John R. Kasich, Governor Mary Taylor, Lt. Governor
Scott J. Nally, Director



### NOV 2 6 2012

Susan Hedman Regional Administrator U.S. EPA, Region 5 77 West Jackson Blvd. R-19J Chicago, Illinois 60604-3507

Re: Request for Review and Approval of the Revised Canton-Massillon Area Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard

Dear Administrator Hedman:

I am writing to formally request review and approval of a revision to the maintenance plan for the Ohio portion of the Canton-Massillon area (Stark County) with respect to the 1997 eighthour ozone standard. Ohio EPA submitted a redesignation request and maintenance plan for this area on June 20, 2006. U.S. EPA approved this requests on May 16, 2007 (72 FR 27648).

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budgets based on emission rates generated from U.S. EPA's latest mobile emissions model, the Motor Vehicle Emission Simulation (MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA's official emission factor model. The area is still attaining and maintaining the 1997 8-hour ozone standard and the point, area and non-road emissions have not changed significantly and did not need to be updated for this submittal.

The enclosed information was compiled by Ohio EPA, Ohio Department of Transportation, and Miami Valley Regional Planning Commission. The public hearing for this package was held on November 8, 2012 in Canton, Ohio. No testimony was provided, nor were any comments received.

This submittal consists of one (1) hard copy of the required documentation. An exact duplicate electronic version of the submittal in PDF format is available at http://epa.ohio.gov/dapc/SIP/1997.aspx under the heading" Redesignations and Maintenance Plans".

50 WestTown Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 www.epa.ohio.gov • (614) 644-3020 •(614) 644-3184(fax)If you have any questions, please contact Jennifer Dines in the Division of Air Pollution Control at (614) 644-3696.

Sincerely, 

# :::.:z

Director

enclosures

cc: Bob Hodanbosi, DAPC Jennifer Dines, DAPC

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR THE CANTON-MASSILLON EIGHT-HOUR OZONE NONATTAINMENT AREA

Stark County, Ohio

Developed By: Ohio Environmental Protection Agency Division of Air Pollution Control

June 20, 2006 Revised November 2012This page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Background .................................................................................................................... ............... 1 Geographical description ...................................................................................................... ........ 2 Status of air quality ......................................................................................................... .............. 2

Chapter Two Requirements for redesignation ................................................................................................ .... 3

Chapter Three Ozone monitoring .......................................................................................................................... 6 Ambient data quality assured ........................................................................................................ 7 Three complete years of data .................................................................................................. ..... 7 Commitment to continue monitoring ............................................................................................. 8

Chapter Four Emission Inventory ............................................................................................................ ............ 9 Base Year Inventory ........................................................................................................... .......... 9 Emission Projections ................................................................................................................... 10 Demonstration of Maintenance .................................................................................................. . 14 Permanent and Enforceable Emissions Reductions ................................................................... 16 Provisions for Future Updates ................................................................................................. ... 17

Chapter Five Control measures and regulations .............................................................................................. 18 Implementation of Past SIP Revisions ........................................................................................ 1 8 New Source Review Provisions ................................................................................................. 20 Assurance of continued controls ............................................................................................... .. 20

Chapter Six Contingency measures .......................................................................................................... ..... 22 Commitment to revise plan ..................................................................................................... .... 22 Commitment for contingency measures ..................................................................................... 22 Potential contingency measures ................................................................................................ . 23 List of VOC and NO x sources...................................................................................................... 24

Chapter Seven Public participation .......................................................................................................... ............ 26

Chapter Eight Conclusions ................................................................................................................... ............. 27ii FIGURES

Figure 1 Stark County Basic Nonattainment Area ............................................................... 6

TABLES

Table 1 Monitoring Data for Stark County 2003 – 2005 ..................................................... 8 Table 2 Emission estimations for on-road mobile sources ............................................... 13 Table 3 Motor vehicle emissions budget .......................................................................... 13 Table 4 Projected VOC emission estimates ..................................................................... 15 Table 5 Projected NO x emission Inventory Totals ............................................................ 15 Table 6 Projected emission estimates 2004-2018 VOC/NO x totals .................................. 16 Table 7 Comparison of 2002-2004 on-road and EGU totals ............................................ 17

APPENDICES

A Aerometric Information Retrieval System (AIRS) Data B Emission Inventories C Emissions Analysis Method D Public Participation Documentationiii This page left intentionally blank1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR CANTON-MASSILLON

EIGHT-HOUR OZONE NONATTAINMENT AREA

STARK COUNTY, OHIO



### CHAPTER ONE

Introduction The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the United States Environmental Protection Agency (U.S. EPA) revised the ai r quality standards for ozone replacing the 1979 one-hour standard with an eight -hour ozone standard set at 0.08 parts per million (ppm.) The standard was challenged legally and upheld by the U.S. Supreme Court in February of 2001.

On April 15, 2004, U.S. EPA designated 134 nonatta inment areas for t he eight-hour ozone standard. Since that time, U.S. EPA has recla ssified nine of the 134 original nonattainment areas to the next lower classification. Sect ion 107(d)(3)(E) of the CAA allows states to request nonattainment areas be redesignated to attainment providing ce rtain criteria are met. The following are the criteria that must be met in order for an ar ea to be redesignated from nonattainment to attainment:

i) A determination that the area has a ttained the eight-hour ozone standard. ii) An approved SIP for the area under Section 110(k). iii) A determination that the improvement in air qua lity is due to permanent and enforceable reductions in emissions resulting fr om implementation of the SIP and other f ederal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements have been
met.

Background As part of the 1990 CAA Amendm ents re-evaluation, Stark County was designated as Unclassifiable/Attainment for the one-hour ozone standard purs uant to the CAA and therefore, has not previously been subject to nona ttainment area rule-makings. As a result of the 2004 ozone designations, U.S. EPA des ignated Stark County basic nonattainment and subject to the eight-hour ozone requirem ents, including development of a plan to reduce volatile organic compounds (V OCs) and oxides of nitrogen (NO x ) emissions and a demonstration that the area will meet the federal eight-hour air quality standard for ozone by June 2009.

This document is intended to support Ohio’s request that Stark County be redesignated from nonattainment to attainm ent for the eight-hour ozone standard. Stark County has2 recorded three (3) years of complete, quality- assured ambient air quality monitoring data for the years 2003 – 2005 demonstrating attainm ent of the eight-hour ozone standard.

Geographical Description Stark County is located in eastern Ohio and c ontains the City of Cant on. Stark County is bordered by Summit and Portage Counties to the north, Mahoning and Columbiana to the east, Tuscarawas and Carroll to the south and Wayne and Holmes to the west. Stark County is shown in Figure 1.

Status of Air Quality Ozone monitoring data for the most recent three (3) years, 2003 through 2005, demonstrates that the air quality has met the N AAQS for ozone in this basic nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter four, supports a r edesignation to attainment for Stark County based on requirements in Section 107(d)(3)(E) of the CAA.3 

### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directo rs. This request for redesignation and maintenance plan is based on t he redesignation guidance, supplemented with additional guidance received from staff of U.S. EPA Region V.

Below is a summary of each redesignation cr iterion as it applies to Stark County.

i.) Attainment of the standard: There are two components involved in ma king this demonstration. The first component relies on ambient air quality data. The data that are used to demonstrate attainment should be the pr oduct of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality-assured in accor dance with 40 CFR 58 and recorded in the Aerometric Information Retrieval S ystem (AIRS) in order for it to be available to the public for review.

The second component relies upon s upplemental U.S. EPA-approved air quality modeling. The s upplemental modeling is not required for ozone nonattainment areas seeking redesignat ion. Therefore, this ozone redesignation request for Stark Count y does not include modeling data. However, in Appendix C the most rec ent modeling results showing future attainment and maintenance are provi ded. Chapter three discusses this requirement in more detail and provi des the attainment demonstration.

ii.) SIP approval: The SIP for the area must be fully approved under Section 110(k) and must satisfy all requirements that apply to t he area. Ohio’s SIP was approved on May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes Stark County. Chapter five discusses this r equirement in more detail and provides the attainment demonstration.

iii.) Permanent and enforceable im provement in air quality; The state must be able to reasonably a ttribute the improvement in air quality to emission reductions which are pe rmanent and enforceabl e. The state should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and implemented by the
state.

Stark County was not designated nonatta inment for ozone as part of the 1990 CAA Amendments re-evaluation. As a result, Ohio has not adopted or implemented control measures beyond the federal measures, the initial 1979 statewide rules and those 1994 and 1995 rules which applied to “rural”4 attainment areas. Chapters four and fi ve discuss this requirement in more detail and provide the atta inment demonstration.

iv.) Section 110 and Part D requirements: For purposes of redesignation, a state mu st meet all requir ements of Section 110 and part D that were applicable prio r to submittal of the complete redesignation request.

Part D consists of general requirem ents applicable to all areas which are designated nonattainment based on a violation of the NAAQS.

i.) Section 172(c) requirements This section contains general r equirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesi gnations because they only have meaning for areas not attaining the standard. The r equirements for an emission inventory will be satisfied by the inventory requirements of the maintenance plan.

ii.) Conformity The state must work with U.S. EPA to show that its SIP provisions are consistent with section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state mu st commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

v.) Maintenance plans. Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan which meets the requirements of Section 175(A). The maintenance plan will constitute a SIP revision and must provide for maintenance of the rele vant NAAQS in the area for at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.

In addition, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a mini mum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.5 States seeking redesignat ion of a nonattainment ar ea should consider the following provisions:

a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification of continued attainment; and e.) contingency plan.

Chapter six discusses this requirem ent in more detail and provides the attainment demonstration.6 

### CHAPTER THREE

OZONE MONITORING CAA Section107 (d)(3)(E)(i)

Requirement 1 of 4 : A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show that violations of the ambient standard are no longer occurring.

Background : There are three monitors measur ing ozone concentrations in this nonattainment area. The monitors are operated by Canton City Health Department’s Air Pollution Control Section. The locations of the monitoring sites for this nonattainment area are shown in Figure 1.

Demonstration :

Figure 1 Map of Stark County7 Requirement 2 of 4 : Ambient monitoring data quality assured in acco rdance with 40 CFR 58.10, recorded in the U.S. EPA Air Quality System (AQS) dat abase, and available for public view.

Demonstration : The Ohio Environmental Protection Agency (Ohio EPA) has quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio Quality Assurance Manual. Ohio EPA has recorded the data in the AQS database and therefore data are available to the public.

Requirement 3 of 4 : A showing that the three-year average of the fourth highest values, based on data from all monitoring sites in the area or its affected dow nwind environs, are below 85 parts per billion (ppb). This showing must rely on three (3) co mplete, consecutive cal endar years of quality assured data.

Background : The following information is taken from U.S. EPA's "Guideline on Data Handling Conventions for the eight-hour Ozone National Ambient Air Quality Standard (NAAQS)," U.S. EPA- 454/R-98-017, December 1998.

