Kathleen Hartnett White, Chairman 

Larry R. Soward, Commissioner 

Glenn Shankle, Executive Director 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas .by Reducing and Preventing Pollution 

March 22, 2007 

Richard E. Greene, Regional Administrator 

U.S. Environmental Protection Agency- Region 6 

1445 Ross Avenue 

Dallas, Texas 752(]2-2733 

Dear Mayor Greene: 

Docket No. 2006.0229-SIP 

On March 7, 2007, the Texas Commission on Environmental Quality (Commission) adopted a revision to the 

State Implementation Plan (SIP) for the control of ozone air pollution for Victoria County. 

The adopted revision to the ozone SIP includes a ten year maintenance plan for the eight-hour ozone standard, 

consistent with requirements in § 11 0( a)( 1) of the Federal Clean Air Act. 

Enclosed are the proposed revision to the SIP, a public hearing certification, a complete record of the public 

hearing, and the accompanying order. I look forward to your expeditious approval of this SIP revision. 

Sincerely, 

·~~~f!~ Chairman 

KHW/ks 

Enclosures 

cc: The Honorable Rick Perry, Governor of Texas . 

Mr. Zak Covar, Office of Budget, Planning and Policy, Office of the Governor 

Mr. Glenn Shankle, Executive Director, Texas Commission on Environmental Quality 

P.O. Box 13087 • Austin, Texas 78711-3087 • 512/239-1000 • Internet address: www.tceq.state.tx.us 
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

THE STATE OF TEXAS 

COUNTY OF TRAVIS 

This is to certify that the attached are true and correct copies of documents for a revision to the Texas 

State Implementation Plan, adopted on March 7, 2007, pursuant to 40 Code of Federal Regulations (C.P.R.) 

§ 51.104. I am the records administrator for the Air Quality Division of the Texas Commission on 

Environmental Quality (Commission). 

Susana M. Hildebrand, P .E. 

Director, Air Quality Division 

Texas Commission on Environmental Quality 
Texas Commission on 

Environmental Quality 

Public Hearing 

October 17, 2006 

Concerning the Victoria County 

Eight-Hour Ozone Maintenance Plan 

Rule Project No. 2006-023-SIP-NR 
INTRODUCTION 

The Texas Commission on Environmental Quality (commission) held a public hearing in Victoria on 

October 17, 2006, to receive testimony concerning revisions to the state implementation plan (SIP). 

This SIP contains current monitoring data along with an updated emissions inventory and is 

reformatted to conform to the current SIP style used by the commission. 

The comment period closed on October 23, 2006. All testimony and comments have been reviewed 

and seriously considered. This hearing record contains a complete record of the public hearing and 

is divided into the following four sections: 

o Public Notification and Proposal 

o Written and Oral Testimony 

o Evaluation of Testimony 

o Staff Recommendations/Order 

Additional copies of this hearing record are maintained in the TCEQ central office at 12100 Park 35 

Circle, Austin, Texas 78753. For further information, please contact Kathy Singleton at (512) 239-

6098. 
PUBLIC 

NOTIFICATION AND 

PROPOSAL 
PUBLIC NOTIFICATION 

Notification to the public of the proposed revisions was conducted by the following procedures: 

1. Publication of notice of public hearing in the following newspapers on the date listed: 

Victoria Advocate, September 8,2006 

2. Publication of the Public Hearing Notice in the September 22, 2006, issue of the Texas Register 

(31 TexReg 8137). 

3. Correspondence forwarding the notice of public hearing to the following officials and agencies: 

Speaker of the House 

Lieutenant Governor 

Alamo Area Council of Governments 

Capital Area Planning Council 

City of Victoria Planning Department 

Dallas Department of Environmental and Health Services 

Dallas Department of Aviation 

East Texas Council of Governments 

El Paso City-County Health and Environmental District 

El Paso Metropolitan Planning Organization 

Federal Highway Administration 

Fort Worth Environmental Management Department 

Galveston County Health District 

Houston Department of Health and Human S~rvices 

Harris County Public Health and Environmental Services 
North Central Texas Council of Governments 

Houston-Galveston Area Council 

South East Texas Regional Planning Commission 

Texas Department of Transportation 

Texas Transportation Institute 

Arkansas Department of Pollution Control and Ecology 

Louisiana Department of Environmental Quality 

New Mexico Environmental Department 

Oklahoma Department of Environmental Quality 

U.S. Environmental Protection Agency 
Example of Newspaper Classified Ad 

Victoria Advocate, September 8, 2006 

NOTICE OF PUBLIC HEARING 

BY THE TEXAS COMMISSION ON ENVIRONMENTAL ·c.,, __ 

QUALITY ON PROPOSED . 

R EV!SIONS TO THE STATE 

IMPLEMENTATION PLAN 

·The Texas Commission on Envi· 

TOn menta/ ... Qualily, (commission) 

will conduct a. public heanng·•to 

receive .. comments.-'. concernmg 

irevisions)o .the state.-implemen-

'lalion:·jJiari:;(SIP), .under.. the.•re-

' quirements .. ·ofTexas .•Heal I~.• and 

iSafety·c•Code: · •§38Z.01 :r· :and 

;§3B2:prs;·:and .40 Code of.-Fed;. 

oeraJ·;REigi:Jialion,s.']SL102 ·. of ·the 

United~,::states·.-.;,;Environmental 

I'Protiiction ·;.Agency: •r~gulations" 

concerning'SJP.s·,,:·;.>: · .... _:. · :·; 

'•The:proposed revision ,would .inf 

•corporate -•a':plan··:'for. mainte_; 

'nance. otthe eight:hour .. .ozone 

national.:•:oamcient .air. quality 

standards (Ni\AOS) in Victoria 

County .. "Th~. ·proposal contains 

:.results-of an·updated.a~ainme,nt 

emissions inventory,.and technical .. analysis .m ·.support .of :.the 

.projections demonstrating main· 

·tenance 6f;the·eight·hour ozone 

standa'd :\hroogh :.20.14; .a dis• 

· · cus.sion .df •mmitoring ·data demonstrating· .catainment. ·.of · the 

_eig_ht:lJD.:l!:9zcoe'N_Af.OS: .and .a ; il1sc1Jss10n ·•or:11l8.•-con11ngency 

: plan.:/:''"''·.· ··<.,!si~':,:.~; i,.. · '.'A:putilic .hearin((iintlhis .proposal 

· will-:be held 'in<V.ii:toiia; ·Texas. 

::·on:;;.()ctc:Jer :-1?;,.2Q0.6(.al 1 :30 

· p:m:;:at-700 Nain:Ceoter; Room 

204 .. .'The hea11ng cwiJI·:be:struc· 

.tured.;lordhe r-ec~ipLdLoral •.or 

written comments'.iby interested 

·personstlndiliduals: may . pres-

' ent.oral.<satements'when called 

upon' in'-'order :at_.- registration. 

There will be·nJ open discussion 

; during 'the•heanl]g; ·however, .a~ 

:·a,geqcy~;.:staff.:.'member ·:will :be 

·. availableftodixuss'.\he. propos<:!/ 

!::lQ1'[ijiily!es;:pixJr:;:to;the hearing 

and ·will:aiiswer:questions before 

and•after'lhe hearin_g.·' ,.: · . : · .... Persons·:·.with .. disabilihes :who 

i have )oipecial ~communication·· or 

.'O!fter .. ;~accomm~dation . needs 

'wha.:are;:plann,ng:too:attend :the 

hearingcshould\::contactthe: Air 

Ouality.:.DivisiiJn.·:al (512) .239; 

4900.-'Requests'should be made 

as :tar . .-i.ri::adv a nee :as possible, , ._ 

Wntlerrcomments·:may '.be 'submitted'td'Ka\hy 'Singleton, ·Me 

.'206; :Air·;.()ualil~ Division, Oh.iel 

.Engineer's O~tce, ·rexas Com. 

mission ·on' Envtronmenlal Ouali· 

ly, !;'.0: ·Box ·13087;.;'Austtn; 

Texas 787t1'3087; oi' laxed''.to 

(512) .239'5687, All comments 

pertaining to lhe.Victona County 

Eight-Hour .Ozone .Ma1ntenance 

·Plan· should :reference ·Project 

'Number:2006-023-S/P.NR. The 

commenl·period.closes at •5:00 

p;m .. on'.:October.23, 2006. Coptes oUhe:proposed ·siP can be 

'obtained 'tram the commission's 

Web ·_ · .. ·.-site · at 

http :1/www .tceq. state .I r.. us~m p le 

men\ation/air/sto/vic.html. For 

further tnlormation, please con· 

lac! Kathy Stngleton, Air Quality 

~b"rr!{''ng Sectton, (512) 239· 

Issued in Austin, Texas. on September 6, 2006. 

(§47) 
(13) COMPANY: SYP Enterprises, Inc. dba Collins Texaco; DOCKET 

NUMBER: 2005-1548-PST-E; TCEQ ID NUMBER: RN102240249; 

LOCATION: 2000 North Collins Street, Arlington, Tanant County, 

Texas; TYPE OF FACILITY: convenience store with retail sales of 

gasoline; RULES VIOLATED: 30 TAC §334.72, by failing to investigate and report to the TCEQ within 24 hours, a suspected release for 

each incident; 30 TAC §334.50(a)(l)(A), (b)(2), and (b)(2)(A)(i)(III) 

and TWC, §26.3475(a) and (c)(!), by failing to provide a method of 

release detection which is capable of detecting a release from any portion of the UST system, by failing to conduct proper release detection 

for the piping associated with the UST system, and by failing to test 

the leak line detectors on an annual basis for performance and operational reliability; 30 TAC §334.48(c), by failing to properly conduct 

inventory control procedures for all USTs involved in the retail sale 

of petroleum substances used as motor fuel; 30 TAC §334.7(d)(3), by 

failing to provide an amended UST registration to the commission for 

any change or additional information regarding USTs within 30 days 

from the date of the occurrence of the change or addition; 30 TAC 

§ 115.245(2) and THSC, §382.085(b), by failing to verify proper operation of the Stage II equipment at least once every 12 months; and 30 

TAC § 115.242(3), (3)(L), and (9) and THSC, §382.085(b), by failing 

to maintain the Stage II Vapor Recovery System in accordance with the 

California Air Resources Board Executive Order, by failing to have an 

approved Dresser Wayne nozzle type installed, and by failing to have 

the Stage II operating instructions posted at the dispensers; PENALTY: 

$26,550; STAFF ATTORNEY: Mark Curnutt, Litigation Division, MC 

175, (512) 239-0624; REGIONAL OFFICE: Dallas-Fort Worth Regional Office, 2309 Gravel Drive, Fort Worth, Texas 76118-6951, (817) 

588-5800. 

TRD-200605064 

Mary R. Risner 

Director, Litigation Division 

Texas Commission on Environmental Quality 

Filed: September 12, 2006 

+ + + 

Notice of Opportunity to Participate in Pennitting Matters 

A person may request to be added to a mailing list for public notices 

processed through the Office of the Chief Clerk for air, water, and waste 

pennitting activities at the TCEQ. You may request to be added to: 

(I) a pennanent mailing list for a specific applicant name and permit 

number; and/or (2) a permanent mailing list for a specific county or 

counties. 

Note that a request to be added to a mailing list for a specific county will 

resu It in notification of all permitting matters affecting that particular 

county. 

To be added to a mailing list, send us your name and address, clearly 

specifying which mailing list(s) to which you wish to be added. Your 

written request should be sent to the TCEQ, Office of the Chief Clerk, 

Mail Code 105, PO. Box 13087, Austin, TX 78711-3087. 

Public notices issued by the Office of the Chief Clerk are also available 

for viewing at www. tceq.state.tx. us/comm _ exec/cc/cc _ db.html. 

Individual members of the public who wish to inquire about the information contained in this notice, or to inquire about other agency pern1it 

applications or permitting processes, should call the TCEQ Office of 

Public Assistance, Toll Free, at 1-800-687-4040. 

TRD-200605096 

LaDonna Castafiuela 

Chief Clerk 

Texas Commission on Environmental Quality 

Filed: September 13, 2006 

+ + + 

Notice of Public Hearing on Proposed Revisions to the State 

Implementation Plan 

The Texas Commission on Environmental Quality (commission) will 

conduct a public hearing to receive comments concerning revisions to 

the state implementation plan (SIP), under the requirements of Texas 

Health and Safety Code, §382.012 and §382.013; and 40 Code ofFederal Regulations §51.1 02 of the United States Environmental Protection Agency regulations concerning SIPs. 

The proposed revision would incorporate a plan for maintenance of the 

eight-hour ozone national ambient air quality standards (NAAQS) in 

Victoria County. The proposal contains results of an updated attainment emissions inventory and technical analysis in support of the projections demonstrating maintenance of the eight-hour ozone standard 

through 2014; a discussion of monitoring data demonstrating attainment of the eight-hour ozone NAAQS; and a discussion of the contingency plan. 

A public hearing on this proposal will be held in Victoria, Texas, on 

October 17, 2006, at 1:30 p.m., at 700 Main Center, Room 204. The 

hearing will be structured for the receipt of oral or written comments 

by interested persons. Individuals may present oral statements when 

called upon in order of registration. There will be no open discussion 

during the hearing; however, an agency staff member will be available 

to discuss the proposal 30 minutes prior to the hearing and will answer 

questions before and after the hearing. 

Persons with disabilities who have special communication or other accommodation needs who are planning to attend the hearing should contact the Air Quality Division at (512) 239-4900. Requests should be 

made as far in advance as possible. 

Written comments may be submitted to Kathy Singleton, MC 206, 

Air Quality Division, Chief Engineer's Office, Texas Commission on 

Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087, 

or faxed to (512) 239-5687. All comments pertaining to the Victoria 

County Eight-Hour Ozone Maintenance Plan should reference Project 

Number 2006-023-SIP-NR. The comment period closes at 5:00 p.m. 

on October 23, 2006. Copies ofthe proposed SIP can be obtained from 

the commission's Web site at http://www.tceq.state.tx.us/implementation/air/sip/vic.html. For further information, please contact Kathy 

Singleton, Air Quality Planning Section, (512) 239-6098. 

TRD-200605080 

Robert Martinez 

Director, Environmental Law Division 

Texas Commission on Environmental Quality 

Filed: September 12, 2006 

+ + 

Notice of Water Quality Applications 

+ 

The following notices were issued during the period of September 7, 

2006 through September 8, 2006. 

The following require the applicants to publish notice in the newspaper. 

Public comments, requests for public meetings, or requests for a contested case hearing may be submitted to the Office of the Chief Clerk, 

Mail Code 105, P.O. Box 13087, Austin, Texas 78711-3087, WITHIN 

IN ADDITION September 22, 2006 31 TexReg 8137 
Kathleen Hartnett White, Chairman 

Larry R. Soward, Commissioner 

Glenn Shankle, Executive Director 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by Reducing and Preventing Pollution 

NOTICE OF PUBLIC HEARING BY THE 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

ON PROPOSED REVISIONS TO THE STATE IMPLEMENTATION PLAN 

The Texas Commission on Environmental Quality (commission) will conduct a public hearing to receive 

comments concerning revisions to the state implementation plan (SIP), under the requirements of Texas Health 

and Safety Code, §382.012 and §382.013; and 40 Code of Federal Regulations §51.102 of the United States 

Environmental Protection Agency regulations concerning SIPs. 

The proposed revision would incorporate a plan for maintenance of the eight-hour ozone national ambient air 

quality standards (NAAQS) in Victoria County. The proposal contains results of an updated attainment 

emissions inventory and technical analysis in support of the projections demonstrating maintenance of the eighthour ozone standard through 20 14; a discussion of monitoring data demonstrating attainment of the eight-hour 

ozone NAAQS; and a discussion of the contingency plan. 

A public hearing on this proposal will be held in Victoria, Texas, on October 17, 2006, at 1:30 p.m., at 700 Main 

Center, Room 204. The hearing will be structured for the receipt of oral or written comments by interested 

persons. Individuals may present oral statements when called upon in order of registration. There will be no 

open discussion during the hearing; however, an agency staff member will be available to discuss the proposal 

30 minutes prior to the hearing and will answer questions before and after the hearing. 

Persons with disabilities who have special communication or other accommodation needs who are planning to 

attend the hearing should contact the Air Quality Division at (512) 239-4900. Requests should be made as far in 

advance as possible. 

Written comments may be submitted to Kathy Singleton, MC 206, Air Quality Division, Chief Engineer's 

Office, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087, or faxed to 

(512) 239-5687. All comments pertaining to the Victoria County Eight-Hour Ozone Maintenance Plan should 

reference Project Number 2006-023-SIP-NR. The comment period closes at 5:00p.m. on October 23, 2006. 

Copies of the proposed SIP can be obtained from the commission's Web site at 

http://www.tceq.state.tx.us/implementation/air/sip/vic.html. For further information, please contact Kathy 

Singleton, Air Quality Planning Section, (512) 239-6098. 

Issued in Austin, Texas, on September 6, 2006. 

