a look at the information we had provided back when EPA was setting the boundary as w ell as the additional information that is part of the plan. I f they agreed with Westfir's co n cerns which were the same as our concerns back in 2008, they would raise that to the next level. We are not sure what that process would be. There are copies of the Westfir letter and DEQ ’s response letters in the packet. EPA also responded and said that had been set as part of normal open process back in 2008. They weren’t convinced to do anything different. Westfir has since responded that they understand the PM 2.5 

### standards, but they don’t agree with it and regarding the boundary they took up DEQ’s offer to take a look at that. So , we will be providing any additional information DEQ would like to see in that process.
Brommelsiek made a suggestion that at some point it might be worth talking to our elected officials in Washington DC , so they are aware beforehand of any significant changes pr oposed by EPA that would affect Lane County or Oregon. Hough said he will be doing a “dry run” of the EQC presentation with DEQ staff on November 28 th 

### and the following week he will be presenting it jointly with Andy Ginsburg from DEQ asking the EQC to adopt the Oakridge attainment plan. It looks like we are on schedule at this point for submitting in December 2012. Forg e asked Merlyn what his take was on the Oakridge meeting last month with the City and police regarding enforcement on this. Hough said he was encouraged that there was support by the Mayor and they have had some counselor changes with the election. We are going to be working clos e ly with the City to be sure they implement their ordinances.
MOTION: Fleck moved to adopt the two proposed amendments

. Lucas SECONDED THE MOTION. VOTE ON MOTION: 6 -0

## At tachment 2
Evidence t hat the state has the necessary legal a uthority

See Attachment 1.1 “Commission Authority” (page # 3 of Staff Report, Agenda Item I of the December 6

- 7 , 2012 , EQC meeting )

## Attachment 3
Provisions submitted for a pproval

3.1 Adopted and amended rules submitted for approval
3.1a General Air Pollution Procedures and Definitions: OAR 340
- 200
- : 0040. Effective December 10 , 2012 3.1b Designation of Air Quality Areas: LRAPA Title 29

. LRAPA Board adopted on October 18, 2012
3.2 Redline/strikeout version of adopted and amended rules submitted for approval
3.2 a General Air Pollution Procedures and Definitions: OAR 340
- 200
- : 0040. Effective December 10 , 2012 3.2 b Designation of Air Quality Areas: LRAPA Title 29

. LRAPA Board adopted on October 18, 2012
3. 3 Attainment plan and appendices submitted for approval
3.3 Oakridge

- Westfir PM 2.5 

### Attainment Plan 3.3a Appendix A

– UMAA 3.3a1 Appendix A1

- Oakridge PM Saturation Study October 2003 3 .3b Appendix B

- Meterology 3.3c1 Appendix C1

- 2010 SF1 Cites M

- P (no header attached) 3.3c2 Appendix C2

- Household and employment growth projections 3.3c3 Appendix C3

- Oakridge VMT Projections 2002

- 2025 by LCOG 3.3d Oakridge emission inventory with att achments 3.3e1 SANDWICH 3.3e2 Oakridge PMF report July 30, 2012 3.3f1 Oakridge ordinance 3.3f2 Smoke management directive 3.3f3 Title 38 New Source Review 3.3f4 Woodstove changeout list 3.3f5 Recommended strategies December 31, 2011 3.3g Design value 3.3h Rollback modeling 3.3i Transportation analysis of Oakridge by LCOG 3.3j RACT

- RACM analysis

## DEPARTMENT OF ENVIRONMENTAL QUALITY

DIVISION 200
GENERAL AIR POLLUTION PROCEDURES AND DEFINITIONS
General
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 the Department of Environmental Quality and is adopted as the state implementation plan (SIP) of the State of Oregon pursuant to the federal Clean Air Act, 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 Commission’s rulemaking procedures in division 11 of this chapter and any other requirements contained in the SIP and will be submitted to the United States Environmental Protection Agency for approval. The State Implementation Plan was last modified by the Commission on December 6, 2012

. (3) Notwithstanding any other requirement contained in the SIP, the Department may: (a) Submit to the Environmental Protection Agency any permit condition implementing a rule that is part of the federally

- approved SIP as a source

- specific SIP revision after the Department has complied with the public hearings provisions of 40 CFR 51.102 (July 1, 2002); and (b) Approve the standards submitted by a regional authority if the regional authority adopts verbatim any standard that the Commission has adopted, and submit the standards to EPA for approval as a SIP revision.
NOTE : Revisions to the State of Oregon Clean Air Act Implementation Plan become federally enforceable upon approval by the United States Environmental Protection Agency. If any provision of the federal ly approved Implementation Plan conflicts with any provision adopted by the Commission, the Department shall enforce the more stringent provision. Stat. Auth.: ORS 468.020, 468A.035 & 468A.070 Stats. Implemented: ORS 468A.035 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 -8 3; 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 -1 986, 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

- 199 5, 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, ce rt. 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

- 200 9, 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 ; DEQ 18

- 2011, f. & cert. ef. 12

- 21

- 11; DEQ 1

- 2012, f. & cert. ef. 5

- 17

- 12

### A mended 10-18-2012 29.1 

### LANE REGIONAL AIR PROTECTION AGENCY
TITLE 29 DESIGNATION OF AIR QUALITY AREAS

Section 29-0010 Definitions The definitions in Title 12 and this rule apply to this division. If the same term is defined in this rule and Title 12, the definition in this rule applies to this division. Definitions of boundaries in this rule also apply to LRAPA Rules and Regulations. (1) "AQCR" means Air Quality Control Region. (2) "AQMA" means Air Quality Maintenance Area. (3) "CO" means Carbon Monoxide. (4) "CBD" means Central Business District. (5) "Criteria Pollutant" means any of the six pollutants set out by the Clean Air Act (sulfur oxides, particulate matter, ozone, carbon monoxide, nitrogen dioxide, and lead) for which the EPA has promulgated standards in 40 CFR 50.4 through 50.12 (July, 1993). (6) "Eugene-Springfield UGB" means the area within the bounds beginning at th e Willamette River at a point due east from the intersection of East Beacon Road and River Loop No.1; thence southerly along the Willamette River to the intersection with Belt Line Road; thence easterly along Belt Line Road approximately one-half mile to the intersection with Delta Highway; thence northwesterly and then northerly along Delta Highway and on a line north from the Delta Highway to the intersection with the McKenzie River; thence generally southerly and easterly along the McKenzie River approximately eleven miles to the intersection with Marcola Road; thence southwesterly along Marcola Road to the intersection with 42nd Street; thence southerly along 42nd Street to the intersection with the northern branch of US Highway 126; thence easterly along US Highway 126 to the intersection with 52nd Street; thence north along 52nd Street to the intersection with High Banks Road; thence easterly along High Banks Road to the intersection with 58th Street; thence south along 58th Street to the intersection with Thurston Road; thence easterly along Thurston Road to the intersection with the western boundary of Section 36, T17S, R2W; thence south to the southwest corner of Section 36, T17S, R2W; thence west to the Springfield City Limits; thence following the Springfield City Limits southwesterly to the intersection with the western boundary of Section 2,T18S, R2W; thence on a line southwest to the Private Logging Road approximately onehalf mile away; thence southeasterly along the Private Logging Road to the intersection with Wallace Creek; thence southwesterly along Wallace Creek to the confluence with

### A mended 10-18-2012 29.2

the Middle Fork of the Willamette River; thence generally northwesterly along the Middle Fork of the Willamette River approximately seven and one-half miles to the intersection with the northern boundary of Section 11, T18S, R3W; thence west to the northwest corner of Section 10, T18S, R3W; thence south to the intersection with 30th Avenue; thence westerly along 30th Avenue to the intersection with the Eugene City Limits; thence following the Eugene City Limits first southerly then westerly then northerly and finally westerly to the intersection with the northern boundary of Section 5, T18S, R4W; thence west to the intersection with Greenhill Road; thence north along Greenhill Road to the intersection with Barger Drive; thence east along Barger Drive to the intersection with the Eugene City Limits (Ohio Street); thence following the Eugene City Limits first north then east then north then east then south then east to the intersection with Jansen Drive; thence east along Jansen Drive to the intersection with Belt Line Road; thence northeasterly along Belt Line Road to the intersection with Highway 99; thence northwesterly along Highway 99 to the intersection with Clear Lake Road; thence west along Clear Lake Road to the intersection with the western boundary of Section 9, T17S, R4W; thence north to the intersection with Airport Road; thence east along Airport Road to the intersection with Highway 99; thence northwesterly along Highway 99 to the intersection East Enid Road; thence east along East Enid Road to the intersection with Prairie Road; thence southerly along Prairie Road to the intersection with Irvington Road; thence east along Irvington Road to the intersection with the Southern Pacific Railroad Line; thence southeasterly along the Southern Pacific Railroad Line to the intersection with Irving Road; thence east along Irving Road to the intersection with Kalmia Road; thence northerly along Kalmia Road to the intersection with Hyacinth Road; thence northerly along Hyancinth Road to the intersection with Irvington Road; thence east along Irvington Road to the intersection with Spring Creek; thence northerly along Spring Creek to the intersection with River Road; thence northerly along River Road to the intersection with East Beacon Drive; thence following East Beacon Drive first east then south then east to the intersection with River Loop No.1; thence on a line due east to the Willamette River and the point of beginning. (7) "Maintenance Area" means any area that was formerly nonattainment for a criteria pollutant but has since met EPA promulgated standards and has had a maintenance plan to stay within the standards approved by the EPA pursuant to 40 CFR 51.110 (July, 1993). (8 ) "Nonattainment Area" means any area that has been designated as not meeting the standards established by the U.S. Environmental Protection Agency (EPA) pursuant to 40 CFR 51.52 (July, 1993) for any criteria pollutant. (9) "O3" means Ozone. (10) “Oakridge PM2.5 Nonattainment A rea” means the area enclosed by the following: T21S, R2E, Sect 11 (NW Corner) east to T21S, R3E, Sect 11 (NE corner), south to T21S , R3E, Sect 23(SE Corner), west to T21S, R2E, Sect 23(SW corner) correctly back to T21S, R2E, Sect 11(NW corner).

### A mended 10-18-2012 29.3

(11) "Oakridge UGB" means the area enclosed by the following: Beginning at the northwest corner of Section 17, T21S, R3E and the city limits; thence south along the western boundary of Section 17, T21S, R3E along the city limits approximately 800 feet; thence southwesterly following the city limits approximately 750 feet; thence west along the city limits approximately 450 feet; thence northwesterly along the city limits approximately 450 feet; thence on a line south along the city limits approximately 250 feet; thence on a line east along the city limits approximately 100 feet; thence southwesterly along the city limits approximately 200 feet; thence on a line east along the city limits approximately 400 feet; thence on a line south along the city limits to the channel of the Willamette River Middle Fork; thence south-easterly up the Willamette River Middle Fork along the city limits approximately 7200 feet; thence exiting the Willamette River Middle Fork with the city limits in a northerly manner and forming a rough semicircle with a diameter of approximately one-half mile before rejoining the Willamette River Middle Fork; thence diverging from the city limits upon rejoining the Willamette River Middle Fork and moving southeasterly approximately 5600 feet up the Willamette River Middle Fork to a point on the river even with the point where Salmon Creek Road intersects with U.S. Highway 58; thence on a line east from the channel of the Willamette River Middle Fork across the intersection of Salmon Creek Road and U.S. Highway 58 to the intersection with the Southern Pacific Railroad Line; thence northerly along the Southern Pacific Railroad Line to the intersection with the northern boundary of Section 22, T21S, R3E; thence west along the northern boundary of Section 22, T21S, R3E to the intersection with Salmon Creek Road; thence on a line north to the intersection with the Southern Pacific Railroad Line; thence east along the Southern Pacific Railroad Line approximately 600 feet; thence on a line north to the intersection with High Prairie Road; thence on a line west approximately 400 feet; thence on a line north to the intersection with the northern boundary of Section 15, T21S, R3E; thence west along the northern boundary of Section 15, T21S, R3E to the intersection with the southeastern corner of Section 9, T21S, R3E; thence north along the eastern boundary of Section 9, T21S, R3E approximately 1300 feet; thence on a line west approximately 1100 feet; thence on a line south to the intersection with West Oak Road; thence northwesterly along West Oak Road approximately 2000 feet; thence on a line south to the intersection with the northern boundary line of the city limits; thence westerly and northwesterly approximately 8000 feet along the city limits to the point of beginning. (12) "Particulate Matter" means all finely divided solid or liquid material, other than uncombined water, emitted to the ambient air as measured by an applicable reference method with the Department's Source Sampling Manual , (January, 1992). (13) PM10: (a) When used in the context of emissions, means finely divided solid or liquid material, including condensible water, other than combined water, with an aerodynamic diameter less than or equal to a nominal 10 microns, emitted to the ambient air as measured by as applicable reference method in accordance with the Department's Source Sampling Manual (January, 1992);

### A mended 10-18-2012 29.4

(b) When used in the context of ambient concentration, means airborne finely divided solid or liquid material with an aerodynamic diameter less than or equal to a nominal 10 microns as measured in accordance with 40 CFR Part 50, Appendix J (July, 1993). (14) "UGA" means Urban Growth Area. (synonymous with “UGB”) (15) "UGB" means Urban Growth Boundary. Section 29-0020 Designation of Air Quality Control Regions Oregon's thirty-six counties are divided into five AQCRs. The AQCR boundaries follow county lines, and there are no counties that belong to more than one AQCR. The five AQCRs are as follows: (1) Portland Interstate AQCR , containing ten counties: (a) Benton County; (b) Clackamas County; (c) Columbia County; (d) Lane County; (e) Linn County; (f) Marion County; (g) Multnomah County; (h) Polk County; (i) Washington County; (j) Yamhill County. (2) Northwest Oregon AQCR , containing three counties: (a) Clatsop County; (b) Lincoln County; (c) Tillamook County. (3) Southwest Oregon AQCR , containing five counties:

### A mended 10-18-2012 29.5

(a) Coos County; (b) Curry County; (c) Douglas County; (d) Jackson County; (e) Josephine County. (4) Central Oregon AQCR , containing eight counties: (a) Crook County; (b) Deschutes County; (c) Hood River County; (d) Jefferson County; (e) Klamath County; (f) Lake County; (g) Sherman County; (h) Wasco County. (5) Eastern Oregon AQCR , containing ten counties: (a) Baker County; (b) Gilliam County; (c) Grant County; (d) Harney County; (e) Malheur County; (f) Morrow County; (g) Umatilla County; (h) Union County;

### A mended 10-18-2012 29.6

(i) Wallowa County; (j) Wheel County. Section 29-0030 Designation of Nonattainment Areas The following areas are designated as Nonattainment Areas: (1) PM10 Nonattainment Areas: (a) The Oakridge Nonattainment Area for PM10 is the Oakridge UGB as defined in Section 29-0010. (2) PM2.5 Nonattainment Areas: (a) The Oakridge Nonattainment Area for PM2.5 is defined in Section 29-0010. Section 29-0040 Designation of Maintenance Areas The following areas are designated as Maintenance Areas: (1) Carbon Monoxide Maintenance Areas: (a) The Eugene Maintenance Area for Carbon Monoxide is the Eugene-Springfield UGB as defined in Section 29-0010. (2) PM10 Maintenance Areas: (a) The Eugene-Springfield Maintenance Area for PM10 is the Eugene-Springfield UGB as defined in Section 29-0010. Section 29-0050 Designation of Prevention of Significant Deterioration Areas (1) All of the following areas which were in existence on August 7, 1977, shall be Class I Areas and may not be redesignated: (a) Mt. Hood Wilderness, as established by Public Law 88-577; (b) Eagle Cap Wilderness, as established by Public Law 88-577; (c) Hells Canyon Wilderness, as established by Public Law 94-199; (d) Mt. Jefferson Wilderness, as established by Public Law 90-548; (e) Mt. Washington Wilderness, as established by Public Law 88-577;

### A mended 10-18-2012 29.7

(f) Three Sisters Wilderness, as established by Public Law 88-577; (g) Strawberry Mountain Wilderness, as established by Public Law 88-577; (h) Diamond Peak Wilderness, as established by Public Law 88-577; ( i) Crater Lake National Park, as established by Public Law 88-577 and expanded in the 1990 Clean Air Act Amendments; (j) Kalmiopsis Wilderness, as established by Public Law 88-577; (k) Mountain Lake Wilderness, as established by Public Law 88-577; (l) Gearhart Mountain Wilderness, as established by Public Law 88-577. (2) All other areas, in Oregon are initially designated Class II, but may be redesignated as provided in Section 29-0060. (3) The following areas may be redesignated only as Class I or II: (a) An area which as of August 7, 1977, exceeded 10,000 acres in size and was a national monument, a national primitive area, a national preserve, a national recreational area, a national wild and scenic river, a national wildlife refuge, a national lakeshore or seashore; and (b) A national park or national wilderness area established after August 7, 1977, which exceeds 10,000 acres in size. (4) The extent of the areas referred to in section (1) and (3) of this rule shall conform to any changes in the boundaries of such areas which occurred between August 7, 1977, and November 15, 1990. Section 29-0060 Redesignation of Prevention of Significant Deterioration Areas (1)(a) All areas in Oregon, except as otherwise provided under Section 29-0050, are designated Class II as of December 5, 1974; (b) Redesignation, except as otherwise precluded by Section 29-0050, may be proposed by LRAPA, as provided below, subject to approval by the EPA Administrator as a revision to the State Implementation Plan. (2) LRAPA may submit to the EPA Administrator a proposal to redesignate areas of the state Class I or II provided that: (a) At least one public hearing has been held in accordance with procedures established in the Plan;

### A mended 10-18-2012 29.8

(b) Other States, Indian Governing Bodies, and Federal Land Managers whose lands may be affected by the proposed redesignation were notified at least 30 days prior to the public hearing; (c) A discussion of the reasons for the proposed redesignation, including a satisfactory description and analysis of the health, environmental, economic, social and energy effects of the proposed redesignation, was prepared and made available for public inspection at least 30 days prior to the hearing and the notice announcing the hearing contained appropriate notification of the availability of such discussion; (d) Prior to the issuance of notice respecting the redesignation of an area that includes any Federal lands, LRAPA has provided written notice to the appropriate Federal Land Manager and afforded adequate opportunity, not in excess of 60 days to confer with LRAPA respecting the redesignation and to submit written comments and recommendations. In redesignating any area with respect to which any Federal Land Manager had submitted written comments and recommendations, LRAPA shall have published a list of any inconsistency between such redesignation and such comments and recommendations together with the reasons for making such redesignation against the recommendation of the Federal Land Manager; and (e) LRAPA has proposed the redesignation after consultation with the elected leadership of local general purpose governments in the area covered by the proposed redesignation. (3) Any area other than an area to which Section 29-0050 refers may be redesignated as Class III if: (a) The redesignation would meet the requirements of section (2) of this rule; (b) The redesignation, except any established by an Indian Governing Body, has been specifically approved by the Governor, after consultation with the appropriate committees of the legislature, if it is in session, or with the leadership of the legislature, if it is not in session, unless state law provides that the redesignation must be specifically approved by state legislation, and if general purpose units of local government representing a majority of the residents of the area to be redesignated enact legislation or pass resolutions concurring in the redesignation; (c) The redesignation would not cause, or contribute to, a concentration of any air pollutant which would exceed any maximum allowable increase permitted under the classification of any other area or any national ambient air quality standard; and (d) Any permit application for any major stationary source or major modification, subject to review under section (1) of this rule, which could receive a permit under this section only if the area in question were redesignated as Class III, and any material submitted as part of that application, were available insofar as was practicable for public inspection prior to any public hearing on redesignation of the area as Class III.