Three (3) complete years of ozone monitoring data are required to demonstrate attainment at a monitori ng site. The eight-hour primary and secondary ozone ambient air quality st andards are met at an ambient air quality monitoring site when the three- year average of t he annual fourthhighest daily maximum eight-hour aver age ozone concentration is less than or equal to 0.08 ppm. When this occurs, t he site is said to be in attainment. Three (3) significant digits must be ca rried in the computations. Because the third decimal digit, in ppm , is rounded, 0.084 ppm is th e largest concentration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight-hour standard is c onsidered to be 0.085 ppm. Values below 0.085 ppm meet the standard, va lues equal to or greater than 0.085 ppm exceed the standard. These dat a handling procedures are applied on an individual basis at each monitor in t he area. An area is in compliance with the eight-hour ozone NAAQS if, and only if, every monitoring site in the area meets the NAAQS. An individual site 's three (3) year average of the annual fourth highest daily maximum eight-hour average ozone concen tration is also called the site's design value. Tabl e 1 shows the monitoring data for the three most recent years, 2003 - 2005, at the nonattainment area sites and was retrieved from the U.S. EPA AQS.8 Demonstration :

Table 1: Monitoring Data for Stark County 2003 – 2005

Data source: U.S. EPA Air Quality System (AQS). http://www.epa.gov/ttn/airs/airsaqs/index.htm

1 s t 2 n d 3 r d 4 th 2003-2005 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 39-151-0016 STARK MALONE COLLE GE 2003 100 .106 .104 .092 .087

.079 39-151-0016 STARK MALONE COLLE GE 2004 92 .086 .082 .076 .074 39-151-0016 STARK MALONE COLLE GE 2005 96 .087 .080 .079 .076 39-151-0021 STARK 245 WEST FIFT H 2003 100 .099 .099 .090 .085

.077 39-151-0021 STARK 245 WEST FIFT H 2004 99 .085 .075 .073 .071 39-151-0021 STARK 245 WEST FIFT H 2005 100 .083 .078 .077 .076 39-151-4005 STARK 1175 WEST VINE 2003 100 .116 .106 .101 .086

.082 39-151-4005 STARK 1175 WEST VINE 2004 98 .084 .079 .076 .076 39-151-4005 STARK 1175 WEST VINE 2005 100 .106 .088 .087 .086 Highest Average 0.82 ppm

A comprehensive list of the site’s des ign values during the 2003-2005 time period is in Appendix A. The area's design value has trended downward as emissions have declined due to such factors as cleaner automobiles and fuels both regionally and loca lly. U.S. EPA’s rule to control nitrogen oxides from specific source categories ( 40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the NO x SIP Call) has significantly reduced emissions from large electric generating units (EGUs), industrial boilers, and cement kilns. Ohio's NO x Budget Trading Program rule was approved on May 25, 2004 [Ohio Administ rative Code (OAC) Chapter 3745- 14]. It is expected that this dow nward trend will continue as the above programs continue and some form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented.

Requirement 4 of 4 : A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration : Ohio commits to continue monitoring ozone levels at the site indicated in Figure 1. Ohio EPA will consult with U. S. EPA Region V staff prior to making changes to the existing monitori ng network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirem ents of 40 CFR 58. Connection to a central station and updates to the Ohio EPA Web site 1 will provide real time availability of the data and knowl edge of any exceedances. Ohio EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.

1 www.epa.state.oh.us/dapc/9 

### CHAPTER FOUR

EMISSION INVENTORY CAA Section107 (d)(3)(E)(iii)

U.S. EPA’s redesignation guidance requires the s ubmittal of a compr ehensive inventory of ozone precursor emissions (VOC and NO x ) representative of t he year when the area achieves attainment of the oz one air quality standard. Ohio also must demonstrate that the improvement in air qua lity between the year that violat ions occurred and the year that attainment was achieved is based on pe rmanent and enforceable emission reductions. Other emissions inventory related requirem ents include a projection of the emission inventory to a year at least 10 years follo wing redesignation; a dem onstration that the projected level of emi ssions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10 year maintenance period.

Requirement 1 of 5 : A comprehensive emission inventory of the pr ecursors of ozone completed for the base
year.

Background : The point source data are taken fr om Ohio's annual emissions reporting program. The 2002 periodic inventory has been identified as the preferred data base for SIP development and does coincide with nonattainment air quality in Stark County.

As part of the NO x SIP Call, many states incl uding Ohio were required to adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted at OAC Chapter 3745-14. The budget represents a statewide cap on NO x emissions. These emissions, capped by t he state rule, should remain at or near this level through the maintenance period covered by this request.

Periodic inventories, which include emissi ons from all sectors - mobile, area, non-road, and point sources - are prepared every three (3) years.

Demonstration : While ozone and its precursors are transpor ted into this region from outside areas, this information does provide some indication of the impact from Ohio sources near the nonattainment area. The emissions are decreasing substantially in response to regional and national programs affecting many EGUs such as the Acid Rain program and the NO x SIP Call. Other sectors of the inventory also impact ozone formati on, but large regional sources such as EGUs have a substantial impact on the formation of ozone.10 Requirement 2 of 5 : A projection of the emi ssion inventory to a year at leas t 10 years following redesignation. Background : Ohio EPA prepared a comprehensive inv entory for Stark County, including area, mobile, and point sources for pr ecursors of ozone (volatile organic compounds and nitrogen oxides) for base year 2002. The information below describes the procedures Ohio EPA used to generate the 2002 base inventories. These inventories were provided to LADCO and have been processed to develop summer day emi ssions for use in the air quality analyses. These processed modeling inv entories have been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to LADCO in clude the Midwest Regional Planning Organization.

• Area sources were taken from the Ohio 2002 periodic inventory submitted to U.S. EPA. These projections were made from the U.S. Department of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information.

• Mobile source emissions were calculated using emissions factors produced with MOVES 2010.

• Point source information was compiled from Ohio EPA’s 2002 annual emissions inventory database and the 2002 U.S. EPA Air Markets acid rain database 2

.

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generat ed by using U.S. EPA’s National Mobile Inventory Model (NMI M) 2002 application. To address concerns about the accuracy of some of the categorie s in U.S. EPA’s non-road emissions model, LADCO contracted with two (2) companies to review the base dat a and make recommendations. One of the contractors also estimat ed emissions for three (3) non-road categories not included in U.S. EPA’s non-road model. Emissions were estimated for aircraft, commercial marine vessels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equi pment category were reviewed and updated based upon surveys completed in the Midwest and the temporal allocation for agricultural sources also was updated.

Demonstration :

On-Road Emission Estimations In coordination with the Stark County Area Transportation Study (SCATS) the Ohio Department of Transportation (O hio DOT) utilizes a regional travel demand forecast model to simulate traffi c in the area and to forecast traffic

2 http://www.epa.gov/airmarkets/acidrain11 flows for given growth expectations. The model is primar ily used as a long range planning tool to evaluate t he transportation system including determination of locations where addi tional travel capacity may be needed and to determine the infrastructure r equirements necessary to meet that need. It is also used as a tool for ai r quality purposes to estimate the total emissions of pollution caused by vehicles in the area. The travel demand forecasting model is used to predict t he total daily vehicle miles traveled (VMT) and an EPA computer program called MOVES 2010 is used to calculate emissions per mile. The pr oduct of these is the total amount of pollution emitted by the on-road vehicl es for the particular analyzed area.

Overview Broadly described, MOVES 2010MOVES 2010 model includes a number of variables that affect the emission fact ors. These variables have national default values, some of which require modification to reasonably reflect local conditions. Some of these variables ar e discussed here. The vehicle fleet (vehicles on the road) age and the vehi cle type have a major effect on the emission factors. The source ty pes are traveling on road types (MOVES 2010 road types are Rural Restricted A ccess, Rural Unrestricted Access, Urban Restricted Access, and Urban Un restricted Access). The vehicle speeds also affect the emission factor values. Meteorological conditions such as air temperature and humidity hav e a significant effect on emission factors. Emission factors produced by MOVES 2010 can also include the effect of emission reduction strategi es such as vehicle inspection and maintenance programs, regulation of fuels, etc. T hese MOVES 2010 inputs are estimated using the best available data.

These inputs are reviewed and agreed to by U.S. EPA and transportation agencies in a formal interagency consultati on process. Emission factors are multiplied by VMT from the travel demand model to estimate the total vehicle emissions.

The emission factors from MOVES 2010 c an be used with the travel demand model information by combining the disaggregate emission rates with VMT, and source type population for each road type, source type and hour of day, and then sum them up to get the total emissions for the area.

The Stark County analysis method, devel oped by Ohio DOT, is to aggregate the emission rates by two source ty pes (cars & trucks), then applying VMT and source type population, thereby reduci ng the intensive pr ocesses. In the first step emission factors are broadly cl assified into total vehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated from trav el demand model are combined with emission factors for each network lin k for each hour. The on-road vehicle emissions for the area is the sum of all individual link-hour emissions. Vehicle-based emissions are obtained by the combination of corresponding emission factors and source type popul ation. Intrazonal emissions are12 computed using a separate method to acc ount for those trips that use local roads to travel within a zone. Intraz onal VMT is combined with corresponding emission factors to get intrazonal emi ssions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions.

Automated programs, using FORTRA N and CUBE scripting, were developed by Ohio DOT to generate total emissions. The process uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process also handles the newer model netwo rk formats and MOVES 2010 generated emission factors.

MOVES 2010 input and output files ar e provided in Appendix C.

Best Available Data Most current vehicle age distribution dat a, temperature data, fuel properties data, source type distribution data, and I/M data provided by Ohio DOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA were used by the Ohio DOT for generating emission factors. Likewis e, the most current transportation planning data available from SCATS and most current Ohio DOT count data were used by Ohio DOT for the emissions estimates.

Analysis Years Analysis years for this re-designat ion request include 2002, 2004, 2009, and 2018 to meet the require ments specified by t he CAA and U.S. EPA. The travel demand model presents the trans portation system conditions for each of these years. Model runs for each future analysis year contain the road network SCATS and Ohio DOT expects to exist at the beginning of that year with corresponding socioeconomic forecasts for that year.

Local Road VMT Most local roads such as subdivision streets are not explic itly modeled in a travel demand model. These local r oads are represented as fictitious roadways called centroid connectors. Loc al road VMT is included in the Ohio DOT post process by including the traffic loaded on centroid connectors. In addition, some local road traffic is capt ured as intra-zonal trips which travel demand models usually do not assign to roadway segments. The Ohio DOT post process includes these trips as local road VMT.

Model area VMT For Stark County, the tr avel demand model covers the entire county and a portion of Mahoning County. VMT for t he portion of model which extends beyond Stark County is removed before total emissions are calculated.13 Emission Estimations Table 2 contains the results of the emissions analysis for the appropriate
years.

Table 2 Emission Estimations for On-Road Mobile Sources for Stark County, Ohio

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Stark County 2002 2004 2009 2018 VMT (miles/day) 8,245,109 8, 511,311 8,597,080 8,916,054
VOC (tons/day) 24.34 22.56 16.67 7.84

NO x (tons/day) 35.19 33.14 24.66 9.89

Motor Vehicle Emission Budget Table 3 contains the motor vehicle emissions budget for Stark County.

Table 3 Mobile Vehicle Emi ssion Budget for Stark County

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2009 2018 VOC (tons/day 19.17 9.02 NO x (tons/day) 28.36 11.37

This budget includes the emission estimates calculated for 2009 and 2018. The emission estimates are derived from the Tranplan travel demand model and MOVES 2010 as described above under the expect ed SCATS 2030 Long Range Plan. The mobile source budget includes 9.02 tons/ day for VOC and11.37 tons/day for NO x for 2018 and 19.17 tons/day for VO C and 28.36 tons/day for NO x for 2009. These correspond to a 15 percent increase fr om the 2009 and 2018 on-road emissions for both VOC and NO x . Appendix C contains data tables and graphs of these emissions.

All methodologies, latest planning assumptions and the safety margins were determined through the interagency cons ultation process described in the Transportation Conformity Memorandum of Understanding (MOU) for SCATS.14 Requirement 3 of 5 : A demonstration that the project ed level of emissions is sufficient to maintain the ozone standard.

Background : In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the maintenance year for this redesignati on request. This document contains projected emissions inventories for 2009 and 2018.

Ohio EPA performed emission projecti ons for Stark County using the following approaches.

• Mobile source emission proj ections are based on the U.S. EPA MOVES 2010 model. The analysis is described in more detail in Appendix C. All projections were made in accordance with “Procedures for Preparing Emissions Projections” U. S. EPA-45/4-91- 019.