P.O. Box 13087 • Austin, Texas 78711-3087 • 512/239-1000 • Internet address: www.tceq.state.tx.us 
REVISIONS TO THE STATE IMPLEMENTATION PLAN (SIP) 

FOR THE CONTROL OF OZONE AIR POLLUTION 

EIGHT -HOUR OZONE MAINTENANCE PLAN 

FOR THE 

VICTORIA COUNTY OZONE ATTAINMENT AREA 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

P.O. BOX 13087 

AUSTIN, TEXAS 78711-3087 

PROJECT NUMBER 

2006-023-SIP-NR 

Proposed on 

September 6, 2006 
VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

TABLE OF CONTENTS 

Chapter 1: General 

1.1 Background 

1.2 Public Hearing Information 

1.3 Social and Economic Consideration 

1.4 Fiscal and Manpower Resources 

Chapter 2: Attainment Emissions Inventory 

2.1 Overview 

Chapter 3: Maintenance Demonstration 

3.1 General 

3.2 Future Emissions and Verification of Continued Attainment 

3.3 Control Strategies 

3.4 Emissions Summary 

Chapter 4: Monitoring Network 

4.1 General 

Chapter 5: Contingency Plan 

5.1 Background 

5.2 Contingency Measures and Trigger Levels 
Number 

1-1 

2-1 

2-2 

3-1 

3-2 

3-3 

3-4 

3-5 

3-6 

4-1 

VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

LIST OF TABLES 

Table Name 

Public Hearing Schedule for the Victoria County Eight-Hour Ozone Maintenance Plan 

Summary of VOC Emissions in Victoria County by Source Type (2002) 

Summary of NOx Emissions in Victoria County by Source Type (2002) 

Summary of VOC Emissions in Victoria County by Source Type (2004, 2010, and 2014) 

Summary ofNOx Emissions in Victoria County by Source Type (2004, 2010, and 2014) 

MOBILE6 Vehicle Classifications 

On-road Mobile Source, Summer- Weekday Emissions Inventory Summary 

Percentage of VOC Emissions in Victoria County by Source Type 

Percentage ofNOx Emissions in Victoria County by Source Type 

Summary of the Design Value ofCAMS87 from 2000-2005 

11 
VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

LIST OF FIGURES 

Number Figure Name 

3-1 Victoria County VOC Emissions by Major Source Category 

3-2 Victoria County NOx Emissions by Major Source Category 

3-3 Victoria County Total VOC Emissions 

3-4 Victoria County Total NOx Emissions 

111 
Number 

VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

LIST OF APPENDICES 

Appendix Name 

Appendix A Development and Production of On-Road Mobile Source Emissions Inventories for 

Victoria County: 2002, 2004, 2010, and 2014 (available at the public TCEQ FTP site, 

ftp://ftp. tnrcc. state. tx.us/pub/OEP AAIT AD/Modeling/Mobile Ell). 

iv 
VICTORIA EIGHT-HOUR OZONE MAINTENANCE PLAN 

LIST OF ACRONYMS 

CAMS - Continuous Air Monitoring System 

CO - carbon monoxide 

C02 - carbon dioxide 

DLC - Diagnostic Link Connector 

DPS- Texas Department of Public Safety 

EDMS - Emissions and Dispersion Modeling System 

EGAS - Economic Growth Analysis System 

EI - emissions inventory 

EIQ - Emissions Inventory questionnaires 

EPA - Environmental Protection Agency 

FCAA- Federal Clean Air Act 

FR - Federal Register 

FMVECP- Federal Motor Vehicle Emission Control Program 

GloBEIS - Global Biogenic Emissions Inventory System 

HAP - hazardous air pollutant 

HB -House Bill 

IIM - inspection/maintenance 

LIRAP - Low Income Repair Assistance, Retrofit, and Accelerated Vehicle Retirement Program 

MPO - Metropolitan Planning Organization 

MSA - Metropolitan Statistical Area 

NAAQS- National Ambient Air Quality Standards 

NNEM- National Non-Road Emissions Model 

NOx - nitrogen oxides 

OBD - Onboard Diagnostic 

PM - particulate matter 

ppm - parts per million 

ppb - parts per billion 

PSDB - Point Source Data Base 

RVP - Reid Vapor Pressure 

SB - Senate Bill 

SIP - State Implementation Plan 

so2- sulfur dioxide 

SOx - sulfur oxides 

STARS- State of Texas Air Reporting System 

TCEQ- Texas Commission on Environmental Quality (formerly the TNRCC) 

TNRCC- Texas Natural Resource Conservation Commission (renamed the TCEQ) 

tpd - tons per day 

tpy - tons per year 

TSI - Two Speed Idle 

TTl - Texas Transportation Institute 

UAM- urban airshed model 

VMT - vehicle miles traveled 

VOC- volatile organic compounds 

v 
EXECUTIVE SUMMARY 

The U.S. Environmental Protection Agency (EPA) designated and classified areas for the eight-hour 

ozone National Ambient Air Quality Standards (NAAQS) with an effective date of June 15, 2004 (69 FR 

23858). Victoria County was classified attainment for the eight-hour ozone standard. However, in 1990, 

Victoria County was designated nonattainment based on incomplete data for the one-hour ozone standard. 

In July 1994, the Texas Natural Resource Conservation Commission (TNRCC), now the Texas 

Commission on Environmental Quality (TCEQ), submitted a redesignation petition and maintenance plan 

State Implementation Plan (SIP) revision to EPA. On May 8, 1995, EPA redesignated Victoria County as 

attainment of the one-hour ozone standard and required a maintenance plan be submitted in eight years. 

The one-hour maintenance plan was submitted to EPA on February 5, 2003; EPA approved the plan on 

January 3, 2005. 

EPA's Phase I Implementation Rule for the eight-hour ozone standard requires areas like Victoria County 

that were designated as attainment for the eight-hour ozone NAAQS and attainment for the one-hour 

ozone NAAQS with an approved maintenance plan to submit a maintenance plan for the eight-hour ozone 

NAAQS that must be consistent with section 110(a)(l) of the Federal Clean Air Act (FCAA). (69 FR 

23951) 

Under 40-CFR 51.905(a)(3) and ( 4), States must submit section 11 O(a)(l) maintenance plans no later than 

3 years after the effective date of the area's eight-hour ozone NAAQS designation. For Victoria County, 

June 15, 2004, is the effective date, therefore, the section 11 O(a)(l) eight-hour ozone maintenance plan 

must be submitted no later than June 15, 2007. Guidance issued by the EPA on May 20, 2005, further 

specifies that states include the following components in the maintenance plan: 

attainment inventory; 

• maintenance demonstration; 

• ambient air quality monitoring; 

• contingency plan; and 

• verification of continued attainment. 

With this SIP revision, the TCEQ is submitting an eight-hour ozone maintenance plan that will ensure the 

County of Victoria remains in attainment of the eight-hour ozone NAAQS. 

Local governments and other interested parties in the Victoria area want to continue implementing 

programs that have proved effective in maintaining healthy air quality. Further, these entities want to take 

these actions now to assure that the area continues to maintain its attainment status for the eight-hour 

ozone standard. The maintenance plan continues to provide the appropriate mechanism for achieving 

these goals and allows individual communities the flexibility to pursue emission reduction strategies most 

appropriate for their circumstances. 

ES-1 
CHAPTER 1: GENERAL 

1.1 BACKGROUND 

1.1.1 Purpose of Plan 

The purpose of this State Implementation Plan (SIP) revision is to submit an eight-hour ozone 

maintenance plan that will ensure Victoria County remains in attainment of the eight-hour ozone 

standard. In addition, the Texas Commission on Environmental Quality (TCEQ) is submitting 

evidence showing that Victoria County is measuring ozone concentration well below 125 ppb, the 

basis for the former one-hour standard. 

1.1.2 One-Hour Ozone History in Victoria 

Victoria County was originally designated nonattainment for ozone in the Federal Register dated 

March 3, 1978 (43 FR 8962). This designation was based on six weeks of EPA contractorcollected data at two sites from September 24, 1977 to November 7, 1977. EPA changed the onehour ozone standard to 0.12 parts per million (ppm) in January 1979. Victoria County ozone data 

was re-examined under the new standard and EPA determined that the Victoria County had 

exceeded the new standard on one occasion. 

The FCAA Amendments of 1990 authorized EPA to designate areas failing to meet the ozone 

NAAQS as nonattainment and to classify them according to severity. Victoria County was 

designated as an "Incomplete or No Data Ozone Nonattainment Area" on November 15, 1990, 

and the county retained its prior ozone nonattainment designation by operation oflaw. The 

FCAA Amendments required unclassifiable nonattainment areas with incomplete or no data to 

collect three consecutive years of monitored data and to reach attainment by November 15, 1995. 

Victoria County completed three consecutive years of monitoring on May 2, 1994, with a design 

value of 0.10 ppm, below the 0.12 ppm standard. 

The general elements required for maintenance plans in incomplete data areas, such as Victoria 

County, were stated in a May 17, 1994, EPA letter from Dr. A. Stanley Meiburg, EPA Region 6 

Director of the Air, Pesticides, and Toxics Division to Ms. Beverly Hartsock, Deputy Executive 

Director, Office of Air Quality, TNRCC. The letter stated that incomplete data areas with ozone 

design values which are less than 85% ofthe ozone standard can be provided with relief from 

certain maintenance plan requirements. Eighty-five percent of the ozone standard is 0.106 ppm, 

so Victoria County qualified for relief. On July 27, 1994, TCEQ submitted a redesignation 

petition and maintenance plan SIP revision to EPA. On May 8, 1995, EPA redesignated Victoria 

County as attainment of the 1-hour ozone standard. 

The FCAA, Section 175A(b) requires the state to submit a subsequent maintenance plan eight 

years after redesignation. The eight-year deadline for submittal was May 8, 2003. The state 

adopted a maintenance plan on February 5, 2003, and submitted the plan to EPA on February 18, 

2003. EPA approved the maintenance plan revision on January 3, 2005. 

1.1.3 Eight-hour Ozone in Victoria 

EPA's Phase I Implementation Rule requires areas like Victoria County to submit a maintenance 

plan for the eight-hour ozone NAAQS that must be consistent with section 110(a)(l) of the 

FCAA. (69 FR 23951) Under 40-CFR 51.905(a)(3) and (4), States must submit section 110(a)(1) 

maintenance plans no later than three years after the effective date of the area's eight-hour ozone 

NAAQS designation. June 15, 2004, is the effective date of eight-hour ozone designations, 

therefore, the section 110(a)(l) eight-hour ozone maintenance plan must be submitted no later 

than June 15, 2007. 

1-1 
1.1.3.1 Maintenance Plan Components 

EPA-issued guidance1 specifies that states must include the following components in the 

maintenance plan: 

• Attainment inventory; 

• Maintenance demonstration; 

• Ambient air quality monitoring; 

• Contingency plan; and 

• Verification of continued attainment. 

1.2 PUBLIC HEARING INFORMATION 

The commission will hold a public hearing at the following time and location: 

Table 1-1: Public Hearing Schedule for Victoria County Eight-Hour Ozone Maintenance 

Plan 

October 17, 2006 1:30 p.m. Victoria 

A question and answer session will be held 30 minutes prior to the hearing. Written comments 

will also be accepted via mail, fax, or e-mail. Written comments must be submitted to the TCEQ 

by 5:00p.m. on October 23, 2006, or in person at the October 17, 2006, public hearing. 

Comments may be submitted to Kathy Singleton, SIP Coordinator, MC 206, Air Quality Planning 

and Implementation Division, Texas Commission on Environmental Quality, P.O. Box 13087, 

Austin, Texas 78711-3087; faxed to (512) 239-5687. Comments must be received by 5:00p.m., 

October 23, 2006. Copies of the proposed SIP revision can be obtained from the TCEQ's web 

site at http://www.tceg.state.tx.us/implementation/air/sip/vic.html. 

1.3 SOCIAL AND ECONOMIC CONSIDERATIONS 

This revision is a continuation of the existing maintenance plan as required by the FCAA and no 

new control strategies have been incorporated into this revision. Therefore, there are no 

additional social or economic costs associated with this revision. 

1.4 FISCAL AND MANPOWER RESOURCES 

The state has determined that its fiscal and manpower resources are adequate and will not be 

adversely affected through implementation of this plan. 

1 EPA Memorandum: Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under 

Section 11 O(a)(1) of Clean Air Act; (May 20, 2005) 

1-2 
CHAPTER 2: ATTAINMENT INVENTORY 

2.1 OVERVIEW 

The attainment inventory is based on the VOC and NOx emissions of an actual typical summer 

day. 2002 is the attainment emission inventory base year. The 1990 Amendments to the FCAA 

require that Emissions Inventories (EI) be prepared for ozone nonattainment areas. Because 

ozone is photochemically produced in the atmosphere when VOCs are mixed with NOx in the 

presence of sunlight, the TCEQ must compile information on the sources of these precursor 

pollutants. EI must identify the source types present in an area, the amount of each pollutant 

emitted, and the types of processes and control devices employed at stationary sources or other 

source categories. The EI provides data for a variety of air quality planning tasks, including 

establishing baseline emission levels, calculating reduction targets, control strategy development 

for achieving the required emission reductions, emission inputs into air quality simulation 

models, and tracking actual emission reductions against the established emissions growth and 

control budgets. The total inventory of emissions ofVOC and NOx for an area is summarized 

from the estimates developed for four general categories of emissions sources, which are each 

explained in Sections 3.2.1- 3.2.4. Summaries of2002 VOC and NOx emissions by source type 

are provided in Table 2-1, Summary of VOC Emissions in Victoria County by Source Type and 

Table 2-2, Summary of NOx Emissions in Victoria County by Source Type. 

Table 2-1: Summary of VOC Emissions in Victoria County by Source Type 

Eight-Hour Ozone Maintenance Evaluation Year 2002 

VOC (tons per average ozone season day) 

Source Category Evaluation Year 

2002 

Area 6.28 

On-road Mobile 3.29 

Non-road Mobile 1.21 

Point 2.60 

Total 13.38 

2-1 
Table 2-2: Summary of NOx Emissions in Victoria County by Source Type 

Eight-Hour Ozone Maintenance Evaluation Year 2002 

NOx (tons per average ozone season day) 

' ' ',, '' Evaluation Year ' Sour.se Cat~g~n"Y, ,,, ' ,,,,, 

" 'i'' • 

2002 

' 

,, 

Area 2.56 

On-road Mobile 11.26 

Non-road Mobile 2.23 

Point 13.00 

Total 29.05 

2-2 
CHAPTER 3: MAINTENANCE DEMONSTRATION 

3.1 GENERAL 

The maintenance plan must demonstrate that the Victoria County area will remain in attainment of the 

eight-hour ozone standard for the 10-year period following the date of designation. The maintenance 

demonstration is satisfied if the state demonstrates that future VOC and NOx emission levels are not 

expected to result in exceedances of the NAAQS. The effective date for Victoria County's attainment 

designation was June 15, 2004, meaning maintenance must be demonstrated through 2014. 

3.2 FUTURE EMISSIONS AND VERIFICATION OF CONTINUED ATTAINMENT 

In order to track the progress of the maintenance plan, the TCEQ will continue to periodically update the 

EI. In addition to the EI for 2002, and the last year of the maintenance plan, 20 14, interim years of 2004 

and 2010 were selected to show a trend analysis for maintenance of the eight-hour ozone NAAQS. 

Tables 3-1, Summary of VOC Emissions in Victoria County by Source Type and 3-2, Summary of NOr 

Emissions in Victoria County by Source Type depict the Eis that will be used to compare against 2002, to 

ensure compliance with the eight-hour ozone NAAQS. The trend analysis shows an overall decrease in 

NO" and VOC emissions for Victoria County and thus shows continued attainment through the end of the 

10-year period following designation under the eight-hour standard. 

Table 3-1: Summary of VOC Emissions in Victoria County by Source Type 

Eight-Hour Ozone Maintenance Evaluation Years 2004, 2010, and 2014 

VOC (tons per average ozone season day) 

Source Category Evaluation Year 

2004 2010 2014 

Area 6.31 6.85 7.23 

On-road Mobile 2.71 1.78 1.40 

Non-road Mobile 1.00 0.64 0.57 

Point 3.10 3.30 3.60 

Total 13.12 12.57 12.8 

3-1 
Table 3-2: Summary of NOxEmissions in Victoria County by Source Type 

Eight-Hour Ozone Maintenance Evaluation Years 2004, 2010, and 2014 

NOx (tons per average ozone season day) 

Area 2.65 2.90 3.07 

On-road Mobile 9.72 4.86 2.90 

Non-road Mobile 2.02 1.77 1.51 

Point 15.00 16.00 17.00 

Total 29.39 25.53 24.48 

3.2.1 Stationary Point Sources 

Major point source emissions and industrial process operating data are collected annually from sites that 

meet the reporting requirements of 30 Texas Administrative Code 101.10. 

To collect emissions and industrial process operating data for these plants, the TCEQ mails Emissions 

Inventory Questionnaires (EIQs) to all sources identified as meeting reporting requirements. Companies 

are required to report not only emissions data for all emission generating units and emission points, but 

also the type and, for a representative sample of sources, the calculations used to determine the emissions 

reported. Information is also requested in the EIQ are process equipment descriptions, operation 

schedules, emissions control devices currently in use, abatement device control efficiency, and stack 

parameters such as location, height, and exhaust gas flow rate. All data submitted via the EIQ is then 

subjected to quality assurance procedures and entered into an electronic data base. Additional information 

is available upon request from the Industrial Emissions and Assessment Section of the TCEQ's Air 

Quality Planning and Implementation Division. The future years 2004, 2010, and 2014 Els for area 

sources were compiled using the Economic Growth Analysis System (EGAS) growth factors. The EGAS 

contains individual growth factors for each category and for each forecasting year. 

3.2.2 Area Sources 

Area sources of emissions are those that fall below the point source reporting levels and that are too 

numerous or too small to identify individually. Area sources are commercial, small-scale industrial, and 

residential categories that use materials or operate processes that generate emissions. Area sources are 

divided into two groups characterized by the emission mechanism: hydrocarbon evaporative emissions or 

fuel combustion emissions. Examples of hydrocarbon evaporative emission sources include: printing 

operations, industrial coatings, degreasing solvents, house paints, leaking underground storage tanks, and 

gasoline service station underground tank filling and vehicle refueling operations. Fuel combustion 

emission sources include stationary source fossil fuel combustion at residences and businesses, vehicle or 

equipment operations, outdoor burning, structural fires, and wildfires. 