### A mended 10-18-2012 29.9

(4) Lands within the exterior boundaries of Indian Reservations may be redesignated only by the appropriate Indian Governing Body. The appropriate Indian Governing Body may submit to the EPA Administrator a proposal to redesignate areas Class I, II, or III; provided that: (a) The Indian Governing Body has followed procedures equivalent to those required of LRAPA under section (2) and subsections (3)(c) and (d) of this rule; and (b) Such redesignation is proposed after consultation with the state(s) in which the Indian Reservation is located and which border the Indian Reservation. (5) The EPA Administrator shall disapprove, within 90 days of submission, a proposed redesignation of any area only if he finds, after notice and opportunity for public hearing, that such redesignation does not meet the procedural requirements of this paragraph or is inconsistent with Section 29-0050. If any such disapproval occurs, the classification of the area shall be that which was in effect prior to the redesignation which was disapproved. (6) If the EPA Administrator disapproves any proposed redesignation, LRAPA or Indian Governing Body, as appropriate, may resubmit the proposal after correcting the deficiencies noted by the EPA Administrator. Section 29-0070 Special Control Areas The following areas are designated as Special Control Areas: (1) Lane County; (2) Within incorporated cities having a population of 4,000 or more, and within three miles of the corporate limits of any such city. Section 29-0080 Motor Vehicle Inspection Boundary Designations In addition to the area specified in ORS 815.300, pursuant to ORS 468A.390, the following geographical areas are designated as areas within which motor vehicles are subject to the requirement under ORS 815.300 to have a Certificate of Compliance issued pursuant to ORS 468A.380 to be registered or have the registration of the vehicle renewed. (1) There are currently no geographic areas in Lane County subject to motor vehicle inspection programs. Section 29-0090 Oxygenated Gasoline Control Areas There currently are no oxygenated gasoline control areas in Lane County.

## DEPARTMENT OF ENVIRONMENTAL QUALITY

DIVISION 200
GENERAL AIR POLLUTION PROCEDURES AND DEFINITIONS
General
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 the Department of Environmental Quality and is adopted as the state implementation plan (SIP) of the State of Oregon pursuant to the federal Clean Air Act, 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 Commission’s rulemaking procedures in division 11 of this chapter an d any other requirements contained in the SIP and will be submitted to the United States Environmental Protection Agency for approval. The State Implementation Plan was last modified by the Commission on December 6, 2012

. (3) Notwithstanding any other requ irement contained in the SIP, the Department may: (a) Submit to the Environmental Protection Agency any permit condition implementing a rule that is part of the federally

- approved SIP as a source

- specific SIP revision after the Department has complied with the public hearings provisions of 40 CFR 51.102 (July 1, 2002); and (b) Approve the standards submitted by a regional authority if the regional authority adopts verbatim any standard that the Commission has adopted, and submit the standards to EPA for app roval as a SIP revision.
NOTE : Revisions to the State of Oregon Clean Air Act Implementation Plan become federally enforceable upon approval by the United States Environmental Protection Agency. If any provision of the federally approved Implementation Plan conflicts with any provision adopted by the Commission, the Department shall enforce the more stringent provision. Stat. Auth.: ORS 468.020, 468A.035 & 468A.070 Stats. Implemented: ORS 468A.035 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

- 1 8

- 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. & ce rt. 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; D EQ 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. e f. 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. & ce rt. 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. & c ert. 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. & c ert. 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

- 200 3, 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; D EQ 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; DEQ 18

- 2011, f. & cert. e f. 12

- 21

- 11; DEQ 1

- 2012, f. & cert. ef. 5

- 17

- 12

### Draft July 19, 2012 29.1 

### LANE REGIONAL AIR PROTECTION AGENCY
TITLE 29 DESIGNATION OF AIR QUALITY AREAS

Section 29-0010 Definitions The definitions in Title 12 and this rule apply to this division. If the same term is defined in this rule and Title 12, the definition in this rule applies to this division. Definitions of boundaries in this rule also apply to LRAPA Rules and Regulations. (1) "AQCR" means Air Quality Control Region. (2) "AQMA" means Air Quality Maintenance Area. (3) "CO" means Carbon Monoxide. (4) "CBD" means Central Business District. (5) "Criteria Pollutant" means any of the six pollutants set out by the Clean Air Act (sulfur oxides, particulate matter, ozone, carbon monoxide, nitrogen dioxide, and lead) for which the EPA has promulgated standards in 40 CFR 50.4 through 50.12 (July, 1993). (6) "Eugene-Springfield UGB" means the area within the bounds beginning at th e Willamette River at a point due east from the intersection of East Beacon Road and River Loop No.1; thence southerly along the Willamette River to the intersection with Belt Line Road; thence easterly along Belt Line Road approximately one-half mile to the intersection with Delta Highway; thence northwesterly and then northerly along Delta Highway and on a line north from the Delta Highway to the intersection with the McKenzie River; thence generally southerly and easterly along the McKenzie River approximately eleven miles to the intersection with Marcola Road; thence southwesterly along Marcola Road to the intersection with 42nd Street; thence southerly along 42nd Street to the intersection with the northern branch of US Highway 126; thence easterly along US Highway 126 to the intersection with 52nd Street; thence north along 52nd Street to the intersection with High Banks Road; thence easterly along High Banks Road to the intersection with 58th Street; thence south along 58th Street to the intersection with Thurston Road; thence easterly along Thurston Road to the intersection with the western boundary of Section 36, T17S, R2W; thence south to the southwest corner of Section 36, T17S, R2W; thence west to the Springfield City Limits; thence following the Springfield City Limits southwesterly to the intersection with the western boundary of Section 2,T18S, R2W; thence on a line southwest to the Private Logging Road approximately onehalf mile away; thence southeasterly along the Private Logging Road to the intersection with Wallace Creek; thence southwesterly along Wallace Creek to the confluence with

### Draft July 19, 2012 29.2

the Middle Fork of the Willamette River; thence generally northwesterly along the Middle Fork of the Willamette River approximately seven and one-half miles to the intersection with the northern boundary of Section 11, T18S, R3W; thence west to the northwest corner of Section 10, T18S, R3W; thence south to the intersection with 30th Avenue; thence westerly along 30th Avenue to the intersection with the Eugene City Limits; thence following the Eugene City Limits first southerly then westerly then northerly and finally westerly to the intersection with the northern boundary of Section 5, T18S, R4W; thence west to the intersection with Greenhill Road; thence north along Greenhill Road to the intersection with Barger Drive; thence east along Barger Drive to the intersection with the Eugene City Limits (Ohio Street); thence following the Eugene City Limits first north then east then north then east then south then east to the intersection with Jansen Drive; thence east along Jansen Drive to the intersection with Belt Line Road; thence northeasterly along Belt Line Road to the intersection with Highway 99; thence northwesterly along Highway 99 to the intersection with Clear Lake Road; thence west along Clear Lake Road to the intersection with the western boundary of Section 9, T17S, R4W; thence north to the intersection with Airport Road; thence east along Airport Road to the intersection with Highway 99; thence northwesterly along Highway 99 to the intersection East Enid Road; thence east along East Enid Road to the intersection with Prairie Road; thence southerly along Prairie Road to the intersection with Irvington Road; thence east along Irvington Road to the intersection with the Southern Pacific Railroad Line; thence southeasterly along the Southern Pacific Railroad Line to the intersection with Irving Road; thence east along Irving Road to the intersection with Kalmia Road; thence northerly along Kalmia Road to the intersection with Hyacinth Road; thence northerly along Hyancinth Road to the intersection with Irvington Road; thence east along Irvington Road to the intersection with Spring Creek; thence northerly along Spring Creek to the intersection with River Road; thence northerly along River Road to the intersection with East Beacon Drive; thence following East Beacon Drive first east then south then east to the intersection with River Loop No.1; thence on a line due east to the Willamette River and the point of beginning. (7) "Maintenance Area" means any area that was formerly nonattainment for a criteria pollutant but has since met EPA promulgated standards and has had a maintenance plan to stay within the standards approved by the EPA pursuant to 40 CFR 51.110 (July, 1993). (8 ) "Nonattainment Area" means any area that has been designated as not meeting the standards established by the U.S. Environmental Protection Agency (EPA) pursuant to 40 CFR 51.52 (July, 1993) for any criteria pollutant. (9) "O3" means Ozone.

( 10 (10) “Oakridge PM2.5 Nonattainment A rea” means the area enclosed by the following: T21S, R2E, Sect 11 (NW Corner) east to T21S, R3E, Sect 11 (NE corner),

### Draft July 19, 2012 29.3

south to T21S, R3E, Sect 23(SE Corner), west to T21S, R2E, Sect 23(SW corner) correctly back to T21S, R2E, Sect 11(NW corner). (11 ) "Oakridge UGB" means the area enclosed by the following: Beginning at the northwest corner of Section 17, T21S, R3E and the city limits; thence south along the western boundary of Section 17, T21S, R3E along the city limits approximately 800 feet; thence southwesterly following the city limits approximately 750 feet; thence west along the city limits approximately 450 feet; thence northwesterly along the city limits approximately 450 feet; thence on a line south along the city limits approximately 250 feet; thence on a line east along the city limits approximately 100 feet; thence southwesterly along the city limits approximately 200 feet; thence on a line east along the city limits approximately 400 feet; thence on a line south along the city limits to the channel of the Willamette River Middle Fork; thence south-easterly up the Willamette River Middle Fork along the city limits approximately 7200 feet; thence exiting the Willamette River Middle Fork with the city limits in a northerly manner and forming a rough semicircle with a diameter of approximately one-half mile before rejoining the Willamette River Middle Fork; thence diverging from the city limits upon rejoining the Willamette River Middle Fork and moving southeasterly approximately 5600 feet up the Willamette River Middle Fork to a point on the river even with the point where Salmon Creek Road intersects with U.S. Highway 58; thence on a line east from the channel of the Willamette River Middle Fork across the intersection of Salmon Creek Road and U.S. Highway 58 to the intersection with the Southern Pacific Railroad Line; thence northerly along the Southern Pacific Railroad Line to the intersection with the northern boundary of Section 22, T21S, R3E; thence west along the northern boundary of Section 22, T21S, R3E to the intersection with Salmon Creek Road; thence on a line north to the intersection with the Southern Pacific Railroad Line; thence east along the Southern Pacific Railroad Line approximately 600 feet; thence on a line north to the intersection with High Prairie Road; thence on a line west approximately 400 feet; thence on a line north to the intersection with the northern boundary of Section 15, T21S, R3E; thence west along the northern boundary of Section 15, T21S, R3E to the intersection with the southeastern corner of Section 9, T21S, R3E; thence north along the eastern boundary of Section 9, T21S, R3E approximately 1300 feet; thence on a line west approximately 1100 feet; thence on a line south to the intersection with West Oak Road; thence northwesterly along West Oak Road approximately 2000 feet; thence on a line south to the intersection with the northern boundary line of the city limits; thence westerly and northwesterly approximately 8000 feet along the city limits to the point of beginning. ( 11 12 ) "Particulate Matter" means all finely divided solid or liquid material, other than uncombined water, emitted to the ambient air as measured by an applicable reference method with the Department's Source Sampling Manual , (January, 1992). ( 12 13 ) PM10: (a) When used in the context of emissions, means finely divided solid or liquid material, including condensible water, other than combined water, with an aerodynamic diameter less than or equal to a nominal 10 microns, emitted to the ambient air as measured by as

### Draft July 19, 2012 29.4

applicable reference method in accordance with the Department's Source Sampling Manual (January, 1992); (b) When used in the context of ambient concentration, means airborne finely divided solid or liquid material with an aerodynamic diameter less than or equal to a nominal 10 microns as measured in accordance with 40 CFR Part 50, Appendix J (July, 1993). ( 13 14 ) "UGA" means Urban Growth Area. (synonymous with “UGB”) ( 14 15 ) "UGB" means Urban Growth Boundary. Section 29-0020 Designation of Air Quality Control Regions Oregon's thirty-six counties are divided into five AQCRs. The AQCR boundaries follow county lines, and there are no counties that belong to more than one AQCR. The five AQCRs are as follows: (1) Portland Interstate AQCR , containing ten counties: (a) Benton County; (b) Clackamas County; (c) Columbia County; (d) Lane County; (e) Linn County; (f) Marion County; (g) Multnomah County; (h) Polk County; (i) Washington County; (j) Yamhill County. (2) Northwest Oregon AQCR , containing three counties: (a) Clatsop County; (b) Lincoln County; (c) Tillamook County.

### Draft July 19, 2012 29.5

(3) Southwest Oregon AQCR , containing five counties: (a) Coos County; (b) Curry County; (c) Douglas County; (d) Jackson County; (e) Josephine County. (4) Central Oregon AQCR , containing eight counties: (a) Crook County; (b) Deschutes County; (c) Hood River County; (d) Jefferson County; (e) Klamath County; (f) Lake County; (g) Sherman County; (h) Wasco County. (5) Eastern Oregon AQCR , containing ten counties: (a) Baker County; (b) Gilliam County; (c) Grant County; (d) Harney County; (e) Malheur County; (f) Morrow County; (g) Umatilla County;

### Draft July 19, 2012 29.6

(h) Union County; (i) Wallowa County; (j) Wheel County. Section 29-0030 Designation of Nonattainment Areas The following areas are designated as Nonattainment Areas: (1) PM10 Nonattainment Areas: (a) The Oakridge Nonattainment Area for PM10 is the Oakridge UGB as defined in Section 29-0010. (2) PM2.5 Nonattainment Areas: (a) The Oakridge Nonattainment Area for PM2.5 is defined in Section 29-0010. Section 29-0040 Designation of Maintenance Areas The following areas are designated as Maintenance Areas: (1) Carbon Monoxide Maintenance Areas: (a) The Eugene Maintenance Area for Carbon Monoxide is the Eugene-Springfield UGB as defined in Section 29-0010. (2) PM10 Maintenance Areas: (a) The Eugene-Springfield Maintenance Area for PM10 is the Eugene-Springfield UGB as defined in Section 29-0010. Section 29-0050 Designation of Prevention of Significant Deterioration Areas (1) All of the following areas which were in existence on August 7, 1977, shall be Class I Areas and may not be redesignated: (a) Mt. Hood Wilderness, as established by Public Law 88-577; (b) Eagle Cap Wilderness, as established by Public Law 88-577; (c) Hells Canyon Wilderness, as established by Public Law 94-199; (d) Mt. Jefferson Wilderness, as established by Public Law 90-548;

### Draft July 19, 2012 29.7

(e) Mt. Washington Wilderness, as established by Public Law 88-577; (f) Three Sisters Wilderness, as established by Public Law 88-577; (g) Strawberry Mountain Wilderness, as established by Public Law 88-577; (h) Diamond Peak Wilderness, as established by Public Law 88-577; ( i) Crater Lake National Park, as established by Public Law 88-577 and expanded in the 1990 Clean Air Act Amendments; (j) Kalmiopsis Wilderness, as established by Public Law 88-577; (k) Mountain Lake Wilderness, as established by Public Law 88-577; (l) Gearhart Mountain Wilderness, as established by Public Law 88-577. (2) All other areas, in Oregon are initially designated Class II, but may be redesignated as provided in Section 29-0060. (3) The following areas may be redesignated only as Class I or II: (a) An area which as of August 7, 1977, exceeded 10,000 acres in size and was a national monument, a national primitive area, a national preserve, a national recreational area, a national wild and scenic river, a national wildlife refuge, a national lakeshore or seashore; and (b) A national park or national wilderness area established after August 7, 1977, which exceeds 10,000 acres in size. (4) The extent of the areas referred to in section (1) and (3) of this rule shall conform to any changes in the boundaries of such areas which occurred between August 7, 1977, and November 15, 1990. Section 29-0060 Redesignation of Prevention of Significant Deterioration Areas (1)(a) All areas in Oregon, except as otherwise provided under Section 29-0050, are designated Class II as of December 5, 1974; (b) Redesignation, except as otherwise precluded by Section 29-0050, may be proposed by LRAPA, as provided below, subject to approval by the EPA Administrator as a revision to the State Implementation Plan. (2) LRAPA may submit to the EPA Administrator a proposal to redesignate areas of the state Class I or II provided that:

### Draft July 19, 2012 29.8

(a) At least one public hearing has been held in accordance with procedures established in the Plan; (b) Other States, Indian Governing Bodies, and Federal Land Managers whose lands may be affected by the proposed redesignation were notified at least 30 days prior to the public hearing; (c) A discussion of the reasons for the proposed redesignation, including a satisfactory description and analysis of the health, environmental, economic, social and energy effects of the proposed redesignation, was prepared and made available for public inspection at least 30 days prior to the hearing and the notice announcing the hearing contained appropriate notification of the availability of such discussion; (d) Prior to the issuance of notice respecting the redesignation of an area that includes any Federal lands, LRAPA has provided written notice to the appropriate Federal Land Manager and afforded adequate opportunity, not in excess of 60 days to confer with LRAPA respecting the redesignation and to submit written comments and recommendations. In redesignating any area with respect to which any Federal Land Manager had submitted written comments and recommendations, LRAPA shall have published a list of any inconsistency between such redesignation and such comments and recommendations together with the reasons for making such redesignation against the recommendation of the Federal Land Manager; and (e) LRAPA has proposed the redesignation after consultation with the elected leadership of local general purpose governments in the area covered by the proposed redesignation. (3) Any area other than an area to which Section 29-0050 refers may be redesignated as Class III if: (a) The redesignation would meet the requirements of section (2) of this rule; (b) The redesignation, except any established by an Indian Governing Body, has been specifically approved by the Governor, after consultation with the appropriate committees of the legislature, if it is in session, or with the leadership of the legislature, if it is not in session, unless state law provides that the redesignation must be specifically approved by state legislation, and if general purpose units of local government representing a majority of the residents of the area to be redesignated enact legislation or pass resolutions concurring in the redesignation; (c) The redesignation would not cause, or contribute to, a concentration of any air pollutant which would exceed any maximum allowable increase permitted under the classification of any other area or any national ambient air quality standard; and (d) Any permit application for any major stationary source or major modification, subject to review under section (1) of this rule, which could receive a permit under this section only if the area in question were redesignated as Class III, and any material submitted as

### Draft July 19, 2012 29.9

part of that application, were available insofar as was practicable for public inspection prior to any public hearing on redesignation of the area as Class III. (4) Lands within the exterior boundaries of Indian Reservations may be redesignated only by the appropriate Indian Governing Body. The appropriate Indian Governing Body may submit to the EPA Administrator a proposal to redesignate areas Class I, II, or III; provided that: (a) The Indian Governing Body has followed procedures equivalent to those required of LRAPA under section (2) and subsections (3)(c) and (d) of this rule; and (b) Such redesignation is proposed after consultation with the state(s) in which the Indian Reservation is located and which border the Indian Reservation. (5) The EPA Administrator shall disapprove, within 90 days of submission, a proposed redesignation of any area only if he finds, after notice and opportunity for public hearing, that such redesignation does not meet the procedural requirements of this paragraph or is inconsistent with Section 29-0050. If any such disapproval occurs, the classification of the area shall be that which was in effect prior to the redesignation which was disapproved. (6) If the EPA Administrator disapproves any proposed redesignation, LRAPA or Indian Governing Body, as appropriate, may resubmit the proposal after correcting the deficiencies noted by the EPA Administrator. Section 29-0070 Special Control Areas The following areas are designated as Special Control Areas: (1) Lane County; (2) Within incorporated cities having a population of 4,000 or more, and within three miles of the corporate limits of any such city. Section 29-0080 Motor Vehicle Inspection Boundary Designations In addition to the area specified in ORS 815.300, pursuant to ORS 468A.390, the following geographical areas are designated as areas within which motor vehicles are subject to the requirement under ORS 815.300 to have a Certificate of Compliance issued pursuant to ORS 468A.380 to be registered or have the registration of the vehicle renewed. (1) There are currently no geographic areas in Lane County subject to motor vehicle inspection programs. Section 29-0090 Oxygenated Gasoline Control Areas

### Draft July 19, 2012 29.10

There currently are no oxygenated gasoline control areas in Lane County.