• Emissions inventories are required to be projected to future dates to assess the influence growth and fu ture controls will have. The LADCO have developed growth and cont rol files for point, area, and non-road categories. These files were used to develop the future year emissions estimates used in this document. This was done so the inventories used for redesignati on are consistent with modeling performed in the future.

The detailed inventory information for Stark County for 2004, 2009 and 2018 is in Appendix B. Emission trends are an important gauge for continued compliance with the ozone standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years for Stark County. Mobile source em ission inventories are described in Appendix B. In addition to LADCO estima tes, point source emissions were projected based upon t he statewide EGU NO x budgets from the Ohio NO x rule.

The following tables include sectors Elec trical Generating Unit (EGU-Point), Non-Electrical Generating Unit (Non- EGU), Non-road Mobile (Non-road), Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road).15 Demonstration :

Table 4 Stark County VOC Emission Inventory Totals for Base Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU 2.90 2.97 3.14 3.77 Non-road 5.83 5.29 3.92 3.22 Other 21.23 21.03 20.49 21.93 MAR 0.15 0.15 0.14 0.14 On-road 24.34 22.56 19.17* 9.02*
TOTAL 54.45 52.00 46.86 38.08 13.92 * includes 15 percent increase to the mobile source budget

Table 5 Stark County NO x Emission Inventory Totals for Base Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a

NonEGU 5.12 4.85 4.16 4.72

Nonroad 6.78 6.22 4.81 2.50

Other 1.23 1.40 1.46 MAR 3.28 3.03 2.39 2.22 On-road 35.19 33.14 28.36* 11.37*
TOTAL 51.54 48.47 41.12 22.27 26.20 * includes 15 percent increase to the mobile source budget16 Table 6 Stark County Comparison of 2004 attainment year and 2018 projected emission estimates (tons per day, Summer)

Data source: Midwest Regional Planning Or ganization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected Change VOC 52.00 38.08 13.92 NO x 48.47 22.27 26.20

VOC emissions in the non-attainment area are projected to decrease by 13.92 tons per day (tpd). Area source emissions and, to a lesser extent, point sources, show an increase due to expectations that the population will grow in this area. However, cleaner v ehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall drop in VOC emissions.

NO x emissions in the nonattainment area are projected to decrease by 26.20 tpd. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 3 , Highway Heavy-Duty Engine Rule 4 and Non-Road Diesel Engine Rule 5 also factored into the changes. Further, due to implementation of the NO x SIP Call across the eastern United States, NO x and ozone levels entering this also decreased.

Requirement 4 of 5 : A demonstration that improvement in air quality between the year violations occurred and attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background : Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for ozone in 2005. U.S. EPA’s redesignation guidance (p 9) states, “A state may generally demons trate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment invent ory, or by modeling to show that the future mix of sources and emissions ra tes will not cause a violation of the NAAQS.”

In Ohio, major point sources in all counties are required to submit air emissions information once every three (3 ) years or annually if VOC potential

3 http://www.epa.gov/fedrgstr/EPA-AIR /2000/February/Day-10/a19a.htm
4 http://www.epa.gov/fedrgstr/EPA-A IR/1997/October/Day-21/a27494.htm
5 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm17 to emit is greater than 250 tons or NO x potential to emit is greater than 2500 tons, in accordance with U.S. EPA’s C onsolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodi c inventory for all ozone precursor emission sectors every three (3) years. These ozone precursor inventories will be prepared for 2005, 2008, and 2011 as necessary to comply with the inventory reporting requirements est ablished in the CAA. Emissions information will be compared to the 2002 base year and the 2018 projected maintenance year inventories to assess emission trends, as necessary, to assure continued compliance with the ozone standard.

Demonstration : Permanent and enforceable r eductions of volatile organic compounds and oxides of nitrogen have contributed to t he attainment of t he eight-hour ozone standard. Some of these reductions we re due to the applic ation of tighter federal standards on new vehicles. Al so, Title IV of the CAA and the NO x SIP Call required the reduction of oxides of nitrogen from utility sources. While no EGU reductions occurred wit hin Stark County, statewide NO x reductions from EGUs were over 85 percent due to this program.

Table 7 Stark County Comparison of 2002 base year and 2004 attainment year on-road and EGU reductions

Data source: Midwest Regional Planning Or ganization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2002 2004 On-road VOC 24.34 22.56 On-road NO x 35.19 33.14 EGU NO x n/a n/a

Requirement 5 of 5 : Provisions for future annual updates of the in ventory to enable tracking of the emission levels including an annual emission st atement from major sources.

Demonstration : As required by Section 175A(b) of the C AA, Ohio commits to submit to the Administrator, eight (8) years after redesignation, an additional revision of this SIP. The revision will contain Ohio 's plan for maintaining the national primary ozone air quality standard for 10 years beyond the first 10 year period after redesignation18 

### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CAA Section107 d)(3)(E)(ii), 107(d)(3)(iv) & 107(d)(3)(E)(v)

Requirement 1 of 4: An U.S. EPA approved SIP control strategy that includes RACT requirements for existing stationary sources covered by Control Technol ogy Guidelines (CTG) as applied in Ohio’s rural counties.

Background : As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s Ohio promulgated rule requiring RACT for emissions of VOCs. There were no specific rules required by the CAA such as RACT for existing sources beyond statewide rules.

Demonstration : Statewide RACT rules have been applied to all new sources locating in Ohio since that time. The Ohio rules are found in OAC Chapter 3745-21.

Requirement 2 of 4: Evidence that control measures required in past ozone SIP revisions have been fully implemented.

Background : The U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emission reductions fr om large EGUs, industrial boilers, and cement kilns in the easte rn United States. Ohio passed this rule in 2001. Beginning in 2004, this rule account s for a reduction of approximately 31 percent of all NO x emissions statewide compar ed to previous uncontrolled years. The other 21 states also have adopted these rules.

Demonstration : U.S. EPA and Ohio EPA performed modeling that indicated this area would attain the eight-hour ozone standard with the implement ation of the NO x SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions covered by this program have been gener ally trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data taken from U.S. EPA Clean Air Markets Web site, quantifies the gradual NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 in response to the SIP Call. OAC chapter 3745-14 regulated EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduction of NO x emissions from EGUs and a 60 percent reduction of NO x emissions from non-EGUs,19 compared to historical levels. This cap will stay in place through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently pub lished Phase II of the NO x SIP Call that establishes a budget for large (great er than 1 ton per day emissions) stationary internal combustion engines . Ohio EPA’s proposed rule OAC 3745-14-12 addresses stationar y internal combustion engines, all used in natural gas pipeline transmissions. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the compliance demonstrat ion will begin May 1, 2007. The 2007 controlled NO x emissions will be 599 tons per day.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, in cluding sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, 65 to 95 perc ent reductions for larger SUVs, vans, and heavier trucks. VOC emission reductions will be approximately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issu ed a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur di esel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoline and diesel trucks and buses. This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industrie s such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The new standards will cut emissions from non-road diesel engines by more than 90 percent. N on-road diesel equipment, as described in this rule, currently accounts for 47per cent of diesel par ticulate matter (PM) and 25 percent of NO x from mobile sources nation wide. Sulfur levels will be reduced in non-road diesel fuel by 99 percent from current levels, from approximately 3,000 ppm now to 15 ppm in 2009.

Together, these rules will substantially reduce local and regional sources of
ozone precursors.20 Requirement 3 of 4: Acceptable provisions to provide for new source review.

Background : Ohio has a long standing and fully impl emented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31. T he chapter includes provisions for the Prevention of Signi ficant Deterioration (PSD) permitting program in OAC 3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of the SIP.

Demonstration : Any facility that is not lis ted in the 2002 emission invent ory, or for the closing of which credit was taken in demonstrat ing attainment, will not be allowed to construct, reopen, modify, or recons truct without meeting all applicable permit rule requirement. The review pr ocess will be identical to that used for new sources. Once the area is r edesignated, Ohio EPA will implement NSR through the PSD program.

Requirement 4 of 4: Assure that existing controls will remain in effect after redesignation unless the State demonstrates through photochemical modeling that the standard can be maintained without one (1) or more controls.

Demonstration : Ohio commits to maintaining the af orementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicabl e to VOC and/or NO x sources, as required for maintenance of the ozone standard in Star k County, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal secti on, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it int ends to continue enforcing all rules that relate to the emission of ozone precursors in Stark County.

LADCO Modeling Analysis for eight-hour Ozone Standard Assessment

LADCO performed modeling to ev aluate the effect of the NO x SIP Call and Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This modeling was originally des igned to assess the one-hour ozone standard. Further analysis was conduc ted and documented in the LADCO’s White Paper “8-Hour Ozone Assessment ” dated May 2, 2001. Base year design values used were the average of the design values for the three (3) three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year21 emissions were taken from 1996 and four (4) ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991

While modeling results were not calc ulated for Stark County, the average decrease in ozone from the base case modeling run with modeling runs that applied emission controls required by the CAA, NO x SIP Call and Tier II /lowsulfur requirements was 15 ppb (2009 Futu re design value of 73.3ppb*.) [* LADCO Base K 2009 Future Base case with on-the-books” including CAIR].

LADCO Modeling for CAIR of 2004

On March 10, 2004, the U.S. EPA promulgated CAIR. NO x emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million to ns by 2009, and 1.3 million tons in 2018 in 28 eastern states and the District of Columbia.

LADCO performed modeling to support t he associated emission reductions for CAIR. This modeling was based on 2001 – 2002 design values for Stark County. Results of the CAIR mode ling show Stark County will continue to attain the eight-hour ozone NAAQS well into the future.22 

### CHAPTER SIX

CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4: A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration : Ohio hereby commits to review its maintenance plan eight (8) years after redesignation, as required by Section 175(A) of the CAA

.
Requirement 2 of 4: A commitment to expeditiously enact and im plement additional contingency control measures in response to exceeding specified pr edetermined levels (triggers) or in the event that future violations of the ambient standards occur.

Demonstration : Ohio hereby commits to adopt and ex peditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response shall be prompted whenever an annual (1-year) fourth high monitored va lue of 88 ppb occurs in a single ozone season within the maintenance area. A warning level response will consist of a study to determine whether the ozone value indi cates a trend toward higher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, t he control measures necessary to reverse the trend taking in to consideration ease and timing for implementation as well as econom ic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expediti ously as possible, but in no event later than 12 months from the conclusion of the most recent ozone season (September 30).

Should it be determined through the warn ing level study that action is necessary to reverse the noted trend, the procedures for control selection and implementation outlined under “action level response” shall be followed.

Action Level Response An action level response shall be prom pted whenever a two (2) year average fourth high monitored value of 85 ppb o ccurs within the maintenance area. In the event that the action level is triggered and is not due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA will determine addi tional control measures needed to assure future attainment of NAAQS fo r ozone. In this case, measures that23 can be implemented in a short time will be selected in order to be in place within eighteen (18) mont hs from the close of the ozone season that prompted the action level.

Control Measure Sele ction and Implementation Adoption of any additional control meas ures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public heari ng, and other measures required by Ohio law for rulemaking by state environmental boards.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and t hat measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnec essary. Furthermore, Ohio will submit to U.S. EPA an analysis to dem onstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4: A list of potential contingency measures t hat would be implemented in such an event.

Demonstration : Contingency measures to be c onsidered will be selected from a comprehensive list of measures deemed appr opriate and effective at the time the selection is made. The select ion of measures will be based on costeffectiveness, emission reduction potential, economic and social considerations or other factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting appropriate cont ingency measures. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, t he list of contingen cy measures outlined below is not comprehensive.

1) Lower Reid vapor pressure gasoline program.

2) Tighten RACT on existing source s covered by U.S. EPA Control Technique Guidelines issued in response to the 1990 CAA.