3-2 
Emissions calculations of area sources are estimated as county-wide totals rather than as individual source 

emissions. These emissions, with some exceptions, may be calculated by multiplication of an established, 

EPA approved, emission factor (emissions per unit of activity) by the appropriate activity or activity 

surrogate responsible for generating emissions. Actual activity data is used when available. Examples 

include gallons of gasoline sold in a county, amount of printer ink used, number of wildfire acres burned, 

and amount of oil and natural gas produced. When actual activity data is unavailable, surrogates are used. 

These include total county population and employment data by industry type. Often actual activity data is 

available only at the state or national level and must be adapted to the county level using an appropriate 

surrogate. 

The 2002 Periodic Emissions Inventory (PEl) was the starting point for the area source 2002 El for 

Victoria County. PEl categories and emissions were reviewed and subsequently updated with current 

methodologies and local activity data when it was available. Major efforts were made to locate 

appropriate activity data. Specific categories were updated usinginformation and data that represent 

2002 activities. For other categories emissions were grown from the 1999 El to 2002. The EPA's EGAS 

growth factors were used for growing these categories. Use of these various methodologies resulted in 

the 2002 area source EI being compiled from several sources of data, including work from various 

contracts, TCEQ research, and the EPA's National Emissions Inventory. 

For those area source categories affected by TCEQ rules, rule effectiveness factors were applied to the 

baseline or uncontrolled emissions. These factors address the efficiency of the controls and the 

percentage of the category's population affected by the rule. The area source Els for future years 2004, 

2010, and 20 14 were compiled using the EGAS growth factors. The EGAS contains individual growth 

factors for each category and for each forecasting year. This is the EPA standard and accepted method 

for developing future year Els. 

Quality assurance of area source emissions involves ensuring that the activity data used for each separate 

category is current and valid. Data such as current population figures, fuel usage, and material usage 

were updated and EPA guidance on emission factors was used. Other routine efforts such as checking 

calculations for errors and conducting reasonableness and completeness checks were implemented. 

3.2.3 Non-Road Mobile Sources 

Non-road mobile categories include aircraft, railroad locomotives, recreational vehicles and boats, and a 

broad range of equipment from 600-horsepower engines in the construction equipment class to onehorsepower string trimmers in the lawn and garden class. For all non-road mobile categories except 

aircraft, locomotives, and commercial marine vessels the EPA NON-ROAD model is used to calculate 

em1sswns. This model generates emissions for over 200 individual types of equipment for the following 

classes: 

• Agricultural 

• Commercial 

• Construction 

• Industrial/Oilfield 

• Lawn and Garden 

• Logging 

• Railway Maintenance 

• Recreational 

3-3 
• Recreational Marine 

Activity data in the NON-ROAD model used to calculate emissions include the equipment count, 

horsepower ranges, and fuel types. The model produces emissions for every county in the state, using 

default activity data pro-rated from national data to the state and county levels using appropriate 

surrogates. Operating the model with all the default surrogates in place is acceptable, however, EPA 

encourages states to update the model with local, county-level data based on surveys and other relevant 

information. Local, county-level data is incorporated into the NON-ROAD model as it becomes available 

to the TCEQ. 

The latest NON-ROAD model, version 2004, was used to develop the Victoria County 2002 non-road EI. 

Recent surveys and local data have improvedTexas' use of the model. Improvements to the following 

classes include the major VOC and NOx non-road mobile categories: construction, lawn and garden, 

oilfield, and recreational marine. 

Emissions from commercial and military aircraft are calculated using the Emissions and Dispersion 

Modeling System (EDMS) model which uses actual recorded landing/takeoff (LTO) data and aircraft 

types to generate emissions. Smaller aircraft emissions are calculated using EPA emission factors and 

applicable LTO data. 

Emissions from locomotives are based on fuel use and track mileage. Individual railroad lines were 

surveyed for actual data to use in emissions calculation. These surveys and discussions with the railroad 

lines are ongoing with the intent to continue to improve the locomotive EI. 

The future years 2004, 2010, and 2014 Els for non-road mobile sources were also developed by the NONROAD model. The model produces future year Eis routinely, and the most recent version contains future 

estimated activities and rules that will have an effect on the emissions, Projected LTO data was used to 

develop the future years for aircraft and ground support Eis, and railroad activity was projected to future 

years using previous year surveys and data collected from the railroad lines. 

Quality assurance procedures for non-road mobile source emissions rely mainly upon the quality of data 

used for each separate category. Data such as local equipment population figures and fuel usage routinely 

change annually. Sources of this information were contacted during the inventory development for 

updates. Using the current EPA NON-ROAD and EDMS models ensures that updates to equipment 

types, horsepower ranges, and results from applicable rules are applied to the emissions. Other routine 

efforts such as checking calculations for errors and conducting reasonableness and completeness checks 

were implemented. 

3.2.4 On-Road Mobile Sources 

On-road mobile sources consist of automobiles, trucks, motorcycles, and other motor vehicles traveling 

on public roadways. Combustion-related emissions are estimated for vehicle engine exhaust, and 

evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources on 

the vehicle. The vehicle types are distributed into calculation bins based upon fuel usage (gasoline and 

diesel), vehicle weight, and vehicle emission standard classifications (cars, light trucks, and heavy trucks). 

The resulting twenty-eight vehicle types are summarized in Table 3-3, MOBILE6 Vehicle Classifications. 

3-4 
Table 3-3: MOBILE6 Vehicle Classifications 

Number Abbreviation Vehicle Clitssification Description 

< 1 LDGV Light-Duty Gasoline Vehicles (Passenger Cars) 

2 LDGT1 Light-Duty Gasoline Trucks 1 (0-6 000 lbs. GVWR, 0-3 750 lbs. L VW) 

3 LDGT2 Light-Duty Gasoline Trucks 2 (0-6,000 lbs. GVWR, 3,751-5,750 lbs. LVW) 

4 LDGT3 Light-Duty Gasoline Trucks 3 (6,001-8,500 lbs. GVWR, 0-5,750 lbs. 

ALVW) 

5 LDGT4 Light-Duty Gasoline Trucks 4 (6,001-8,500 lbs. GVWR, greater than 5,751 

lbs. ALVW) 

6 HDGV2b Class 2b Heavy-Duty Gasoline Vehicles (8,501-10,000 lbs. GVWR) 

7 HDGV3 Class 3 Heavy-Duty Gasoline Vehicles (10,001-14,000 lbs. GVWR) 

8 HDGV4 Class 4 Heavy-Duty Gasoline Vehicles (14,001-16,000 lbs. GVWR) 

9 HDGV5 Class 5 Heavy-Duty Gasoline Vehicles (16,001-19,500 lbs. GVWR) 

10 HDGV6 Class 6 Heavy-Duty Gasoline Vehicles (19,501-26,000 lbs. GVWR) 

11 HDGV7 Class 7 Heavy-Duty Gasoline Vehicles (26,001-33,000 lbs. GVWR) 

12 HDGV8a Class 8a Heavy-Duty Gasoline Vehicles (33,001-60,000 lbs. GVWR) 

13 HDGV8b Class 8b Heavy-Duty Gasoline Vehicles (>60,000 lbs. GVWR) 

14 LDDV Light-Duty Diesel Vehicles (Passenger Cars) 

15 LDDT12 Light-Duty Diesel Trucks land 2 (0-6,000 lbs. GVWR) 

16 HDDV2b Class 2b Heavy-Duty Diesel Vehicles (8,501-10,000 lbs. GVWR) 

17 HDDV3 Class 3 Heavy-Duty Diesel Vehicles (10,001-14,000 lbs. GVWR) 

18 HDDV4 Class 4 Heavy-Duty Diesel Vehicles (14,001-16,000 lbs. GVWR) 

19 HDDVS Class 5 Heavy-Duty Diesel Vehicles (16,001-19,500 lbs. GVWR) 

20 HDDV6 Class 6 Heavy-Duty Diesel Vehicles (19,501-26,000 lbs. GVWR) 

21 HDDV7 Class 7 Heavy-Duty Diesel Vehicles (26,001-33,000 lbs. GVWR) 

22 HDDV8a Class 8a Heavy-Duty Diesel Vehicles (33,001-60,000 lbs. GVWR) 

23 HDDV8b Class 8b Heavy-Duty Diesel Vehicles (>60,000 lbs. GVWR) 

24 MC Motorcycles (Gasoline) 

25 HDGB Gasoline Buses (School, Transit and Urban) 

26 HDDBT Diesel Transit and Urban Buses 

27 HDDBS Diesel School Buses 

28 LDDT34 Light-Duty Diesel Trucks 3 and 4 (6,001-8,500 lbs. GVWR) 

To estimate emissions from the twenty-eight vehicle types, an emission rate per unit activity, 

emission factor, and the activity level for each vehicle type must be determined. Both the 

emission factors and the activity level for on-road mobile vehicles may be estimated at various 

levels of temporal and spatial specificity. The level of specificity is generally determined based 

upon the final use of the inventory. Since the primary use of the Victoria County inventory is to 

confirm future emission level trends and n~ particular photochemical modeling will be performed 

using the inventories, they were developed spatially at the county-wide level of detail using 

HPMS facility types rather than a roadway link network. The activity was temporally allocated to 

hourly time periods for purposes of speed calculation and emission estimations. The emission 

factors were developed using the newest version ofEPA's on-road mobile emission factor model, 

MOBILE6.2.03, released November 2003. To the extent that local data was available, inputs to 

MOBILE6.2.03 were modified to reflect those inputs. For the Victoria County inventories, 

3-5 
information concerning local fuel parameters, meteorological conditions, and fleet characteristics 

were obtained and processed for input into MOBILE6.2.03. All inventory development methods 

used are consistent with the EPA guidelines for development of on-road mobile source 

inventories for use in SIPs. 

The Victoria County on-road mobile source emission inventories were developed under a TCEQ 

contract with the Texas Transportation Institute (TTl). A summary of the emission inventory 

development results is presented in Table 3-4, Victoria County Eight-Hour Ozone Maintenance 

SIP. The final contract report documenting all activities performed to develop the inventories and 

the emission results is provided as Appendix A: Development and Production of On-road Mobile 

Source Emissions Inventories for Victoria County: 2002, 2004, 2010, and 2014. All electronic 

files associated with the inventory development and results are available at the public TCEQ FTP 

site, 

ftp://ftp.tnrcc.state.tx.us!pub!OEPAAITAD/Modeling/Mobile_EII. 

Table 3-4: Victoria County Eight-Hour Ozone Maintenance SIP 

On-Road Mobile Source, Summer-Weekday1 Emissions Inventory Summary 

Year VMT. Speed voc NOx. 

(miles/day) (mph}_ (tons/day) 

2002 2,633,141 39.2 3.29 11.26 

2004 2,581,761 39.5 2.71 9.72 

2010 2,800,537 39.3 1.78 4.86 

2014 2,951,083 39.2 1.40 2.90 

1 Based on average June through August, Monday through Friday activity estimates and average 

June through August2002 VIctoria Regional Airport meteorological data. 

Source: Development and Production of On-road Mobile Source Emissions Inventories for 

Victoria County: 2002, 2004, 2010, and 2014, Texas Transportation Institute, October 2005 

3.2.5 Biogenic Sources 

Biogenic sources include pine and oak forests, crops, and lawn grass that produce VOC emissions 

such as isoprene, monoterpene, and alpha-pinene. In addition, nitric oxide emissions are 

produced by soils. EPA, using the latest Biogenic Emissions Inventory System (BEIS) model, 

provided the 2002 biogenic EI to the states. Data used in the model includes vegetation types and 

land use from satellite imaging, field biomass surveys, and emission factors for plant species. 

EPA guidance excludes biogenic emissions from the baseline and future inventories, and thus this 

submittal does not consider biogenics. However, biogenic emissions are necessary to determine 

the overall emissions profile of an area and therefore are required for air quality modeling. 

3.3 CONTROL STRATEGIES 

To address the significant air quality concerns under the one-hour ozone NAAQS and the 

potential challenges imposed by the eight-hour ozone NAAQS, Texas and EPA have developed 

strategies to reduce NOx and VOC emissions. These strategies will help reduce ozone levels in 

the Victoria area. The following are descriptions of some of the strategies. 

3-6 
3.3.1 National Low Emission Vehicle Program 

Automobile manufacturers made a commitment through the NLEV program to introduce cleaner 

cars. This commitment along with improvements in gasoline quality, combined with the 

advanced vehicle technology, should assist areas in achieving their overall air quality goals by 

reducing NOx emissions. The Tier 2 cars and trucks, which will have more stringent emission 

standards than NLEV s, were phased in beginning with the 2004 model year. In this same time 

frame a federally required low-sulfur gasoline fuel was implemented. 

3.3.2 Stage I Vapor Recovery 

The commission adopted the Stage I vapor recovery rules on June 30, 1999, to reduce VOC 

emissions. These rules already apply to approximately 7,000 gasoline stations in the BeaumontPort Arthur (BPA), El Paso (ELP), Houston-Galveston-Brazoria (HGB), and Dallas-Fort Worth 

(DFW) areas, and across 95 counties in east and central Texas. The vapor recovery rules regulate 

the filling of gasoline storage tanks at gasoline stations by tank trucks. To comply with Stage I 

requirements, a vapor balance system is typically used to capture the vapors from the gasoline 

storage tanks that would otherwise be displaced to the atmosphere as these tanks are filled with 

gasoline. The captured vapors are routed back to the tanker truck and processed by a vapor 

control system when the tanker truck is subsequently refilled at a gasoline terminal or gasoline 

bulk plant and handled in an appropriate manner. The effectiveness of Stage I vapor recovery 

rules depends on the captured vapors being: ( 1) effectively contained within the gasoline tanker 

truck during transit; and (2) controlled when the transport vessel is refilled at a gasoline terminal 

or gasoline bulk plant. 

3.3.3 Cleaner Gasoline 

Low Reid Vapor Pressure (RVP) gasoline is fuel that is refined to have a lower evaporation rate 

and lower volatility than conventional gasoline. This gasoline also reduces the evaporative 

emissions generated during vehicle refueling and therefore decreases the emissions of volatile 

organic compounds (VOCs). 

The Regional Low RVP Gasoline program requires low RVP gasoline in 95 central and eastern 

Texas counties during the summer months. The program, which began May 1, 2000, requires 

that all gasoline sold from retail gasoline-dispensing facilities within the affected counties have a 

maximum RVP of 7.8 pounds per square inch (psi) from June 1 through October 1 of each year. 

Gasoline suppliers are required to supply low RVP gasoline to the affected counties from May 1 

through October 1 of each year. 

3.3.4 Texas Low Emission Diesel (TxLED) 

This rule reduces emissions ofNOx and other pollutants from diesel-powered motor vehicles and 

non-road equipment operating within 110 counties in the eastern half of Texas including the 

Beaumont-Port Arthur, Dallas-Fort Worth, and Houston-Galveston-Brazoria eight-hour ozone 

nonattainment areas. The rule was originally adopted by the commission in December 2000, and 

was revised in March 2005 and April 2006. TxLED rules require that diesel fuel produced for 

delivery and ultimate sale to the consumer must contain less than 10 percent by volume aromatic 

hydrocarbons and must have a cetane number of 48 or greater. Some compliance options are 

allowed. TxLED implementation dates were October 31, 2005, for producers and importers; 

December 15, 2005, for bulk distribution facilities; and January 31, 2006, for retail fuel 

dispensing outlets, wholesale bulk purchasers, consumer facilities, and all other affected persons. 

3-7 
3.3.5 Portable Fuel Container Rule 

A statewide portable fuel container rule was adopted by the commission on October 27, 2004, to 

reduce VOC emissions. The rule establishes design criteria for "no-spill" portable fuel containers 

and portable fuel container spouts based in large part on the California Air Resources Board 

(CARB) standards. Effective December 31, 2005, these rules limit the type of portable fuel 

containers and portable fuel container spouts sold, offered for sale, manufactured, and/or 

distributed in the State of Texas. Fuel released into the environment can lead to the 

contamination of both air and water. This rule ensures that portable fuel containers manufactured 

under these standards will release a smaller amount of fuel as the result of spillage and 

evaporation. 

3.3.6 Texas Emission Reduction Plan (TERP) 

In 2001 the 77th Texas Legislature passed Senate Bill5 which established the Texas Emission 

Reduction Plan (TERP). The TERP includes incentive grants programs to reduce emissions of 

NOx from internal combustion engines on mobile sources. Eligible grant projects include fleet 

expansions with cleaner engines, replacements of old vehicles and equipment, repower of old 

engines, and on-vehicle and on-site infrastructure for idle reduction, electrification, and delivery 

of alternative fuels. 

The current funding mechanisms for the TERP program are expected to generate approximately 

$140 million per fiscal year through August 31, 201 0. Approximately $116 million is expected to 

be appropriated for use in the incentive grants program each year. 

As of March 2006, the program has awarded over $322 million for 720 projects, which are 

estimated to result in NOx reductions of over 73,000 tons, at an average cost per ton of NOx 

reduced of $4,397. In the Victoria County area, the projects funded thus far are projected to 

result in NOx reductions of223.5794 total tons, which equate to 0.1295 tons per day in 2007. 