# Oakridge Fine Particulate Matter (PM 2.5 

# ) Attainment Plan

1010 Main Street Springfield, Oregon 97477


## November 15, 2012 Final with changes from Board of Director’s Adoption October 18, 2012 and November 15, 2012

### November 15, 2012
– Final 2 

# Intentionally Blank

•••

### November 15, 2012
– Final 3 

## Table of Contents
EXECUTIVE SUMMARY
................................................................................................................ 7 T HE 

### O AKRIDGE 

### PM 2.5 

### A TTAINMENT 

### P LAN


### .......................................................................................... 7 A TTAINMENT OF 

### S TANDARDS


### ........................................................................................................... 8 S TRATEGIES AND 

### C ONTINGENCY 

### P LAN


### ................................................................................................ 9 Woodstove Curtailment and other Woodstove Strategies
....................................... 9 Other Strategies
..................................................................................................... 10 Contingency Plan Elements
.................................................................................... 11 INTRODUCTION ........................................................................................................................12 B ACKGROUND


### ............................................................................................................................ 12 W HAT IS 

### PM 2.5 

### ?

........................................................................................................................ 12 N ATIONAL 

### A MBIENT 

### A IR 

### Q UALITY 

### S TANDARDS FOR 

### PM 2.5 

### ................................................................... 12 P URPOSE OF 

### A TTAINMENT 

### P LAN


### .................................................................................................... 12 O AKRIDGE 

### A REA 

### D ESCRIPTION


### ....................................................................................................... 13 H ISTORY OF 

### E FFORTS TO 

### A DDRESS 

### P ARTICULATE 

### M ATTER IN 

### O AKRIDGE


### ................................................... 15 W HAT IS IN THIS 

### A TTAINMENT 

### P LAN 

### ?

.............................................................................................. 16 Nonattainment Area
.............................................................................................. 16 Attainment Demonstration
.................................................................................... 17 Implementation
..................................................................................................... 18 Attainment Plan Development Process
.................................................................. 18 NONATTAINMENT AREA ...........................................................................................................19 A MBIENT 

### A IR 

### Q UALITY 

### M ONITORING IN 

### O AKRIDGE


### ............................................................................ 19 N ATIONAL 

### A MBIENT 

### A IR 

### Q UALITY 

### S TANDARDS 

### (NAAQS)

.................................................................... 20 Annual PM 2.5 

### standard
........................................................................................... 20 24 -hour PM 2.5 

### standard
.......................................................................................... 20 Additional Monitoring
........................................................................................... 21 V ERIFICATION OF 

### M ONITORING 

### L OCATION


### ........................................................................................ 22 ATTAINMENT PLAN AND DEMONSTRATION ............................................................................24 E MISSION 

### I NVENTORY


### .................................................................................................................. 24 B ASE 

### Y EAR 

### E MISSION 

### I NVENTORY 

### (2008)

........................................................................................ 24 Residential Wood Combustion
............................................................................... 25 Mobile and Nonroad Sources
................................................................................. 25 Industrial Point Sources
.......................................................................................... 25 A TTAINMENT 

### Y EAR 

### E MISSION 

### I NVENTORY 

### (2014)

.............................................................................. 26 Economic Factors
................................................................................................... 26 Growth Rates
......................................................................................................... 27 C OMPARISON OF 

### 2008 T O 

### 2014 E MISSIONS


### .................................................................................... 27

### November 15, 2012
– Final 4 

### A TTAINMENT 

### S TRATEGIES 

### – E MISSION 

### R EDUCTION 

### A NALYSIS


### ................................................................ 27 P ARTICULATE 

### M ATTER 

### R EDUCTION 

### S TRATEGIES 

### (1989 -2008)

............................................................. 28 The Oakridge Air Pollution Control Ordinance #889
.............................................. 28 LRAPA Advisory Programs
...................................................................................... 29 Open Burning Ordinance
........................................................................................ 30 Woodstove Change-out Programs
......................................................................... 30 Statewide Certification of Woodstoves
.................................................................. 30 Highway Road Sanding
.......................................................................................... 31 Smoke Management
.............................................................................................. 31 Road Paving
........................................................................................................... 31 Industrial Requireme nts ......................................................................................... 31 Public Education
..................................................................................................... 31 Additional Strategies
............................................................................................. 32 C URRENT 

### S TRATEGIES 

### 2009 -2011

................................................................................................ . 32 Wood Stove Change-out program
.......................................................................... 32 He at Smart: Stove Removal upon Sale of Home
.................................................... 32 Public Education
..................................................................................................... 33 Transportation and Fuel-Related Emissions
........................................................... 33 S TRENGTHENED 

### O NGOING 

### S TRATEGIES IN 

### 2012 -2014

....................................................................... 33 Oakridge Air Quality Advisory Committee Strategy Recommendations
................ 34 Woodstove Change- outs ........................................................................................ 34 Enforcement of Oakridge Ordinance
...................................................................... 34 Enhancements to Key Ongoing Strategies
............................................................. 34 Contingency Strategies
.......................................................................................... 35 Industrial Emission Reductions
............................................................................... 35 E STIMATED 

### R EDUCTIONS AND 

### C REDITS FOR 

### F UTURE 

### S TRATEGIES


### ............................................................ 36 A TTAINMENT 

### D EMONSTRATION


### ..................................................................................................... 36 Baseline Design Value
............................................................................................ 36 Background on Precursors
...................................................................................... 37 Speciated Filter Sample Analysis
............................................................................ 38 Minor PM 2.5 

### Components
....................................................................................... 39 Rollback Model
...................................................................................................... 40 Modeled Air Quality Improvements of the Key RWC Strategies
............................. 41 Unmonitored Area Analysis
................................................................................... 41 Application of Future Strategies
............................................................................ 42 Contingency Plan
................................................................................................... 42 ACKNOWLEDGEMENTS .............................................................................................................45 O AKRIDGE 

### A DVISORY 

### C OMMITTEE


### .................................................................................................. 45 P RINCIPAL 

### A UTHORS


### .................................................................................................................... 45 C ONTRIBUTORS


### .......................................................................................................................... 45

### November 15, 2012
– Final 5 

### T ABLE OF 

### T ABLES 

### T ABLE 

### 1: PM 2.5 

### A TTAINMENT 

### D EMONSTRATION


### ..................................................................................... 9 T ABLE 

### 2: 2002 -2003 O AKRIDGE 

### M ONITORING 

### S URVEY 

### R ESULTS


### ............................................................. 23 T ABLE 

### 3: 2008 E STIMATED 

### T YPICAL 

### S EASON 

### D AY AND 

### W ORST 

### -C ASE 

### D AY 

### PM 2.5 

### E MISSIONS


### . ......................... 24 T ABLE 

### 4: 2014 E STIMATED 

### T YPICAL 

### S EASON 

### D AY AND 

### W ORST 

### -C ASE 

### D AY 

### PM 2.5 

### E MISSIONS


### . ......................... 27 T ABLE 

### 5: O AKRIDGE 

### W OOD 

### C HANGE


### - OUT 

### P ROGRAMS 

### (1993-96/2006- 07)

............................................. 30 T ABLE 

### 6: O AKRIDGE 

### W OOD 

### C HANGE


### - OUT 

### P ROGRAMS 

### (2009/2010- 11)

.................................................. 32 T ABLE 

### 7: A NNUAL 

### PM 2.5 VALUES USED TO CALCULATE BASELINE DESIGN VALUE


### . ............................................ 37 T ABLE 

### 8: C ONTRIBUTION BY SPECIATED COMPONENTS


### . R ESULTS OF 

### SANDWICH ANALYSIS FOR THE TOP 

### 25% HIGH CONCENTRATION WINTER 

### (O CT 

### -M AR 

### ) DAYS


### . ................................................................................ 39 T ABLE 

### 9: B ASELINE AND 

### F UTURE PROJECTED DESIGN VALUES


### .................................................................... 40 T ABLE 

### 10 : A LLOCATION OF EMISSIONS AND MODELED CONCENTRATIONS FOR BASE AND FUTURE YEARS


### . ............. 42 Table of Figures F IGURE 

### 1: O AKRIDGE 

### N ONATTAINMENT 

### A REA 

### 2008 W ORST 

### C ASE 

### D AY 

### E MISSIONS


### ......................................... 8 F IGURE 

### 2: S PECIAL 

### P ROTECTION 

### Z ONE 

### S URROUNDING 

### O AKRIDGE


### .............................................................. 10 F IGURE 

### 3: O AKRIDGE 

### L OCATION


### ........................................................................................................ 14 F IGURE 

### 4: N ONATTAINMENT 

### A REA


### ..................................................................................................... 15 F IGURE 

### 5: PM 2.5 

### A NNUAL 

### S TANDARD COMPARISON CONCENTRATIONS FROM THE 

### O AKRIDGE MONITOR


### . ............ 20 F IGURE 

### 6: PM 2.5 

### 24

- HOUR 

### S TANDARD COMPARISON CONCENTRATIONS FROM THE 

### O AKRIDGE MONITOR


### . ........... 21 F IGURE 

### 7: N EPHELOMETER ESTIMATE D 

### PM 2.5 FOR 

### O AKRIDGE AND 

### W ESTFIR DURING WINTER 

### 2009 -2010.

........ 22 F IGURE 

### 8: 2002 -2003 O AKRIDGE 

### M ONITORING 

### S URVEY 

### S ITE 

### M AP


### .......................................................... 22 F IGURE 

### 9: O AKRIDGE 

### PM 2.5 

### E MISSION 

### I NVENTORY FOR 

### 2008 W ORST 

### W INTER 

### D AYS


### ................................... 25 F IGURE 

### 10 : S PECIATED 

### C OMPONENTS OF 

### PM 2.5 

### ( USING 

### SANDWICH ANALYSIS 

### )

......................................... 38 Image I MAGE 

### 1: S MOKE INVERSION OVER 

### O AKRIDGE 

### , WHERE THE 

### W ILLAMETTE 

### A CTIVITY 

### C ENTER IS LOCATED


### . T HE PARTICULATE MATTER TRAPPED NEAR THE SURFACE BY A TEMPERATURE INVERSION IS CLEARLY VISIBLE


### . ........ 19

### November 15, 2012
– Final 6 

### Table of Appendices

A) Unmonitored Area Analysis (UMAA) 1) Saturation Survey B) Meteorological conditions C) Growth projections 1) Population & household (census 2010) 2) Employment 3) Vehicle Miles Traveled (VMT) from Lane Council of Governments (LCOG) D) Emission inventory E) Speciation studies 1) SANDWICH (Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbonaceous Material Balance Approach) 2) Positive Matrix Factorization (PMF) model F) Strategies 1) Oakridge ordinance 2) Smoke Management Directive 3) Title 38

–

Major New Source Review 4) Woodstove Changeout list 5) Oakridge Advisory Committee Report 6) Oakridge Title IX

–

General Regulations (see p.25) G) Design Value H) Rollback Modeling I) Transportation Analysis J) RACT/RACM Analysis K) Transportation Conformity Analysis

### November 15, 2012
– Final 7 

## EXECUTIVE SUMMARY The U.S. Environmental Protection Agency (EPA) adopted revisions to the National Ambient Air Quality Standards (NAAQS) for PM 2.5 

### in September 2006. PM 2.5 

### is fine particulate matter two and a half microns and less in diameter, or about 1/28 th 

### the diameter of a human hair. Also referred to as respirable particulate matter, these tiny particles are inhaled deep into the lungs where they accumulate and aggravate respiratory conditions, particularly asthma. Fine particulate (PM 2.5 

### microns and smaller) are associated with heart and lung disease, increased respiratory symptoms and disease, decreased lung function, and premature death. Chronic exposure to fine particulate has also been implicated in increased risk for cardiac events. Populations especially at risk include children, the elderly, and those with existing health problems.

On O ctober 8, 2009, the Environmental Protection Agency (EPA) issued final area nonattainment designations for the 24-hour national air quality standards for fine particulate matter (PM 2.5 

### ). Oakridge was designated a non-attainment area in Oregon. Under the Clean Air Act, an area that violates the federal standards is designated as “nonattainment” and must adopt a plan with emission reduction measures to bring the area back into compliance. The area designated as non-attainment for PM 2.5 

### contains Oakridge, the small town of Westfir and surrounding area. The Oakridge PM 2.5 

### Attainment Plan The City of Oakridge has struggled to meet air quality standards. Oakridge was proposed a PM 10 

### “non

- attainment” area in September 1992, and designated on January 20, 1994. The City last exceeded that standard in 1993. Voluntary measures to reduce wood smoke emissions adopted in 1999 have reduced measured particulate levels. Progress in reducing wood smoke emissions made it possible for the City of Oakridge to meet the 1997 PM 2.5 

### standard of 65 μg /m 3 

### . Despite progress in improving air quality, the tightening of the PM 2.5 

### standard in 2006 presented yet another challenge. Local climate and topography make Oakridge prone to wintertime temperature inversions, low wind speeds and poor atmospheric dispersion. During the winter months, Oakridge air quality is often threatened due to high concentrations of smoke from woodstoves settling on the valley fl oor of the city. Figure 1 shows the worst case day 1 

### contribution of each of these source categories in the Oakridge nonattainment area.

1 A worst case day is defined as a design value corresponding to the 98 th percentile of the data collected for a given year or an average of the 98 th percentile of three years.

### November 15, 2012
– Final 8 Figure 1: Oakridge Nonattainment Area 2008 Worst Case Day Emissions



### Attainment of Standards Despite significant progress in reducing particle pollution, the Oakridge area exceeded and consequently violated the federal 24-hour fine particulate (PM 2.5 

### ) 2006 standard of 35 μg/m 3 

### but complied with the annual PM 2.5 

### standard of 15 μg/m 3 

### in the 2001-2011 period. PM 2.5 

### concentrations above the 24-hour standard during this period are linked to wintertime inversions and high emissions. The main purpose of the Oakridge PM 2.5 

### attainment plan is to return the Oakridge area back to compliance with the 2006 24-hour standard by 2014 as required by federal law. Oakridge does not violate the annual PM 2.5 

### standard. This attainment plan fulfills federal requirements regarding EPA designated nonattainment areas. The City of Oakridge has taken steps to address pollution from woodstoves. On February 20, 2003, the Oakridge City Council adopted a home wood heating ordinance that:

Changed previous voluntary woodburning curtailment measures to mandatory, Prohibited burning garbage in woodstoves and fireplaces, Incorporated a 40 % opacity limit on chimneys, Incorporated the PM 2.5 

### standard into the program, and Required the removal of uncertified woodstoves from property to be sold or rented. Industry 0.2% Open Fireplaces 7.7% Non
- Certified Woodstoves 31.7% Certified Woodstoves 45.4% Pellet Stoves 1.3% Other Area

Sources 0.9% On
- Road Cars & Trucks 6.8% Re
- entrained Road Dust 5.0% Railroads

1.1% 

# Oakridge PM2.5 Emission Inventory for 2008 Worst Winter Days

### November 15, 2012
– Final 9 

### In December 2008, the Oakridge City Council passed an ordinance prohibiting the use of an uncertified solid fuel heating device in a residence. The Lane Regional Air Protection Agency (LRAPA) has also worked closely with the City of Oakridge and other partners to help residents replace old, uncertified wood stove with new, cleaner burning and energy efficient heating systems. LRAPA also issues daily home wood heating advisories November 1 through the last day of February. When air quality is forecast to be in the unhealthy for sensitive groups range, LRAPA activates an automatic “ callware ” system to alert residents by telephone about burning restrictions. The use of these strategies and others identified by an advisory committee should further reduce ambient concentration of PM 2.5 

### below the national health-based standard by 2014. The estimated ambient concentrations for both the annual and the worst case day are predicted to decrease based on a ratio of the 2008 ambient concentration to the projected emission inventory for the year 2014. The base year Design Value concentration confirms that additional strategies, beyond those implemented by 2008, are needed to bring the area into attainment. The future year concentration in Table 1 is based on implementation of the additional strategies and confirms that these strategies will be sufficient to meet the federal 24-hour standard by 2014.

Base Year Future Year Worst Case Day Concentration 39.5 μg/m 3 

### 28. 2 μg/m 3



### Federal Standard 35 μg/ m 3 

### 35 μg/ m 3

Table 1 : PM 2.5 Attainment Demonstration



### Strategies and Contingency Plan Woodstove Curtailment and other Woodstove Strategies 

### Oakridge has been proactive in adopting a number of strategies to reduce emissions from home wood heating. These strategies include:

City ordinances to curtail burning during stagnant weather periods. City ordinance requiring the removal of an uncertified wood stove upon sale of a home. City ordinance prohibiting the use of a noncertified wood stove in a residence. Partnering in additional change-out programs to encourage removal of noncertified stoves.

### November 15, 2012
– Final 10 

### A new stove certification program by EPA and the woodstove replacement programs continue to result in a significant emissions reduction in Oakridge. The continued replacement of older woodstoves coupled with better enforcement of daily advisories is expected to continue to decrease emissions through 2014 even with a moderate growth in households. Other Strategies 

### Curtailing open burning has been identified as a way to reduce PM emissions. The Oakridge City Ordinance prohibits burning within the City limits on days with high concentrations of particulate matter in the month of October and March 1

– June 15. All open burning is prohibited between November 1 and February 28 inside the City limits

. Oregon Department of Forestry (ODF) requires federal land managers to follow strict smoke management instructions and avoid smoke impacts to Oakridge. ODF has designated Oakridge as a Special Protection Zone (SPZ) shown in Figure 2

. During the November 15 through February 15 period, prescribed burning in the SPZ is allowed only when the ODF smoke management meteorologist believes there will be no measurable smoke impacts within the nonattainment area. The SPZ prohibits any prescribed burning on red advisory days.