3) Apply RACT to smaller existing sources.

4) One or more transportation control measures sufficient to achieve at least half a percent reduction in actual area wide VOC emissions. Transportation measures will be sele cted from the following, based upon the factors listed above after c onsultation with affected local governments:24 a) trip reduction programs, including, but not limited to, employerbased transportation management plans, area wide rideshare programs, work schedule changes, and telecommuting;

b) traffic flow and transit improvements;

c) other new or innovative trans portation measures not yet in widespread use that affects state and local governments deemed appropriate.

5) Alternative fuel and diesel re trofit programs for fleet vehicle operations.

6) Controls on consumer produc ts consistent with those adopted elsewhere in the United States.

7) Require VOC or NO x emission offsets for new and modified major

sources.

8) Require VOC or NO x emission offsets for new and modified minor

sources.

9) Increase the ratio of emission offsets required for new sources.

10) Require VOC or NO x controls on new minor sources (less than 100 tons).

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the ti me they are under consideration, can be fully evaluated.

Requirement 4 of 4: A list of VOC and NO x sources potentially subject to future controls.

Demonstration : The following is a list of VOC and NO x sources potentially subject to future controls.

NO x RACT

• EGUs

• asphalt batching plants

• industrial/commercial and institutional boilers

• process heaters

• internal combustion engines25 • combustion turbines

• other sources greater than 100 tons per year

VOC RACT

• consumer products

• architectural and industrial maintenance coatings

• stage I gasoline dispensing facilities (including pressure valves)

• automobile refinishing shops

• cold cleaner degreasers

• portable fuel containers

• synthetic organic compound manufacturing

• organic compound batch processes

• wood manufacturing

• industrial wastewater

• aerospace industry

• shipbuilding

• bakeries

• plastic parts coating

• volatile organic liquid storage

• industrial solvent cleaning

• offset lithography

• industrial surface coating

• other sources greater than 50 tons per year26 

### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio will publish a notification for a public hearing and solicitation for public comment concerning the draft redesi gnation petition and maintenance plan in a widely distributed newspaper in the area.

The public hearing to receive comments on the redesignation request was held on November 8, 2012 at 189 25th S t. NW Canton, Ohio. The public comment period closed on November 8, 2012. No comments were re ceived during the public comment period and no testimony was provided at t he hearing. Appendix D includes a copy of the public notice and hearing transcript.27 

### CHAPTER EIGHT

CONCLUSIONS

The Stark County basic nonatta inment area has attained the NAAQS standard and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of basic ozone nonattainment ar eas. Documentation to that effect is contained herein. Ohio EPA has prepared a state implement ation and maintenance plan that meets the requirement of Sect ion 110 (a)(1) of the 1990 CAA.

Ohio has performed an analysis that shows the air quality impr ovements are due to permanent and enforceable measures. In addition, significant regional NO x reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements necessary for redesignation have been met.

Based on this presentation, the Stark C ounty ozone basic nonattain ment area meets the requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, because this area is subject to significant transport of pollutants, significant regional NO x reductions will ensure continued compliance (maintenance) with t he standards with an increasing margin of safety.

The State of Ohio hereby requests that t he Stark County ozone bas ic nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio state implementation and Maintenance Plan provisions contained herein.Page left intentionally blankSynopsis of Changes
Revised Canton-Massillion Maintenance Pl an under the 1997 Ozone Standard

The original redesignation request and maintenance plan document was submitted to U.S. EPA on June 20, 2006. U.S. EPA approved this requests on May 16, 2007 (72 FR 27648).

Ohio EPA is now requesting a revision to the maintenanc e plan to update mobile emission projections and conformity budgets based on emission rates generated from U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation (MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s official emission factor model. The area is still attaining an d maintaining the 1997 8-hour ozone standard and the point, area and non-road emissions have not changed significantly and did not need to be updated for this submittal.

A redline/strike-out version of the original document follows this synopsis and identifies all changes that were made to the original approved request. In summary, revisions were made to the on-road (mobile) source emission estimates and budgets contained within the tables and text below. In addition, the discussion section regarding on-road modeling protocols was updated to identify the latest process applicable to the use of the newer MOVES model. Other minor changes were made to conform to current terminology, grammar, and formatting conventions.

In addition to this document, additional ch anges were also made to the Appendices of the original submitta l, as follows:

• Appendix C: this appendix contains the detailed modeling protocol used to generate on-road mobile source emission estimates. The document contained within this revised submittal is an entirely new document compared to the original modeling protocol document submitted in 2006. Both the original and revised documents are available on Ohio EPA’s website under the “Appendix” link.

• Appendix E: this appendix contains documents relevant to the public comment period and the public hearing. This will contain a re vised public notice and revised hearing transcript. In some cases, if comments are received or testimony provided, it will also contain a revised response to comments document. Both the original and revised documents are available on Ohio EPA’s website under the “Appendix” link.

These documents can all be found at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx in the table under the heading “Redesignations and Maintenance Plans.”

# REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENT IN THE CANTON-MASSILLON EIGHT-HOUR OZONE 

# BASIC NONATTAINMENT AREA

Stark County, Ohio

Developed By: Ohio Environmental Protection Agency Division of Air Pollution Control

June 20, 2006 Revised November 2012 Formatted: Font: 12 pt

Formatted: Font: 12 pt

Formatted: Font: 20 ptThis page left intentionally blanki TABLE OF CONTENTS

Chapter One Introduction .................................................................................................................. ................. 1 Background .................................................................................................................... ............... 1 Geographical description ...................................................................................................... ........ 2 Status of air quality ......................................................................................................... .............. 2

Chapter Two Requirements for redesignation ................................................................................................ .... 3

Chapter Three Ozone monitoring .......................................................................................................................... 6 Ambient data quality assured ........................................................................................................ 7 Three complete years of data ..........................

........................................................................ ..... 7 Commitment to continue monitoring ............................................................................................. 8

Chapter Four Emission Inventory ........................................................................................................................ 9 Base Year Inventory ........................................................................................................... .......... 9 Emission Projections ................................................................................................................... 10 Demonstration of Maintenance .................................................................................................. . 14 Permanent and Enforceable Emissions Reductions ................................................................... 16 Provisions for Future Updates .........................

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

Chapter Five Control measures and regulation s .............................................................................................. 18 Implementation of Past SIP Revisions ........................................................................................ 1 8 New Source Review Provisions ................................................................................................. 20 Assurance of continued controls ............................................................................................... .. 20

Chapter Six Contingency measures .......................................................................................................... ..... 22 Commitment to revise plan ..................................................................................................... .... 22 Commitment for contingency measures ..................................................................................... 22 Potential contingency measures ................................................................................................ . 23 List of VOC and NO x sources...................................................................................................... 24

Chapter Seven Public participation .......................................................................................................... ............ 26

Chapter Eight Conclusions ...................................................................................................................

......... 2627ii FIGURES

Figure 1 Stark County Basic Nonattainment Area ............................................................... 6

TABLES

Table 1 Monitoring Data for St ark County 2003 – 2005 ..................................................... 8 Table 2 Emission estimati ons for on-road mobile sources ............................................... 13 Table 3 Motor vehicle emissions budget ...................................................................... 1413 Table 4 Projected VOC emission estimates ................................................................. 1415 Table 5 Projected NO x emission Inventory Totals ........................................................ 1315 Table 6 Projected emission estimates 2004-2018 VOC/NO x totals .............................. 1416 Table 7 Comparison of 2002-2 004 on-road and EGU totals ........................................ 1417

APPENDICES

A Aerometric Information Retrieval System (AIRS) Data B Emission Inventories C Emissions Analysis Method D Public Participation Documentationiii This page left intentionally blank1 REQUEST FOR REDESIGNATION AND MAINTENANCE PLAN FOR OZONE ATTAINMENTCANTON-MASSILLON IN THE EIGHT-HOUR OZONE BASIC NONATTAINMENT AREA

STARK COUNTY, OHIO

CHAPTER ONE

Introduction The Clean Air Act (CAA) requir es areas failing to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the United States Environmental Protection Agency (U.S. EPA) revised the air quality standards for ozone replacing the 1979 one-hour standard with an eight-hour ozone standard set at 0.08 parts per million (ppm.) The standard was challenged legally and upheld by the U.S. Supreme Court in February of 2001.

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone standard. Since that time, U.S. EPA has reclas sified nine of the 1 34 original nonattainment areas to the next lower classification. Sectio n 107(d)(3)(E) of the CAA allows states to request nonattainment areas be redesignated to attainment providing certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has a ttained the eight-hour ozone standard. ii) An approved SIP for the area under Section 110(k). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements have been
met.

Background As part of the 1990 CAA Amendments re-evaluation, Stark County was designated as Unclassifiable/Attainment for the one-hour ozone standard pursuant to the CAA and therefore, has not previously been subject to nonattainment area rule-makings. As a result of the 2004 ozone de signations, U.S. EPA designated Stark County basi c nonattainment and subject to the eight-hour ozone requirements, including development of a plan to reduce volatile organic compounds (VOCs) and oxides of nitrogen (NO x ) emissions and a demonstration that the area will meet the federa l eight-hour air quality standard for ozone by June 2009. Formatted: Font color: Auto

Formatted: Font color: Auto2 This document is intended to support Ohio’s request that Stark County be redesignated from nonattainment to attainment for the eight-hour ozone standard. Stark County has recorded three (3) years of complete, quality-assured ambient air quality monitoring data for the years 2003 – 2005 demonstrating attainment of the eight-hour ozone standard.

Geographical Description Stark County is located in eastern Ohio and contains the City of Canton. Stark County is bordered by Summit and Portage Counties to the north, Mahoning and Columbiana to the east, Tuscarawas and Carroll to the south and Wayne and Holmes to the west. Stark County is shown in Figure 1.

Status of Air Quality Ozone monitoring data for the most recent three (3) years, 2003 through 2005, demonstrates that the air quality has met the NAAQS for ozone in this basic nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter four, supports a redesignation to attainment for Stark County based on requirements in Section 107(d)(3)(E) of the CAA.3 CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Direct ors. This request for redesignation and maintenance plan is based on the redesignation guidance, supplemented with additional guidance received from st aff of U.S. EPA Region V.

Below is a summary of each redesignation criterion as it applies to Stark County.

i.) Attainment of the standard: There are two components involved in making this demonstration. The first component relies on ambient air quality data. The data that are used to demonstrate attainment should be the product of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality-assured in accordance with 40 CFR 58 and recorded in the Aerometric Information Retrieval Sy stem (AIRS) in order for it to be available to the public for review.

The second component relies upon supplemental U.S. EPA-approved air quality modeling. The supplemental modeling is not required for ozone nonattainment areas seeking redesignation. Therefore, this ozone redesignation request for Stark County does not include modeling data. However, in Appendix C the most recent modeling results showing future attainment and maintenance are provided. Chapter three discusses this requirement in more detail and provides the attainment demonstration.

ii.) SIP approval: The SIP for the area must be fully approved under Section 110(k) and must satisfy all requirements that apply to the area. Ohio’s SIP was approved on May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes Stark County. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

iii.) Permanent and enforceable improvement in air quality; The state must be able to reasonably attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and implemented by the
state.4 Stark County was not designated nonattainment for ozone as part of the 1990 CAA Amendments re-evaluation. As a result, Ohio has not adopted or implemented control measures beyond the federal measures, the initial 1979 statewide rules and those 1994 and 1995 rules which applied to “rural” attainment areas. Chapters four and five discuss this requirement in more detail and provide the attainment demonstration.

iv.) Section 110 and Part D requirements: For purposes of redesignation, a state must meet all requirements of Section 110 and part D that were applicable prior to submittal of the complete redesignation request.