The current TERP funding priorities are aimed at the nonattainment areas. Decisions on future 

TERP funding for projects in the Victoria area will depend upon the availability of funds and the 

need for reductions in the priority nonattainment areas under the new eight-hour SIP strategies in 

those areas. 

For information on recent TERP activities, please visit the TERP web site: www.terpgrants.org. 

3.3.7 Non-Road Source Control Strategies 

The ozone control strategy for the Victoria area includes reductions realized from various federal 

engine standards for non-road sources. Non-road sources are eligible for TERP funding, 

including locomotives, non-road Heavy-Duty Diesel (HDD), small engines, and marine vessel 

engines. 

3.3.8 Local Programs 

The City of Victoria's air quality program, Air Victoria, is a non-profit organization that works to 

inform Victoria about air quality issues, promote voluntary compliance with clean air standards 

and educate the public about health problems related to air quality. The following are 

descriptions of these programs. 

3.3.8.1 Air Victoria Team 

A cooperative effort of the City of Victoria and the TCEQ to reduce emissions of ozone 

producing chemicals in the Victoria area. This coalition consists of more than 40 businesses that 

agree to comply with best practices for improving air quality and participate in the TCEQ Small 

3-8 
Business and Local Government Assistance or Pollution Prevention site visit program. The 

program continues to grow as more businesses embrace environmental stewardship and as 

environmental education results in more participation by businesses and organizations. 

3.3.8.2 Ozone Alert System 

The ozone alert system provided by TCEQ is available through the Air Victoria website at 

http://www.airvictoria.org. In addition, the Victoria Advocate weather page (local newspaper 

with 75,000 readers/day) provides information on signing up for the TCEQ alerts, which are 

released during ozone season, from May 1 to October 15. Ozone alerts advisories are 

communicated to the community via television, radio, and print media. Air Victoria team 

members also display ozone alert flags during alerts. 

3.3.8.3 Community Advisory Panel 

The air quality program is advised by the community advisory panel on outreach and education 

and by an expert technical advisory committee with regards to modeling and emissions inventory 

technical work. 

3.3.8.4 Public Education 

The public education program uses the model of community based social marketing and includes, 

but is not limited to: public speaking, outdoor advertising, radio, television, print media and 

publication of informational and educational materials. The program coordinator has an 

interactive relationship with all schools in the city and works to provide or enhance air quality 

curriculum and programs in all grade levels. 

3.4 EMISSIONS SUMMARY 

The 2002 base year and the 2004, 2010, and 2014 future year emissions inventory summaries by 

source categories for Victoria County are shown in Figures 3-1, Victoria County VOC Emissions 

by Major Source and 3-2, Victoria County NOx Emissions by Major Source. EmissioH. totals are 

shown in Figures 3-3, Victoria County Total VOC Emissions and 3-4, Victoria County Total NOx 

Emissions. These figures illustrate that the greatest man-made contribution ofVOC is from area 

sources and ofNOx., is from point sources. Contributions from biogenic emissions are not 

included in the summary because the maintenance measures are limited to the reduction of manmade emissions only. 

The percentages of emissions by source type for 2002, 2004, 2010, and 2014 are reflected in 

Table 3-5, Percentages of VOC Emissions in Victoria County by Source Type and Table 3-6, 

Percentages of NO, Emissions in Victoria County by Source Type. 

3-9 
Table 3-5 Percentages of VOC Emissions in Victoria County by Source Type 

Eight-Hour Ozone Maintenance Evaluation Years 2002, 2004, 2010, and 2014 (See Tables 3-1 

and 3-2 for tons per average ozone season day) 

Area 46.9% 48.1% 54.5% 

On-road Mobile 24.6% 20.7% 14.2% 

Point 19.4% 23.6% 26.2% 

Non-road Mobile 9.1% 7.6% 5.1% 

Table 3-6 Percentages of NOx Emissions in Victoria County by Source Type 

Eight-Hour Ozone Maintenance Evaluation Years 2002, 2004, 2010, and 2014 

source Category 

Point 44.7% 51.0% 62.7% 

On -road Mobile 38.8% 33.1% 19.0% 

Area 8.8% 9.0% 11.4% 

Non-road Mobile 7.7% 6.9% 6.9% 

3-10 

56.5% 

10.9% 

28.1% 

4.5% 

69.4% 

11.9% 

12.5% 

6.2% 
Figure 3-1 Victoria County VOC Emissions by Major Source 

c ~ 5 -l------1' 

0:: 

w 

a.. 4 -l-----1' 

"' z 

0 

t- 3 -+---I 

2002 2004 

E POINT 

ONROAD MOBILE 

3-11 

2010 2014 

~ AREA 

~~ NONROAD MOBILE 
Figure 3-2 Victoria County NOx Emissions by Major Source 

2002 2004 2010 2014 

lm POINT 

L~ ONROAD MOBILE 

AREA 

NON ROAD MOBILE· 

3-12 
Figure 3-3 Victoria County Total VOC Emissions 

2002 2004 2010 2014 

3-13 
Figure 3-4 Victoria Coooty Total NOx Emissions 

2002 2004 2010 2014 

3-14 
CHAPTER 4: MONITORING NETWORK 

4.1 GENERAL 

The method chosen to verify continued attainment is the ambient air quality monitoring network. 

The ambient air monitoring sites will remain active at their present locations during the entire 

length of the maintenance plan period (2014) or if relocated or removed, will be done with EPA's 

concurrence. This data will be quality controlled and submitted to EPA AIRS on a monthly basis. 

A set of indicators and trigger levels, based on monitoring data, is specified in Section 

VI.B.lO.a.7(e), Contingency Plan. 

The Victoria County monitoring network consists of two ambient air monitors. The first monitor 

is located in the City of Victoria (CAMS 87) and is the monitor driving the area's design value. 

The monitors are managed in accordance with 40 CFR Part 58, to verify the attainment status of 

the county. The TCEQ commits to keep the monitors in place until the end of the maintenance 

period (2014). The second monitor located southeast of the City of Victoria (CAMS 602) became 

operational on July 19, 2000. CAMS 602 is only run half a year each year and does not meet 

EPA requirements for data completeness for showing attainment. Both monitors will be used to 

detect if and when appropriate levels have been exceeded for contingency measure triggering 

purposes. 

The eight-hour ozone design value based upon data collected from 2003-2005 at the CAMS 87 

monitor is 76 parts per billion (ppb). Table 4-1, Summary of the Design Value of CAMS 87 from 

2000-2005, summarizes the design value of the CAMS 87 monitor from 2000-2005. 

Table 4-1: Summary of the Design Value of CAMS 87 from 2000-2005 

4-1 
CHAPTER 5: CONTINGENCY PLAN 

5.1 BACKGROUND 

Phase I of EPA's Eight-Hour Ozone Implementation Rule requires the section llO(a)(l) 

maintenance plan include contingency provisions to promptly correct any exceedances of the 

NAAQS. The contingency plan ensures that the contingency measures are adopted expeditiously 

if they are triggered. In accordance with EPA guidance2 a series of early triggers have been 

established in order to effectuate appropriate and timely responses to indications of a possible 

future violation of the NAAQS. Thus, actions may be taken that can avoid a violation and 

potential redesignation to nonattainment. 

5.2 CONTINGENCY MEASURES AND TRIGGER LEVELS 

If air quality monitoring data indicates three or more eight-hour ozone exceedances within one 

calendar year, then the TCEQ will analyze available data regarding the air quality, meteorology, 

transport, and related activities in the area to determine the cause of the exceedances. The TCEQ 

will notify EPA of its findings·. 

If the area monitors an eight-hour ozone three-year average at or above 82 ppb, the ozone 

advisory staff will institute a voluntary program with industry to reschedule, revise, or curtail 

activities for the ozone advisory days. This program will be developed and available within 30 

days after notification by TCEQ that the contingency measure will be required. 

If the area monitors an eight-hour ozone three-year average at or above 83 ppb, and if the TCEQ 

determines the cause of the exceedance can be controlled by state actions, then the TCEQ will 

take prompt and appropriate action to reduce the ozone levels to the extent necessary to keep the 

design value below 85ppb. In addition, any previous efforts to reduce ozone may need to be 

retained. · · 

Since the implementation of potential contingency measures is not expected until possibly well 

into the future, the identification of specific, detailed measures is not practical. The most 

appropriate contingency measures may be significantly different from the measures mentioned 

due to technological, societal, economic and political factors beyond the TCEQ's ability to 

predict. 

2 EPA Memorandum: Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under 

Section JJO(a)(l) of Clean Air Act; pages 8-9(May 20, 2005) 

5-1 
WRITTEN AND 

ORAL TESTIMONY 
Reference Number 

W-1 

INDEX OF WRITTEN TESTIMONY 

Submitted By 

Thomas H. Diggs, Chief of the Air Planning 

Section, U.S. Environmental Protection 

Agency, Region 6 
• 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 6 

Ms. Kathy Singleton 

Air Quality Division 

Chief Engineer's Office 

1445 ROSS AVENUE, SUITE 1200 

DALLAS, TX 75202-2733 

October 23,2006 

Texas Commission on Environmental Quality, MC 206 

P.O. Box 13087 

Austin, TX 78711-3087 

Dear Ms. Singleton: 

Thank you for the opportunity to comment on the proposed revisions to the State 

Implementation Plan (SIP) for the Control of Ozone Air Pollution, 8-hour Ozone Maintenance 

Plan for the Victoria County Ozone Attainment Area, Project Number 2006-023-SIP-NR. We 

have organized our comments by section in the proposal, and when possible, made reference to 

specific table and paragraph numbers within the submittal. 

Maintenance Demonstration (Chapter 3) 

Texas Emission Reduction Plan (Chapter 3.3.6). The third paragraph of this chapter 

needs to be reformatted. 

Monitoring Network (Chapter 4) 

General Monitoring Network (Chapter 4.1). In this chapter, references to CAMS 602 

should be removed. Since CAMS 602 does not meet the U.S. Environmental Protection 

Agency's (EPA) monitoring Quality Assurance requirements from40 CFR Part 58 and was 

deactivated on February 23, 2006, discussion of this monitor should not be included in the 

maintenance plan. 

In Table 4-1, Summary of the Design Value of CAMS 87 from 2000-2005, the 8-hour 

ozone design value for the year 2000 should be 79 ppb. 

Contingency Plan (Chapter 5) 

Consistent with our regulations and guidance, the plan must include contingency 

provisions, as necessary, to promptly correct any violations of the standard (40 CFR 

51.905(a)(4)(ii)). Throughout this chapter, it is important to define the triggers, timeline, and 

contingency measures as accurately as possible. 

Internet Address (URL) - http://www.epa.gov/earth1 r6/ 

Recycled/Recyclable - Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 

W-1 
2 

Triggers: The proposed Plan has two exceedance triggers which EPA supports. At a 

minimum, the Contingency Plan must ensure that any violation of the 8-hour standard is 

promptly corrected. The proposed Chapter lacks an enforceable commitment that if there is a 

violation of the 8-hour ozone standard, the Texas Commission on Environmental Quality 

(TCEQ) will implement one or more specifically identified control measures. The proposed Plan 

includes exceedance triggers, but no violation trigger. See the second and third paragraphs of 

5.2. 

Timelines: The plan must include specific timelines for implementation of the measures. 

The time lines must ensure that all of the tasks required by the Contingency Plan will be adopted 

and implemented as expeditiously as practicable but no later than 24 months. Specifically, the 

second paragraph's proposed timeline is too vague. The phrase "after notification by TCEQ that 

the contingency measure will be required" is not clear the measure will be implemented no later 

than 24 months of the exceedance. For the third paragraph, first sentence, the following phrase 

needs to be deleted: "and if the TCEQ determines the cause of the exceedance can be controlled 

by state actions." It is acceptable to EPA if TCEQ revises this phrase to read as follows, "and if 

the TCEQ determines the cause of the exceedance can be controlled within the state's 

jurisdiction through regulatory actions." Also this paragraph lacks a specific timeline for 

implementation. The new paragraph that will address the situation where there is a violation of 

. the standard will require a specific timeline too. 

Contingency Measures: The plan must include clearly identified contingency measures 

associated with each trigger. The third paragraph (the second trigger, an exceedance of 83 ppb) 

does not include a list of any specified control measures. The new paragraph addressing the 

trigger of violation of the standard also will require a list of specific control measures. 

Regarding the fourth paragraph, although we understand the concern about the uncertainty of 

determining appropriate control measures since the State believes the Contingency Plan will not 

be triggered until possibly well in the future, several specifically identified measures need to be 

included in the Plan for the second trigger and the violation trigger. 

Once again, we appreciate the opportunity to review and comment on this proposed SIP 

revision. If you have questions regarding any of these comments, please feel free to contact me 

or Ellen Belk at (214) 665-2164. 

Sincerely yours, 

~~'be Thomas H. Diggs 

Chief 

Air Planning Section 
INDEX OF ORAL TESTIMONY 

Reference Number Submitted by 

No oral testimony was received pertaining to this proposal. 
Texas Commission on Environmental Quality 

Public Hearing Registration 

Location: Victoria Date: October 17, 2006 

Concerning: Revision to the Texas State Implementation Plan (Docket No. 2006-0229-SIP) 

Name Representing Presenting Oral Testimony? 

(Circle One) 

(Please Print) 

~ j ... /UJA"~ {Jy"Clz--t.,.,~ (l 

~(hi . o·r v~,r~vY / ( .__ t&?~ 

') Yes 

~ w tJ/f.l / I :.~~ 

tAL ri~ v,ufvf('c, / lev,;.; Jl~. ( Yes L~/ 

1 cr I I /..---...~ 

()Juu;~ ~UJ~ c~ f)[dYes LNo_) 

~ ?I (/ !/ 

Yes No 

Yes No 

Yes No 

Yes No 
EVALUATION OF 

TESTIMONY 
To: 

Thru: 

From: 

Texas Commission on Environmental Quality 

INTEROFFICE MEMORANDUM 

Commissioners Date: February 16, 2007 

LaDonna Castafiuela, Chief Clerk 

Glenn Shankle, Executive Director 

David c. Schanbacher, P.E., Chief Engineer ~r 

Docket No.: 2006-0229-SIP 

Subject: Commission Approval for Victoria County Eight-Hour Ozone Maintenance Plan Adoption 

Project No. 2006-023-SIP-NR 

Reasons for the SIP revision: 

Under what authority are we adopting these changes? 

The authority to propose and adopt this SIP revision is derived from the Texas Health and Safety 

Code, Texas Clean Air Act (TCAA), §382.002, which provides that the policy and purpose of the 

TCAA is to safeguard the state's air resources from pollution; TCAA, §382.011, which authorizes 

the commission to control the quality of the state's air; §382.012, which authorizes the commission 

to prepare and develop a general, comprehensive plan for the control of the state's air; and 

§382. 013, which identifies areas of the state for air quality program implementation purposes. 

Is this SIP revision required by federal rule or state statute? Which. ones? 

This SIP revision is required by Section llO(a)(l) of the Federal Clean Air Act and 40 CFR 

§51.905(a)(4)(ii). Victoria was designated as attainment for eight-hour ozone NAAQS and 

attainment for one-hour ozone NAAQS with an approved maintenance plan, so, must adopt and 

submit a ten-year maintenance plan within three years of designation. On December 22, 2006, the 

U.S. Court of Appeals for the District of Columbia, vacated the implementing rule and remanded 

the matter to the U.S. Environmental Protection Agency (EPA) (SCAQMD v. EPA, No. 04-

1200). Any subsequent actions by EPA and/or the court may impact the requirements being 

addressed in this package. 

Are there any legal deadlines by which this SIP revision must be adopted, or effective? 

Yes, the eight-hour ozone maintenance plan must be submitted to the EPA by June 15, 2007. 

What issue(s) or problern(s) are we trying to solve? 

This SIP revision would demonstrate continued maintenance of the eight-hour ozone standard for 

Victoria County. 

Why is it important that we do this SIP revision? 

The EPA designated and classified areas for the eight-hour ozone NAAQS with an effective date of 

June 15, 2004 (See 69 FR 23858). Victoria was classified attainment (69 FR 23936) for the eighthour ozone standard, but under the EPA's Phase I Implementation Rule is required to submit a 

maintenance plan by June 15, 2007. This revision will provide the elements required by the EPA. 

According to the Phase I Implementation Rule [ 40 CFR §51. 905( e)], the contingency measure 

obligations that are part of the approved one-hour maintenance plan remain federally enforceable 

until such time as the EPA approves a SIP revision removing these obligations. There are no 
Commissioners 

Page 2 

February 16, 2007 

Re: Docket No. 2006-0229-SIP 

contingency measures that the TCEQ intends to remove from the one-hour ozone maintenance 

plan. 

Other important background or historical information. 

Victoria County was designated as an incomplete or no data ozone nonattainment area in 1990. 

A Redesignation Petition and Maintenance Plan was submitted to EPA in 1994 and on May 8, 

1995, Victoria County was redesignated as attainment for the one-hour ozone standard. The OneHour Ozone Maintenance Plan was submitted on February 5, 2003. On June 15, 2004, the EPA 

designated Victoria as attainment for the eight-hour ozone NAAQS. 

Scope of the SIP revision: 

This eight-hour ozone maintenance plan documents the Victoria area's ability to maintain the eighthour ozone standard with existing control measures. 

Changes required by federal rule: 

This SIP revision is required by 40 CFR Section 51.905(a)(4)(ii) of the EPA's Eight-Hour Ozone 

Implementation Rule. 

Changes required by state statute: 

None 

Staff recommendations that are not expressly required by federal rule or state statute: 

None 

Impact on the regulated community: 

There are no proposed rulemaking changes associated with this SIP revision, only a revision to the 

SIP narrative; therefore, there are no new impacts to the regulated community. 