Figure 2: Special Protection Zone Surrounding Oakridge

### November 15, 2012
– Final 11 Contingency Plan Elements 

### Th e following strategies will be implemented as contingency strategies to fully meet the air quality standards, if it becomes clear that the strengthened ongoing strategies will not be sufficient to attain the PM 2.5 

### standards by 2014 and or to maintain compliance with the standards through 2024 and beyond:

• Stricter opacity limit on all green or yellow advisory days, revising the current 40% opacity limit to a more restrictive 20% limit, as has been done in some other northwest communities. A 20% opacity limit on green and yellow advisory days will help reduce emissions with the goal of avoiding red advisories when no visible emissions are allowed. Stricter green-yellow-red advisory program, with more yellow and red advisory days each winter. Further restrictions on the city woodstove curtailment exemptions (for sole source, economic hardship). If Oakridge meets the EPA Clean Air Act deadline for meeting the standard, the contingency plan will not be implemented

. While this plan is not intended to attain any proposed standard, LRAPA estimates that Oakridge will meet a tightened annual standard of 12 μg/m3.

### November 15, 2012
– Final 12 

## INTRODUCTION Background This plan addresses the 24-hour and the annual ambient air quality standards for PM 2.5 

### as defined in the federal Clean Air Act. In September 2006, the U.S. Environmental Protection Agency (EPA) strengthened the daily (24-hr) PM 2.5 

### (fine particulate) standard by lowering the level from 65 g/m 3 

### to 35 g/m 3 

### and retained the annual PM 2.5 

### standard of 15 g/m 3



### . Areas in violation of the PM 2.5 

### standard (based on the most recent three years of federal reference monitoring data) are designated as a “nonattainment area” by the EPA. Oakridge, Oregon has been designated as nonattainment for the daily PM 2.5 

### standard. The Lane Regional Air Protection Agency (LRAPA) must develop an attainment plan that will bring air quality into compliance with the standard as soon as possible, and submit this plan to EPA. What is PM 2.5 

### ? Particulate matter (PM) is the general term used for a mixture of solid particles or liquid droplets found in the air. Some particles are large or dark enough to be seen as soot or smoke. Others are so small they can be detected only with an electron microscope. These particles come in a wide range of sizes (“fine” particles are less than 2.5 micrometers in diameter and coarser-sized particles are larger than 2.5 micrometers), and originate from many different sources. Fine particles (PM 2.5 

### ) generally result from fuel combustion from residential fireplaces and woodstoves, pile and forest burning, industrial facilities, and motor vehicles. Coarse particles (PM 10 

### ) are generally emitted from sources such as vehicles traveling on paved and unpaved roads, materials handling, and wood products operations, as well as wind-blown dust. These particles can accumulate in the respiratory system and are associated with numerous health effects. Fine particles are most closely associated with such health effects as increased hospital admissions and emergency room visits for heart and lung disease, increased respiratory symptoms and disease, decreased lung function and premature death. Sensitive groups that are at greatest risk include the elderly, individuals with cardiopulmonary disease such as asthma, and children. National Ambient Air Quality Standards for PM 2.5 

### EPA has established National Ambient Air Quality Standards (NAAQS) for PM 2.5 

### at 35 micrograms per cubic meter (μg/m 3 

### ) for a daily (24-hour) standard and 15 μg/m 3 

### as an annual standard. Any value monitored above these levels, as defined by federal rules and guidance, is considered an exceedance. EPA uses the 98 th 

### percentile of the 24-hr PM 2.5 

### within any given year and averages it over three calendar years. An exceedance of the average 98 th 

### percentile over three years greater than 35 μg/m 3 

### is considered a violation. An exceedance of the annual standard averaged over three years becomes a violation of the annual standard. If an area violates either standard, EPA designates it as a nonattainment area. This plan includes a demonstration of continuing attainment with both standards. Purpose of Attainment Plan This document provides a pathway for continued improvement to reduce particulate emissions and to return the Oakridge Nonattainment Area (NA) to attainment for PM 2.5 

### (state

### November 15, 2012
– Final 13 

### classification will be “maintenance”) by achieving the more protective national health standards adopted in 2006. It is a plan to ensure Oakridge meets the 24-hour and annual National Ambient Air Quality Standards for PM 2.5 

### and maintains the annual standard for PM 2.5 

### . This document complies with the applicable 1990 Federal Clean Air Act (CAA) requirements and Environmental Protection Agency (EPA) guidance and policies. The attainment plan provides strategies to meet the PM 2.5 

### standards by 2014 and provides contingency measures should Oakridge not meet the deadline. To demonstrate "attainment" requires the collection of representative monitoring data using approved measuring instruments and procedures, with adequate quality assurance. EPA will review the plan to determine if it is approvable and publish its findings in the Federal Register. Redesignation back to attainment is possible only after Oakridge meets the standards for three consecutive years and a maintenance plan is drafted, adopted by the LRAPA Board of Directors, the Environmental Quality Commission (EQC) and approved by EPA. EPA will then formally redesignate Oakridge back into attainment in the Federal Register. Oakridge Area Description Oakridge, Oregon lies in an alluvial plain in the foothills at the southern end of the Willamette River valley. The city is in Lane County, Oregon, approximately 45 miles east-southeast of Eugene, and 28 miles west of Willamette Pass, the summit of the Cascade Mountain Range. The city limits of present-day Oakridge includes the historic City of Oakridge and, directly west, the area formerly known as Willamette City. Figure 3 shows the location of Oakridge in Lane County.

### November 15, 2012
– Final 14

Figure 3: Oakridge Location

### November 15, 2012
– Final 15

Figure 4: Nonattainment Area


### The area of applicability for this attainment plan includes an area that contains the City of Oakridge and the small town of Westfir. Figure 4 shows the Oakridge non-attainment area. The City of Oakridge is situated in a valley oriented east-west, through which flows the middle fork of the Willamette River. Elevation of the area ranges from 1100 feet at the lower (west) end to 1600 feet with areas of densest population situated between 1100 feet and 1200 feet. Mountains rise on the north and south sides to 1700 feet and 1600 feet, respectively. Westfir is a very small (population 335) isolated rural mountain community that is located along the north fork of the Willamette River about 1 mile NW of Oakridge. Its elevation is about the same as Oakridge and it is surrounded by the same high mountains. Westfir and Oakridge are in separate steep sided river valleys separated by a 400-foot ridge. The Westfir valley is very narrow, only about 1/4 mile across at its widest point, while the Oakridge valley is about 1 mile across at its widest point. History of Efforts to Address Particulate Matter in Oakridge Oakridge has historically struggled with air quality issues during the winter months, especially on cold days during periods of air stagnation. Oakridge was proposed a PM 10 

### non-attainment area in December 1993 , effective on January 9, 1994. PM 10 

### is defined as particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers as measured by

### November 15, 2012
– Final 16 

### an approved method listed in 40 CFR 53. Initial efforts to curtail wood smoke were developed for the Oakridge Urban Growth Boundary (UGB) by 1991, however, at that time the area still had not met the standard. LRAPA subsequently submitted a formal PM 10 

### plan to EPA in 1996. EPA approved the attainment plan on May 14, 1999. One of the key strategies in the plan included a mandatory woodstove curtailment program and a woodstove change-out program. On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to allow open backyard burning only during the months of October, March, April, and May and bans the use of burn barrels. Oakridge City Code 92.04.A.2 currently regulates open backyard burning inside the Oakridge city limits. This eliminated burning during wintertime periods of maximum atmospheric stagnation when burning is more likely to contribute to exceedances of the 24-hour standard. An aggressive wood stove change-out project, along with a voluntary residential wood burning advisory program, further reduced winter time PM 10 

### emissions. In a letter of agreement with the Oregon Department of Transportation (ODOT), dated July 29, 1996, ODOT agreed to use a chemical de-icing compound on Highway 58 as an alternative to sanding roads during the winter season. As a result of these strategies, the area was able to meet and continue to meet the PM 10 

### standards from 1994 to present. EPA revised the particulate standard in 1997 to include PM 2.5 

### and established a daily standard of 65 μg/m 3



### . LRAPA began monitoring fine particulate matter (PM 2.5 

### ) concentrations in 1998. The original PM 10 

### strategies included in the 1996 attainment plan were so successful in maintaining clean air that Oakridge also met the fine particulate (PM 2.5 

### ) standard. In 2006, EPA modified the PM 2.5 

### standard, cutting the threshold for the 24-hour exceedance day roughly in half to 35 μg/m 3



### . Oakridge has not yet been able to meet this new daily PM 2.5 

### standard, so continued progress is need to further reduce particulate emissions. LRAPA has measured PM 2.5 

### at the same location in the Oakridge (Willamette Activity Center) since 1998 and PM 10 

### since 1989. LRAPA has also operated a nephelometer in Oakridge since 1989 which makes it possible to estimate PM 2 .5 

### during 1989-1998. Many of the same pollutant sources for PM 10 

### are the same for PM 2.5 

### . Between 2006 and 2011, PM 2.5 

### concentrations in Oakridge on worst winter days violated the more protective 24-hour national health standard adopted in 2006. There were no exceedances of the annual PM 2.5 

### standard. EPA’s deadline for meeting the standards is December 2014. Emission reduction strategies included in this plan should provide compliance with the Clean Air Act Amendments even with a modest population growth. If the community fails to meet the standard by 2014, automatic contingency measures will be implemented and are clearly identified in this plan. What is in this Attainment Plan?
Nonattainment Area 

### The plan provides an analysis of the existing nonattainment area situation. It describes the past and the current state of air quality. It identifies and quantifies the current nature of the air quality problem.

### November 15, 2012
– Final 17 Attainment Demonstration 

### The key component of the plan is in the attainment demonstration analysis where emissions are predicted into the future but strategies are identified to reduce emissions. There is also an explanation of the past and current economic situation and past and current meteorological situation. It predicts air quality into the future based on a growth analysis to show how much worse the air quality can become. It tells how the air quality can improve by implementing these various approaches or tactics to reduce emissions enough to meet the standards. Credit is given to each strategy or tactic and emission reductions are estimated into the future. It provides for a commitment by the community to return Oakridge to attainment status and explains and quantifies those commitments. The commitment shows how to improve air quality by using these strategies and promises to watch for changes to assure the commitment is met. If the commitment is not met, it identifies what future additional strategies will be necessary to implement immediately, should the initial commitments fail to meet the standard by 2014. The following strategies are in place and critical for meeting the PM 2.5 

### air quality health standards by 2014:

• Woodstove change-out programs. A model is in place to replace non-certified woodstoves with heat pumps, pellet stoves, or high-efficiency certified woodstoves. The current funding has been committed, and th e most recent phase of this program was completed during December 2011.

• Continue woodstove-fireplace curtailment program (green-yellow-red advisories, with curtailment required during air stagnation pollution episodes); the city ordinance requires curtailment on red days; LRAPA provides the daily air quality and meteorological forecasts during November-February.

• Continue program prohibiting backyard/open burning: Burning of garbage is prohibited at all times; city ordinance prohibits open burning of yard debris during November-February; LRAPA provides daily open burning advisory during March-May and October; and open burning is prohibited in June-September during the fire season established by fire departments.

• Maintain the Special Protection Zone for Oakridge as required in the ODF smoke Management Plan.

• Continue outdoor recreational fire (chimineas and other patio heaters) program; LRAPA rules prohibit outdoor recreational fires on yellow-red advisory days during November-February.

• Continue Oregon Heat Smart program; requires removal of non-certified woodstoves upon home sale, and prohibits burning of garbage in woodstoves and fireplaces.

• Prohibit the use of uncertified woodstoves The plan proposes strengthening existing strategies and introduces new strategies to be implemented in the community. The plan demonstrates that new and continued permanent and voluntary strategies are sufficient to meet the PM 2.5 

### standards by 2014 and the community will continue to meet the standard into the future.

### November 15, 2012
– Final 18 

### The primary source of PM 2.5 

### in Oakridge is residential wood heating. The most serious PM 2.5 

### problems occur during the winter in the urban area of Oakridge, when cooler temperatures trap particles near the ground by atmospheric inversions. Monitoring data clearly shows the high particulate levels occurring during the nighttime periods with light winds and strong temperature inversion. The levels drop significantly after sunrise. These diurnal high and low concentration periods also correspond to the general use of woodstoves as home heating devices. The emissions are greatest during the evening and nighttime periods. Implementation 

### The plan describes final commitments by Oregon and the Oakridge community to make the plan work. It outlines the commitment for LRAPA to work with the local community to find solutions to the air quality problem. Attainment Plan Development Process 

### LRAPA used the 2008 PM 2.5 

### emission inventory and the feedback of the Oakridge Advisory Committee, the Lane Council of Governments (LCOG), and the Oregon Department of Transportation (ODOT) to develop the PM 2.5 

### attainment plan. The Advisory Committee prepared a list of strategies that was submitted to LRAPA for inclusion in the plan. Additional strategies recommended by the committee are included in the Attainment Plan and Demonstration section of this document

. The LRAPA Advisory Committee and the Oregon Department of Transportation also reviewed and made recommendations on the plan.

### November 15, 2012
– Final 19 

## NONATTAINMENT AREA Since the 1990s, Oakridge has undertaken many efforts to manage or control particulate emissions. For example, efforts have been made on several occasions to improve air quality by implementing very stringent controls such as a clean air ordinance to regulate both burning in woodstoves and open burning. Due to the success of these programs to address PM 10 

### emissions, when EPA revised the PM standard in 1997 to include PM 2.5 

### , Oakridge was in compliance. Despite these aggressive efforts, in 2006 when the PM 2.5 

### standard was revised Oakridge found itself in violation of the 24-hour PM 2.5 

### standard. Ambient Air Quality Monitoring in Oakridge The Oakridge area has one particulate (PM 2.5 

### ) monitoring site with the sampler located at 47674 School Street, also known as the Willamette Activity Center. LRAPA has monitored at the Willamette Activity Center site since 1987 for PM 10 

### and since 1998 for PM 2.5 

### . After rigorous quality assurance, the data from the Willamette Activity Center site is transferred to ODEQ and on to EPA’s database. The data from the Willamette Activity Center monitor was used as the basis for the nonattainment determination and for determining compliance with the standard.

Image 1: Smoke inversion over Oakridge, where the Willamette Activity Center is located. The particulate matter

trapped near the surface by a temperature inversion is clearly visible.

### November 15, 2012
– Final 20 

### National Ambient Air Quality Standards (NAAQS) As mentioned previously, in 2006 the EPA revised the PM 2.5 

### standard to more accurately reflect the latest health information. EPA revised the 24-hour standard from 65 μg/m 3 

### to 35 μg/m 3


### , and kept the annual standard at 15.0 μg/m 3 

### . EPA determines compliance with the PM 2.5 

### standards based on averaging air quality measurements both annually and on a 24-hour basis.
Annual PM 2.5 standard 

### The annual standard for PM 2.5 

### is met whenever the three year average of the annual mean PM 2.5 

### concentrations for a designated monitor is less than or equal to 15.0 μg/m 3 

### . Oakridge has met this standard since monitoring started at Willamette Activity Center (Figure 5).

Figure 5 : PM 2.5 Annual Standard comparison concentrations from the Oakridge monitor. 24 -hour PM 2.5 standard 

### The 24-hour standard for PM 2.5 

### is met whenever the three year average of the annual 98 th 

### percentile of values at a monitoring site is less than or equal to 35 μg/m 3 

### . The 98 th 

### percentile is a concentration below which 98% of observations fall. This value is used for the 24-hour standard instead of the maximum observation for any given year. By doing so, EPA ensures infrequent peaks are ignored and a more robust value is used for comparison. From 2001 through 2005, Oakridge was in compliance with the PM 2.5 

### standard of 65 μg/m 3



### . However in 2006, when EPA revised the standard to 35 μg/m 3 

### , Oakridge violated the 24-hour standard. The three year average 98 th 

### percentile for the Oakridge monitoring site has continued to violate the 24-hour standard each year since the standard tightened in 2006, but has decreased significantly over the period 2006 - 2011.

13.2 13.7 13.4 12.8 12.4 12.0 11.5 11.0 11.0 10.5 8.9

0 2 4 6 8 10 12 14 16

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011μg/m3 

## Oakridge PM 2.5 

## : 3
- year Average of Annual Means

Willamette Activity Center Annual PM2.5 Standard

### November 15, 2012
– Final 21 Figure 6 : PM 2.5 24 -hour Standard comparison concentrations from the Oakridge monitor. Additional Monitoring 

### In addition to the Oakridge Federal Reference Method (FRM) monitor, between October 2009 and March 2010, investigative monitoring was done in the Westfir area to determine PM 2.5 

### concentrations there, and relative difference from the Willamette Activity Center monitor. Several saturation samplers and a Nephelometer were used for this purpose. Figure 7 shows the relative PM 2.5 

### concentrations, as a function of Nephelometer light scattering, of Westfir and Oakridge. More information regarding the methods and results of this monitoring is available in Appendix A.1.

56.2 55.6 56.1 51.6 52.6 47.7 46.6 40.0 40.9 37.7 38.8

0 10 20 30 40 50 60 70

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011μg/m3 

## Oakridge PM 2.5 

## : 3
- year Average of Annual 98 th 

## Percentile

Willamette Activity Center 24

- Hour Standard

### November 15, 2012
– Final 22 Figure 7: Nephelometer estimated PM 2.5 for Oakridge and Westfir during winter 2009- 2010. 

### Verification of Monitoring Location LRAPA has conducted a field study to verify that the Willamette Activity Center PM 2.5 

### monitoring site generally represents peak level PM 2.5 

### concentrations within Oakridge, and is the most appropriate location for a PM 2.5 

### monitor. The one year, six site monitoring survey was conducted in 2002-2003, and is attached in Appendix A. Results are summarized in Figure 8 and Table 2.

Figure 8: 2 002 -2003 Oakridge Monitoring Survey Site Map

### November 15, 2012
– Final 23

n (max 103) Capture

rate Annual

mean μg/m 3 Maximum value μg/m 3 n > 15 μg/m 3 Difference from primary (MV401) (%) WAC FRM 100 96% 12.8 56.8 28

- MV401 (primary) 99 95% 13.6 58.1 29

- MV402 (duplicate) 96 92% 13.5 57.1 28

- MV403 95 91% 10.9 53.3 18

- 19.9 MV404 100 96% 11.4 41.0 23

- 16.2 MV405 94 90% 8.3 42.3 8

- 39.0 MV406 96 92% 8.6 36.7 14

- 36.8 MV407 98 94% 13.0 47.6 26

- 4.4

Table 2: 2002 -2003 Oakridge Monitoring Survey Results


### Findings of this survey agreed with those of PM 10 

### saturation studies from 1991 and 1994. Within Oakridge the highest levels were found in the southwestern portion of the town. Therefore, it was confirmed that this site represents peak levels of PM 2.5 

### concentrations in Oakridge. In addition, the Willamette Activity Center monitor also represents an area where people live, work, and play, reconfirming the monitor location is the most appropriate for Oakridge.