Part D consists of general requirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS.

i.) Section 172(c) requirements This section contains general requirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesi gnations because they only have meaning for areas not attaining the standard. The requirements for an emission inventory will be satisfied by the inventory requirements of the maintenance plan.

ii.) Conformity The state must work with U.S. EPA to show that its SIP provisions are consistent with section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA’s conformity regulation upon issuance, as applicable. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

v.) Maintenance plans. Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan which meets the requirements of Section 175(A). The maintenance plan will constitute a SIP revision and must provide for maintenance of the relevant NAAQS in the area for at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.5 In addition, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state w ill implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a no nattainment area should consider the following provisions:

a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification of continued attainment; and e.) contingency plan.

Chapter six discusses this requirement in more detail and provides the attainment demonstration.6 CHAPTER THREE

OZONE MONITORING CAA Section107 (d)(3)(E)(i)

Requirement 1 of 4 : A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show th at violations of the ambient standard are no longer occurring.

Background : There are three monitors measuring ozone concentrations in this nonattainment area. The monitors ar e operated by Canton City Health Department’s Air Pollution Control Section. The locations of the monitoring sites for this nonattainment area are shown in Figure 1.

Demonstration :

Figure 1 Map of Stark County7 Requirement 2 of 4 : Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the U.S. EPA Air Quality System (AQS) databa se, and available fo r public view.

Demonstration : The Ohio Environmental Protection Agency (Ohio EPA) ha s quality assured all data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio Quality Assurance Manual . Ohio EPA has recorded the data in the AQS database and therefore data are available to the public.

Requirement 3 of 4 : A showing that the three-year average of the fourth highest values, based on data from all monitoring sites in the area or its affected downwind environs, are below 85 parts per billion (ppb). This showing must rely on three (3) complete, consecutive calendar years of quality assured data.

Background : The following information is taken from U.S. EPA's "Guideline on Data Handling Conventions for the eight-hour Ozone National Ambient Air Quality Standard (NAAQS)," U.S. EPA-45 4/R-98-017, December 1998.

Three (3) complete years of ozone monitoring data are required to demonstrate attainment at a monitoring site. The eight-hour primary and secondary ozone ambient air quality standards are met at an ambient airquality monitoring site when the three-year average of the annual fourthhighest daily maximum eight-hour average ozone concentration is less than or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. Three (3) significant digits must be carried in the computations. Because the third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concentration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight-hour standard is co nsidered to be 0.085 ppm. Values below 0.085 ppm meet the standard, values equal to or greater than 0.085 ppm exceed the standard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in compliance with the eight-hour ozone NAAQS if, and only if, every monitoring site in the area meets the NAAQS. An individual site's three (3) year average of the annual fourth highest daily maximum eight-hour average ozone concentration is also called the site's design value. Table 1 shows the monitoring data for the three most recent years, 2003 - 2005, at the nonattainment area sites and was retrieved from the U.S. EPA AQS.8 Demonstration :

Table 1: Monitoring Data for Stark County 2003 – 2005

Data source: U.S. EPA Air Quality System (AQS). http://www.epa.gov/ttn/airs/airsaqs/index.htm

1 s t 2 n d 3 r d 4 th 2003-2005 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 39-151-0016 STARK MALONE COLLEGE 2003 100 .106 .104 .092 .087 .079 39-151-0016 STARK MALONE COLLEGE 2004 92 .086 .082 .076 .074 39-151-0016 STARK MALONE COLLEGE 2005 96 .087 .080 .079 .076 39-151-0021 STARK 245 WEST FIFTH 2003 100 .099 .099 .090 .085 .077 39-151-0021 STARK 245 WEST FIFTH 2004 99 .085 .075 .073 .071 39-151-0021 STARK 245 WEST FIFTH 2005 100 .083 .078 .077 .076 39-151-4005 STARK 1175 WEST VINE 2003 100 .116 .106 .101 .086 .082 39-151-4005 STARK 1175 WEST VINE 2004 98 .084 .079 .076 .076 39-151-4005 STARK 1175 WEST VINE 2005 100 .106 .088 .087 .086 Highest Average 0.82 ppm

A comprehensive list of the site’s design values during the 2003-2005 time period is in Appendix A. The area's design value has trended downward as emissions have declined due to such factors as cleaner automobiles and fuels both regionally and locally. U.S. EPA’s rule to control nitr ogen oxides from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the NO x SIP Call) has significantly reduced emissions from large electric generating units (EGUs), industrial boilers, and cement kilns. Ohio's NO x Budget Trading Program rule was approved on May 25, 2004 [Ohio Administrative Code (OAC) Chapter 3745- 14]. It is expected that this do wnward trend will cont inue as the above programs continue and some form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented.

Requirement 4 of 4 : A commitment that once redesignated, the st ate will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration : Ohio commits to continue monitoring ozone levels at the site indicated in Figure 1. Ohio EPA will consult with U. S. EPA Region V staff prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58. Connection to a Formatted Table9 central station and updates to the Ohio EPA Web site 1 will provide real time availability of the data and knowledg e of any exceedance s. Ohio EPA will enter all data into AQS on a timely basis in a ccordance with federal guidelines.

CHAPTER FOUR

EMISSION INVENTORY CAA Section107 (d)(3)(E)(iii)

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO x ) representative of the year when the area achieves attainment of the ozone air quality st andard. Ohio also must demonstrate that the improvement in air quality between the year th at violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions. Other emissions inventory related requirements include a projection of the emission inventory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10 year maintenance period.

Requirement 1 of 5 : A comprehensive emission inventory of the precursors of ozone completed for the base
year.

Background : The point source data are taken from Ohio's annual emissions reporting program. The 2002 periodic inventory has been identified as the preferred data base for SIP development and does coincide with nonattainment air quality in Stark County.

As part of the NO x SIP Call, many states includ ing Ohio were required to adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted at OAC Chapter 3745-14. The budget represents a statewide cap on NO x emissions. These emissions, capped by the state rule, should remain at or near this level through the maintenance period covered by this request.

Periodic inventories, which include emissions from all sectors - mobile, area, non-road, and point sources - are prepared every three (3) years.

Demonstration :

1 www.epa.state.oh.us/dapc/10 While ozone and its precursors are transported into this region from outside areas, this information does provide some indication of the impact from Ohio sources near the nonattainment area. The emissions are decreasing substantially in response to regional and national programs affecting many EGUs such as the Acid Rain program and the NO x SIP Call. Other sectors of the inventory also impact ozone formation, but large regional sources such as EGUs have a substantial impact on the formation of ozone.

Requirement 2 of 5 : A projection of the emission inventory to a year at least 10 years following redesignation. Background : Ohio EPA prepared a comp rehensive inventory for Stark County, including area, mobile, and point sources for precursors of ozone (volatile organic compounds and nitrogen oxides) for base year 2002. The information below describes the procedures Ohio EPA us ed to generate the 2002 base inventories. These inventories were provided to LADCO and have been processed to develop summer day emissions for use in the air quality analyses. These processed modeling inv entories have been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organization.

• Area sources were taken from the Ohio 2002 periodic inventory submitted to U.S. EPA. These projections were made from the U.S. Department of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information.

• Mobile source emissions were calculated using emissions factors produced with MOBILE6.2MOVES 2010

.

• Point source information was comp iled from Ohio EPA’ s 2002 annual emissions inventory database an d the 2002 U.S. EPA Air Markets acid rain database 2

.

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generat ed by using U.S. EPA’s National Mobile Inventory Model (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA’s non-road emissions model, LADCO contracted with two (2) companies to review the base data and make recommendations. One of the contractors also estimated emissions for three (3) non-road categories not included in U.S. EPA’s non-road model. Emissions were estimated for aircraft, commercial marine vessels and railroads.

2 http://www.epa.gov/airmarkets/acidrain11 Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment category were reviewed and updated based upon surveys completed in the Midwest and the temporal allocation for agricultural sources also was updated.

Demonstration :

On-Road Emission Estimations In coordination with the Stark County Area Transportation Study (SCATS) the Ohio Department of Transportation (Ohio DOT) utilizes a regional travel demand forecast model to simulate traffic in the area and to forecast traffic flows for given growth expectations. The model is primarily used as a long range planning tool to evaluate the transportation system including determination of locations where additi onal travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as a tool for air quality purposes to estimate the total emissions of pollution caused by vehicles in the area. The travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT) and an EPA computer program called MOBILE6.2MOVES 2010 is used to calculate emissions per mile. The product of these is the total amount of pollution emitted by the on-road vehicles for the particular analyzed area . In areas outside the regional travel demand model, traffic counts and statewide traffic growth rates are used for the VMT estimates

.

Overview Broadly described, MOBILE6.2 is used to generate “emission factors”, which are the average emissions per mile (grams/mile) for ozone precursors, NO x and VOC. The MOBILE6.2Broadly described, MOVES 2010MOVES 2010 model includes a number of variables that affect the emission factors. These variables have national default values, some of which require modification to reasonably reflect local conditions. Some of these variables are discussed here. The vehicle fleet (vehicles on the road) age and the vehicle type have a major effect on the emission factors. The vehiclesource types are traveling

on facilityroad types . Vehicle (MOVES 2010 road types are Rural Restricted Access, Rural Unrestricted Access, Urban Restricted Access, and Urban Unrestricted Access). The vehicle speeds also affect the emission factor values. Meteorological conditions such as air temperature and humidity also significantly affectshave a significant effect on emission factors. Emission factors produced by MOBILE6.2MOVES 2010 can also include the effect of emission reduction strategies such as vehicle inspection and maintenance programs, regulation of fuels, etc. These MOBILE6.2MOVES 2010 inputs are estimated using the best available data and.

These inputs are reviewed and agreed to by U.S. EPA and transportation Formatted: Normal, Level 2, Keep with next

Formatted: Normal, Level 2, Keep with next12 agencies in a formal interagency consultation process. Emission factors are multiplied by VMT from the travel demand model to estimate the total vehicle emissions.

There are a number of ways emission factors from MOBILE6.2 can be used with the travel demand model information. One of the simplest methods is to input extensive vehicle fleet, area-specific speed and facility type information MOBILE6.2 to generate a single emission factor that represents the average for all vehicles and facility types in the modeled area. This only requires multiplying this emission factor by th e total VMT of the analyzed area to getthe total emissions for the area. Another method is to create multidimensional emission factor “look-up” tables that describe the emission factors by speed, temperature, and facility type. This requires more extensive processing, but the resulting total emissions of this method are more sensitive to even minor changes in the roadway system. Tables of emission factors are created using MOBILE6.2 for each facility type, temperature, and speed given the vehicl e fleet on that facility. Then, the travel model provides information on each segment of road (or “link”) regarding speed and facility type which is then “looked-up” in the appropriate emission factor table. It should be noted that speed is estimated as a post process to the travel demand model. Speeds are not taken directly from the travel demand model. The post process for emissions analysis by Ohio DOT is by hour of day. This emission fa ctor is multiplied by the link’s trafficvolume and length or VMT to get the emissions from that link for that hour. There are other methods as well, each with its advantages and disadvantages. The Stark County analysis uses the latter more complex method, a table of emission factors.

It should be noted that each year an alyzed will have different emission factors, volumes, speeds and roadway networks.

Some of the assumptions built into MOBILE6.2 are: older vehicles have much higher emission factors than newer vehicles, diesel vehicles have much higher NO x emission factors and lower VOC emission factors than gasoline vehicles, and higher average speeds have lower emission factors except for diesel vehicles which have higher NO x at higher speeds. MOBILE6.2 The emission factors from MOVES 2010 can be used with the travel demand model information by combining the disaggregate emission rates with VMT, and source type population for each road type, source type and hour of day, and then sum them up to get the total emissions for the area.

