Kathleen Hartnett White, Chairman Larry R. Soward, Commissioner
Glenn Shankle, Executive Director



## TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Protecting Texas .by Reducing andPreventing 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 §

### 110(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 OFTEXAS

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 QualityTexas Commission on Environmental Quality Public Hearing October 17, 2006
Concerning the Victoria County Eight-Hour Ozone Maintenance Plan Rule Project No. 2006-023-SIP-NRINTRODUCTION

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 ofthe 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 PROPOSALPUBLIC 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 ServicesNorth 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 AgencyExample 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::advanee :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** ple 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 ofdetecting 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 ofpetroleum 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 ofthe ChiefClerk 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 ofthe ChiefClerk, Mail Code 105, PO. Box 13087, Austin, TX 78711-3087.
Public notices issued by the Office ofthe ChiefClerk are also available for viewing at www.tceq.state.tx.us/comm

_exec/cc/cc

_db.html.
Individual members ofthe 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 ofPublic 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 ofthe 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 ofthe projections demonstrating maintenance of the eight-hour ozone standard through 2014; a discussion of monitoring data demonstrating attainment ofthe eight-hour ozone NAAQS; and a discussion ofthe 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 ofregistration. There will be no open discussion during the hearing; however, an agency staffmember 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 planningto 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, ChiefEngineer'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 ofWater 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 ofthe ChiefClerk, Mail Code 105, P.O. Box 13087, Austin, Texas 78711-3087, WITHIN

INADDITION September 22, 2006 31 TexReg 8137Kathleen 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 ofthe projections demonstrating maintenance ofthe eighthour ozone standard through 20 14; a discussion of monitoring data demonstrating attainment of the eight-hour

ozone NAAQS; and a discussion ofthe 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 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.

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.usREVISIONS 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, 2006VICTORIA 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 ofContinued 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 LevelsNumber

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 ofVOC Emissions in Victoria County by Source Type (2002) Summary ofNOx 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 ofVOC Emissions in Victoria County by Source Type Percentage ofNOx Emissions in Victoria County by Source Type Summary ofthe Design Value ofCAMS87 from 2000-2005

11VICTORIA 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

111Number VICTORIA COUNTY EIGHT-HOUR OZONE MAINTENANCE PLAN LIST OF APPENDICES
Appendix Name
Appendix A Development and Production ofOn-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/OEPAAITAD/Modeling/Mobile Ell).



### ivVICTORIA 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 ofPublic 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 ofTexas 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



### vEXECUTIVE 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 ofJune 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 ofthe 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) ofthe Federal Clean Air Act (FCAA). (69 FR 23951)

Under 40-CFR 51.905(a)(3) and (4), States must submit section 11O(a)(l) maintenance plans no later than 3 years after the effective date ofthe 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 ofcontinued attainment.

With this SIP revision, the TCEQ is submitting an eight-hour ozone maintenance plan that will ensure the County ofVictoria remains in attainment ofthe 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 ofPlan The purpose ofthis State Implementation Plan (SIP) revision is to submit an eight-hour ozone maintenance plan that will ensure Victoria County remains in attainment ofthe 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 ofmonitored data and to reach attainment by November 15, 1995. Victoria County completed three consecutive years ofmonitoring on May 2, 1994, with a design value of0.10 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 ofthe Air, Pesticides, and Toxics Division to Ms. Beverly Hartsock, Deputy Executive Director, Office ofAir 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 relieffrom certain maintenance plan requirements. Eighty-five percent ofthe 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 ofthe 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) ofthe 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 ofthe area's eight-hour ozone NAAQS designation. June 15, 2004, is the effective date ofeight-hour ozone designations, therefore, the section 110(a)(l) eight-hour ozone maintenance plan must be submitted no later than June 15, 2007.



### 1-11.1.3.1 Maintenance Plan Components EPA-issued guidance 1 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 ofthe 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 ofthe 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 ofthis plan.

1 EPA Memorandum: Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas Under Section 11 O(a)(1) ofClean AirAct; (May 20, 2005)

1-2CHAPTER 2: ATTAINMENT INVENTORY

2.1 OVERVIEW The attainment inventory is based on the VOC and NOx emissions ofan 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 ofeach pollutant emitted, and the types ofprocesses and control devices employed at stationary sources or other

source categories. The EI provides data for a variety ofair 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 ofemissions ofVOC and NOx for an area is summarized from the estimates developed for four general categories ofemissions 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 ofVOC 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



### 2-1Table 2-2: Summary ofNOx 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



### 2-2CHAPTER 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 ofthe maintenance plan, 20 14, interim years of2004 and 2010 were selected to show a trend analysis for maintenance of the eight-hour ozone NAAQS. Tables 3-1, Summary ofVOC 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 ofthe 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 ofthe 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 ofemissions 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 ofhydrocarbon 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.



### 3-2Emissions 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 ofan established, EPA approved, emission factor (emissions per unit ofactivity) by the appropriate activity or activity surrogate responsible for generating emissions. Actual activity data is used when available. Examples include gallons ofgasoline sold in a county, amount ofprinter ink used, number ofwildfire acres burned, and amount ofoil 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 ofthese various methodologies resulted in the 2002 area source EI being compiled from several sources ofdata, 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 ofthe controls and the percentage ofthe 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 ofarea 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 ofequipment 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 ofequipment 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 ofthe 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 ofdata used for each separate category. Data such as local equipment population figures and fuel usage routinely change annually. Sources ofthis 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.