### November 15, 2012
– Final 24 

## ATTAINMENT PLAN AND DEMONSTRATION Emission Inventory An emission inventory consists of emission estimates from sources that emit PM 2.5 

### within the Oakridge nonattainment area boundary. The emissions inventory data is essential in developing the attainment demonstration, as it helps identify the sources contributing to the air quality problem and the emission reduction strategies, once implemented, that reduce pollution levels below the standard. Sources of PM 2.5 

### in Oakridge include minor industry, onroad mobile sources (e.g., car and truck exhaust, road dust), railroads, and area sources (e.g., outdoor burning, woodstoves, and fireplaces). Base Year Emission Inventory (2008) The base year emission inventory is used as the starting point for the attainment demonstration. This inventory includes sources in the nonattainment area during the 2 008 baseline year. The 2008 emission inventory is summarized in Table 3 and Figure 9. The calculation procedures are included in Appendix D.

-- lbs/per day

-- Percent of Total NAA Emissions Typical Season Day Worst

- Case Day Typical Season Day Worst

- Case Day Permitted Point Sources (1) Oakridge Sand & Gravel: Rock crushing operation 0.4 0.8 0.1% 0.1% Oakridge Sand & Gravel: Cement plant 0.1 0.1 0.0% 0.0% Stationary Area Sources Residential Wood Combustion: Fireplace (2) 38.5 42.3 7% 8% Residential Wood Combustion: Non

- Certified Woodstove/Insert (2) 158.9 174.8 30% 32% Residential Wood Combustion: Certified Woodstove/Insert (2) 228.0 250.8 43% 45% Pellet Stoves 6.7 7.4 1% 1% All Other Stationary Area Sources 47.4 4.7 9% 1% On

- Road Sources On

- Road: Exhaust, Brake, Tire 26.6 37.3 5% 7% Re

- Entrained Road Dust 12.1 27.8 2% 5% Nonroad Sources Union Pacific Railroad 6.0 6.0 1% 1% Total, All Sources, lbs/day 525 552 (1) Worst

- case day = Peak month production/20 workdays. (2) Worst

- case day = Peak Heating Degree Day

Table 3 : 2008 Estimated Typical Season Day and Worst-Case Day PM 2.5 Emissions.


### The emissions inventory on worst winter days is of most interest since the PM 2.5 

### concentrations measured in Oakridge do not meet the current 24-hour PM 2.5 

### standard and the peak PM 2.5 

### concentrations occur on cold, stagnant days during the November-February wood-heating season. Residential wood-heating emissions (from certified and non-certified woodstoves, fireplaces, and pellet stoves) account for about 86% of the emissions on worst winter days, as illustrated in Figure 9.

### November 15, 2012
– Final 25 Figure 9 : Oakridge PM 2.5 Emission Inventory for 2008 Worst Winter Days Residential Wood Combustion 

### Residential wood combustion is a common way to heat homes in Oregon. To estimate emissions from wood burning, LRAPA conducted a survey for the 2009-2010 heating season in Oakridge-Westfir. The survey provided LRAPA with information on how many homes use various types of wood-heating devices, the amount of wood burned, and other information on wood-heating practices. Mobile and Nonroad Sources 

### Road dust and tailpipe emissions of PM 2.5 

### from motor vehicles were calculated by Lane Council of Governments (LCOG) transportation staff by applying emission factors from the EPA MOVES computer program to total vehicle miles traveled in the nonattainment area. Estimated vehicle miles traveled are from previous transportation modeling by LCOG for the Oregon Department of Transportation. Emissions from railroads were provided by Union Pacific Railroad staff using the EPA NONROAD2008a emissions protocol. Industrial Point Sources 

### LRAPA maintains data on industrial point source emissions in Lane County. The only operating industrial point sources within Oakridge-Westfir area are two minor aggregate industry sources operated by Oakridge Sand & Gravel. Industry 0.2% Open Fireplaces 7.7%

Non
- Certified Woodstoves 31.7% Certified Woodstoves 45.4% Pellet Stoves 1.3% Other Area Sources 0.9% On
- Road Cars & Trucks 6.8%
Re
- entrained Road Dust 5.0% Railroads 1.1% 

# Oakridge PM2.5 Emission Inventory for 2008 Worst Winter Days

### November 15, 2012
– Final 26 

### Attainment Year Emission Inventory (2014) The attainment year inventory is an estimation of emissions for the year that the area is expected to have attain ed the PM 2.5 

### standard. It includes projected emissions for the attainment year based on a number of different factors. Growth rates for population, employment, and VMT through 2014 were used to estimate 2014 emissions. LRAPA took credit for emissions reductions as a result of the woodstove replacement project implemented during 2009 -2012 that reduced the number of non-certified woodstoves accounted for in the 2008 emission inventory. The attainment year emission inventory is based on 2008 emissions inventory, estimated growth rates and the emission reduction strategies that have recently been put into effect. The emission reduction strategies primarily include the continued implementation (with specific strengthening revisions in some cases) of the existing control measures that have been effective in achieving the PM 10 

### standards and the initial (1997) PM 2.5 

### standards on schedule. The key ongoing control strategies, which were in place prior to 2008, include:

• City ordinance to curtail burning during stagnant weather periods;

• City ordinance requiring the removal of a non-certified wood stoves upon sale of a home;

• City ordinance prohibiting the use of a non-certified wood stove in a residence; and

• Partnering in additional change-out programs to encourage removal of non-certified woodstoves. Details of the ongoing control strategies, strengthened control strategies, and contingency measures are described in the subsequent section on the Oakridge Advisory Committee recommendations.
Economic Factors

### The economy in Oakridge has shifted from logging-based industries to a more recreationoriented model. The decline in the harvesting and processing of timber has left Oakridge with no industrial employer or businesses that support the lumber industry. In the 1990’s, the population in Oakridge declined sharply as jobs disappeared. Current census figures show only modest growth of 1.8% between 2000 and 2010, with the current population at 3,205. Within the civilian labor force, 16% were unemployed in 2010 and 21.7% of all families had incomes below the poverty level. The low cost of living has attracted low-income and unemployed people to Oakridge. The recreation industry has picked up in Oakridge, with mountain biking being very popular. A hostel, brew pub, and other small businesses have opened to support the visitors attracted to the area. Despite the recent business growth, few jobs have been created. Population and employment in Oakridge are expected to increase only modestly over the next 20 years. The population estimate for the year 2025 is 4,000. Any new employment has been assigned to the potential development of the Oakridge Industrial Park.

### November 15, 2012
– Final 27 Growth Rates 

### Growth is expected to be low to moderate in the Oakridge-Westfir area through 2014. Population, housing, and employment forecasts are expected to increase gradually. VMT growth is based on the previous transportation modeling by LCOG in the Highway 58 corridor. The 2014 emission inventory is summarized in Table 4. The calculation procedures are included in Appendix D.

Percent of Total

-- lbs/per day

-- NAA Emissions Typical Season Day Worst

- Case

Day Typical Season

Day Worst

- Case

Day Permitted Point Sources (1) Oakridge Sand & Gravel: Rock crushing operation 1.7 4.0 0.4% 1.1% Oakridge Sand & Gravel: Cement plant 4.3 14.0 0.9% 3.7% Stationary Area Sources Residential Wood Combustion: Fireplace (2) 38.5 29.6 8% 8% Residential Wood Combustion: Non

- Certified Woodstove/Insert (2) 106.1 81.7 22% 21% Residential Wood Combustion: Certified Woodstove/Insert (2) 252.4 194.4 52% 51% Pellet Stoves 7.3 8.0 1% 2% All Other Stationary Area Sources 47.4 4.7 10% 1% On

- Road Sources On

- Road: Exhaust, Brake, Tire 15.7 22.2 3% 6% Re

- Entrained Road Dust 7.1 16.3 1% 4% Nonroad Sources Union Pacific Railroad 6.0 6.0 1% 2% Total, All Sources, lbs/day 486 381 (1) Worst

- case day = Permitted hourly (x24) operating capacity (2) Worst

- case day = Peak Heating Degree Day

Table 4 : 2014 Estimated Typical Season Day and Worst-Case Day PM 2.5 Emissions.


### Comparison of 2008 to 2014 Emissions The emission inventory shows an overall decrease in emissions for the attainment year (2014) based on the effectiveness of the emission control strategies.
The differences in the 2008 and 2014 emission inventories are the combination of increases due growth factors and decreases due to emission control strategies. For example, motor vehicle emissions decreased overall due to progressively cleaner gasoline and diesel fuels and motor vehicles, but part of the emissions decrease was offset by gradual growth in traffic volumes. Industry emissions were conservatively increased to reflect operation at maximum capacity in 2014, but both industrial sources are minor so this did not have a major effect on the 2014 inventory. The most significant category is residential wood-heating; emissions were increased to reflect population growth during 2008-2014, decreased due to non-certified woodstove replacements with cleaner burning units during 2009-2012, and decreased due to improvements in the programs for curtailment during stagnant air episodes. Attainment Strategies

– Emission Reduction Analysis This section describes strategies currently in place or those to be implemented to achieve compliance with the 24 hour PM 2.5 

### standard. These strategies are expected to improve air quality and meet the PM 2.5 

### standard by the required 2014 attainment date. These strategies

### November 15, 2012
– Final 28 

### are also known as Reasonably Available Control Measures (RACM). For large industrial emission sources they are called Reasonably Available Control Technologies (RACT) but currently there are not any large industrial facilities located in the Oakridge-Westfir area. For the Oakridge nonattainment area, the main source of emissions is wood smoke from residential wood combustion, and RACM is applicable to this emission category. The current and proposed emission control strategies are consistent with the RACM requirements for residential wood combustion (EPA-450/2- 89 -015). The RACT / RACM analysis took into account direct PM2.5 and the precursors NOx and SO2 as required by the 2007 implementation rule. Preliminary analysis of the airshed found very little contribution of local sources to secondary sulfate and nitrate relative to direct PM2.5. Since the total local emissions of NOx and SO2 are not a major factor in ambient PM2.5 at the violating monitor, it was a reasonable hypothesis that small changes in that total NOx and SO2 emission budget would be a very minor factor in PM2.5 in Oakridge relative to primary PM2.5 emissions. Thus the attainment model was simplified to not take attainment credit for emission changes in PM2.5 nitrate and sulfate precursors. LRAPA is confident that direct PM2.5 is the cause of (and solution to) PM2.5 nonattainment and that there is little opportunity for reducing PM2.5 through emission reductions of NOx and SO2. Particulate Matter Reduction Strategies (1989

- 20 08 ) The strategies and regulations implemented between 1989 and 20 08 resulted in a reduction of PM 2.5 

### emissions. Projections show implementing and strengthening ongoing strategies will make it possible for the Oakridge area to achieve the standard by 2014. Future strategies are a continuum of past strategies developed over the years that have been adjusted and updated to address the current PM 2.5 

### standard. Local efforts include revisions to the existing Oakridge clean air ordinance, public education, and woodstove change-outs. State and federal regulations recently implemented affect woodstoves and transportation emissions. These strategies are permanent and enforceable; they are currently implemented and enacted by city ordinance, state, or federal rules. There are penalties for violating these ordinances or rules. The Oakridge Air Pollution Control Ordinance #8 89 

### LRAPA and the City of Oakridge initiated a voluntary home wood heating advisory program in 19 89 after air quality data showed Oakridge exceeded the federal PM 10 

### standard on numerous occasions. Five years later, on January 20, 1994, EPA officially declared Oakridge a PM 10 

### nonattainment area. In August of 1996, the City of Oakridge adopted a wood heating curtailment program. A plan to get the area back into attainment with the standards was adopted by EPA in March 1999, and became effective on May 14 th 

### of that year. The Oakridge plan included voluntary measures. On February 20, 2003, the Oakridge City Council revised the home wood heating ordinance that:

• Changed their voluntary curtailment measures to mandatory,

### November 15, 2012
– Final 29 

### • Prohibited burning garbage in woodstoves and fireplaces,

• Incorporated a 40% opacity limit on chimneys,

• Incorporated the PM 2.5 

### standard into the program, and

• Required the removal of uncertified woodstoves from property to be sold or rented. In fall 2007, the City of Oakridge revised its home wood heating ordinance to reflect the tightened PM 2.5 

### standard of 35 μg/m 3



### . The revision changed the concentration levels that trigger the green/yellow/red advisories. A revision to the ordinance in December 2008 included a provision that stated a person or persons may not install or use any solid fuel heating device in any structure within the City except for certified wood stoves or certified pellet stoves with emissions that do not exceed 1.0 grams/hour weighted average tested in conformance with the EPA method, or a fireplace that is not a sole source of heat. LRAPA Advisory Programs 

### Since initiated in 1989, the LRAPA advisory program has provided a daily wood burning advisory for Oakridge. The program is operated by LRAPA in cooperation with the City of Oakridge and local news media. The advisory, issued daily by LRAPA staff during the months of November through February, is determined by comparing current pollution levels to meteorological conditions and weather forecasts. The advisories are displayed daily on the LRAPA website and can be obtained via telephone at a dedicated hotline number. Advisories are broadcast on radio and television and daily in the regional newspaper. An automati c phone “callware” system is activated when a ir quality is deteriorating and long periods of stagnant conditions are forecast. The phone system calls all numbers with the 782 prefix in the Oakridge/Westfir area and leaves a recorded message. (a) The advisory operates using a "green-yellow-red" system as described in the Oakridge City ordinance

. A "green" advisory is issued when PM 2.5 

### levels are forecast by LRAPA to be less than 25 g/m 3 

### , and good smoke dispersion conditions are forecast. "Yellow" advisories are posted when PM 2.5 

### levels are forecast by LRAPA to be equal to or greater than 25 g/m 3 

### , but less than 30 g/m 3 

### , and the forecast is for marginal smoke dispersion conditions. Under this advisory, residents are advised to burn wood sparingly, and only if alternatives are unavailable. A "Red" advisory is posted when PM 2.5 

### levels are forecast to be equal to or greater than 30 g/m 3 

### , and the forecast is for marginal or poor smoke dispersion conditions. During a Red advisory, no person in charge of a property shall operate or allow to be operated a solid fuel heating device which emits visible emissions unless the person has been granted an exemption by the Oakridge City Administrator. Residents with exemptions may use any solid fuel heating device

. Exemptions are based on sole source of heat or economic need. During Stage II Red II advisory, when PM 2.5 

### levels are forecast to be equal to or greater than 35 micrograms per cubic meter no person in charge of property shall operate or allow to be operated a solid fuel burning device unless: the person has been granted an exemption to use the device by the City

### November 15, 2012
– Final 30 

### Administrator; or the person is operating a pellet stove which emits no visible emissions into the air outside of the building housing the device. Open Burning Ordinance 

### On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to allow open backyard burning only during the months of October, March, April, and May and bans the use of burn barrels. Oakridge City Code 92.04.A.2 currently regulates open backyard burning inside the Oakridge city limits. This eliminates burning during wintertime periods of maximum atmospheric stagnation when burning is more likely to contribute to exceedances of the 24-hour PM 2.5 

### standard. The open burning restrictions provide a more protective measure to avoid additional contributions to the particulate levels. Woodstove Change-out Programs 

### Since 1993, LRAPA has administered woodstove change-out programs to help residents replace old, uncertified wood stoves with cleaner burning, more efficient heating systems. This control measure is central to achieving attainment, and will enhance both long- and short-term compliance. The first program conducted in 1993 provided economic incentives for residents to replace old, high polluting woodstoves with alternative heating systems with lower emission rates. These include electric furnaces and heat pumps, oil, gas, pellet stoves, or EPA certified low-emission woodstoves. The initial program was funded by the U.S. EPA, together with support from the Oregon Department of Environmental Quality and LRAPA. The program provided up to $2,500.00 per low- or moderate- income household for installation of approved alternative heat sources, either as no-interest loans or outright grants. Participants were required to certify, in writing, that they disposed of their old stoves, and would not utilize non-approved alternatives in the future. A total of 130 stoves were replaced. In 2005, LRAPA developed the Warm Homes, Clean Air Program for Oakridge. The program is ongoing as funding becomes available. Warm Homes matches Oakridge and Westfir residents with funding from nine partner agencies to help with heating upgrades, weatherization, and home repairs. As part of the program, LRAPA has provided funding for woodstove replacements. During a change-out conducted between 2006 and 2008, 59 uncertified woodstoves were replaced. Table 5 shows a historical view of the Oakridge Wood Stove Change-outs. Oakridge Wood Stove Change

- out Programs

Years 1993

- 96 2006

- 07 # of Stoves 130 59 Table 5: Oakridge Wood Change-out Programs (1993-96/2006- 07)

Statewide Certification of Woodstoves 

### In 1986, the Oregon Legislature required the certification of any woodstove sold in Oregon. This requirement was subsequently adopted by EPA on a national basis in 1990. Additionally,

### November 15, 2012
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### the State Building Code Agency prohibits the installation of uncertified woodstoves. The dual effect of this certification and installation requirement resulted in reducing the amount of wood smoke pollution that used to be emitted from the uncertified stoves

. Highway Road Sanding 

### In an effort to reduce PM 10 

### emissions from road sanding during winter months, the Oregon Department of Transportation (ODOT) signed a letter of agreement regarding using anti-icing agents as an alternative to sand on Highway 58 running through Oakridge. The use of the chemical de-icing compound, calcium magnesium acetate, inhibits ice formation. The practice has resulted in a significant reduction of particulate, however it is not likely to contribute to PM 2.5 

### reductions. Smoke Management 

### By statute, the Oregon Department of Forestry (ODF) is responsible for administering a smoke management program. Smoke from prescribed burning has not significantly impacted the nonattainment area in the past, however, there have been safeguards implemented to prevent unintended smoke impacts to the Oakridge nonattainment area. Oakridge is protected under the Oregon Smoke Management Plan as a smoke sensitive area. This means that all prescribed burning during the year is managed in such a way as to avoid any smoke intrusions into the community. In addition, a Special Protective Zone (SPZ) surrounds Oakridge where additional restrictions apply to prescribed burning within the zone during the winter months (November 15 through February 15). During this time, prescribed burning is allowed only when the ODF smoke management meteorologist determines there would be no measurable smoke within the nonattainment area. Between December 1 and February 15, no prescribed burning is allowed in the SPZ on “red” woodstove days. Between November 15 and February 15, no pile burning is allowed if ODF believes that the piles will produce significant smoke after the third day. Road Paving 

### According to the emissions inventory done prior to 1991, there were about 2.4 miles of unpaved streets in Oakridge. Since then, based on city records, virtually all unpaved roads have been paved, along with numerous unpaved commercial driveways and parking lots. Industrial Requirements 

### Within the designated Oakridge PM 2.5 

### nonattainment area, new major sources and major modifications of a nonattainment pollutant, including PM 2.5 

### precursors SO 2 

### or NO X 

### , are required to meet LAER control technology. Industrial sources must also obtain emission offsets and demonstrate that a net air quality benefit will be achieved. These are the most stringent requirements for industry. In addition, existing sources will be evaluated for RACT and will be required to meet performance standards for certain industry.
Public Education 