The Stark County analysis method, developed by Ohio DOT, is to aggregate the emission rates by two source types (cars & trucks), then applying VMT and source type population, thereby reducing the intensive processes. In the13 first step emission factors are broadly cl assified into total vehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated from travel demand model are combined with emission factors for each network lin k for each hour. The on-road vehicle emissions for the area is the sum of all individual link-hour emissions. Vehicle-based emissions are obtained by the combination of corresponding emission factors and source type po pulation. Intrazonal emissions are computed using a separate method to account for those trips that use local roads to travel within a zone. Intraz onal VMT is combined with correspondingemission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions.

Automated programs, using FORTRAN and CUBE scripting, were developed by Ohio DOT to generate total emissions. The process uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process also handles the newer model network formats and MOVES 2010 generated emission factors.

MOVES 2010 input and output files are provided in Appendix C.

Best Available Data Most current vehicle age distribution data, temperature data, and fuel properties data , source type distribution data, and I/M data provided by Ohio DOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA waswere used by the Ohio DOT for generating emission fact ors. Likewise, the most current transportation planning data available from the SCATS and most current Ohio DOT count data waswere used by the Ohio DOT for the emissions estimates . Details about each data set and how it was used is documented in Ohio DOT’s “SCATS 8-Hour Ozon e Air Quality Conformity Analysis Technical Memo” dated 5/24/2006

.
Analysis Years Analysis years for this re-designation request include 2002, 2004, 2009, and 2018 to meet the requirements spec ified by the CAA and U.S. EPA. The travel demand model presents the transportation system conditions for each of these years. Model runs for each future analysis year contain the road network SCATS and ODOTOhio DOT expects to exist at the beginning of that year with corresponding socioeconomic forecasts for that year.

Local Road VMT Most local roads such as subdivision st reets are not explicitly modeled in a travel demand model. These local roads are represented as fictitious roadways called centroid connectors. Local road VMT is included in the Ohio DOT post process by including the traffic loaded on centroid connectors. In Formatted: Normal, Level 2, Keep with next

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Model area VMT For Stark County, the travel demand model covers the entire county and a portion of Mahoning County. VMT for the portion of model which extends beyond Stark County is removed before total emissions are calculated.

Emission Estimations Table 2 contains the results of the em issions analysis for the appropriate
years.

Table 2 Emission Estimations for On-Road Mobile Sources for Stark County, Ohio

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Stark County 2002 2004 2009 2018 VMT (miles/day) 7,929,7908,245,109 8, 014,259511,311 8, 490,027597,080 8, 811,255916,054
VOC (tons/day) 16.5624.34 14.0322.56 8.7116.67 4.677.84

NO x (tons/day) 25. 35 .19 22.0033.14 15.6824.66 6.169.89

Motor Vehicle Emission Budget Table 3 contains the motor vehicle emissions budget for Stark County.

Table 3 Mobile Vehicle Emission Budget for Stark County

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2009 2018 VOC (tons/day 10.0219.17 5.379.02 NO x (tons/day) 18.0328.36 7.0811.37

This budget includes the emission estimates calculated for 2009 and 2018. The emission estimates are derived from the Tranplan travel demand model and MOBILE6.2MOVES 2010 as described above under the expected Stark County Area Transportation Study ( SCATS ) 2030 Long Range Plan. The mobile source budget includes 59.02 tons/day for VOC and11 .37 tons/day for VOC and 7.08 tons/day for NO x . for 2018 and 19.17 tons/day for VOC and 28.36 tons/day for NO x for 2009. These correspond to a 15 percent increase from the 2009 and 2018 onFormatted: Normal, Level 2, Keep with next

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Formatted Table15 road emissions for both VOC and NO x . Appendix C contains data tables and graphs of these emissions.

All methodologies, latest planning a ssumptions and the safety margins were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) for SCATS.

Requirement 3 of 5 : A demonstration that the projected level of emissions is sufficient to maintain the ozone standard.

Background : In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the maintenance year for this redesignation request. This document contains projected emissions inventories for 2009 and 2018.

Ohio EPA performed emission projec tions for Stark County using the following approaches.

• Mobile source emission projec tions are based on the U.S. EPA MOBILE6.2MOVES 2010 model. The analysis is described in more detail in Appendix C. All projecti ons were made in accordance with “Procedures for Preparing Emission s Projections” U.S. EPA-45/4-91- 019.

• Emissions inventories are required to be projected to future dates to assess the influence growth and future controls will have. The LADCO have developed growth and control files for point, area, and non-road categories. These files were used to develop the future year emissions estimates used in this document. This was done so the inventories used for redesignation are consistent with modeling performed in the future.

The detailed inventory information for Stark County for 2004, 2009 and 2018 is in Appendix B. Emission trends are an important gauge for continued compliance with the ozone standard. Therefore, Ohio EPA performed an16 initial comparison of the inventories for the base year and maintenance years for Stark County. Mobile source emission inventories are described in Appendix B. In addition to LADCO es timates, point source emissions were projected based upon the statewide EGU NO x budgets from the Ohio NO x rule.

The following tables include sectors Elec trical Generating Unit (EGU-Point), Non-Electrical Generating Unit (Non -EGU), Non-road Mo bile (Non-road), Other Area (Other), Marine, Aircraft, Rail (MAR), On-roa d Mobile (On-road).

Demonstration :

Table 4 Stark County VOC Emission Inventory Totals for Base Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a Non-EGU 2.90 2.97 3.14 3.77 Non-road 5.83 5.29 3.92 3.22 Othe r 21.23 21.03 20.49 21.93 MAR 0.15 0.15 0.14 0.14 On-road 16.5624.34 14.0322.56 10.0219.17 * 5.379.02 *

TOTAL 46.6754.45 43.4752.00 37.7146.86 34.4338.08 9.0413.92 * includes 15 percent increase to the mobile source budget Formatted: Indent: Left: 0"

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Formatted: Font color: Black Formatted: Font color: Black17 Table 5 Stark County NO x Emission Inventory Totals for Base Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004 Attainment 2009 Interim 2018 Maintenance Safety Margin EGU Point n/a n/a n/a n/a

NonEGU 5.12 4.85 4.16 4.72

Nonroad 6.78 6.22 4.81 2.50

Other 1.17 1.23 1.40 1.46
MAR 3.28 3.03 2.39 2.22 On-road 25. 35 .19 22.0033.14 18.0328.36 * 7.0811.37 *

TOTAL 41.7051.54 37.3348.47 30.7941.12 17.9822.27 19.3526.20 * includes 15 percent increase to the mobile source budget

Table 6 Stark County Comparison of 2004 attainment year and 2018 projected emission estimate s (tons per day, Summer)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected Change
V OC 43.4752.00 34.4338.08 8.0413.92 NO x 37.3348.47 17.9822.27 19.3526.20

VOC emissions in the non-attainment area are projected to decrease by 8.0413.92 tons per day (tpd). Area source emissions and, to a lesser extent, point sources, show an in crease due to expectations that the population will Formatted Table

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Formatted Table18 grow in this area. However, cleaner vehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall drop in VOC emissions.

NO x emissions in the nonattainment area are projected to decrease by 19.3526.20 tpd. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 3

, Highway Heavy-Duty Engine Rule 4 and Non-Road Diesel Engine Rule 5 also factored into the changes. Further, due to implementation of the NO x SIP Call across the eastern United States, NO x and ozone levels entering this also decreased.

Requirement 4 of 5 : A demonstration that improvement in air quality between the year violations occurred and attainment was achieved is based on perm anent and enforceable em ission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background : Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for ozone in 2005. U.S. EPA’s redesignation guidance (p 9) states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the future mix of sources and emissions ra tes will not cause a violation of the NAAQS.”

In Ohio, major point sources in all c ounties are required to submit air emissions information once every three (3) years or annually if VOC potential to emit is greater than 250 tons or NO x potential to emit is greater than 2500 tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor emission sectors every three (3) years. These ozone precursor inventories will be prepared for 2005, 2008, and 2011 as necessary to comply with the inventory reporting requirements established in the CAA. Emissions information will be compared to the 2002 base year and the 2018 projected maintenance year inventories to assess emission trends, as necessary, to assure continued compliance with the ozone standard.

Demonstration : Permanent and enforceable reductions of volatile organic compounds and oxides of nitrogen have contributed to the attainment of the eight-hour ozone

3 http://www.epa.gov/fedrgstr/EPA-A IR/2000/February/Day-10/a19a.htm
4 http://www.epa.gov/fedrgstr/EPA-A IR/1997/October/Day-21/a27494.htm
5 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm19 standard. Some of these reductions were due to the application of tighter federal standards on new vehicles. Also, Title IV of the CAA and the NO x SIP Call required the reduction of oxides of nitrogen from utility sources. While no EGU reductions occurred within Stark County, statewide NO x reductions from EGUs were over 85 percent due to this program.

Table 7 Stark County Comparison of 2002 base year and 2004 attainment year on-road and EGU reductions

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2002 2004 On-road VOC 16.5624.34 14.0322.56 On-road NO x 25. 35 .19 22.0033.14 EGU NO x n/a n/a

Requirement 5 of 5 : Provisions for future annual updates of the inventory to enable tracking of the emission levels including an annual emission statement from major sources.

Demonstration : As required by Section 175A(b) of the CAA, Ohio commits to submit to the Administrator, eight (8) ye ars after redesignation, an additional revision of this SIP. The revision will contain Ohio 's plan for maintaining the national primary ozone air quality standard for 10 years beyond the first 10 year period after redesignation

.

CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CAA Section107 d)(3)(E)(ii), 10 7(d)(3)(iv) & 107(d)(3)(E)(v)

Requirement 1 of 4: An U.S. EPA approved SIP control strategy that includes RACT requ irements for existing stationary sources covered by Control Technolo gy Guidelines (CTG) as applied in Ohio’s rural counties.

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Formatted: None, Tab stops: Not at 0" + 0.5"20 As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s Ohio promulgated rule requiring RACT for emissions of VOCs. There were no specific rules required by the CAA such as RACT for existing sources beyond statewide rules.

Demonstration : Statewide RACT rules have been applied to all new sources locating in Ohio since that time. The Ohio rules are found in OAC Chapter 3745-21.

Requirement 2 of 4: Evidence that control measures required in past ozone SIP revisions have been fully implemented.

Background : The U.S. EPA NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. Ohio passed this rule in 2001. Beginning in 2004, this rule accounts for a reduction of approximately 31 percent of all NO x emissions statewide compared to previous uncontrolled years. The other 21 states also have adopted these rules.

Demonstration : U.S. EPA and Ohio EPA performed modelin g that indicated this area would attain the eight-hour ozone standard with the implementation of the NO x SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions covered by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data taken from U.S. EPA Clean Air Markets Web site, quantifies the gradual NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 in response to the SIP Call. OAC chapter 3745-14 regulated EGUs and certain non-EGUs under a cap and trade program based on an 85 percent reduction of NO x emissions from EGUs and a 60 percent reduction of NO x emissions from non-EGUs, compared to historical levels. This c ap will stay in plac e through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently pub lished Phase II of the NO x SIP Call that establishes a budget for large (great er than 1 ton per day emissions) stationary internal comb ustion engines. Ohio EPA’s proposed rule OAC 3745-14-12 addresses stationary internal combustion engines, all used in natural gas pipeline transmissions. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the complianc e demonstration will begi n May 1, 2007. The 2007 controlled NO x emissions will be 599 tons per day.21 Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, in cluding sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make clea ner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. VOC emission re ductions will be approximately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoline and diesel trucks and buses. This rule will result in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Ai r Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleane r fuel standard similar to the highway diesel program. The new standards w ill cut emissions from non-road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, currently accounts for 47percent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwi de. Sulfur levels will be reduced in non-road diesel fuel by 99 percent from current levels, from approximately 3,000 ppm now to 15 ppm in 2009.

Together, these rules will su bstantially reduce local and regional sources of
ozone precursors.