Impact on the public: 

The public continues to benefit from efforts made to ensure air quality standards are met. 

Impact on agency programs: 

No new effects. The TCEQ will continue air quality monitoring activities and emissions inventory 

data gathering activities in support of the maintenance plan. The Victoria area is not subject to 

transportation conformity because of the area's eight-hour ozone designation. 

Potentially controversial matters: 

None 

Public comment: 

A c.omment letter was received from EPA and the substantive issue is summarized below: 

EPA stated that the Contingency Plan in Chapter 5 must include contingency provisions, as necessary, to 

promptly correct any violations of the standard [40 CFR 51.905(a)(4)(ii)] and it is important to define the 

triggers, timeline, and contingency measures as accurately as possible. 
Commissioners 

Page 3 

February 16, 2007 

Re: Docket No. 2006-0229-SIP 

Significant changes from proposal: 

Additional control strategies were added to Chapter 3, Maintenance Demonstration. 

The EPA is working to amend the federal standards regulating the volatile organic compound (VOC) 

content of consumer products and architectural and industrial maintenance coatings, requiring stricter VOC 

limits. The proposal is scheduled for April 2007, with promulgation in November 2007 and compliance 

by January 2009. The EPA is also considering federal emission standards on marine and railroad engines 

to reduce nitrogen oxides (NOx) and particulate matter (PM). EPA is expected to propose the rules in 

Spring 2007. 

In response to EPA's comments, the triggers, timelines, and contingency measures were clarified as 

needed in Chapter 5, Contingency Measures. 

Agency contacts: 

Kathy Singleton, Project Manager, 239-6098, Air Quality Division 

John Minter, Staff Attorney, 239-0663 

Attachments 

cc: Chief Clerk, 5 copies 

Executive Director's Office 

David C. Schanbacher, P.E. 

Jason Skaggs 

Ashley K. W adick 

Office of General Counsel 

Kathy Singleton 

cc (without attachments): 

John Minter, Staff Attorney 

Kerry Howard, Program Office Liaison 

Booker Harrison, OLS Liaison 

Russ Kimble, OLS 

Theresa Pella, Manager, Air Quality Planning 

Kelly Keel, Team Leader, SIP Team 
Response to Comments Received Regarding the 

Eight-Hour Ozone Maintenance Plan for the Victoria County Ozone Attainment Area 

State Implementation Plan Revision 

A public hearing was held in Victoria on October 17, 2006, at 1:30 p.m. No oral comments were 

received at this hearing. The commission did receive written comments from the U.S. 

Environmental Protection Agency (EPA). 

The EPA's comments: 

Maintenance Demonstration (Chapter 3) 

The EPA commented that the Texas Emission Reduction Plan, Chapter 3.3.6, needs to be 

reformatted. 

The commission appreciates EPA identifying the formatting issue and the correction has 

been made. 

Monitoring Network (Chapter 4) 

The EPA commented that the reference to CAMS 602 in Chapter 4, Monitoring Network, should 

be removed since it does not meet the EPA monitoring Quality Assurance requirements from 40 

CFR Part 58 and was deactivated on February 23, 2006. 

The commission agrees with the EPA, and the references to CAMS 602 in the maintenance 

plan have been deleted. 

The EPA commented that in Table 4-1, Summary of the Design Value of CAMS 87 from 2000-

2005, the eight-hour ozone design value for the year 2000 should be 79 ppb. 

The commission agrees with EPA that the correct design value for 2000 is 79 ppb and the 

correction has been made. 

Contingency Plan (Chapter 5) 

The EPA indicated that the maintenance plan must include contingency provisions, as necessary, 

to promptly correct any violations of the standard (40 CFR 51.905(a)(4)(ii)). The EPA supports 

the two exceedance triggers in the maintenance plan but stated that the plan should include a 

violation trigger as well. 

The plan has been revised based on this comment. The commission has added a violation 

trigger to the Contingency Plan. 

The EPA commented that all contingency measures must include specific time lines for 

implementation of the measures to ensure that all of the tasks required by the Contingency Plan 

will be adopted and implemented as expeditiously as practicable but no later than 24 months. 

The plan has been revised based on this comment. The commission added specific timelines 

for all triggers stating that the control measures will be adopted and implemented as 

expeditiously as practicable but no later than 24 months. 

The EPA commented that the phrase "and if the TCEQ determines the cause of the exceedance 

can be controlled by state actions" needs to be deleted. It is acceptable to EPA if TCEQ revised 

RTC-1 
this phrase to read as follows: "and if the TCEQ determines the cause of the exceedance can be 

controlled within the state's jurisdiction through regulatory actions." 

The plan has been revised based on this comment. The commission revised the phrase as 

indicated by EPA. 

The EPA commented that the plan must include clearly identified contingency measures 

associated with each trigger. The second trigger and the added violation trigger need to include 

specific control measures. 

Chapter 5 of the plan has been revised based on this comment to include specific voluntary 

control measures identified by the City of Victoria in the event of an exceedance. 

Additional text was added to clarify the steps to be taken if the area monitors an eight-hour 

ozone three-year average at or above 85 ppb, and if the TCEQ determines the cause of the 

violation can be controlled within the state's jurisdiction through regulatory actions. 

RTC-2 
STAFF 

RECOMMENDATIONS 
RECE AIR IVEO- 6PDL 

PLANNING SEC 

07HAR 28 PH /: 43. 

REVISIONS TO THE STATE IMPLEMENTATION PLAN (SIP) 

FOR THE CONTROL OF OZONE AIR POLLUTION 

EIGHT-HOUR OZONE MAINTENANCE PLAN 

FOR THE 

VICTORIA COUNTY OZONE ATf AINMENT AREA 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

P.O. BOX 13087 

. AUSTIN, TEXAS 78711-3087 

PROJECT NUMBER 

2006-023-SIP-NR 

Adopted 

March 7, 2007 
i 

VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

TABLE OF CONTENTS

Chapter 1: General 

1.1 Background 

1.2 Public Hearing Information 

1.3 Social and Economic Consideration 

1.4 Fiscal and Manpower Resources 

Chapter 2: Attainment Emissions Inventory 

2.1 Overview 

Chapter 3: Maintenance Demonstration 

3.1 General 

3.2 Future Emissions and Verification of Continued Attainment 

3.3 Control Strategies 

3.4 Emissions Summary 

Chapter 4: Monitoring Network 

4.1 General 

Chapter 5: Contingency Plan 

5.1 Background 

5.2 Contingency Measures and Trigger Levels 
ii 

VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

 LIST OF TABLES

Number Table Name 

2-1 Summary of VOC Emissions in Victoria County by Source Type (2002) 

2-2 Summary of NOX Emissions in Victoria County by Source Type (2002) 

3-1 Summary of VOC Emissions in Victoria County by Source Type (2004, 2010, and 2014) 

3-2 Summary of NOX Emissions in Victoria County by Source Type (2004, 2010, and 2014) 

3-3 MOBILE6 Vehicle Classifications 

3-4 On-road Mobile Source, Summer - Weekday Emissions Inventory Summary 

3-5 Percentage of VOC Emissions in Victoria County by Source Type 

3-6 Percentage of NOX Emissions in Victoria County by Source Type 

4-1 Summary of the Design Value of CAMS87 from 2000 - 2005 
iii 

VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

LIST OF FIGURES

Number Figure Name 

3-1 Victoria County VOC Emissions by Major Source Category 

3-2 Victoria County NOX Emissions by Major Source Category 

3-3 Victoria County Total VOC Emissions 

3-4 Victoria County Total NOX Emissions 
iv 

VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN 

APPENDICES

Number Appendix Name 

Appendix A Development and Production of On-Road Mobile Source Emissions Inventories for 

 Victoria County: 2002, 2004, 2010, and 2014 (available at the public TCEQ FTP site, 

ftp://ftp.tnrcc.state.tx.us/pub/OEPAA/TAD/Modeling/Mobile_EI/). 

Appendix B City of Victoria voluntary control measures 

 
v 

VICTORIA EIGHT-HOUR OZONE MAINTENANCE PLAN

LIST OF ACRONYMS 

LIST OF ACRONYMS 

ACT -- Alternative Control Techniques 

AF -- Air-to-Fuel 

AIM – architectural and industrial maintenance 

AIRS – Aerometric Information Retrieval System 

APU -- Auxiliary Power Units 

ARPDB -- Acid Rain Program Data Base 

ATCM – Airborne Toxic Control Measure 

auto-GC -- Automated Gas Chromatograph 

BACT -- Best Available Control Technology 

BCCA-AG -- Business Coalition for Clean Air-Appeal Group 

BMP -- Best Management Practices 

BPA -- Beaumont-Port Arthur 

Btu/hr -- British Thermal Units per Hour 

Btu/scf -- British Thermal Units per Square Cubic Feet 

CAE -- Cetane Additive Enhanced Diesel Fuel 

CAIR -- Clean Air Interstate Rule 

CAMx -- Comprehensive Air Model with Extensions 

CARB -- California Air Resources Board 

CBD -- Houston's Central Business District 

CFR -- Code of Federal Regulations 

CMAQ -- Congestion Mitigation and Air Quality 

CO -- Carbon Monoxide 

CTG -- Control Technique Guidelines 

DECS -- Diesel Emission Control Strategy 

DERC -- Discrete Emission Reduction Credits 

DFW -- Dallas-Fort Worth 

DPM -- Diesel Particulate Matter 

DRRP -- Diesel Risk Reduction Program 

DV -- Design Value 

DVc -- Current Design Value 

DVf -- Future Design Value 

EAC -- Early Action Compact 

EDMS -- Emissions and Dispersion Modeling System 

E-GRID-2007 -- Emissions and Generation Resource Integrated Database 

EE/RE -- Energy Efficiency/Renewable Energy 

EGAS -- Economic Growth Analysis System 

EGF -- Electric Generating Facilities 

EGU -- Electric Generating Units 

EI -- Emissions Inventory 

ELP – El Paso 

EPA -- United States Environmental Protection Agency 

EPS3 -- Emissions Processing System, version 3 

ERC -- Emission Reduction Credits 

ERCOT -- Electric Reliability Council of Texas 

ESAD -- Emission Specification for Attainment Demonstration 
vi 

ESL -- Energy Systems Laboratory, the Texas A&M University System 

F -- Fahrenheit 

FAA -- Federal Aviation Administration 

FCAA -- Federal Clean Air Act 

FCV -- Fuel Cell Vehicle 

FGR -- Flue Gas Recirculation 

FHWA -- Federal Highway Administration 

FR -- Federal Register 

FT -- Fischer-Tropsch Diesel Fuel 

GIS -- Geographic Information System 

GloBEIS -- Global Biosphere Emissions and Interactions System 

gpm -- Gallons per Minute 

GTM -- Gross Ton Mile 

GVWR – Gross Vehicle Weight Rating 

HAP -- Hazardous Air Pollutant 

HARC -- Houston Advanced Research Center 

HDT -- Heavy-Duty Truck 

HECT -- Highly-Reactive Volatile Organic Compound Emissions Cap and Trade Program 

HGB -- Houston-Galveston-Brazoria 

H-GAC -- Houston-Galveston Area Council 

HOV -- High Occupancy Vehicle 

hp -- Horsepower 

HPMS -- Highway Performance Monitoring System 

HRVOC -- Highly-Reactive Volatile Organic Compound 

HSC -- Houston Ship Channel 

IC -- Internal Combustion 

ICI -- Industrial, Commercial, and Institutional 

IECC -- International Energy Conservation Code 

I/M -- Inspection and Maintenance 

km -- Kilometer 

KVs -- Vertical Exchange Coefficient 

LAER -- Lowest Achievable Emission Rate 

lb/MMBtu -- Pound per Million British Thermal Units 

LDAR -- Leak Detection and Repair 

LDIR -- Light Detection and Ranging 

LDEQ -- Louisiana Department of Environmental Quality 

LDGV -- Light-Duty Gasoline Vehicle 

LDT -- Light-Duty Truck 

LDV -- Light-Duty Vehicle 

LED -- Low Emission Diesel 

LEV -- Low Emission Vehicle 

LEV II -- California's Low Emission Vehicle II Program 

LIRAP -- Low Income Repair and Assistance Program 

LNB -- Low Nitrogen Oxides (NOX) Burners 

LNC -- Low Nitrogen Oxides (NOX) Combustors 

LNG -- Liquefied Natural Gas 

LTO -- Landing and Take-Off 

MACT -- Maximum Achievable Control Technology 

Mcf -- Thousand Cubic Feet 

MCR -- Mid-Course Review 

MDPV -- Medium-Duty Passenger Vehicle 
vii 

MECT -- Mass Emissions Cap and Trade Program 

MM5 -- Fifth Generation Meteorological Model 

MMBtu/hr -- Million British Thermal Units per Hour 

MMcf -- Million Cubic Feet 

MMS -- Minerals Management Service 

MOA -- Memorandum of Agreement 

MON -- Miscellaneous Organic National Emission Standards for Hazardous Air Pollutants 

(NESHAP) 

mph -- Miles per Hour 

MVEB -- Motor Vehicle Emissions Budget 

MW -- Megawatts 

MY -- Model Year 

NAAQS -- National Ambient Air Quality Standard 

NEGU -- Non-Electric Generating Units 

NEI -- National Emissions Inventory 

NESHAP -- National Emission Standards for Hazardous Air Pollutants 

ng/J -- Nanogram per Joule 

NLEV – National Low Emission Vehicle 

NMIM -- National Mobile Inventory Model 

NOAA -- National Oceanic and Atmospheric Administration 

NOX -- Nitrogen Oxides 

NOy -- Nitrogen Species 

NSCR -- Non-Selective Catalytic Reduction 

NTRD -- New Technology Research and Development Program 

O3 -- Ozone 

OGV -- Ocean-Going Vessel 

OTC – Ozone Transport Commission 

PAYD -- Pay As You Drive 

PBL -- Planetary Boundary Layer 

PCA – Principle Component Analysis 

PEI -- Periodic Emissions Inventory 

PERP -- Portable Engine Registration Program 

PiG -- Plume-in-Grid 

PM -- Particulate Matter 

PM2.5 -- Particulate Matter less than 2.5 microns 

ppb -- Parts Per Billion 

ppbC -- Parts Per Billion Carbon 

ppbv -- Parts Per Billion by Volume 

ppm -- Parts Per Million 

PSCF -- Potential Source Contribution Factors 

PSDB -- Point Source Database 

psia -- Pounds per Square Inch Absolute 

PUC -- Public Utility Commission 

RACT -- Reasonably Available Control Technology 

RACM -- Reasonably Available Control Measure 

RFP -- Reasonable Further Progress 

RMSE -- Root Mean Square Error 

ROP -- Rate-of-Progress 

RRF -- Relative Reduction Factor 

SB -- Senate Bill 

SCAQMD -- South Coast Air Quality Management District 
viii 

scfm -- Square Cubic Feet per Minute 

SCR -- Selective Catalytic Reduction 

SEP -- Supplemental Environmental Programs 

SETPMTC -- Southeast Texas Photochemical Modeling Technical Committee 

SIC -- Standard Industrial Classification 

SIP -- State Implementation Plan 

SNCR -- Selective Non-Catalytic Reduction 

SOV -- Single Occupancy Vehicle 

STP -- Surface Transportation Program 

SWCV -- Solid Waste Collection Vehicle 

TAC -- Texas Administrative Code 

TACB -- Texas Air Control Board 

TCAA -- Texas Clean Air Act 

TCEQ -- Texas Commission on Environmental Quality (commission) 

TCM -- Transportation Control Measure 

TDM -- Travel Demand Model 

TERP -- Texas Emission Reduction Plan 

TexAQS 2000 -- Texas Air Quality Study 2000 

TexAQS II -- Texas Air Quality Study 2006 

TKE -- Turbulent Kinetic Energy 

TNMHC -- Total Nonmethane Hydrocarbon 

TNRCC -- Texas Natural Resource Conservation Commission 

tpd -- Tons Per Day 

tpy -- Tons Per Year 

TSE -- Truck Stop Electrification 

TTI -- Texas Transportation Institute 

TUC -- Texas Utility Code 

TxDOT -- Texas Department of Transportation 

TxLED -- Texas Low Emission Diesel 

USC -- United States Code 

VMEP -- Voluntary Mobile Source Emissions Reduction Program 

VMT -- Vehicle Miles Traveled 

VOC -- Volatile Organic Compound 

VRU -- Vapor Recovery Unit 

ZEB -- Zero Emission Bus 

ZEV -- Zero Emissions Vehicle
ES-1 

EXECUTIVE SUMMARY 

The U.S. Environmental Protection Agency (EPA) designated and classified areas for the eight-hour 

ozone National Ambient Air Quality Standards (NAAQS) with an effective date of June 15, 2004 (69 FR 

23858). Victoria County was classified attainment for the eight-hour ozone standard. However, in 1990, 

Victoria County was designated nonattainment based on incomplete data for the one-hour ozone standard. 

In July 1994, the Texas Natural Resource Conservation Commission (TNRCC), now the Texas 

Commission on Environmental Quality (TCEQ), submitted a redesignation petition and maintenance plan 

State Implementation Plan (SIP) revision to the EPA. On May 8, 1995, the EPA redesignated Victoria 

County as attainment of the one-hour ozone standard and required a maintenance plan be submitted in 

eight years. The one-hour maintenance plan was submitted to the EPA on February 5, 2003; the EPA 

approved the plan on January 3, 2005. 