### LRAPA has maintained a strong presence on the Oakridge community through public education programs aimed to inform residents and teach school age children about air quality issues. In 2006, LRAPA developed a school flag project for Oakridge Elementary School. LRAPA provides

### November 15, 2012
– Final 32 

### air quality flags that are hung at the entrance to the school, which is located on a main street near downtown Oakridge. The highly visible flags display the current Air Quality Index (AQI) reading for that day. Information on air quality is obtained by students from the LRAPA website. The flags have also been used during periods of bad air quality caused by wildfires. A specialized curriculum was developed by LRAPA public affairs staff for third

– fifth grade students. An LRAPA staff person makes an annual visit to the school in the fall to teach a class on air quality and explain how to use the flags. For over ten years, LRAPA has taught an air quality class at outdoor school, held each May in Oakridge. The class focuses on the science of air pollution and the specific challenges of wood smoke pollution in Oakridge. An average of 75 sixth grade students attends the class each year. Additional Strategies 

### Beginning in the early 90 ’s , LRAPA developed various strategies to reduce and track wood smoke emissions

. LRAPA provided plastic tarps to residents for covering wood piles to keep wood dry. A seasonal worker, hired by LRAPA, conducts drive-by compliance surveys on green, yellow, and red days using pre-established survey routes. Surveys are turned in monthly November- February. Current Strategies 2009-2011 Wood Stove Change-out program 

### The Warm Homes wood stove change-out program continued in 2009. Funding from U.S. EPA helped replace 11 uncertified wood stoves with new heating devices. In October 2010, LRAPA received funds from the American Recovery and Reinvestment Act. LRAPA used the funding to conduct another round of wood stove change-outs in Oakridge and Westfir. The program offered two-tier funding for qualified residents within the non-attainment boundary designated by U.S. EPA. Residents who qualified as low income based on Housing and Urban Development’s (HUD) income guidelines received a full rebate of up to $5,000 to pay for a ductless heat pump, certified wood stove or pellet stove. All other qualified applicants received a rebate of up to $2,000 based on emission reductions. The program ended in December 2011. LRAPA provided rebates to replace 79 stoves. Wood heat was most popular; 56 new wood stoves were installed, 10 pellet stoves, and 13 electric ductless systems. Oakridge Wood Stove Change

- out Programs Years 2009 2010

- 11 # of Stoves 11 79 Table 6 : Oakridge Wood Change-out Programs (2009/2010- 11)

Heat Smart: Stove Removal upon Sale of Home 

### In 2010, a statewide requirement mandating the removal of an uncertified stove at the time of home sale went into effect. This statewide rule closely mirrored the existing requirement in the Oakridge ordinance. Under the rule, all uncertified devices that are on the property being sold (including residences, shops, garages, and outbuildings) must be removed at the time of home

### November 15, 2012
– Final 33 

### sale. The Oregon Heat Smart law requires DEQ to confirm residences where owners removed or changed-out uncertified woodstoves upon home sale. DEQ currently administers the Heat Smart program and tracks submittals of all uncertified removals at the time of home sale. These submittals can be used to estimate the level of compliance in Oakridge and identify any need for additional education or follow-up. DEQ has established in rules, penalties for noncompliance and hopes to conduct periodic enforcement sweeps throughout the state.
Public Education 

### As mentioned earlier in this section, LRAPA has maintained a vigorous public education program in Oakridge. In 2009 -2011, the program was expanded to reach a wider audience. In 2010, LRAPA produced a television commercial to promote compliance with home wood heating advisories and clean burning practices. The commercial has run every fall on three major television networks; all are available to Oakridge viewers. Radio ads targeting open burning and home wood heating have aired on a network of radio stations in Lane County since 2009 . Almost stations all are available in Oakridge. Articles in the weekly newspaper, the Dead Mountain Echo, serving the Oakridge area have been submitted by LRAPA staff periodically to keep the public informed about poor air quality, LRAPA programs, and other topics related to wood smoke. Display advertisements and fliers inserted into the paper are also used to promote high profile projects, the Warm Homes program being an example. Transportation and Fuel-Related Emissions 

### Federal, state and local transportation regulations and programs recently implemented will reduce mobile and non-road emissions. These include:

Federal regulations requiring:

 Reduced sulfur content of gasoline and diesel

 Increased fuel economy Oregon regulations requiring:

 Low emissions vehicles beginning with model year 2009 and newer

 Renewable fuel standard for biodiesel

– 5% Local programs:

 Implementing diesel retrofits of school buses The Transportation Conformity Analysis is included in Appendix K. The Motor Vehicle Emissions Budgets are:

 On -Road Worst Case Day PM 2.5 

### Emissions of 38.5 pounds per day (22.2 pounds per day of exhaust, brake and tire wear, and 16.3 pounds per day of re-entrained road dust); and

 On -Road Worst Case Day NOx Emissions of 562.3 pounds per day.

### November 15, 2012
– Final 34 

### Strengthened Ongoing Strategies in 20 12 -2 014 While the current strategies in place indicate Oakridge will reach attainment with the PM 2.5 

### standard by 2014, to ensure compliance, a number of future strategies were identified by a local advisory committee

. The advisory committee evaluated options for how to improve air quality in Oakridge and suggested potential control measures. With the help of the committee, LRAPA developed a list of strategies to ensure Oakridge meets the 2014 attainment date. Oakridge Air Quality Advisory Committee Strategy Recommendations 

### In July 2011, LRAPA formed an advisory committee in Oakridge to discuss current air quality strategies and explore the feasibility of a number of new strategies identified that would reduce PM 2.5 

### emissions

. They also discussed contingency strategies should Oakridge fail to meet the standard by 2014. While the strategies in place (e.g., City ordinance, LRAPA’s advisory programs, federal and state regulations) indicated the area would meet the standard by 2014, the committee suggested strengthening the strategies to provide a cushion to ensure attainment by 2014. The following strategies are included as part of this plan. Woodstove Change-outs 

### Due to the effectiveness of this strategy in the past, LRAPA will continue to pursue funds to continue offering woodstove change outs within the nonattainment area. Implementation of this strategy may provide substantial reductions in PM 2 .5 

### in the future. LRAPA is not applying any emission credit for this strategy to the 2014 inventory, as it is dependent upon the acquisition of funding which affects the number of stoves replaced. In the most recent round of wood stove change-outs, 75% of the participants qualified as low-income. The poor economy in Oakridge makes it essential any future change-out incentives include grants to cover all of the cost of replacement for low income individuals and substantial (at least 50%) incentives to residents who are not “low income”. Enforcement of Oakridge Ordinance 

### Oakridge Ordinance #889 allows the City to impose a penalty not greater than $500.00 upon anyone who violates City Code related to the use of a solid fuel heating device. Each day’s violation will incur additional fines. At this time, the City of Oakridge has enforcement authority of the ordinance. LRAPA is working with the Oakridge Police Department to strengthen enforcement on Red advisory days. LRAPA has provided a series of door hangers that can be left at a residence with an excessively smoky chimney. The door hangers include language from the City Ordinance, including potential fines for a violation.
Enhancements to Key Ongoing Strategies 

### The Oakridge Advisory Committee identified several strategy enhancements that were felt to be key to the success of the ongoing strategies

. Most of these strategies can be implemented without additional resources.

• Expanded education and outreach, including multiple versions of educational doorhangers that can be distributed to all homes in Oakridge.

• Training and certification of police on smoke reading and opacity limits enforcement.

### November 15, 2012
– Final 35 

### • Enforcement with citations as appropriate for violations of curtailment during pollution episodes, excessive opacity (40%) requirements, operation of non-certified woodstoves, and burning of garbage.

• Ongoing improvements in the air quality forecasting and green-yellow-red advisory programs to ensure that all problem stagnation days are addressed appropriately, which may increase the number of yellow or red days.

• Alternatives to fines payment as appropriate (e.g., attend workshop on clean burning practices, replacement of non-certified woodstove with cleaner burning unit, etc.).

• Use of fines to fund ongoing woodstove replacement program or other emission reduction strategies. Contingency Strategies 

### The following strategies are recommended as contingency strategies to fully meet the air quality standards, if it becomes clear that the strengthened ongoing strategies described above will not be sufficient to attain the PM 2.5 

### standards by 2014 and or to maintain compliance with the standards through 2024 and beyond:

• Stricter opacity limit on all green or yellow advisory days, revising the current 40% opacity limit in the city ordinance to a more restrictive 20% limit, as has been done in some other northwest communities. A 20% opacity limit on green and yellow advisory days will help reduce emissions with the goal of avoiding red advisories when no visible emissions are allowed.

• Stricter green-yellow-red advisory program, with more yellow and red advisory days each winter.

• Further restrictions on city woodstove curtailment exemptions (for sole source, economic hardship).
Industrial Emission Reductions 

### Reasonably Available Control Technology. The two existing industrial sources in the OakridgeWestfir area are minor industrial sources of PM 2.5 

### emissions. The facilities are a portable rock crusher and a ready-mix concrete plant owned and operated by Oakridge Sand & Gravel. These two minor sources together emit less than one ton per year of PM 2.5 

### emissions and contribute less than 1% to the base year emission inventory. These two minor sources are well below the LRAPA significant emission rate (SER) for PM 2.5 

### of 10 tons per year. The air pollution control technology installed on these sources are the standard for the industry and meet RACT requirements. The rock crusher has water-spray controls and the concrete plant has baghouse controls. Even the elimination of the emissions from these two sources would not significantly affect progress to meet the PM 2.5 

### standard. For example, the worst-day PM 2.5 

### concentrations need to be reduced by about one microgram per cubic meter (μg/m 3 

### ) per year in order to meet the PM 2.5 

### standard by 2014 (i.e., reduced from 39.5 μg/m 3 

### in the 2006-2010 baseline period to 35

### November 15, 2012
– Final 36 

### μg/m 3 

### by the 2014 attainment date). The modeled impact of these two sources if operated at maximum permitted production rates in 2014 is much less than one μg/m 3 

### , or much less than the annual progress required by 2014. Further, both of these sources consistently operate well below maximum production rates, especially during the winter months when PM 2.5 

### concentrations are a problem.
Estimated Reductions and Credits for Future Strategies The emission changes between 2008 and 2014 are due to the combination of increases due to growth factors and decreases due to emission control strategies. The most significant category is residential wood-heating; emissions were increased in the 2014 inventory to reflect population growth during 2008-2014, decreased due to non- ce rtified woodstove replacements with cleaner burning units during 2010-2012, and decreased due to 2012 -2013 improvements in the programs for curtailment during stagnant air episodes. The emission decrease due to woodstove replacements was based on the actual number of woodstove replacements documented after the 2008 baseline year. The emission decrease for the more effective woodstove curtailment program is conservatively estimated at a 30% emission reduction on worst winter days as a result of enforcement of the existing city ordinances during stagnant air episodes subsequent to the 2006-2010 baseline period; mandatory curtailment programs in Oregon have historically documented reductions of 50% or more. Traffic volumes are projected to gradually increase in future years but motor vehicle emissions are calculated to decrease overall due to progressively cleaner gasoline and diesel fuels and motor vehicles. Industry emissions were conservatively increased in the inventory to reflect operation at maximum capacity in 2014, but both industrial sources are minor so this did not have a major effect on the 2014 emission inventory. Attainment Demonstration The attainment demonstration shows how Oakridge will meet the PM 2.5 

### standard by 2014 through the implementati on of control measures listed above. LRAPA used a “proportional rollback/rollforward analysis” or rollback model to conduct the analysis. The goal of this section is to demonstrate that future concentrations are less than the NAAQS at the Willamette Activity Center monitor and other unmonitored parts of the designated nonattainment area. Baseline Design Value 

### The demonstration starts with estimating the baseline design value, or baseline concentration, for PM 2.5 

### . The baseline design value is a statistic, expressed as a concentration that describes the PM 2.5 

### levels at the Willamette Activity Center monitor relative to the NAAQS. The procedure for its calculation is presented in Appendix N to 40 CFR 50, “Interpretation of the National Ambient Air Quality Standards for Particulate Matter” and “ EPA Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for O 3 

### , PM 2.5 

### , and Regional Haze”. PM 2.5 

### measurements from 2006 to 2010 are used to calculate the design

### November 15, 2012
– Final 37 

### value of 39.5 μg/m 3 

### (see Table 7). Detailed methods on the baseline design value calculation are in Appendix G.

Year PM 2.5 (μg/m 3 ) 2006 38.6 2007 42.7 2008 38.7 2009 41.3 2010 33.0 Baseline DV 39.5 Table 7: Annual PM 2.5 values used to calculate baseline design value.

Background on Precursors 

### Speciated PM 2.5 

### samples were collected at Willamette Activity Center for the period July 2009- 2011. The samples showed the dominance of organic and elemental carbon, with secondary inorganic aerosol nitrate and sulfate comprising relatively minor concentrations of total PM 2.5 

### . Concern had been expressed about the role of secondary organic aerosols (SOAs) as components of total organic carbon, and an additional analysis was conducted by a research scientist at Portland State University (PSU) in collaboration with ODEQ to better understand the magnitude of these aerosols in the Klamath Falls, Oregon air shed. The results of this analysis showed that the contributions from both biogenic and anthropogenic sources to be minor, less than 1% and 3%, respectively, of total design value PM 2.5 

### . In consultation with EPA, LRAPA chose to adopt these percent contributions as a conservative assumption for the Oakridge NAA demonstration. Because all secondary aerosols were determined to be minor contributors to total PM 2.5 

### , these components and their concentrations are held constant in the rollback model and assigned a Relative Response Factor (RRF) of 1.0, assuming future year precursor concentrations are constant or declining. The precursor emissions to secondary aerosols, including NO X 

### , SO 2 

### , ammonia, and biogenic and anthropogenic VOCs, are not used in the attainment demonstration (LRAPA is utilizing a rollback analysis for the attainment demonstration). In addition to the study of secondary aerosols, a positive matrix factorization (PMF) study based on the speciated data from Willamette Activity Center was conducted by EPA Region 10 to identify likely sources of speciated PM 2.5 

### . The study showed the importance of residential woodsmoke to the high levels of organic carbon, an estimated 70-75% of total PM concentrations. The SANDWICH speciation formulation, based on adjusted and corrected Willamette Activity Center speciation data, is used to speciate the FRM measured design value (DV) for use in the rollback model. The SANDWICH is a profile of the DV with which to describe the components that contribute to PM 2.5 

### exceedances. This profile is shown in Figure 10 , and shows that over 95% of total PM is from organic and elemental carbon with smaller amounts of secondary inorganic aerosols, such as sulfate (1%) and nitrate (0.4%). The SANDWICH analysis, and the

### November 15, 2012
– Final 38 

### PMF study are described in more detail in Appendix E.1 and Appendix E.2

. Based on the evidence cited above, the major sources contributing to nonattainment in Oakridge are considered to be those that emit direct emissions of PM 2.5 

### . As a result, LRAPA has focused its strategies for the attainment demonstration on these sources.

Figure 10 : Speciated Components of PM 2.5 (using SANDWICH analysis)

Speciated Filter Sample Analysis 

### PM 2.5 

### is a mixture and can be divided into major components: mass associated with sulfates, nitrates, ammonium, organic carbon, elemental carbon, particle bound water, and other primary inorganic particulate matter. Percent contribution to the total mass by each of these major components is used to estimate relative contribution by different emission sources. From July 2009 to 2011, LRAPA conducted PM 2.5 

### speciation monitoring at the Willamette Activity Center location. Total PM 2.5 

### mass measurements using the FRM are used mainly to determine attainment or nonattainment of the standard. However, to provide information about particular source contribution to that total mass it was necessary to co-locate a speciation sampler that allows the breakdown of the total mass into different chemical species.
The total mass of PM 2.5 

### using the FRM sampler is not equal to the simple sum of the measured components from the speciation filter, therefore it is necessary to make adjustments to 1% 0.4%

88% 8% 0.03%
3% 

# Oakridge PM 2.5 

# Composition

Sulfate

Nitrate Organic Carbon
Elemental Carbon

Ammonium
Other

### November 15, 2012
– Final 39 

### represent FRM mass. In order to apply the results of the speciated filter analysis to the aerosol mass measurements, EPA Region 10 conducted the Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbonaceous Material Balance Approach (SANDWICH) which is the default method in EPA modeling guidance to define baseline PM 2.5 

### . The SANDWICH approach uses a combination of speciation measurements and modeled estimates to represent FRM PM 2.5 

### measurements. The goal is to reconstruct the measured speciated components so that they add up to the measured FRM PM 2.5 

### mass. Table 8 shows the results as percent contribution by a speciated component (sulfates, nitrates, organic carbon (OC), elemental carbon (EC), ammonia (NH 3 

### ), and other primary particulate (OPP)). Detailed methods of the SANDWICH analysis are included in Appendix E.1.

% Sulfate % Nitrate % OC % EC % Water % NH3 % OPP
1.1 0.4 88.4 7.6 1.4 0.03 1.1 Table 8 : Contribution by speciated components. Results of SANDWICH analysis for the top 25% high concentration winter (Oct-Mar) days.

Minor PM 2.5 Components 

### In addition to the speciated components in Table 8, ODEQ, in partnership with Portland State University, examined contribution by secondary organic aerosols in Klamath Falls, Oregon and found it to be relatively low. Anthropogenic secondary organic aerosols contribute 3% and biogenic 1% to the total measured PM 2.5 

### mass. LRAPA chose to adopt these percent contributions as a conservative assumption for the Oakridge NAA demonstration. Secondary organic aerosols and the other minor components sulfate, nitrate, and background EC and OC are assumed to be constant in rollback modeling. More details about this analysis are included in Appendix E.1. Each source emits a different proportion of OC, EC, and OPP, the three components used to develop a speciated emissions inventory. This proportion, or the speciation profiles, for each source category are taken primarily from EPA SPECIATE 4.2 and 4.3 databases. The following source categories are included in the analysis:

### November 15, 2012
– Final 40 Rollback Model 

### In evaluating the appropriate modeling analysis of PM 2.5 

### for Oakridge, LRAPA considered many different modeling approaches, including rollback and more sophisticated methods such as dispersion modeling. However, both dispersion and receptor are more resource intensive and do not offer substantial improvements in demonstrating attainment under conditions that exist in Oakridge. A rollback model can simulate worst case day conditions when stagnant conditions and slow emissions movement within the nonattainment area occur. Oakridge is particularly well suited for a rollback demonstration because of a) the relatively small area of the NAA, b) the bowl shape of the local airshed and the presence of inversions and low mixing heights during evening hours when measured particulates are highest, c) the very few types of emissions sources in the NAA, with home wood heating devices dominating the emissions. Based on these considerations, LRAPA has chosen a rollback model for the area. The rollback model is based on the assumption that there is a direct correlation between emissions of a pollutant and measured concentrations of that pollutant in the same airshed, and that changes in emissions will result in corresponding changes in concentration. This correlation is used to predict future concentrations based on future emissions. The change in concentrations caused by changes in emissions is represented by the Relative Response Factor (RRF). An RRF less than one indicates a reduction in future concentrations, RRF equal to one indicates no change, and RRF larger than one indicates an increase. RRFs are calculated for each speciated component (EC, OC, and OPP) used in the rollback model. Details of the analysis are presented in Appendix H. The results show a cumulative RRF = 0.696, which indicates a decrease in future concentrations. After the cumulative RRF is applied to the input data for the baseline design value, the results are used to calculate a future design value of 28.2 μg/m 3



### .

Year Baseline DV PM 2.5 (μg/m 3 ) Future DV

PM 2.5 (μg/m 3 ) 2006 38.6 27. 5 2007 42.7 30. 4 2008 38.7 27. 6 2009 41.3 29. 6 2010 33.0 23. 6 

### Design Value 39.5 28. 2

Table 9 : Baseline and Future projected design values


### The future ambient concentration levels are below the NAAQS (35 μg/m 3 

### ) for a 24-hour average and the attainment of the standard is demonstrated with the application of the current strategies in place. The current reduction strategies described earlier in this section lower the emissions enough to meet the NAAQS at the Willamette Activity Center monitor.