Requirement 3 of 4: Acceptable provisions to provide for new source review.

Background : Ohio has a long standing and fully implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31. The chapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting program in OAC 3745-31-01 to 3745-31-20. Ohio's PSD program was22 conditionally approved on October 10, 200 1 (66 FR 51570) and received final approval on January 22, 20 03 (68FR 2909) by U.S. EPA as part of the SIP.

Demonstration : Any facility that is not listed in the 2002 emission inventory, or for the closing of which credit was taken in demonstrat ing attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable permit rule requirement. The review process will be identical to that used for new sources. Once the area is redesign ated, Ohio EPA will implement NSR through the PSD program.

Requirement 4 of 4: Assure that existing controls will remain in effect after redesignation unless the State demonstrates through photochemical modeling that the standard can be maintained without one (1) or more controls.

Demonstration : Ohio commits to maintaining the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicab le to VOC and/or NO x sources, as required for maintenance of the ozone standard in St ark County, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal sect ion, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in Stark County.

LADCO Modeling Analysis for eight -hour Ozone Standard Assessment

LADCO performed modeling to evaluate the effect of the NO x SIP Call and Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This modeling was originally designed to assess the one-hour ozone standard. Further analysis was conducted and documented in the LADCO’s White Paper “8-Hour Ozone Assessment” dated May 2, 2001. Base year design values used were the average of the design values for the three (3) three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year emissions were taken from 1996 and four (4) ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991

While modeling results were not calculated for Stark County, the average decrease in ozone from the base case modeling run with modeling runs that applied emission controls required by the CAA, NO x SIP Call and Tier II /lowsulfur requirements was 15 ppb (2009 Future design value of 73.3ppb*.) [* LADCO Base K 2009 Future Base case with on-the-books” including CAIR].23 LADCO Modeling for CAIR of 2004

On March 10, 2004, the U.S. EPA promulgated CAIR. NO x emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 eastern st ates and the District of Columbia.

LADCO performed modeling to support the associated emission reductions for CAIR. This modeling was based on 2001 – 2002 design values for Stark County. Results of the CAIR modelin g show Stark County will continue to attain the eight-hour ozone NAAQS well into the future.

CHAPTER SIX

CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v) Formatted: Left24 Requirement 1 of 4: A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration : Ohio hereby commits to review its maintenance plan eight (8) years after redesignation, as required by Section 175(A) of the CAA

.
Requirement 2 of 4: A commitment to expeditiously enact and im plement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the event that future violations of the ambient standards occur.

Demonstration : Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response shall be prompted whenever an annual (1-year) fourth high monitored value of 88 ppb occurs in a single ozone season within the maintenance area. A wa rning level respon se will consist of a study to determine whether the ozone value indicates a trend toward higher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expe ditiously as possible, but in no event later than 12 months from the conclusion of the most recent ozone season (September 30).

Should it be determined through the warning level study that action is necessary to reverse the noted trend, the procedures for control selection and implementation outlined under “action level response” shall be followed.

Action Level Response An action level response shall be prompted whenever a two (2) year average fourth high monitored value of 85 ppb occurs within the maintenance area. In the event that the action level is triggered and is not due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA will determine additional control measures needed to assure future attainment of NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within eighteen (18) months from the close of the ozone season that prompted the action level.25 Control Measure Selection and Implementation Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking by state environmental boards.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be un necessary. Furthermore, Ohio will submit to U.S. EPA an analysis to de monstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4: A list of potential contingency measures that would be implemented in such an event.

Demonstration : Contingency measures to be cons idered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social considerations or other factors that Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive.

1) Lower Reid vapor pressure gasoline program.

2) Tighten RACT on existing so urces covered by U.S. EPA Control Technique Guidelines issued in response to the 1990 CAA.

3) Apply RACT to smaller existing sources.

4) One or more transportation control measures sufficient to achieve at least half a percent reduction in actual area wide VOC emissions. Transportation measures will be se lected from the following, based upon the factors listed above after consultation with affected local governments:

a) trip reduction programs, including, but not limited to, employerbased transportation management plans, area wide rideshare programs, work schedule changes, and telecommuting;26 b) traffic flow and transit improvements;

c) other new or innovative transportation measures not yet in widespread use that affects state and local governments deemed appropriate.

5) Alternative fuel and diesel re trofit programs for fleet vehicle operations.

6) Controls on consumer products consistent with those adopted elsewhere in the United States.

7) Require VOC or NO x emission offsets for new and modified major

sources.

8) Require VOC or NO x emission offsets for new and modified minor

sources.

9) Increase the ratio of emission offsets required for new sources.

10) Require VOC or NO x controls on new minor sources (less than 100 tons).

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.

Requirement 4 of 4: A list of VOC and NO x sources potentially subject to future controls.

Demonstration : The following is a list of VOC and NO x sources potentially subject to future controls.

NO x RACT

• EGUs

• asphalt batching plants

• industrial/commercial an d institutional boilers

• process heaters

• internal combustion engines

• combustion turbines

• other sources greater than 100 tons per year27 VOC RACT

• consumer products

• architectural and industrial maintenance coatings

• stage I gasoline dispensing facilities (inc luding pressure valves)

• automobile refinishing shops

• cold cleaner degreasers

• portable fuel containers

• synthetic organic compound manufacturing

• organic compound batch processes

• wood manufacturing

• industrial wastewater

• aerospace industry

• shipbuilding

• bakeries

• plastic parts coating

• volatile organic liquid storage

• industrial solvent cleaning

• offset lithography

• industrial surface coating

• other sources greater than 50 tons per year28 CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio will publish a notificati on for a public hearing and so licitation for public comment concerning the draft redesignation petition and maintenance plan in severala widely distributed publications 30 days prior tonewspaper in the public hearingarea

.
The public hearing to receive comments on the redesignation request will bewas held on July 27, 2006,November 8, 2012 at the189 25th St. NW Canton, Ohio University-Eastern Branch Shannon Hall Room 218, located at 45 425 National Road, St. Clairsville, Ohio.. The public comment period will closeclosed on July 28, 2006.November 8, 2012. No comments were received during the public comment period and no testimony was provided at the hearing. Appendix D will includeincludes a copy of the public notice , certifications of publication, and the and hearing transcript from the public hearing..29 CHAPTER EIGHT

CONCLUSIONS

The Stark County basic nonattainment area has attained the NAAQS standard and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of basic ozone nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a state implem entation and maintenance plan that meets the requirement of Section 110 (a)(1) of the 1990 CAA.

Ohio has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures. In addition, significant regional NO x reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements necessary for redesignation have been met.

Based on this presentation, the Stark County ozone basic nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, because this area is subject to significant tr ansport of pollutants, significant regional NO x reductions will ensure contin ued compliance (maintenance) with the standards with an increasing margin of safety.

The State of Ohio hereby requests that the Stark County ozone basic nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio state implementation and Maintenance Plan provisions contained herein. Formatted: Font: 14 pt, BoldPage left intentionally blankUNITES STATES ENVIRONMENTAL PROTECTION AGENCY

QUICKLOOK CRITERIA PARAMETERS

Jan. 11, 2007 Report Request ID: 396645 Report Code: AMP450

Selection Criteria Page 1 User ID: GYE

State County City

Site Parameter POC AQCR UAR MSA CMSA EPA Region Method Duration Begin Date End Date

39 151 GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS

Parameter
Classification Parameter Method Duration

CRITERIA 44201 W

SELECTED OPTIONS

MERGE PDF FILES

EVENTS PROCESSING Option Type Option Value

YES

EXCLUDE REGIONALLY CONCURRED EVENTS SORT ORDER

1

2

3

4

5

6

7 Order Column

PARAMETER_CODE

STATE_CODE

COUNTY_CODE

SITE_ID

POC

DATES

EDT_ID

GLOBAL DATES

2004 Start Date End Date

2006 TribalJan. 11, 2007

Note: The * indicates that the mean does
not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM
QUICK LOOK REPORT (AMP450)

Page 1 of 4 EXCEPTIONAL DATA TYPES

EDT DESCRIPTION

0

1

2

3

4

5

6

7 NO EVENTS

EVENTS EXCLUDED

EVENTS INCLUDED

EXCEPTIONAL EVENTS EXCLUDED

NATURAL EVENTS EXCLUDED

EVENTS WITH CONCURRENCE EXCLUDED

EXCEPTIONAL EVENTS WITH CONCURRENCE EXCLUDED

NATURAL EVENTS WITH CONCURRENCE EXCLUDEDJan. 11, 2007

Note: The * indicates that the mean does
not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM
QUICK LOOK REPORT (AMP450)

Page 2 of 4 Ozone (44201) Ohio Parts per million (007)

SITE ID P

O

C REP

ORG CITY COUNTY ADDRESS YEAR METH VALID

DAYS

MEAS 4TH

MAX

8-HR CERT EDT

39-151-0016

39-151-0016

39-151-0016

39-151-0021

39-151-0021

39-151-0021

39-151-1009

39-151-4005

39-151-4005

39-151-4005 1

1

1

1

1

1

1

1

1

1 0151

0151

0151

0151

0151

0151

0151

0151

0151

0151 Canton

Canton

Canton

Brewster

Brewster

Brewster

Not in a city

Alliance

Alliance

Alliance Stark

Stark

Stark

Stark

Stark

Stark

Stark

Stark

Stark

Stark 515 25TH. ST.

515 25TH. ST.

515 25TH. ST.

245 W. 5TH ST.

245 W. 5TH ST.

245 W. 5TH ST.

6318 HEMINGER

AVE. NE., PLAIN

TOWNSHIP

1175 WEST VINE

1175 WEST VINE

1175 WEST VINE 2004

2005

2006

2004

2005

2006

2004

2004

2005

2006 047

047

047

047

047

047

047

047

047

047 .086

.087

.083

.085

.083

.085

.084

.084

.106

.082 .082

.080

.081

.075

.078

.081

.081

.079

.088

.078 Y

Y

Y

Y

Y

Y

Y

Y

Y

Y 0

0

0

0

0

0

0

0

0

0 8-HOUR

NUM

DAYS

REQ

214

214

214

214

214

214

214

214

214

214 .076

.079

.080

.073

.077

.079

.077

.076

.087

.075 .074

.076

.078

.071

.076

.079

.076

.076

.086

.075 DAY
MAX>/=

0.085

1

1

0

1

0

1

0

0

5

0 197

205

195

211

213

208

196

210

214

199 %OBS

92

96

91

99

100

97

92

98

100

93 1ST

MAX

8-HR 2ND

MAX

8-HR 3RD

MAX

8-HRJan. 11, 2007

Note: The * indicates that the mean does
not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM
QUICK LOOK REPORT (AMP450)

Page 3 of 4 44201 047 INSTRUMENTAL ULTRA VIOLET PARAMETER METHOD

CODE COLLECTION METHOD ANALYSIS METHOD METHODS USED IN THIS REPORTJan. 11, 2007

Note: The * indicates that the mean does
not satisfy summary criteria. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM
QUICK LOOK REPORT (AMP450)

Page 4 of 4 REPORTING ORGANIZATIONS USED IN THIS REPORT

REPORTING

ORGANIZATION

CODE AGENCY DESCRIPTION

0151 Canton City Health Department Air Pollution ControlSTREET ADDRESS:

Lazarus Government Center
122 S. Front Street Columbus, Ohio 43215

CERTIFIED MAIL

January 10, 2007 State of Ohio Environmental Protection Agency

TELE: (614) 644·3020 FAX: (614) 644·3184 www.epa.state.oh.us

Mr. Steve Rothblatt, Chief
Air and Radiation Branch U.S.EPA, Region V
77 West Jackson Boulevard Chicago, Illinois 60604

RE: 2006 SLAMS Ozone Data Certification

Dear Mr. Rothblatt: MAILING ADDRESS:

P.O. Box 1049 Columbus, OH 43216·1049

Please find enclosed our SLAMS Reports (AMP-450 and AMP-240) for
calendar year 2006 ozone data as required in 40 CFR, Part 58,
Section 58.26.