### 3-4Table 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. 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 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 oftemporal and spatial specificity. The level of specificity is generally determined based upon the final use ofthe inventory. Since the primary use ofthe 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 ofdetail 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,



### 3-5information 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 ofon-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 ofthe 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 AppendixA: Development and Production of On-roadMobile Source Emissions Inventoriesfor 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 ofOn-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 ofan 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 ofsome ofthe 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 NLEVs, 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 ofgasoline 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 ofvolatile 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 ofeach year. Gasoline suppliers are required to supply low RVP gasoline to the affected counties from May 1 through October 1 ofeach 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 halfofTexas 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 of48 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 ofportable fuel containers and portable fuel container spouts sold, offered for sale, manufactured, and/or distributed in the State ofTexas. Fuel released into the environment can lead to the contamination ofboth air and water. This rule ensures that portable fuel containers manufactured under these standards will release a smaller amount offuel 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 ofold vehicles and equipment, repower ofold engines, and on-vehicle and on-site infrastructure for idle reduction, electrification, and delivery ofalternative 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 ofVictoria'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 ofthese programs.



### 3.3.8.1 Air Victoria Team A cooperative effort ofthe City ofVictoria and the TCEQ to reduce emissions ofozone producing chemicals in the Victoria area. This coalition consists ofmore than 40 businesses that agree to comply with best practices for improving air quality and participate in the TCEQ Small



### 3-8Business 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 ofcommunity based social marketing and includes, but is not limited to: public speaking, outdoor advertising, radio, television, print media and publication ofinformational 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 ofmanmade 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.



### 3-9Table 3-5 Percentages ofVOC 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 ofNOx 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

3-14CHAPTER 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 ofthe maintenance plan period (2014) or ifrelocated 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 ofthe City ofVictoria (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 ofCAMS 87 from 2000-2005, 

### summarizes the design value ofthe CAMS 87 monitor from 2000-2005.

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



### 4-1CHAPTER 5: CONTINGENCY PLAN

5.1 BACKGROUND Phase I ofEPA's Eight-Hour Ozone Implementation Rule requires the section llO(a)(l) maintenance plan include contingency provisions to promptly correct any exceedances ofthe NAAQS. The contingency plan ensures that the contingency measures are adopted expeditiously ifthey are triggered. In accordance with EPA guidance2 a series ofearly triggers have been established in order to effectuate appropriate and timely responses to indications ofa possible future violation ofthe 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 ofthe exceedances. The TCEQ will notify EPA ofits findings·.

Ifthe area monitors an eight-hour ozone three-year average at or above 82 ppb, the ozone advisory staffwill 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.

Ifthe area monitors an eight-hour ozone three-year average at or above 83 ppb, and ifthe TCEQ determines the cause ofthe 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 ofpotential 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 AirAct; pages 8-9(May 20, 2005)



### 5-1

# WRITTEN AND ORAL TESTIMONYReference 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 ChiefEngineer'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 ofthis 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 ofthe 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 ofthe 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 ofthe 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 timelines must ensure that all ofthe 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. Forthe third paragraph, first sentence, the following phrase needs to be deleted: "and ifthe TCEQ determinesthe cause of the exceedance can be controlled by state actions." It

### is acceptable to EPA ifTCEQ 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 ofthe 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 inthe 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 SectionINDEX 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)

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# 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

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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 noCommissioners 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. Wadick 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 TeamResponse 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 ofthe 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 ofthe measures to ensure that all ofthe 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 ifthe TCEQ determines the cause ofthe exceedance

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

RTC-1this phrase to read as follows: "and ifthe TCEQ determines the cause ofthe exceedance can be controlled within the state'sjurisdiction 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 ifthe TCEQ determines the cause ofthe violation can be controlled within the state'sjurisdiction 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 ATfAINMENT 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 KV

### s -- 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 standardand required a maintenance plan be submitted in eight years. The one-hour maintenance plan was submitted to the EPA on Febr uary 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:

Cattainment inventory;

Cmaintenance demonstration;

Cambient air quality monitoring;

Ccontingency plan; and

Cverification 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 withthe 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 standardcan 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. OnMay 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.

1EPA 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 Typeand Table 2-2: Summary ofNOX

### 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 datefor 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 Typeand 3-2: Summary of NOX 

### Emissions in Victoria County by Source Typedepict 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)

VOC (tons per average O3 

### season day) Source Category

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)

NOX

### (tons per average O3

### season day) Source Category

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 werereviewed 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 workfrom 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-DutyGasoline 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 pa rticular 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 f actor 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, f tp://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

1Based 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 constructionequipment 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 futureyears 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 thisinformation 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 requirementsof 30 Texas Administrative Code §101.10. To collect emissions and industrial process operating data for these plants, the TCEQ mails Emissions Inventory Questionnaires (EIQs) toall 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 toquality 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’sAir 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 phasedin 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 va por 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 anappropriate 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 inthe 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 practicesfor 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 basedsocial 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 Sourceand 3-2, Victoria County NOX

### Emissions by Major Source. Emission totals are shown in Figures 3-3, Victoria County Total VOC Emissionsand 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 Typeand Table 3-6: Percentages ofNOX

### 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)

Evaluation Year Source Category

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

Evaluation Year Source Category

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-yearaverage 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 advisorydays. 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 ina 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

2EPA 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 expectedto 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 TCEQdetermines 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 inDCAT 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 identif ied, contacted, and baseline information collected. Viablepollution 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 exchangegas 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 patrolteam 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 ServicesORDER ADOPTING REVISION TO THE STATE IMPLEMENT ATlON 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 RegionalAdministrator 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