### November 15, 2012
– Final 41 Modeled Air Quality Improvements of the Key RWC Strategies 

### The key long-term permanent residential wood combustion (RWC) strategies have been: the woodstove change-out programs replacing uncertified woodstoves with cleaner burning and more efficient home heating units; the Oregon and EPA woodstove certification programs requiring any new woodstoves installed since 1986 to be certified woodstoves; and the Oakridge ordinance and Oregon Heat Smart law requiring removal of uncertified woodstoves upon home sale. These programs have been critical to the significant improvement in Oakridge PM 2.5 

### concentrations during 2005-2011 as outlined in Figures 5 and 6. In addition, the combined emission reduction of these programs will more than offset the growth in population and housing between 2008 and 2014, with a net RWC emission reduction of about 28 lb/day on typical season days and 31 lb/day on worst-case days and reduce future PM 2.5 

### concentrations by 2.1 μg/m 3 

### on worst-case days. The key short-term RWC strategy is a strengthened mandatory curtailment program to reduce fireplace and woodstove emissions by 30% on an average of 20 red days per year (based on the number of days above 30 μg/m 3 

### PM 2.5 

### during 2005-2011). This will reduce RWC emissions by 131 lb/day and reduce future PM 2.5 

### concentrations by 8.7 μg/m 3 

### on worst-case days. Additional details on the modeled air quality improvements due to these emission reductions are included in Appendix H (Rollback Analysis) and Appendix J (Residential Wood Combustion RACM).

Unmonitored Area Analysis 

### The previous section describes the demonstration of attainment at the Willamette Activity Center monitor. In addition, a supplemental analysis was conducted to examine future design values away from the Willamette Activity Center, both within Oakridge and in the neighboring city of Westfir. The unmonitored area analysis is based on a 2002

– 2003 saturation survey of Oakridge, and the 2009-2010 monitoring of Westfir. These monitoring efforts are described in greater detail in Appendix A. The ratio of average concentration at each of these monitors to the average concentration at Willamette Activity Center is applied to the baseline design value at Willamette Activity Center to establish a “baseline” design value fo r each monitor. The same ratio is then applied to the Willamette Activity Center future design value to estimate a future design value for each site. Since there is currently only one small point source in the emissions inventory for Oakridge, a dispersion modeling exercise to estimate source impacts was deemed unnecessary. In both monitoring efforts referenced here, the Willamette Activity Center was the location of the highest observed concentration. Base and future design values for all monitored locations

### November 15, 2012
– Final 42 

### were below the NAAQS, indicating that the Willamette Activity Center concentration is the highest in the area. More detail of the unmonitored area analysis is available in Appendix A. Application of Future Strategies 

### Including current strategies, and strengthening of these strategies, the rollback model shows that the Oakridge non-attainment area will achieve the standard of 35 μg/m3 by 2014. At 28.2 μg/m3, the future design value includes a buffer for potential variation while still meeting the st andard. The Oakridge Advisory Committee developed contingency strategies that are part of the attainment plan and will automatically take effect, if necessary, in order to make continued progress should the area not achieve the standard by 2014. Using these contingency strategies would result in additional emission reductions and consequently could also be used to show further reduction in the attainment demonstration roll back model. At this time, these additional measures do not appear necessary. The results of the rollback at Willamette Activity Center show a cumulative RRF of 0. 70 with current strategies and future strengthening of these strategies recommended by the committee.

Table 10 shows the estimated emissions, and proportional concentrations, based on all current attainment strategies:

Table 10 : Allocation of emissions and modeled concentrations for base and future years.

Contingency Plan 

### The attainment plan must contain contingency measures that would be implemented in the event that the Oakridge nonattainment area fails to meet the standard on or after December 2014. The contingency measures are designed to correct the violation of the PM 2.5 

### standards and be implemented immediately. EPA requires that any contingency measures must equal one year equivalent of reasonable further progress (RFP).

### November 15, 2012
– Final 43 

### In Oakridge, the worst-day PM 2.5 

### concentrations need to be reduced by about one microgram per cubic meter (μg/m 3 

### ) per year in order to meet the PM 2.5 

### standard by 2014 (i.e., reduced from 39.5 μg/m 3 

### in the 2006-2010 baseline period to 35 μg/m 3 

### by the 2014 attainment date). Therefore the RFP requirement in Oakridge would equal about one μg/m 3 

### of further reduction.

The Oakridge PM 2.5 

### attainment plan includes the following strategies as contingency strategies to fully meet the air quality standards, if it becomes clear that the strengthened ongoing strategies described above will not be sufficient to attain the PM 2.5 

### standards by 2014 and or to maintain compliance with the standards through 2024 and beyond:

• Stricter opacity limit, revising the current 40% opacity limit in the city ordinance to a more restrictive 20% limit, as has been done in some other northwest communities.

• Stricter green-yellow-red advisory program, with more yellow and red advisory days each winter.

• Further restrictions on city woodstove curtailment exemptions (for sole source, economic hardship). The most quantifiable and most quickly implemented of these contingency measures would be further strengthening of the mandatory curtailment program by more consistent enforcemen t of the city curtailment ordinance and stricter criteria for expanding the number of yellow and red advisory days. If the standard is not met by 2014, the number of red curtailment days would be increased to an average of 30 days per year (based on the number of days above 25 μg/m 3 

### PM 2.5 

### during 2005-2011) and the frequency of curtailment enforcement (warnings and citations) would be increased accordingly in order to increase the effectiveness of the curtailment to 40% (or to 50% if necessary) on worst case days. As outlined in the earlier section on Attainment Demonstration, a 30% RWC emission reduction from a strengthened mandatory curtailment program is projected to reduce concentrations on worst-case days by about 8.7 μg/m 3 

### in 2014. If the mandatory curtailment program is increased from an average of 20 days per year (based on 30 μg/m 3 

### PM 2.5 

### ) to 30 days per year (based on 25 μg/m 3 

### PM 2.5 

### in the contingency plan) this will further ensure that the full 8.7 μg/m 3 

### is achieved. The contingency measures for stronger enforcement on more red advisory days is expected to increase the curtailment effectiveness.

Using these contingency strategies to increase curtailment effectiveness to 40% is expected to reduce RWC emissions by 44 lb/day and reduce PM 2.5 

### concentrations by an additional 2.9 μg/m 3 

### on worst case days. Using these contingency strategies to increase curtailment effectiveness to 50% is expected to reduce RWC emissions by 87 lb/day and reduce PM 2.5 

### concentrations by 5.8 μg/m 3 

### on worst case days.

### November 15, 2012
– Final 44 

### Either of these contingency measures would more than achieve the one μg/m 3 

### target needed to meet the EPA RFP test. If Oakridge meets the PM 2.5 

### standard by the EPA Clean Air Act 2014 deadline, the contingency plan will not be enacted. If Oakridge does not meet the PM 2.5 

### standard by the EPA Clean Air Act 2014 deadline, the contingency plan will be enacted by the beginning of the immediate next wood-heating season, November 15, 2015. If the high PM 2.5 

### concentration was determined to be an Exceptional Event based on EPA's Exceptional Events Rule, as flagged by ODEQ and concurred by EPA, no further action may be needed.

### November 15, 2012
– Final 45 

## Acknowledgements
Oakridge Advisory Committee LRAPA w ould like to thank the members of the Oakridge Advisory Committee for their efforts in developing the list of strategies aimed at reducing PM 2.5 

### emissions in the community.
Committee Members : James Affa Private Citizen James Coey Private Citizen Rob DeHarpport Private Citizen Herb Hilton Private Citizen Glenn Fortune Oakridge City Council Don Hampton Former Oakridge Mayor Gordon Zimmerman Former Oakridge City Manager John Murray Lane Electric Coop Paul Engelking University of Oregon Chemistry Professor, LRAPA Citizens Advisory

Committee Brian Forge LRAPA Board Member LRAPA Staff Support to Committee : Merlyn Hough Director Tim Sawyer Data Management Coordinator Ralph Johnston Senior Scientist Sally Markos Public Affairs Coordinator
Principal Authors Merlyn Hough LRAPA Director Tim Sawyer LRAPA Data Management Coordinator Sally Markos LRAPA Public Affairs Coordinator Robbye Lanier LRAPA Environmental Technician

Contributors Lane Council of Governments Oregon Department of Transportation Oregon Department of Environmental Quality U.S. Environmental Protection Agency

### Appendix A



## Appendix A - Unmonitored Area Analysis An additional analysis, or unmonitored area analysis (UMAA), was used to evaluate future year DVs in other areas of the NAA. The UMAA was based on a saturation survey conducted by LRAPA between May 2002 and May 2003, and a survey study of the Westfir area performed over the winter of 2009

– 2010. The 2002-2003 study was performed in order to validate the location of the Willamette Activity Center FRM site. This study included five sites within 2 kilometers of the FRM site, along with two collocated reference monitors at the FRM site. Samples were taken every third day over the year. The Willamette Activity Center site measured the highest annual average and highest peak value of all sites in the study. This study is included as an appendix to this demonstration.
The October 2009

–

March 2010 sampling in Westfir, Oregon was performed to measure PM 2.5 

### impacts in the Westfir area. A MiniVol portable air sampler was collocated with the Willamette Activity Center (WAC) FRM, one was placed in the east end of Westfir at the cityhall, and one was collocated with a Nephelometer at the Westridge School. The Westridge School is at the west end of Westfir, at the confluence of the rivers that pass through Oakridge and Westfir. A map of these sites is included below.

Figure 1 2009-2010 Westfir survey site locations.

### Appendix A

This study consisted of 20 sample events, roughly every sixth day, and completed capture rates at all sites was 90% or greater. All samplers used in the study had entrance and exit calibrations using an NIST traceable flow transfer standard. Sampling for this study followed LRAPA’s existing PM 2.5 

### quality assurance and quality control procedures. The Nephelometer collected minute and hourly values over the study period. The Willamette Activity Center measured the highest peak PM 2.5 

### value of 33.1 μg/m3, and the highest study average value of 13.0 μg/m3. The Nephelometer comparison between the Westfir site and the Willamette Activity Center (plot included in the attainment demonstration) shows that Oakridge regularly experiences significantly higher concentrations than the Westfir area. The UMAA was conducted using the survey sampler concentrations from these two studies. The reference survey sampler collocated at the FRM site were used as the basis to calculate a concentration ratio for other survey sites. This ratio of reference site to survey site was applied to the base year concentration to calculate an estimated future year concentration for each survey location. The results of these calculations for each study are included in the table below.

Figure 2 : UMAA calculation table of values.


### For example, the 98 th 

### percentile for site 404 in the 2002-2003 study was 37.2 μg/m3. Calculating the ratio to the reference sampler (401) gives 37.2/55.3 = 0.7. Multiplying this ratio by the rollback base and future year concentrations of 39.5 and 28.2 μg/m3, site 404 has a calculated base year value of 26.6 μg/m3 and a calculated future year of 19.0 μg/m3. A map of the 2002-2003 Oakridge survey sites is provided below as a reference for the site numbers listed here.

### Appendix A

Figure 3 : 2002-2003 Oakridge survey site locations.


### Future year concentration estimates for all survey sites are lower than that of the Willamette Activity Center.

# Oakridge, Oregon PM 2.5 

# Saturation Study

Lane Regional Air Pollution Authority

Monitoring & Data Analysis Section October 2003

## TABLE OF CONTENTS

I. INTRODUCTION ....................................................... 1
II. DESIGN .................................................................. 1
III. RESULTS ................................................................ 3
IV. DISCUSSION AND CONCLUSIONS................................ 8

LIST OF TABLES
1. Saturation site locations ....................................................... 1 2. Laboratory and field error statistics .......................................... 3 3. PM 2.5 

## concentrations in μ g/m 3



## ................................................ 4 4. Data summary ................................................................... 5 5. MiniVol precision data ......................................................... 6 6. MiniVol accuracy data ......................................................... 7

LIST OF FIGURES
1. Oakridge survey site locations ................................................. 2 2. MiniVol precision ............................................................... 6 3. MiniVol accuracy ............................................................... 7

This study was funded, in part, by a supplemental grant from Region 10 of the U.S. Environmental Protection Agency. The following staff members of the Lane Regional Air Pollution Authority’s Monitoring and Data Analysis Section performed this study: Jerry Boyum Lance Giles Gordon Griffin Tim Sawyer Calvin Yoshida

i

## I. INTRODUCTION The Lane Regional Air Pollution Authority (LRAPA) conducted a one year monitoring study for PM 2.5 

### in the city of Oakridge, Oregon. The purpose of this study was to validate the representativeness of a previously established PM 2.5 

### site. The site to be validated was the Willamette Activity Center (WAC) in Oakridge 1 

### . A federal reference method (FRM) PM 2.5 

### sampler at this site determines the fine particulate levels for the Oakridge area. This site must be shown to accurately represent the PM 2.5 

### levels on a neighborhood scale.



## II. DESIGN This was a one year study beginning May 2002 and ending May 2003. A total of seven AirMetrics MiniVol PM 2.5 

### samplers were used. Two MiniVols were collocated at the FRM site to be validated, and three samplers were placed within a two kilometer distance of the FRM site. Two samplers were placed further east in Oakridge to gather data for comparison to a previous PM10 study. Table 1 lists the locations of each survey site. Figure 1 displays these site locations. The sampling was carried out on the E.P.A. 3-day monitoring schedule. The FRM sampler used in this study was a Rupprecht & Patashnick (R&P) Partisol-Plus model 2025.

Table 1. Saturation site locations:
Oakridge Sites
MV401 WAC-A MV405 Commercial St. and Ash St. MV402 WAC-B (collocated) MV406 48284 Hills St.
MV403 Teller Rd., St. Luke’s Church MV407 Jones Rd. and Elgin St.

MV404 W. 1 st 

### St. and Portal Dr.

The MiniVol and FRM samplers were operated with Whatman PTFE 47mm filters, a pure teflon filter. All filters were weighed on a Sartorius MC 5 microbalance. Field and laboratory procedures, including gravimetric analysis of these filters, were performed in accordance with E.P.A. and Oregon Department of Environmental Quality PM 2.5 

### quality assurance plans.

1 Willamette Activity Center E. P.A. ID: 410392013, O.D.E.Q. ID: 2030003

1Figure 1. Oakridge survey site locations.2

### All MiniVols were calibrated before being placed in the field, again within one year, and once more upon completion of study. Each calibration was performed using a National Institute of Standards and Technology (NIST) traceable laminar flow element. Quarterly audits were performed on the MiniVols using NIST traceable transfer standards. MiniVol rotometer set points were determined seasonally using historical temperature and pressure averages for the area. The MiniVols were rotated through the sites regularly to avoid any site bias due to a particular sampler. The FRM sampler underwent annual calibration along with monthly audits, both performed with NIST traceable transfer standards.



## III. RESULTS The sampling began on May 11, 2002 and ended May 30, 2003. The survey samplers were run on the E.P.A. 3-day schedule, however not every run day was observed. Sample days near New Year’s Day were changed to sample on that holiday, when concentrations were expected to be higher. There were 104 possible sampling events for each site. Table 3 is a complete list of all sample events considered in this study. All failures are shown in Table 3 as a missing value. Most failures were due to sampler component or battery failure (67%), operator error (11%), or filter problems or damage (11%). The total capture rate for the MiniVols was 93%. Individual site capture rates are shown in Table 4, along with a general summary of the data. All QA/QC checks of MiniVols and FRMs were within E.P.A. tolerances. Laboratory quality assurance included use of lab blanks and re-weighing 10% of all filters weighed, both pre-sampling and post-sampling. Field blanks were used to determine error in loading and unloading filters, as well as transporting filters. Table 2 shows the statistics regarding these errors. In translating error from mass to μ 

### g/m 3 

### , we assume that each MiniVol ran for 24 hours at 5 LPM, yielding a volume of 7.2 m 3 

### . Further, we assume that the FRM ran for 24 hours at 16.67 LPM, yielding a volume of 24.0 m 3 

### . Combining the re-weigh and lab blank 95% limits, the total laboratory error is 1.0 μ 

### g/m 3 

### for the MiniVol and 0.4 μ 

### g/m 3 

### for the FRM. Considering laboratory and field error together, the total measurable error is 1.3 μ 

### g/m 3 

### for the MiniVol and 0.4 μ 

### g/m 3 

### for the FRM.

Table 2. Laboratory and field error statistics:

n Average difference ( μ g) Standard deviation ( μ g) Maximum difference ( μ g) Upper 95% limit ( μ g) Lower 95% limit ( μ g) MiniVol Re-weighs 210 0.0 1.3 -4.0 2.6 -2.6 MiniVol Lab blanks 103 -0.3 2.6 -8.0 4.7 -5.3 MiniVol Field blanks 27 4.1 3.5 10.0 10.9 -2.8 Total MiniVol error 340 0.2 2.3 10.0 4.8 -4.3

FRM Re-weighs 99 0.0 1.6 6.0 3.2 -3.1 FRM Lab blanks 43 0.2 3.0 9.0 6.2 -5.7 FRM Field blanks 15 3.8 4.1 14.0 11.8 -4.2 Total FRM error 157 0.4 2.6 14.0 5.5 -4.7