The EPA’s Phase I Implementation Rule for the eight-hour ozone standard requires areas like Victoria 

County that were designated as attainment for the eight-hour ozone NAAQS and attainment for the onehour ozone NAAQS with an approved maintenance plan to submit a maintenance plan for the eight-hour 

ozone NAAQS that must be consistent with Section 110(a)(l) of the Federal Clean Air Act (FCAA). (69 

FR 23951) 

Under 40-CFR 51.905(a)(3) and (4), States must submit Section 110(a)(1) maintenance plans no later 

than 3 years after the effective date of the area’s eight-hour ozone NAAQS designation. For Victoria 

County, June 15, 2004, is the effective date, therefore, the Section 110(a)(1) eight-hour ozone 

maintenance plan must be submitted no later than June 15, 2007. Guidance issued by the EPA on May 

20, 2005, further specifies that states include the following components in the maintenance plan: 

C attainment inventory; 

C maintenance demonstration; 

C ambient air quality monitoring; 

C contingency plan; and 

C verification of continued attainment. 

 

With this SIP revision, the TCEQ is submitting an eight-hour ozone maintenance plan that will ensure the 

County of Victoria remains in attainment of the eight-hour ozone NAAQS. 

Local governments and other interested parties in the Victoria area will continue implementing programs 

that have proved effective in maintaining healthy air quality to assure that the area continues to maintain 

its attainment status for the eight-hour ozone standard. The maintenance plan is the appropriate 

mechanism and allows individual communities the flexibility to pursue emission reduction strategies most 

appropriate for their circumstances.
1-1 

CHAPTER 1: GENERAL

1.1 BACKGROUND

1.1.1 Purpose of Plan 

The purpose of this State Implementation Plan (SIP) revision is to submit an eight-hour ozone 

maintenance plan that will ensure Victoria County remains in attainment of the eight-hour ozone 

standard. In addition, the Texas Commission on Environmental Quality (TCEQ) is submitting 

evidence showing that Victoria County is measuring ozone concentration well below 125 parts 

per billion (ppb), the basis for compliance with the former one-hour ozone standard which 

equates to 0.12 parts per million (ppm). 

 

1.1.2 One-Hour Ozone History in Victoria County 

Victoria County was originally designated nonattainment for ozone in the Federal Register dated 

March 3, 1978 (43 FR 8962). This designation was based on six weeks of U.S. Environmental 

Protection Agency (EPA) contractor-collected data at two sites from September 24, 1977 to 

November 7, 1977. The EPA changed the one-hour ozone standard to 0.12 ppm in January 1979. 

Victoria County ozone data was re-examined under the new standard and the EPA determined 

that Victoria County had exceeded the new standard on one occasion. 

The 1990 Federal Clean Air Act (FCAA) Amendments authorized the EPA to designate areas 

failing to meet the ozone National Ambient Air Quality Standards (NAAQS) as nonattainment 

and to classify them according to severity. Victoria County was designated as an "Incomplete or 

No Data Ozone Nonattainment Area" on November 15, 1990, and the county retained its prior 

one-hour ozone nonattainment designation by operation of law. The FCAA Amendments 

required unclassifiable nonattainment areas with incomplete or no data to collect three 

consecutive years of monitored data and to reach attainment by November 15, 1995. Victoria 

County completed three consecutive years of monitoring on May 2, 1994, with a design value of 

0.10 ppm, below the 0.12 ppm standard. 

The general elements required for maintenance plans in incomplete data areas, such as Victoria 

County, were stated in a May 17, 1994, EPA letter from Dr. A. Stanley Meiburg, EPA Region 6 

Director of the Air, Pesticides, and Toxics Division to Ms. Beverly Hartsock, Deputy Executive 

Director, Office of Air Quality, Texas Natural Resource Conservation Commission (predecessor 

agency to the TCEQ). The letter stated that incomplete data areas with ozone design values that 

are less than 85 percent of the ozone standard can be relieved of certain maintenance plan 

requirements. Eighty-five percent of the ozone standard is 0.106 ppm, therefore, Victoria County 

qualified for relief. On July 27, 1994, the TCEQ submitted a redesignation petition and 

maintenance plan SIP revision to the EPA. On May 8, 1995, the EPA redesignated Victoria 

County as attainment of the one-hour ozone standard. 

The FCAA, Section 175A(b) requires the state to submit a subsequent maintenance plan eight 

years after redesignation. The eight-year deadline for submittal was May 8, 2003. The state 

adopted a maintenance plan on February 5, 2003, and submitted the plan to the EPA on February 

18, 2003. The EPA approved the maintenance plan revision on January 3, 2005. 

1.1.3 Eight-hour Ozone in Victoria County 

The EPA’s Phase I Implementation Rule requires areas like Victoria County to submit a 

maintenance plan for the eight-hour ozone NAAQS that must be consistent with Section 110(a)(l) 

of the FCAA (69 FR 23951). Under 40-CFR 51.905(a)(3) and (4), states must submit Section 

110(a)(1) maintenance plans no later than three years after the effective date of the area’s eight-
1-2 

hour ozone NAAQS designation. June 15, 2004, was the effective date of eight-hour ozone 

designations, therefore, the Section 110(a)(1) eight-hour ozone maintenance plan must be 

submitted no later than June 15, 2007. 

1.1.3.1 Maintenance Plan Components

The EPA-issued guidance1 specifies that states must include the following components in the 

maintenance plan: 

C Attainment inventory; 

C Maintenance demonstration; 

C Ambient air quality monitoring; 

C Contingency plan; and 

C Verification of continued attainment. 

1.2 PUBLIC HEARING INFORMATION

The commission held a public hearing at the following time and location: 

DATE TIME LOCATION

October 17, 2006 1:30 p.m. 700 Main Center, Room 204 

Victoria, Texas 

No oral comments were received at the hearing. The comment period ended on October 23, 

2006, at 5:00 p.m. One written comment was received from the EPA. The response to comments 

has been attached to this document. 

Copies of the adopted SIP revision and all appendices can be obtained from the TCEQ’s web site 

at http://www.tceq.state.tx.us/implementation/air/sip/sipplans.html or upon request to: 

 

 Texas Commission on Environmental Quality 

 Air Quality Division 

 P. O. Box 13087 

 Mail Code 206 

 Austin, Texas 78711-3087 

 Re: Victoria Maintenance Plan Information 

1.3 SOCIAL AND ECONOMIC CONSIDERATIONS

This revision is a continuation of the existing maintenance plan as required by the FCAA and no 

new control strategies have been incorporated into this revision. Therefore, there are no 

additional social or economic costs associated with this revision. 

1.4 FISCAL AND MANPOWER RESOURCES

The state has determined that its fiscal and manpower resources are adequate and will not be 

adversely affected through implementation of this plan. 

 

1

 EPA Memorandum: Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under 

Section 110(a)(1) of Clean Air Act; (May 20, 2005) 
2-1 

CHAPTER 2: ATTAINMENT EMISSIONS INVENTORY 

2.1 OVERVIEW 

The attainment inventory is based on the volatile organic compounds (VOC) and nitrogen oxides 

(NOX) emissions of an actual typical summer day. The attainment emission inventory base year 

is 2002. The 1990 Federal Clean Air Act (FCAA) Amendments, require that emissions 

inventories (EI) be prepared for ozone nonattainment areas. Because ozone is photochemically 

produced in the atmosphere when VOCs are mixed with NOX in the presence of sunlight, the 

Texas Commission on Environmental Quality (TCEQ) must compile information on the sources 

of these precursor pollutants. EI must identify the source types present in an area, the amount of 

each pollutant emitted, and the types of processes and control devices employed at stationary 

sources or other source categories. The EI provides data for a variety of air quality planning 

tasks, including establishing baseline emission levels, calculating reduction targets, control 

strategy development for achieving the required emission reductions, emission inputs into air 

quality simulation models, and tracking actual emission reductions against the established 

emissions growth and control budgets. The total VOC and NOX emissions inventory for an area 

is summarized from the estimates developed for four general categories of emissions sources, 

which are each explained in Sections 3.2.1 through 3.2.4. Summaries of the 2002 VOC and NOX

emissions by source type are provided in Table 2-1: Summary of VOC Emissions in Victoria 

County by Source Type and Table 2-2: Summary of NOX Emissions in Victoria County by Source 

Type. 

Table 2-1: Summary of VOC Emissions in Victoria County by Source Type (2002)

Eight-Hour Ozone Maintenance Evaluation Year 2002 

Source Category VOC 

tons per average ozone 

season day 

Area 6.28 

On-road Mobile 3.29 

Non-road Mobile 1.21 

Point 2.60 

Total 13.38 
2-2 

Table 2-2: Summary of NOX Emissions in Victoria County by Source Type (2002)

Eight-Hour Ozone Maintenance Evaluation Year 2002 

Source Category NOX

tons per average ozone 

season day 

Area 2.56 

On-road Mobile 11.26 

Non-road Mobile 2.23 

Point 13.00 

Total 29.05 
3-1 

CHAPTER 3: MAINTENANCE DEMONSTRATION

3.1 GENERAL

The maintenance plan must demonstrate that the Victoria County area will remain in attainment of the 

eight-hour ozone standard for the ten-year period following the date of designation. The maintenance 

demonstration is satisfied if the state demonstrates that future volatile organic compounds (VOC) and 

nitrogen oxides (NOX) emission levels are not expected to result in exceedances of the National Ambient 

Air Quality Standards (NAAQS). The effective date for Victoria County’s attainment designation was 

June 15, 2004, meaning maintenance must be demonstrated through 2014. 

3.2 FUTURE EMISSIONS AND VERIFICATION OF CONTINUED ATTAINMENT 

In order to track the progress of the maintenance plan, the Texas Commission on Environmental Quality 

(TCEQ) will continue to periodically update the emissions inventory (EI). In addition to the EI for 2002, 

the emission inventory base year, and the last year of the maintenance plan, 2014, interim years of 2004 

and 2010 were selected to show a trend analysis for maintenance of the eight-hour ozone NAAQS. 

Tables 3-1: Summary of VOC Emissions in Victoria County by Source Type and 3-2: Summary of NOX

Emissions in Victoria County by Source Type depict the EIs that will be used to compare against 2002, to 

ensure compliance with the eight-hour ozone NAAQS. The trend analysis shows an overall decrease in 

NOX and VOC emissions for Victoria County and thus shows continued attainment through the end of the 

ten-year period following designation under the eight-hour standard. 

Table 3-1: Summary of VOC Emissions in Victoria County by Source Type (2004, 2010, and 2014)

Eight-Hour Ozone Maintenance Evaluation Years 2004, 2010, and 2014 

VOC (tons per average ozone season day) 

Source Category VOC (tons per average O3 season day) 

2004 2010 2014 

Area 6.31 6.85 7.23 

On-road Mobile 2.71 1.78 1.40 

Non-road Mobile 1.00 0.64 0.57 

Point 3.10 3.30 3.60 

Total 13.12 12.57 12.8 
3-2 

Table 3-2: Summary of NOX Emissions in Victoria County by Source Type (2004, 2010, and 2014)

Eight-Hour Ozone Maintenance Evaluation Years 2004, 2010, and 2014 

NOX (tons per average ozone season day) 

Source Category NOX (tons per average O3 season day) 

2004 2010 2014 

Area 2.65 2.90 3.07 

On-road Mobile 9.72 4.86 2.90 

Non-road Mobile 2.02 1.77 1.51 

Point 15.00 16.00 17.00 

Total 29.39 25.53 24.48 

3.2.1 Area Sources

Area sources of emissions are those that fall below the point source reporting levels and that are too 

numerous or too small to identify individually. Area sources are commercial, small-scale industrial, and 

residential categories that use materials or operate processes that generate emissions. Area sources are 

divided into two groups characterized by the emission mechanism: hydrocarbon evaporative emissions or 

fuel combustion emissions. Examples of hydrocarbon evaporative emission sources include: printing 

operations, industrial coatings, degreasing solvents, house paints, leaking underground storage tanks, and 

gasoline service station underground tank filling and vehicle refueling operations. Fuel combustion 

emission sources include stationary source fossil fuel combustion at residences and businesses, vehicle or 

equipment operations, outdoor burning, structural fires, and wildfires. 

 

Area source emission calculations are estimated as county-wide totals rather than as individual source 

emissions. These emissions, with some exceptions, may be calculated by multiplication of an established, 

U.S. Environmental Protection Agency (EPA) approved, emission factor (emissions per unit of activity) 

by the appropriate activity or activity surrogate responsible for generating emissions. Actual activity data 

is used when available. Examples include gallons of gasoline sold in a county, amount of printer ink 

used, number of wildfire acres burned, and amount of oil and natural gas produced. When actual activity 

data is unavailable, surrogates are used. These surrogates include total county population and 

employment data by industry type. Often actual activity data is available only at the state or national 

level and must be adapted to the county level using an appropriate surrogate. 

The 2002 Periodic Emissions Inventory (PEI) was the starting point for the area source 2002 EI for 

Victoria County. PEI categories and emissions were reviewed and subsequently updated with current 

methodologies and local activity data when it was available. Major efforts were made to locate 

appropriate activity data. Specific categories were updated using information and data that represent 

2002 activities. For other categories, emissions were grown from the 1999 EI to 2002 using the EPA’s 

EGAS growth factors. Use of these various methodologies resulted in the 2002 area source EI being 

compiled from several sources of data, including work from various contracts, TCEQ research, and the 

EPA’s National Emissions Inventory. 
3-3 

 

For those area source categories affected by TCEQ rules, rule effectiveness factors were applied to the 

baseline or uncontrolled emissions. These factors address the efficiency of the controls and the 

percentage of the category’s population affected by the rule. The area source EIs for future years 2004, 

2010, and 2014 were compiled using the EGAS growth factors. The EGAS contains individual growth 

factors for each category and for each forecasting year. This is the EPA standard and accepted method 

for developing future year EIs. 

Quality assurance of area source emissions involves ensuring that the activity data used for each separate 

category is current and valid. Data such as current population figures, fuel usage, and material usage 

were updated and EPA guidance on emission factors was used. Other routine efforts such as checking 

calculations for errors and conducting reasonableness and completeness checks were implemented. 

3.2.2 On-Road Mobile Sources

On-road mobile sources consist of automobiles, trucks, motorcycles, and other motor vehicles traveling 

on public roadways. Combustion-related emissions are estimated for vehicle engine exhaust, and 

evaporative hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources on 

the vehicle. The vehicle types are distributed into calculation bins based upon fuel usage (gasoline and 

diesel), vehicle weight, and vehicle emission standard classifications (cars, light trucks, and heavy trucks). 

The resulting 28 vehicle types are summarized in Table 3-3, MOBILE6 Vehicle Classifications. 
3-4 

Table 3-3: MOBILE6 Vehicle Classifications 

Number Abbreviation Vehicle Classification Description

1 LDGV Light-Duty Gasoline Vehicles (Passenger Cars) 

2 LDGT1 Light-Duty Gasoline Trucks 1 (0-6,000 lbs. GVWR, 0-3,750 lbs. LVW)

3 LDGT2 Light-Duty Gasoline Trucks 2 (0-6,000 lbs. GVWR, 3,751-5,750 lbs. LVW) 

4 LDGT3 Light-Duty Gasoline Trucks 3 (6,001-8,500 lbs. GVWR, 0-5,750 lbs. 

ALVW) 

5 LDGT4 Light-Duty Gasoline Trucks 4 (6,001-8,500 lbs. GVWR, greater than 5,751 

lbs. ALVW) 

6 HDGV2b Class 2b Heavy-Duty Gasoline Vehicles (8,501-10,000 lbs. GVWR) 

7 HDGV3 Class 3 Heavy-Duty Gasoline Vehicles (10,001-14,000 lbs. GVWR) 

8 HDGV4 Class 4 Heavy-Duty Gasoline Vehicles (14,001-16,000 lbs. GVWR) 

9 HDGV5 Class 5 Heavy-Duty Gasoline Vehicles (16,001-19,500 lbs. GVWR) 

10 HDGV6 Class 6 Heavy-Duty Gasoline Vehicles (19,501-26,000 lbs. GVWR) 

11 HDGV7 Class 7 Heavy-Duty Gasoline Vehicles (26,001-33,000 lbs. GVWR) 

12 HDGV8a Class 8a Heavy-Duty Gasoline Vehicles (33,001-60,000 lbs. GVWR) 

13 HDGV8b Class 8b Heavy-Duty Gasoline Vehicles (>60,000 lbs. GVWR) 

14 LDDV Light-Duty Diesel Vehicles (Passenger Cars) 

15 LDDT12 Light-Duty Diesel Trucks 1and 2 (0-6,000 lbs. GVWR) 

16 HDDV2b Class 2b Heavy-Duty Diesel Vehicles (8,501-10,000 lbs. GVWR) 

17 HDDV3 Class 3 Heavy-Duty Diesel Vehicles (10,001-14,000 lbs. GVWR) 

18 HDDV4 Class 4 Heavy-Duty Diesel Vehicles (14,001-16,000 lbs. GVWR) 

19 HDDV5 Class 5 Heavy-Duty Diesel Vehicles (16,001-19,500 lbs. GVWR) 

20 HDDV6 Class 6 Heavy-Duty Diesel Vehicles (19,501-26,000 lbs. GVWR) 

21 HDDV7 Class 7 Heavy-Duty Diesel Vehicles (26,001-33,000 lbs. GVWR) 

22 HDDV8a Class 8a Heavy-Duty Diesel Vehicles (33,001-60,000 lbs. GVWR) 

23 HDDV8b Class 8b Heavy-Duty Diesel Vehicles (>60,000 lbs. GVWR) 

24 MC Motorcycles (Gasoline) 

25 HDGB Gasoline Buses (School, Transit and Urban) 

26 HDDBT Diesel Transit and Urban Buses 

27 HDDBS Diesel School Buses 

28 LDDT34 Light-Duty Diesel Trucks 3 and 4 (6,001-8,500 lbs. GVWR) 

To estimate emissions from the 28 vehicle types, an emission rate per unit activity, or emission 

factor, and the activity level for each vehicle type must be determined. Both the emission factors 

and the activity level for on-road mobile vehicles may be estimated at various levels of temporal 

and spatial specificity. The level of specificity is generally determined based upon the final use 

of the inventory. Since the primary use of the Victoria County inventory is to confirm future 

emission level trends and no particular photochemical modeling will be performed using the 

inventories, the inventories were developed spatially at the county-wide level of detail using 

Highway Performance Monitoring System (HPMS) facility types rather than a roadway link 

network. The activity was temporally allocated to hourly time periods for purposes of speed 

calculation and emission estimations. The emission factors were developed using the newest 

version of the EPA's on-road mobile emission factor model, MOBILE6.2.03, released November 

2003. To the extent that local data was available, inputs to MOBILE6.2.03 were modified to 
3-5 

reflect those inputs. For the Victoria County inventories, information concerning local fuel 

parameters, meteorological conditions, and fleet characteristics were obtained and processed for 

input into MOBILE6.2.03. All inventory development methods used are consistent with the EPA 

guidelines for development of on-road mobile source inventories for use in State Implementation 

Plans (SIP). 