3

### Table 3. PM 2.5 

### concentrations in μ 

### g/m 3 

### : Sample

Date WAC FRM MV 401 MV 402 MV 403 MV 404 MV 405 MV 406 MV 407 Sample Date WAC FRM MV 401 MV 402 MV 403 MV 404 MV 405 MV 406 MV 407 05/11/02 14.8 14.4 14.6 8.8 7.1 8.3 8.9 13.2 11/22/02 19.0 23.8 24.0 - 15.3 12.3 - - 05/14/02 6.2 5.7 6.3 4.8 6.0 5.9 5.6 6.4 11/28/02 35.8 35.1 35.7 49.1 34.9 14.8 23.0 25.3 05/17/02 3.6 4.7 4.3 4.1 4.4 4.1 - 5.8 12/04/02 31.3 31.4 31.9 32.7 25.1 19.4 19.5 29.4 05/23/02 4.6 - 4.9 4.0 3.2 2.7 2.4 4.2 12/07/02 26.0 26.8 27.0 29.6 19.2 14.9 18.3 17.3 05/26/02 2.8 3.3 3.9 3.0 4.9 4.1 4.6 3.9 12/10/02 19.4 19.5 19.6 11.8 21.4 9.7 13.3 24.8 05/29/02 1.8 3.1 2.7 3.5 2.4 1.7 3.2 2.8 12/13/02 21.5 11.3 9.9 6.9 10.9 6.0 4.6 12.9 06/01/02 6.2 6.3 - 7.3 7.1 7.3 7.5 7.6 12/19/02 31.5 30.7 31.4 23.2 24.6 16.3 18.7 34.8 06/04/02 3.3 3.0 3.6 3.9 3.1 4.5 3.8 4.2 12/22/02 11.8 13.3 12.7 7.6 15.0 9.1 6.4 10.9 06/07/02 4.1 4.2 4.4 4.6 2.9 4.0 3.5 3.9 12/25/02 16.7 17.1 16.2 - 20.3 11.2 7.7 18.3 06/13/02 7.7 7.7 8.2 7.9 6.3 7.0 7.9 8.1 12/28/02 13.3 - - - - - - - 06/16/02 4.2 4.2 2.9 3.8 4.9 4.4 4.8 5.0 01/01/03 22.9 23.8 25.2 15.4 20.7 8.8 11.3 22.9 06/19/02 3.8 4.7 4.2 4.8 3.4 4.6 5.4 5.4 01/06/03 31.2 29.7 29.1 27.3 22.4 11.8 12.9 - 06/22/02 4.0 4.8 5.7 4.9 5.3 4.6 4.9 5.2 01/09/03 30.0 28.8 29.0 - 35.9 18.2 17.4 25.6 06/25/02 5.2 7.7 8.7 - 5.9 6.9 7.6 6.9 01/12/03 32.4 31.8 - 28.7 31.6 12.2 9.9 27.2 06/28/02 3.1 2.8 3.2 2.9 3.2 3.0 3.2 2.6 01/15/03 16.3 17.4 16.9 18.0 12.9 9.2 10.3 12.1 07/04/02 - - - - - - - - 01/21/03 54.0 53.7 54.2 51.9 41.0 15.9 16.6 47.6 07/10/02 10.5 10.6 11.1 9.9 9.8 9.6 9.8 11.6 01/27/03 - 9.4 9.5 8.9 - 6.7 - 11.6 07/13/02 10.1 10.9 10.0 10.4 9.3 9.6 10.3 10.6 01/30/03 27.0 25.0 24.2 17.3 28.6 18.2 14.8 25.2 07/16/02 6.0 9.0 6.7 6.2 6.9 9.4 7.0 7.3 02/02/03 8.0 8.6 9.3 5.8 7.4 4.6 5.3 9.5 07/22/02 11.3 11.5 11.6 12.5 10.9 - 11.2 14.2 02/05/03 23.1 25.9 24.3 17.0 18.1 11.8 9.7 27.4 07/25/02 7.9 8.7 7.7 8.1 8.1 8.6 9.2 8.1 02/08/03 56.8 55.3 56.1 33.0 14.7 16.7 17.1 41.4 07/31/02 7.6 7.7 8.5 7.9 9.9 9.6 9.1 7.7 02/11/03 45.1 43.5 42.8 - 15.9 15.0 15.4 31.7 08/03/02 5.3 6.3 5.5 6.1 4.9 5.6 6.0 6.6 02/17/03 7.7 8.6 - 8.0 - 6.4 8.3 11.2 08/07/02 13.8 13.0 13.8 14.4 12.2 11.5 13.1 13.6 02/20/03 10.2 10.2 10.1 6.3 10.3 - 4.9 12.5 08/09/02 - 23.0 23.0 24.6 22.6 - 19.0 23.8 02/23/03 9.0 9.2 - 6.9 10.0 3.3 3.0 10.0 08/15/02 7.4 8.7 7.9 6.3 6.4 6.3 5.9 - 02/26/03 37.3 36.3 35.6 - 20.2 14.9 16.0 38.8 08/18/02 5.4 6.3 5.2 6.3 5.8 5.3 6.1 6.3 03/01/03 13.3 11.9 11.6 6.4 10.7 6.1 - 12.1 08/21/02 3.9 5.1 4.9 4.5 4.0 4.5 4.7 4.5 03/04/03 8.6 8.0 - 8.1 9.7 7.5 - 4.6 08/24/02 6.3 7.3 - 6.4 6.1 6.2 6.6 7.4 03/07/03 13.1 12.4 12.0 10.7 11.9 6.9 5.8 11.7 08/27/02 6.2 6.6 6.4 5.9 6.3 6.4 6.6 7.7 03/13/03 11.3 10.7 11.3 7.5 11.2 5.1 4.3 11.5 09/02/02 26.5 26.9 26.1 17.8 37.2 42.3 36.7 33.3 03/16/03 5.4 5.8 5.6 5.4 7.1 5.6 3.6 7.6 09/05/02 9.1 - 10.7 11.6 10.1 10.0 9.1 10.4 03/19/03 11.7 12.1 11.9 9.7 13.5 - 4.4 12.6 09/08/02 4.8 4.6 4.2 4.2 4.2 4.1 3.4 5.0 03/22/03 9.9 10.4 10.9 4.8 8.2 4.3 4.4 12.6 09/11/02 7.5 8.7 7.2 8.1 7.7 7.7 7.4 7.9 03/28/03 6.8 - 7.6 4.9 7.3 - 4.0 8.1 09/14/02 10.6 10.9 10.0 10.6 10.0 11.5 10.4 11.0 04/03/03 6.1 5.9 5.9 6.8 10.2 4.0 3.8 7.2 09/20/02 4.1 3.5 3.5 4.4 4.4 - 4.2 4.9 04/06/03 6.6 6.5 6.6 6.4 7.8 6.7 5.1 9.1 09/26/02 11.5 12.1 11.8 10.8 9.0 10.5 9.2 13.7 04/09/03 2.7 4.1 2.9 3.3 4.4 3.8 2.5 4.0 09/29/02 4.8 5.3 4.8 4.4 4.7 4.5 3.4 6.3 04/12/03 3.1 4.4 6.4 4.6 6.5 4.1 - 4.3 10/02/02 10.4 11.5 10.5 7.0 6.3 5.7 4.4 14.8 04/15/03 3.8 3.0 3.5 4.8 5.2 2.1 2.6 5.0 10/05/02 4.9 5.9 5.9 3.5 4.8 3.8 5.4 6.0 04/18/03 9.5 10.0 9.8 6.3 9.3 7.5 5.9 - 10/11/02 17.5 16.1 16.4 7.1 7.7 4.5 4.3 17.0 04/24/03 4.5 2.2 5.3 4.4 7.0 5.3 3.8 6.6 10/17/02 17.8 17.2 17.9 10.2 7.4 7.5 11.0 11.5 04/27/03 5.8 6.2 6.3 6.0 8.9 5.2 3.2 5.4 10/20/02 15.1 15.2 13.9 9.0 12.7 8.4 10.1 15.7 04/30/03 3.3 3.6 3.3 3.9 4.4 0.7 1.5 3.4 10/23/02 28.6 27.2 27.2 15.7 12.0 11.4 11.6 21.6 05/03/03 5.7 5.6 5.6 6.2 7.8 6.6 5.9 7.9 10/26/02 22.4 21.4 22.1 17.7 16.9 15.0 17.5 22.8 05/06/03 7.3 8.1 8.1 6.6 7.4 7.6 8.0 9.0 10/29/02 18.2 17.8 17.6 14.2 12.6 9.0 7.6 20.3 05/12/03 4.2 3.9 4.3 4.1 3.5 4.9 4.1 4.5 11/04/02 - 58.1 57.1 53.3 25.8 16.2 19.1 34.7 05/15/03 5.3 5.1 6.1 5.4 6.3 5.2 5.4 7.6 11/07/02 10.6 11.2 10.0 7.5 9.5 7.1 7.1 12.5 05/18/03 6.0 6.1 6.2 4.2 6.2 3.5 3.4 5.4 11/10/02 13.6 14.7 16.4 8.9 17.5 7.7 7.6 19.0 05/21/03 8.6 9.3 9.7 8.6 8.5 - 9.0 10.8 11/13/02 16.1 16.0 16.2 15.0 17.3 9.9 8.7 16.7 05/24/03 4.9 5.7 6.4 6.4 6.4 6.0 6.4 5.6 11/16/02 12.4 12.2 12.5 13.3 14.0 11.0 11.3 11.8 05/27/03 4.0 5.3 6.0 6.3 5.6 7.4 8.7 6.9

411/20/02 23.3 23.0 21.3 23.6 15.7 - 16.6 21.3 05/30/03 5.3 6.3 6.4 - 6.6 7.2 7.1 8.0 

### Table 4. Data summary:

n (max 103) Capture rate Annual mean (μ g/m 3 ) Maximum value (μ g/m 3 ) n > 15 μ g/m 3 Site average 1 (μ g/m 3 ) Difference from Site average (%) WAC FRM 100 96% 12.8 56.8 28 - - MV401 (primary) 99 95% 13.6 58.1 29 WAC 13.6 - MV402 (duplicate) 96 92% 13.5 57.1 28 - MV403 95 91% 10.9 53.3 18 - -19.9 MV404 100 96% 11.4 41.0 23 - -16.2 MV405 94 90% 8.3 42.3 8 - -39.0 MV406 96 92% 8.6 36.7 14 - -36.8 MV407 98 94% 13.0 47.6 26 - -4.4

1 Site average represents the arithmetic average of annual mean values for the two collocat ed MiniVols at the FRM site. 

### According to the Code of Federal Regulations 1 

### , collocated measurement pairs where one or both concentrations are 6 μ 

### g/m 3 

### or less may agree relatively poorly. Therefore, the following precision and accuracy calculations use only collocated pairs where both measurements are greater than 6 μ 

### g/m 3



### . Precision statistics for the MiniVols were derived using data obtained from the set of collocated samplers. Table 5 shows the sample data used in a simple linear regression, displayed in Figure 3. Sampler MV401 is considered primary; while collocated sampler MV402 is considered duplicate. The precision results indicate that dur ing this study the concentrations reported by the MiniVols varied less than 1%. Accuracy statistics for the MiniVol as compared to the R&P model 2025 FRM sampler were computed by pairing each collocated MiniVol with the R&P from the FRM site. The data set can be found in Table 6 by looking at the two pairs made up from WAC FRM with MV401 then MV402. The concentrations found using MiniVols were consistently higher than those found using FRM samplers. The accuracy results indicate that during this study the MiniVol reported concentrations approximately 2% higher than the R&P. Figure 4 displays these results. These accuracy results show the MiniVol annual average values are comparable to the R&P annual averages, making the MiniVol a suitable tool for PM 2.5 

### measurement.

1 40 CFR Part 58 Appendix A, Section 5.5
5

### Table 5. MiniVol precision data:
Sample

Date MV 401 MV 402 Diff Sample Date MV 401 MV 402 Diff Sample Date MV 401 MV 402 Diff 05/11/02 14.4 14.6 -0.2 10/26/02 21.4 22.1 -0.7 01/27/03 9.4 9.5 -0.1 06/13/02 7.7 8.2 -0.5 10/29/02 17.8 17.6 0.2 01/30/03 25 24.2 0.8 06/25/02 7.7 8.7 -1.0 11/04/02 58.1 57.1 1.0 02/02/03 8.6 9.3 -0.7 07/10/02 10.6 11.1 -0.5 11/07/02 11.2 10.0 1.2 02/05/03 25.9 24.3 1.6 07/13/02 10.9 10.0 0.9 11/10/02 14.7 16.4 -1.7 02/08/03 55.3 56.1 -0.8 07/16/02 9.0 6.7 2.3 11/13/02 16 16.2 -0.2 02/11/03 43.5 42.8 0.7 07/22/02 11.5 11.6 -0.1 11/16/02 12.2 12.5 -0.3 02/20/03 10.2 10.1 0.1 07/25/02 8.7 7.7 1.0 11/20/02 23 21.3 1.7 02/26/03 36.3 35.6 0.7 07/31/02 7.7 8.5 -0.8 11/22/02 23.8 24 -0.2 03/01/03 11.9 11.6 0.3 08/07/02 13.0 13.8 -0.8 11/28/02 35.1 35.7 -0.6 03/07/03 12.4 12 0.4 08/09/02 23.0 23.0 0.0 12/04/02 31.4 31.9 -0.5 03/13/03 10.7 11.3 -0.6 08/15/02 8.7 7.9 0.8 12/07/02 26.8 27 -0.2 03/19/03 12.1 11.9 0.2 08/27/02 6.6 6.4 0.2 12/10/02 19.5 19.6 -0.1 03/22/03 10.4 10.9 -0.5 09/02/02 26.9 26.1 0.8 12/13/02 11.3 9.9 1.4 04/06/03 6.5 6.6 -0.1 09/11/02 8.7 7.2 1.5 12/19/02 30.7 31.4 -0.7 04/18/03 10 9.8 0.2 09/14/02 10.9 10 0.9 12/22/02 13.3 12.7 0.6 04/27/03 6.2 6.3 -0.1 09/26/02 12.1 11.8 0.3 12/25/02 17.1 16.2 0.9 05/06/03 8.1 8.1 0.0 10/02/02 11.5 10.5 1.0 01/01/03 23.8 25.2 -1.4 05/18/03 6.1 6.2 -0.1 10/11/02 16.1 16.4 -0.3 01/06/03 29.7 29.1 0.6 05/21/03 9.3 9.7 -0.4 10/17/02 17.2 17.9 -0.7 01/09/03 28.8 29 -0.2 05/30/03 6.3 6.4 -0.1 10/20/02 15.2 13.9 1.3 01/15/03 17.4 16.9 0.5 10/23/02 27.2 27.2 0.0 01/21/03 53.7 54.2 -0.5



### Figure 2. MiniVol precision: Regression Line :

0 10 20 30 40 50 60 70Colocated sampler (ug/m3)

0 10 20 30 40 50 60 70 Primary sampler (ug/m3) 

## MiniVol Precision

Primary vs. Colocated 

### y = 1.0021x – 0.1684 r 2 

### = 0.9958
Precision Statistics :
n = 64
Standard deviation: 0.79
Maximum difference: 2.3 Average difference: 0.1

6

## IV. DISCUSSION AND CONCLUSIONS The most straightforward conclusion to be drawn fr om the data presented here is that Oakridge experienced high PM 2.5 

### levels during this study. Several annual averages for samplers within two kilometers of WAC were approaching the 15 μ 

### g/m 3 

### annual standard. During the study the FRM sampler located at the WAC measured three daily exceedances of the 65 μ 

### g/m 3 

### standard. Each of these three days, however, was not on the study’s survey sampler schedule. Analysis of FRM data collected at WAC during the 2002 and 2003 calendar years gives 348 days with valid PM 10 

### and PM 2.5 

### samples. The average of the daily ratios of PM 2.5 

### to PM 10 

### reveals that about 77% of PM 10 

### is PM 2.5 

### . This ratio suggests that it is reasonable to compare results of this study with those of previous Oakridge PM 10 

### studies, in general terms.
PM 10 

### studies were performed in the Oakridge area in 1991 and 1994. The 1991 study included, as did this study, sites in both the eastern half and western half of Oakridge. The 1991 study agreed with the findings here, that eastern Oakr idge has significantly lower particulate levels. “The highest PM 10 

### concentrations collected during the study were located at Sites ... which are in western Oakridge. Most of these sites are south of the railroad tracks ... eastern Oakridge recorded the lowest concentrations.” 1 

### . The 1994 study included only sites in the western half of Oakridge, and determined “Like the 1991 study, the highest concentrations are observed in the western- and southern-most sites.” 2 

### The small geographic size of the Oakridge community, along with the representative population density of southwestern Oakridge indicates the particulate levels of interest occur in this southwestern portion of the community. This further limited geographic area that comprises southwestern Oakridge leaves few options for relocating the FRM PM 2.5 

### site according to EPA site criteria.
These facts lead to the conclusion that the WAC is the best available site to monitor the particulate problem in Oakridge. Further study of Oakridge, especially of the southwestern area, is planned using both survey samplers and a mobile nephelometer.

1 Jacqueline Fern, et al, Lane Regi onal Air Pollution Authority, “OAKRIDGE PM 10 SATURATION STUDY February 8, 1991 – February 28, 1991”, September 1991. 2 Monitoring & Data Analysis Section, Lane Re gional Air Pollution Authority, “Oakridge, Oregon 1994 PM 10 Saturation Monitoring Study”, July, 1995. 8

### Appendix B



## Appendix B

– Meteorology Common Meteorological Conditions During High Particulate Events PM 2.5 

### standard exceedances in Oakridge generally occur on winter days when winds are light and mixing is poor. During these air stagnation events, concentrations can build over several days until weather fronts of sufficient strength to scour the valley occur. The following graphs detail conditions of high PM 2.5 

### levels; periods of calm winds (< 2.0 mph) with stable atmospheric conditions generally marked by strong surface based temperature inversions.

Figure 1: This figure plots over 26,000 values of 1- hour average Nephelometer and Wind Speed. The Nephelometer correlation to PM 2.5 for this site places the daily standard of 35 μg/m 3 at 1.7 (x 10 -4 ) Bscat. This graph demonstrates that significant levels of PM 2.5 occur with calm winds (≤ 2.0 mph).

### Appendix B

Figure 2: A typical winter period of stagnation is displayed above. Each of these six days had measured PM 2.5 values between 36 and 58 μg/m 3 . A positive ‘Del T’ value indicates a temperature inversion between 2 and 10 meters above the surface. There is a clear diurnal pattern with high PM 2.5 occurring at night under low wind speed, temperature inversion conditions.


### Representativeness of Base Year Meteorological Conditions The base year for this attainment demonstration was chosen to be 2008 for a variety of reasons, mostly related to emissions inventory. The meteorology of 2008 is assessed here to ensure that 2008 conditions are generally representative of average conditions over the period 2006 -2011. The Oakridge PM 2.5 

### problem is with the 24-hour standard, and no exceedance of the Annual standard has occurred. Because of this, and the argument above regarding conditions that cause PM problems, only winter months of January, February, November, and December were used in this analysis. The parameters used for this comparison are ambient temperature at two meters above the surface, wind speed at 10 meters, stability as determined by temperature difference between 2 and 10 meters above the surface, and heating degree days. The table below shows these values for the Oakridge monitoring site for the period 2006-2011.

### Appendix B

The following plots show values for these parameters over 2006-2011, along the period average. For this purpose winter is defined as January, February, November, and December of the indicated year.

.s::. c. 3 6 35

3

. 0
2.5

E 2 .0

._.



## ... ::J**~** 1 .5



## ... <II c. lfl 1.0**~** 0 .5

0.0 

### Oakridge Average Winter Temperature, 2006 - 2011

2 006 2 007 2 008 2 009 2 010 2 011
Av e r age T e mp
- 2 006 -2 011 Av g


### Oakridge Average Winter Wind Speed, 2006-2011

2 006 2 007 2 008 2 009 2 010 2 011

- Av e r age Wind S p ee d

- 2 00 6

- 2 011 Av g

### Appendix B

Using these parameters, the meteorology in Oakridge for the 2008 calendar year is representative of the larger time period of 2006-2011.