The Victoria County on-road mobile source emission inventories were developed under a TCEQ 

contract with the Texas Transportation Institute (TTI). A summary of the emission inventory 

development results is presented in Table 3-4: On-Road Mobile Source, Summer-Weekday1

Emissions Inventory Summary. The final contract report documenting all activities performed to 

develop the inventories and the emission results is provided as Appendix A: Development and 

Production of On-road Mobile Source Emissions Inventories for Victoria County: 2002, 2004, 

2010, and 2014. All electronic files associated with the inventory development and results are 

available at the public TCEQ FTP site, 

ftp://ftp.tnrcc.state.tx.us/pub/OEPAA/TAD/Modeling/Mobile_EI/. 

Table 3-4: On-Road Mobile Source, Summer-Weekday1

 Emissions Inventory Summary 

Year VMT 

(miles/day) 

Speed 

(mph) 

VOC 

(tons/day) 

NOX

2002 2,633,141 39.2 3.29 11.26 

2004 2,581,761 39.5 2.71 9.72 

2010 2,800,537 39.3 1.78 4.86 

2014 2,951,083 39.2 1.40 2.90 

1

 Based on average June through August, Monday through Friday activity estimates and average June 

through August 2002 Victoria Regional Airport meteorological data. 

Source: Development and Production of On-road Mobile Source Emissions Inventories for Victoria 

County: 2002, 2004, 2010, and 2014. Texas Transportation Institute, October 2005. 

3.2.3 Non-Road Mobile Sources

Non-road mobile categories include aircraft, railroad locomotives, recreational vehicles and 

boats, and a broad range of equipment from 600-horsepower engines in the construction 

equipment class to one-horsepower string trimmers in the lawn and garden class. For all nonroad mobile categories except aircraft, locomotives, and commercial marine vessels the EPA 

NON-ROAD model is used to calculate emissions. This model generates emissions for over 200 

individual types of equipment for the following classes: 

C Agricultural 

C Commercial 

C Construction 

C Industrial/Oilfield 

C Lawn and Garden 

C Logging 

C Railway Maintenance 

C Recreational 

C Recreational Marine 

Activity data in the NON-ROAD model used to calculate emissions include the equipment count, 

horsepower ranges, and fuel types. The model produces emissions for every county in the state, 
3-6 

using default activity data pro-rated from national data to the state and county levels using 

appropriate surrogates. Operating the model with all of the default surrogates in place is 

acceptable, however, the EPA encourages states to update the model with local, county-level data 

based on surveys and other relevant information. Local, county-level data is incorporated into the 

NON-ROAD model as it becomes available to the TCEQ. 

The latest NON-ROAD model, version 2004, was used to develop the Victoria County 2002 nonroad EI. Recent surveys and local data have improved Texas’ use of the model. Improvements to 

the following classes include the major VOC and NOX non-road mobile categories: construction, 

lawn and garden, oilfield, and recreational marine. 

Emissions from commercial and military aircraft are calculated using the Emissions and 

Dispersion Modeling System (EDMS) model which uses actual recorded landing/takeoff (LTO) 

data and aircraft types to generate emissions. Smaller aircraft emissions are calculated using the 

EPA’s emission factors and applicable LTO data. 

Emissions from locomotives are based on fuel use and track mileage. Individual railroad lines 

were surveyed for actual data to use in emissions calculation. These surveys and discussions with 

the railroad lines are ongoing with the intent to continue to improve the locomotive EI. 

The future years 2004, 2010, and 2014 EIs for non-road mobile sources were also developed by 

the NON-ROAD model. The model produces future year EIs routinely, and the most recent 

version contains future estimated activities and rules that will have an effect on the emissions. 

Projected LTO data was used to develop the future years for aircraft and ground support EIs, and 

railroad activity was projected to future years using previous year surveys and data collected from 

the railroad lines. 

Quality assurance procedures for non-road mobile source emissions rely mainly upon the quality 

of data used for each separate category. Data such as local equipment population figures and fuel 

usage routinely change annually. Sources of this information were contacted during the inventory 

development for updates. Using the current EPA NON-ROAD and EDMS models ensures that 

updates to equipment types, horsepower ranges, and results from applicable rules are applied to 

the emissions. Other routine efforts such as checking calculations for errors and conducting 

reasonableness and completeness checks were implemented. 

3.2.4 Stationary Point Sources

Stationary point source emissions and industrial process operating data are collected annually 

from sites that meet the reporting requirements of 30 Texas Administrative Code §101.10. To 

collect emissions and industrial process operating data for these plants, the TCEQ mails 

Emissions Inventory Questionnaires (EIQs) to all sources identified as meeting reporting 

requirements. Companies are required to report emissions data for all emission generating units 

and emission points, the type, and, for a representative sample of sources, the calculations used to 

determine the emissions reported. Information also requested in the EIQ are: process equipment 

descriptions; operation schedules; emissions control devices currently in use; abatement device 

control efficiency; and stack parameters such as location, height, and exhaust gas flow rate. All 

data submitted via the EIQ is then subjected to quality assurance procedures and entered into an 

electronic data base. Additional information is available upon request from the Industrial 

Emissions and Assessment Section of the TCEQ’s Air Quality Division. The evaluation years 

2004, 2010, and 2014 EIs for area sources were compiled using the Economic Growth Analysis 

System (EGAS) growth factors. The EGAS contains individual growth factors for each category 

and for each forecasting year. 
3-7 

3.2.5 Biogenic Sources

Biogenic sources include pine and oak forests, crops, and lawn grass that produce VOC emissions 

such as isoprene, monoterpene, and alpha-pinene. In addition, nitric oxide emissions are 

produced by soils. The EPA, using the latest Biogenic Emissions Inventory System (BEIS) 

model, provided the 2002 biogenic EI to the states. Data used in the model includes vegetation 

types and land use from satellite imaging, field biomass surveys, and emission factors for plant 

species. 

The EPA guidance excludes biogenic emissions from the baseline and future inventories, and thus 

this submittal does not consider biogenics. However, biogenic emissions are necessary to 

determine the overall emissions profile of an area and therefore are required for air quality 

modeling.

3.3 CONTROL STRATEGIES

To address the significant air quality concerns under the one-hour ozone NAAQS and the 

potential challenges imposed by the eight-hour ozone NAAQS, the TCEQ and the EPA have 

developed strategies to reduce NOX and VOC emissions. These strategies will help reduce ozone 

levels in the Victoria area. The following are descriptions of the strategies. 

3.3.1 National Volatile Organic Compound Emission Standards for Consumer Products 

Federal rules regulating the VOC content of consumer products are codified in 40 CFR 59 

Subpart C. These rules were promulgated in 1998. Since that time, rules requiring stricter VOC 

limits have been adopted in California and in the Ozone Transport Commission (OTC) states. 

The EPA is working to amend the federal rules based on the OTC model rule. Proposal is 

scheduled for April 2007, with promulgation in November 2007 and compliance by January 

2009. A study conducted by Principle Component Analysis (PCA) Services, Inc. for the Houston 

Advanced Research Center (HARC) under project H54 estimated that such a rule would reduce 

VOC emissions from consumer products by approximately 14.6% from baseline levels. 

3.3.2 National Organic Compound Emission Standards for Architectural Coatings 

Federal rules regulating the VOC content of architectural and industrial maintenance (AIM) 

coatings are codified in 40 CFR 59 Subpart D. These rules were promulgated in 1998. Since that 

time, rules requiring stricter VOC limits have been adopted in California and in the OTC states. 

The EPA is working to amend the federal rules based on the OTC model rule. Proposal of these 

rules is scheduled for April 2007, with promulgation in November 2007 and compliance by 

January 2009. A study conducted by PCA Services, Inc. for HARC under project H54 estimated 

that such a rule would reduce VOC emissions from AIM coatings by approximately 30% from 

baseline levels.

3.3.3 National Low Emission Vehicle (NLEV) Program/Tier 2 Engine and Fuel Standards 

Automobile manufacturers made a commitment through the NLEV program to introduce cleaner 

cars. This commitment along with improvements in gasoline quality, combined with the 

advanced vehicle technology, was to assist areas in achieving their overall air quality goals by 

reducing NOX emissions. The federal Tier 2 car and truck standards that have even more stringent 

emission standards than NLEVs, were phased in for all onroad and nonroad vehicles and 

equipment beginning with the 2004 model year. 
3-8 

3.3.4 Stage I Vapor Recovery

The commission adopted the Stage I vapor recovery rule on June 30, 1999, to reduce VOC 

emissions. These rules apply to approximately 7,000 gasoline stations in the Beaumont-Port 

Arthur (BPA), El Paso (ELP), Houston-Galveston-Brazoria (HGB), and Dallas-Fort Worth 

(DFW) areas, and across 95 counties in east and central Texas including Victoria County. The 

vapor recovery rules regulate the filling of gasoline storage tanks at gasoline stations by tank 

trucks. To comply with Stage I requirements, a vapor balance system is typically used to capture 

the vapors from the gasoline storage tanks that would otherwise be displaced to the atmosphere as 

these tanks are filled with gasoline. The captured vapors are routed back to the tanker truck and 

processed by a vapor control system when the tanker truck is subsequently refilled at a gasoline 

terminal or gasoline bulk plant and handled in an appropriate manner. The effectiveness of Stage 

I vapor recovery rules depends on the captured vapors being: (1) effectively contained within the 

gasoline tanker truck during transit; and (2) controlled when the transport vessel is refilled at a 

gasoline terminal or gasoline bulk plant. 

3.3.5 Cleaner Gasoline 

Low Reid Vapor Pressure (RVP) gasoline is fuel that is refined to have a lower evaporation rate 

and lower volatility than conventional gasoline. This gasoline also reduces the evaporative 

emissions generated during vehicle refueling and therefore decreases the emissions of volatile 

organic compounds (VOC). 

 

The Regional Low RVP Gasoline program requires low RVP gasoline in 95 central and eastern 

Texas counties during the summer months. The program, which began May 1, 2000, requires 

that all gasoline sold from retail gasoline-dispensing facilities within the affected counties have a 

maximum RVP of 7.8 pounds per square inch (psi) from June 1 through October 1 of each year. 

Gasoline suppliers are required to supply low RVP gasoline to the affected counties from May 1 

through October 1 of each year. 

3.3.6 Texas Low Emission Diesel (TxLED) 

This rule reduces emissions of NOX and other pollutants from diesel-powered motor vehicles and 

non-road equipment operating within 110 counties in the eastern half of Texas including Victoria 

County and the BPA, DFW, and HGB eight-hour ozone nonattainment areas. The rule was 

originally adopted by the commission in December 2000, and was revised in March 2005 and 

April 2006. TxLED rules require that diesel fuel produced for delivery and ultimate sale to the 

consumer must contain less than ten percent by volume aromatic hydrocarbons and must have a 

cetane number of 48 or greater. Some compliance options are allowed. TxLED implementation 

dates were October 31, 2005, for producers and importers; December 15, 2005, for bulk 

distribution facilities; and January 31, 2006, for retail fuel dispensing outlets, wholesale bulk 

purchasers, consumer facilities, and all other affected persons. 

3.3.7 Portable Fuel Container Rule

A statewide portable fuel container rule was adopted by the commission on October 27, 2004, to 

reduce VOC emissions. The rule establishes design criteria for “no-spill” portable fuel containers 

and portable fuel container spouts based in large part on the California Air Resources Board 

(CARB) standards. Effective December 31, 2005, these rules limit the type of portable fuel 

containers and portable fuel container spouts sold, offered for sale, manufactured, and/or 

distributed in Texas. Fuel released into the environment can lead to the contamination of both air 

and water. This rule ensures that portable fuel containers manufactured under these standards 

will release a smaller amount of fuel as the result of spillage and evaporation. 
3-9 

3.3.8 Texas Emission Reduction Plan (TERP) 

In 2001, the 77th Texas Legislature passed Senate Bill 5 which established the Texas Emission 

Reduction Plan (TERP). The TERP includes incentive grants programs to reduce emissions of 

NOX from internal combustion engines on mobile sources. Eligible grant projects include fleet 

expansions with cleaner engines, replacements of old vehicles and equipment, repower of old 

engines, and on-vehicle and on-site infrastructure for idle reduction, electrification, and delivery 

of alternative fuels. 

The current funding mechanisms for the TERP program are expected to generate approximately 

$140 million per fiscal year through August 31, 2010. Approximately $116 million is expected to 

be appropriated for use in the incentive grants program each year. 

As of March 2006, the program has awarded over $322 million for 720 projects, which are 

estimated to result in NOX reductions of over 73,000 tons, at an average cost per ton of NOX

reduced of $4,397. In the Victoria County area, the projects funded thus far are projected to 

result in NOX reductions of 223.5794 total tons, which equate to 0.1295 tons per day in 2007. 

The current TERP funding priorities are aimed at the nonattainment areas. Decisions on future 

TERP funding for projects in the Victoria area will depend upon the availability of funds and the 

need for reductions in the priority nonattainment areas under the new eight-hour SIP strategies in 

those areas. 

For information on recent TERP activities, please visit the TERP web site: www.terpgrants.org.

3.3.9 Non-Road Source Control Strategies 

The ozone control strategy for the Victoria area includes reductions realized from various federal 

engine standards for non-road sources. 

3.3.9.1 Anticipated Federal Emission Standards on Marine and Railroad Engines

The EPA is considering locomotive and marine diesel engine emission standards modeled after 

the 2007/2010 clean highway and non-road diesel engine program, with an emphasis on 

achieving large reductions in particulate matter (PM) emissions as early as possible through the 

use of advanced emission control technology. These standards, which could apply as early as 

2011, would be based on the application of high-efficiency catalytic aftertreatment enabled by the 

availability of clean diesel fuel with a sulfur content capped at 15 parts per million. The EPA 

estimated that the 2007/2010 clean highway and non-road diesel engine programs could reduce 

NOX and PM by 90 percent. The EPA expects that similar levels of NOX and PM reductions 

could be achieved by applying similar technologies to locomotives and marine diesel engines. 

The EPA is expected to propose the rule in the spring of 2007. 

3.3.10 Local Programs 

The City of Victoria’s air quality program, Air Victoria, is a non-profit organization that works to 

inform citizens in the Victoria area about air quality issues, promote voluntary compliance with 

clean air standards, and educate the public about health problems related to air quality. The 

following are descriptions of these programs. 

3.3.10.1 Air Victoria Team

The Air Victoria Team is a cooperative effort of the City of Victoria and the TCEQ to reduce 

emissions of ozone producing chemicals in the Victoria area. This team consists of more than 40 

businesses that agree to comply with best practices for improving air quality and participate in the 

TCEQ Small Business and Local Government Assistance or Pollution Prevention site visit 
3-10 

program. The program continues to grow as more businesses embrace environmental 

stewardship and as environmental education results in more participation by businesses and 

organizations. 

3.3.10.2 Ozone Alert System

The ozone alert system provided by the TCEQ is available through the Air Victoria website at 

http://www.airvictoria.org. The TCEQ provides e-mail alerts for ozone forecasts and ozone 

warnings for several metropolitan areas throughout Texas, including the Victoria area. Ozone 

forecasts are made for each day of the ozone season for each forecast area. Ozone warning e-mail 

notifications are generated automatically about 20 minutes after the hour when the high ozone 

was measured for that particular area. In addition, the Victoria Advocate weather page (local 

newspaper with 75,000 readers/day) provides information on signing up for the TCEQ alerts, 

which are released during ozone season, from May 1 to October 15. Ozone alert advisories are 

communicated to the community via television, radio, and print media. The Air Victoria team 

members also display ozone alert flags during alerts. 

3.3.10.3 Community Advisory Panel

The Victoria area air quality program is advised by the community advisory panel on outreach 

and education and by an expert technical advisory committee with regards to modeling and 

emissions inventory technical work. 

3.3.10.4 Public Education

The public education program uses community based social marketing and includes, but is not 

limited to: public speaking, outdoor advertising, radio, television, print media and publication of 

informational and educational materials. The program coordinator has an interactive relationship 

with all schools in the city and works to provide or enhance air quality curriculum and programs 

in all grade levels. 

3.4 EMISSIONS SUMMARY 

The 2002 base year and the 2004, 2010, and 2014 future year emissions inventory summaries by 

source categories for Victoria County are shown in Figures 3-1: Victoria County VOC Emissions 

by Major Source and 3-2, Victoria County NOX Emissions by Major Source. Emission totals are 

shown in Figures 3-3, Victoria County Total VOC Emissions and 3-4, Victoria County Total NOX

Emissions. These figures illustrate that the greatest man-made contribution of VOC is from area 

sources. For NOX, the greatest man-made contribution is from point sources. Contributions from 

biogenic emissions are not included in the summary because the maintenance measures are 

limited to the reduction of man-made emissions only. 

The percentages of emissions by source type for 2002, 2004, 2010, and 2014 are reflected in 

Table 3-5: Percentages of VOC Emissions in Victoria County by Source Type and Table 3-6: 

Percentages of NOX Emissions in Victoria County by Source Type. 
3-11 

Table 3-5: Percentages of VOC Emissions in Victoria County by Source Type

Eight-Hour Ozone Maintenance Evaluation Years 2002, 2004, 2010, and 2014 (See Tables 3-1 

and 3-2 for tons per average ozone season day) 

Source Category Evaluation Year 

2002 2004 2010 2014 

Area 46.9% 48.1% 54.5% 56.5% 

On-road Mobile 24.6% 20.7% 14.2% 10.9% 

Point 19.4% 23.6% 26.2% 28.1% 

Non-road Mobile

 

 9.1% 7.6% 5.1% 4.5% 

Table 3-6: Percentages of NOX Emissions in Victoria County by Source Type

Eight-Hour Ozone Maintenance Evaluation Years 2002, 2004, 2010, and 2014

Source Category Evaluation Year 

2002 2004 2010 2014 

Point 44.7% 51.0% 62.7% 69.4% 

On-road Mobile 38.8% 33.1% 19.0% 11.9% 

Area 8.8% 9.0% 11.4% 12.5% 

Non-road Mobile 7.7% 6.9% 6.9% 6.2% 
3-12 

2002 2004 2010 2014

0

1

2

3

4

5

6

7

8

POINT AREA

ONROAD MOBILE NONROAD MOBILE

Figure 3-1: Victoria County VOC Emissions by Major Source
3-13 

2002 2004 2010 2014

0

5

10

15

20

POINT AREA

ONROAD MOBILE NONROAD MOBILE

Figure 3-2: Victoria County NOx Emissions by Major Source
3-14 

13.38 13.12

12.57 12.8

2002 2004 2010 2014

0

5

10

15

Figure 3-3: Victoria County Total VOC Emissions
3-15 

29.1 29.4

25.5

24.5

2002 2004 2010 2014

0

5

10

15

20

25

30

35

Figure 3-4: Victoria County Total NOx Emissions
4-1 

CHAPTER 4: MONITORING NETWORK

4.1 GENERAL

The method chosen to verify continued attainment is the ambient air quality monitoring network. 

The ambient air monitoring site will remain active at the present location during the entire length 

of the maintenance plan period (2014) or if relocated or removed, will be done with the U.S. 

Environmental Protection Agency’s (EPA) concurrence. This data will be quality controlled and 

submitted to the EPA’s Aerometric Information Retrieval System (AIRS) on a monthly basis. A 

set of indicators and trigger levels, based on monitoring data, is specified in Section 

VI.B.10.a.7(e), Contingency Plan. 

The Victoria County monitoring network consists of an ambient air monitor located in the City of 

Victoria (CAMS 87) and is the monitor driving the area’s design value. The monitor is managed 

in accordance with 40 CFR Part 58, to verify the attainment status of the county. The TCEQ 

commits to keep the monitor in place until the end of the maintenance period (2014). The 

monitor will be used to detect if and when appropriate levels have been exceeded for contingency 

measure triggering purposes. 

 

The eight-hour ozone design value based upon data collected from 2003-2005 at the CAMS 87 

monitor is 76 parts per billion (ppb). Table 4-1: Summary of the Design Value of CAMS 87 from 

2000-2005, summarizes the design value of the CAMS 87 monitor from 2000-2005. 

Table 4-1: Summary of the Design Value of CAMS 87 from 2000-2005

 

2000 2001 2002 2003 2004 2005 

79ppb 79ppb 76ppb 78ppb 79ppb 76ppb 
5-1 

CHAPTER 5: CONTINGENCY PLAN

5.1 BACKGROUND

Phase I of the U.S. Environmental Protection Agency’s (EPA) Eight-Hour Ozone Implementation 

Rule requires that the Section 110(a)(1) maintenance plan include contingency provisions to 

promptly correct any exceedances of the National Ambient Air Quality Standards (NAAQS). 

The contingency plan ensures that the contingency measures are adopted expeditiously if they are 

triggered. In accordance with the EPA guidance2

, a series of early triggers have been established 

in order to effectuate appropriate and timely responses to indications of a possible future violation 

of the NAAQS. Thus, actions may be taken that can avoid a violation and potential redesignation 

to nonattainment. 

5.2 CONTINGENCY MEASURES AND TRIGGER LEVELS 

If air quality monitoring data indicates three or more eight-hour ozone exceedances within one 

calendar year, then the Texas Commission on Environmental Quality (TCEQ) will analyze 

available data regarding the air quality, meteorology, transport, and related activities in the area to 

determine the cause of the exceedances. The TCEQ will notify the EPA of its findings. 

If the area monitors an eight-hour ozone three-year average at or above 82 parts per billion (ppb), 

the local ozone advisory staff will institute a voluntary program with industry to reschedule, 

revise, or curtail activities during ozone advisory days. This program will be developed and 

available within 30 days after notification by the TCEQ that the contingency measure will be 

required. This program will be implemented as expeditiously as practicable, but no later than 24 

months after the TCEQ’s notification that the contingency measure is needed. 

 

If the area monitors an eight-hour ozone three-year average at or above 83 ppb, the TCEQ will 

work with the City of Victoria and the local Air Victoria Team to implement various voluntary 

control measures that may include: 

- increasing the number of businesses notified on Ozone Action Days substantially; 

- increasing the number of public announcements about ozone; and 

- other voluntary control measures as identified in a letter from the City of Victoria, dated 

December 11, 2006 (Appendix B: City of Victoria voluntary control measures). 

In addition, any previous efforts to reduce ozone may need to be retained. This program will be 

developed and available within 30 days after notification by the TCEQ that the contingency 

measure will be required. This program will be implemented as expeditiously as practicable, but 

no later than 24 months. 

Implementing voluntary emissions reduction measures usually require changes in personal or 

business behavior. Public awareness, notification, and education programs, as well as federal 

measures, are critical to achieving the goal of maintaining the eight-hour ozone standard. The 

exceedance triggers identified above and the proactive steps to be taken are expected to be 

sufficient to minimize exceedances and prevent violations of the eight-hour standard. However, 

if the area monitors an eight-hour ozone three-year average at or above 85 ppb, and if the TCEQ 

determines the cause of the violation can be controlled within the state’s jurisdiction through 

regulatory actions, then the TCEQ will take prompt and appropriate action, within 24 months, to 

identify and develop appropriate regulations or other quantifiable, permanent, and enforceable 

measures to reduce the ozone levels to the extent necessary to bring the design value below 

 

2

 EPA Memorandum: Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under 

Section 110(a)(1) of Clean Air Act; pages 8-9(May 20, 2005) 
5-2 

85 ppb. The Victoria area may also be expected to voluntarily implement some additional local 

control measures. 

 
RTC-1 

Response to Comments Received Regarding the 

Eight-Hour Ozone Maintenance Plan for the Victoria County Ozone Attainment Area 

State Implementation Plan Revision 

A public hearing was held in Victoria on October 17, 2006, at 1:30 p.m. No oral comments were 

received at this hearing. The commission did receive written comments from the U.S. 

Environmental Protection Agency (EPA). 

The EPA’s comments: 

Maintenance Demonstration (Chapter 3)

The EPA commented that the Texas Emission Reduction Plan, Chapter 3.3.6, needs to be 

reformatted. 

The commission appreciates EPA identifying the formatting issue and the correction has 

been made. 

Monitoring Network (Chapter 4)

The EPA commented that the reference to CAMS 602 in Chapter 4, Monitoring Network, should 

be removed since it does not meet the EPA monitoring Quality Assurance requirements from 40 

CFR Part 58 and was deactivated on February 23, 2006. 

The commission agrees with the EPA, and the references to CAMS 602 in the maintenance 

plan have been deleted. 

The EPA commented that in Table 4-1, Summary of the Design Value of CAMS 87 from 2000-

2005, the eight-hour ozone design value for the year 2000 should be 79 ppb. 

The commission agrees with EPA that the correct design value for 2000 is 79 ppb and the 

correction has been made. 

Contingency Plan (Chapter 5)

The EPA indicated that the maintenance plan must include contingency provisions, as necessary, 

to promptly correct any violations of the standard (40 CFR 51.905(a)(4)(ii)). The EPA supports 

the two exceedance triggers in the maintenance plan but stated that the plan should include a 

violation trigger as well. 

The plan has been revised based on this comment. The commission has added a violation 

trigger to the Contingency Plan. 

The EPA commented that all contingency measures must include specific timelines for 

implementation of the measures to ensure that all of the tasks required by the Contingency Plan 

will be adopted and implemented as expeditiously as practicable but no later than 24 months. 

The plan has been revised based on this comment. The commission added specific timelines 

for all triggers stating that the control measures will be adopted and implemented as 

expeditiously as practicable but no later than 24 months. 

The EPA commented that the phrase “and if the TCEQ determines the cause of the exceedance 

can be controlled by state actions” needs to be deleted. It is acceptable to EPA if TCEQ revised 
RTC-2 

this phrase to read as follows: “and if the TCEQ determines the cause of the exceedance can be 

controlled within the state’s jurisdiction through regulatory actions.” 

The plan has been revised based on this comment. The commission revised the phrase as 

indicated by EPA. 

The EPA commented that the plan must include clearly identified contingency measures 

associated with each trigger. The second trigger and the added violation trigger need to include 

specific control measures. 

Chapter 5 of the plan has been revised based on this comment to include specific voluntary 

control measures identified by the City of Victoria in the event of an exceedance. 

Additional text was added to clarify the steps to be taken if the area monitors an eight-hour 

ozone three-year average at or above 85 ppb, and if the TCEQ determines the cause of the 

violation can be controlled within the state’s jurisdiction through regulatory actions. 
CITY OF VICTORIA

Established 1824, Founded By congress, Republic of Texas, 1839 

ENVIRONMENTAL SERVICES DEPARTMENT 

700 Main Center, Suite 108

P.O. BOX 175 · VICTORIA, TEXAS 77902-1758 · (361) 485-338 · FAX (361) 

485-3385 

1

December 11, 2007 

Kathy Singleton 

Air Quality Planning Staff 

Dear Kathy: 

The City of Victoria offers the following voluntary control measures on the Victoria 

Maintenance plan: 

• Air quality curricula (Andy Airedale) in all third grade classrooms and Drive Clean 

Across Texas in all fourth grade classrooms in public and private schools in Victoria 

County 

• PowerPoint presentations modified for diverse audiences with an accompanying 

educational materials (brochure, collaterals) addressing the subject matters of 

Air Quality and Health, Medical Presentation for Health Care Professionals, Air 

Friendly Landscaping, Air Victoria—Keep It Clean, Air Victoria Team, Idle Reduction 

and Walking School Bus 

• Contributions of articles, editorials and photos to the Victoria Advocate newspaper 

with a circulation of 75,000/day 

• Conduct an ozone season kick off event 

• Sponsorship of bus wraps with clean air message on 2 Victoria Transit buses 

• Implementation of the “Statewide Transportation Air Quality Public Outreach and 

Education Program” in partnership with the Texas Transportation Institute, Texas 

Department of Transportation, and Texas Commission on Environmental Quality using 

television spots, billboards, and radio spots to encourage Texans to “Drive Clean across 

Texas” through car-pooling, proper vehicle maintenance and alternative transportation 

options and participate in DCAT Speaker’s bureau 

• Employment of TCEQ’s world-wide-web-based “Today’s Air Quality Forecast” 

extending over four days, giving participants more advance notice enabling better 

planning of ozone action day activities on television, radio, newspaper and email blast 

• Implementation of ozone action day messages and recommendations on National 

Weather Service telephone recordings, web site, television weather information 

channels, and weather radio announcements 

• Continued growth of the Air Victoria Team program educating small businesses on 

methods to reduce emissions focusing on mobile sources. The program features 

Pollution Prevention site visits provided by TCEQ contract staff. Team members 

annually report emission reductions and participate in ongoing education through 

meetings, publications and emails. 
P.O. BOX 175 · VICTORIA, TEXAS 77902-1758 · (361) 485-338 · FAX (361) 

485-3385 

2

• Implementation of Clean Cities program to educate vehicle fleet operators and fleet 

maintenance facilities on the use of alternative fuels and transportations affect on air 

quality. Owners of commercial and fleet vehicles will be identified, contacted, and 

baseline information collected. Viable pollution prevention strategies including 

alternate fuels and installation of pollution prevention equipment is promoted. 

• Expand provision of bus service to City of Victoria employees on “Free Ride” days 

• Facilitation of Lawn Care Equipment Exchange event to exchange gas powered lawn 

equipment for electric powered equipment 

• Facilitation of Car Care Month event to promote vehicle maintenance to improve air 

quality 

• Facilitation of educational booth at major community events with distribution of 

educational materials and public interaction 

• Install Stop at the Click stickers on 1100 gas pumps in the city of Victoria 

• Implementation of Blue Sky Initiative to reduce school zone idling including bus 

driver/parent/teacher/administrator/student education programs and materials and 

development of a Blue Sky patrol team for fifth grade students 

• Educational marketing on television, radio, outdoor and print media on air quality 

messages in both English and Spanish language including 

o Fuel up, mow and run errands after 5 p.m. 

o Rideshare and tripchain 

o Stop at the Click 

o Reduce Idling 

Should any of these voluntary control measures require further clarification, please be in 

touch. Thank you for your support of our air quality program in Victoria. 

Regards, 

Joni Brown, Environmental Programs Coordinator 

City of Victoria, Environmental Services 
ORDER ADOPTING REVISION 

TO THE STATE IMPLEMENT A Tl ON PL ~~·onrnl cu,,wr.ueio:, Chief Cieri\ . 

let~ Commission on Environmental Quality 

Docket No. 2006-0229-SIP 

On March 7, 2007, the Texas Commission on Environmental Quality (Commission), during a public 

meeting, considered adoption of a revision to the State Implementation Plan (SIP) to incorporate a plan for 

maintenance of the eight-hour ozone National Ambient Air Quality Standard (NAAQS) in Victoria County as 

required by 40 Code of Federal Regulations §5l.905(a)(3) and (4). The C01runission adopts this revision to 

SIP. The revision incorporating the ozone maintenance plan contains results of an updated attainment 

emissions inventory and teclmical analyses in support of the projections demonstrating maintenance of the 

eight-hour ozone NAAQS through 2014; a discussion of monitoring data demonstrating attainment of the 

eight-hour ozone NAAQS; and a discussion of the contingency plan and trigger levels. Under Tex. Health & 

Safety Code Ann. §§ 382.011, 382.012, and 382.023 (Vernon 2001), the Commission has the authority to 

control the quality of the state's air and to issue orders consistent with the policies and purposes of the Texas 

Clean Air Act, Chapter 382 of the Tex. Health & Safety Code. Notice of the proposed SIP revision was 

published for c01mnent in the September 22, 2006 issue of the Texas Register (31 TexReg 8137). 

Pursuant to 40 Code of Federal Regulations § 51.102 and after proper notice, the Commission 

conducted a public hearing to consider the revision to the SIP. Proper notice included prominent 

advertisement in the areas affected at least 30 days prior to the date of the hearing. A public hearing was held 

in Victoria, Texas on October 17, 2006. 

The Commission circulated hearing notices of its intended action to the public, including interested 

persons, the Regional Administrator of the EPA, and all applicable local air pollution control agencies. The 

public was invited to submit data, views, and recmrunendations on the proposed SIP revision, either orally or 

in writing, at the hearing or during the comment period. Prior to the scheduled hearing, copies of the 

proposed SIP revision were available for public inspection at the Commission's central office and on the 

Commission's Web site. 

Data, views, and recommendations of interested persons regarding the proposed SIP reviSIOn were 

submitted to the Commission during the comment period, and were considered by the Commission as 

reflected in the analysis of testimony incorporated by reference to this Order. The Commission finds that the 

analysis of testimony includes the names of all interested groups or associations offering comment on the 

proposed SIP revision and their position concerning the same. 

IT IS THEREFORE ORDERED BY THE COMMISSION that the revision to the SIP incorporated by 

reference to this Order is hereby adopted. The adopted revision to the SIP is incorporated by reference in this 

Order as if set forth at length verbatim in this Order. 

IT IS FURTHER ORDERED BY THE COMMISSION that on behalf of the Commission, the 

Chairman should transmit a copy of this Order, together with the adopted revision to the SIP, to the Regional 
Administrator of EPA as a proposed revision to the Texas SIP pursuant to the Federal Clean Air Act, § 110, 

codified at 42 U.S. Code Ann.§§ 7401- 767lq, as amended. 

If any portion of this Order is for any reason held to be invalid by a court of competent jurisdiction, 

the invalidity of any portion shall not affect the validity of the remaining portions. 

Date issued: MAR 14 Z007 TEXAS COMMISSION ON 

ENVIRONMENTAL QUALITY