I certify that the data in the report are accurate to the best of

our knowledge. There were no incidents of air pollution that
reached or exceeded levels as specified by Section 51.151 which
could cause significant harm to the he.alth of persons.

Sincerely,

Robert Hodanbosi Chief, Division of Air Pollution Control

Enclosure



### @ Printed on Recycled Paper Bob Taft, Governor Bruce Johnson, Lieutenant Governor Joseph P. Koncelik, Director

Ohio EPA is an Equal Opportunity Employer1 

## Ohio 2002 Base Year SIP Inventory

Ohio Environmental Protection Agency Lazarus Government Center 122 South Front Street Columbus Ohio 432152 

## Table of Contents

Section Page

Introduc tion ................................................................................................ 3

1.0 Point S ources ............................................................................................. 4

2.0 Non Road Sources ..................................................................................... 8

3.0 Area Sour ces ........................................................................................... 12

4.0 MAR Sour ces ........................................................................................... 25

5.0 On Road S ources ..................................................................................... 283 

## 2002 Base Year SIP Inventory for Ohio

Introduction

In April 2004, the United States Protection Agency (U .S. EPA) designated over 400 counties nationwide as non-attainment for the new eight-hour ozone ambient air quality standard, includi ng thirty three counties in Ohio. The 1990 Clean Air Act Amendments (CAAA) requires all st ates to revise and submit state implementation plans (SIPs) for areas wh ich are classified as nonattainment of the National Ambient Air Quality Standar ds (NAAQS) for ozone. The followingsite provides a map of Ohio’s counties with either a Moderate or basic nonattainment designation: http://www.epa.state.oh.us/dapc/general/Ohio8- Hour_Non-attainmentAreas0415204_1.pdf

As part of the designation of nonattain ment areas for the eight-hour ozone standard, a new attainment demonstration SIP will be necessary. A key element in the overall SIP planning process is an updated emission in ventory. This document presents the 2002 Base Year Ozone State Im plementation Plan (SIP) Emissions Inventory for Ohio as requir ed by the 1990 CAAA. It includes oxides of nitrogen (NO x ) and volatile organic compounds (VOC) emissions for point, area, on-road mobile, non-road mobile and biogenic emissions for Ohio.

This technical report documents the proc edures and the methodologies that were used in the development of summer day vo latile organic co mpound and nitrogen oxides emissions for all Ohio counties . This report describes the following:

1. Identification of stationary and mobile sources included in the inventory; 2. Sources of data, and data co llection methods used in the development of the inventory; 3. Methods and procedures used to estimate volatile organic and nitrogen oxides; and 4. Assumptions considered in the development of emission inventories.

The intent of this report is to describe how the inve ntory was prepared, and what information was considered in the inventory development.

This document comprises of five sections; one section for each inventory category. The biogenic in ventory is not being discussed in the document. Ohio EPA did not participate in the generation of the biogenic inventory. The Lake Michigan Air Directors C onsortium (LADCO) utiliz ed U.S. EPA’s Biogenic Emission Inventory System (BEIS) m odel in the Emission Modeling System (EMS) to generate summer weekday emissions for VOC and NO x .4 

### SECTION 1

POINT SOURCES

Emissions and source specif ic data for point sources are collected for the 2002 base year SIP inventory by the Ohio Environmental Protection Agency (Ohio EPA.) The primary source of data for point sources is facility-reported STARShip files. STARShip is a software package de veloped by Ohio EPA, Division of Air Pollution Control (DAPC), to assist t he regulated community in preparing and submitting a variety of electronic permi t applications and reports to DAPC. These data are reported by the Title V faci lities annually as part of the emissions fee/inventory process conducted by Oh io EPA and include emissions, process rates, operating schedules, emissions control data and other relevant information. The STARShip files are electronically transferred to DAPC and stored into the division’s Oracle database, STARS. The files are reviewed by the local air agencies and Ohio EPA district and c entral office staff. After review, the data are imported into Ex cel and linked with an Acce ss® database to further process the information into the federally approved National Em ission Inventory (NEI) database format in version 3.0. T he files are quality assured again using U.S.EPA QA/QC software for format and cont ent. The data are finally submitted to LADCO for emissions processing th rough the EMS. The State provided inventory for Electric Generating Units (EGU) is replaced with the federal EGU inventory. The EGU inventory is compiled by U.S. EPA’s Acid Rain Program. It is based on facility reported emissions as measured by continuous emissions monitors. In conclusion, the final point s ource inventory is a hybrid of the federal EGU inventory and the stat e provided non-EGU units.

A major distinction typically made in emi ssions inventories is that between point and area sources. In this inventory, point sources are sources for which individual records are maintained for that source. Such records are maintained for all Ohio Title V facilities (753 facilities statewide). The area source inventory accounts for facilities from non-Title V facilities and calculates emissions information using surrogate emissions factors based on energy usage, population or other reliable data. A more detailed discussion of the area source inventory is provided in Section 3. The point source inventory described herein is considered to be the most current and accurate source of emissions data available for 2002.

1.1 Point Source Process Emissions
Ohio EPA defines point source process emissions as those which occur at an identifiable Title V stationary stack or v ent. Point source emissions not emitted from discrete stacks or vents are termed fugitive emissions and are discussed in Section 1.2.5 1.1.1 Source Identificati on and Data Collection

The sources to be included in the 2002 base year inventory are identified using the Title V STARS database. Facili ty production and emissions data are included in this database. This info rmation is facility-reported actual 2002 emissions.

1.1.2 Non-reactive VOC Emission Adjustments
Sources are required to identify emissions of photochemically non-reactive VOC. Based upon this information, those emissions have been specifically excluded from the 2002 base line inventory in acco rdance with U.S. EPA’s “Recommended Policy on the Control of Volatile Organic Compounds.” A complete list of the compounds that U.S. EPA has identified as being photochemically non-reactive, and therefore not included in the inventory, are listed below:

• Methane

• Ethane

• Methylene chloride

• Methyl chloroform

• Trichlorofluoromethane (CFC-11)

• Dichlorodifluoromethane (CFC-12)

• Chlorodifluoromethane (CFC-22)

• Trifluoromethane (HFC-23)

• Chlorofluoromethance (HCFC-31)

• Difluoromethane (HFC-32)

• Decafluoropentane (HFC-43-10mee)

• Ethylfluoride (HFC-161)

• Trichlorotrifluoroethane (CFC-113)

• Dichlorotetrafluoroethane (CFC-114)

• Chloropentafluoroethane (CFC-115)

• 2,2-Dichloro-1,1,1-trifluoroethane (HCFC-123)

• 1,1,2-Trifluoroethane (HCFC-123a)

• 2-Chloro-1,1,1,2-tetrafluoroethane (HCFC-124)

• Pentafluoroethane (HFC-125)

• 1,1,2,2,-Tetrafluoroethane (HFC-134)

• 1,1,1,2-Tetrafluoroethane (HFC-134a)

• 1,1-Dichloro-1-fluoroethane (HCFC-141b)

• 1-Chloro-1,1,-difluoroethane (HCFC-142b)

• 1,1,1-Trifluoroethane (HFC-143a)

• Fluoroethane (HCFC-151a)

• 1,1-Difluoroethane (HFC-152a)

• Pentafluoropropane (HFC-225ca)

• Pentafluoropropane (HFC-225cb)

• Hexafluoropropane (HFC-236ea)

• Hexafluoropropane (HFC-236fa)

• Pentafluoropropane (HFC-245ca)

• Pentafluoropropane (HFC-245ea)

• Pentafluoropropane (HFC-245eb)6 • Pentafluoropropane (HFC-245fa)

• Pentafluorobutane (HFC-365mfc)

• Parachlorobenzotrifluoride (PCBTF)

• Methoxybutane

• Nonaflourobutane

• Heptafluoropropane ((CF 3 ) 2 CFCF 2 OCH 3 )

• Heptafluoropropane ((CF 3 )CFCF 2 OC 2 H 5 )

• Perchloroethylene

• Cyclic, branched or linear completely methylated siloxanes

• Methyl acetate

• Volatile methyl siloxanes

• Acetone

1.1.3 Emissions Esti mation Methodologies
Since source reported actual annual emi ssions are used in the 2002 base year inventory, no estimation methods are nec essary. The reports are provided to LADCO in National Emissions Inventory Input Format (NIF) 3.0 format. LADCO imported and processed the NIF files in EMS and applie d temporal and spatial profiles to the annual emissions to calculat e the July weekday emissions rates. The final point source inventory is split into two separate r eports, the EGU which is the U.S. EPA inventory for electric generating units and the non-EGU which is the state inventory minus the EGU units.

1.2 Point Source Fugitive Emissions
Another type of emissions data which is required to be f iled from point sources is fugitive emissions. Before 1990, fugiti ve emissions were categorized as area sources due to the lack of detailed informa tion available for fugitive sources. However, since these emissions are now electronically reported in the state’s ORACLE database, STARS, these emissions can be classified as point sources.

1.3 References Recommended Policy on the Control of Volatile Organic Compounds. U.S. Environmental Protection Agency, Research Triangle Park, NC, Revised January 18, 1989.

Procedures for the Preparat ion of Emission Inventories for Carbon Monoxide and Precursors of Ozone, Volume I: General Guidance for Stationary Sources. EPA450/4-91-016, Office of Air Quality Pl anning & Standards Re search, Triangle Park, NC. May 1991.

Compilation of Air Pollution Emission Fact ors, Fourth Editio n and Supplements, AP-42. U.S. Environmental Protection Agency, Research Triangle Park, NC, September 1985.7 Guidance for the Preparation of Qua lity Assurance Plans for O3/CO SIP Emission Inventories. EPA- 450/4-88-023, U.S. EPA Office of Air Quality Planning and Standards, Research Triangl e Par, NC, December 1988.

Documentation for the 2002 Electric G enerating Unit Nati onal Emissions Inventory (NEI). Eastern research gr oup, Inc., 1600 Perimeter Park Drive, Morrisville, NC 27560 and E.H. Pech an and Associates, Inc., 5528–B Hempstead Way8 

### SECTION 2

NON-ROAD SOURCES

The non-road inventory is generated regio nally by running U.S. EPA’s National Mobile Inventory Model (NMIM) model. The Wisconsin Department of Natural Resources undertook the responsibility of customizing the NMIM input files and submit the output file in NIF format to LADCO and U.S. EPA. LADCO processed the NMIM files in their emissions model and generated summer emissions rates. Below are two e-mails from Grant Heatheringt on from the Wisconsin Department of Natural Resources that we re distributed to the LADCO States. The first e-mail provides a summary of activities to revi se the NMIM county pr ofile files while the second e-mail provides an overall descrip tion of the modifications related to NMIM.

First e-mail from Grant Heater ington on NMIM Model and Input Descriptions 11/7/05

2.1 Activity Data
LADCO states: The activity data have be en revised to include E. H. Pechan & Associates, Inc. (Pechan), an air quality consulting firm www.pechan.com

, construction data. There are 130 source classification codes (SCC) impacted. The revised NMIM files are saved as five separate f iles: 1700002.act, 1800002.act, 2600002.act, 3900002.act and 5500002.act even though each file is identical. These duplicat es simplify the external file structures in NMIM. NonLADCO states: Minnesota provided revised activity data. The revised activity data are saved as 2700002.act.

2.2 Allocation Data

LADCO states: The allocation data hav e been revised to include Environ’s recreational marine data. The re vised NMIM files are saved as 17000wib_rev.alo, 17000wob_rev.alo, 18000wib_rev.alo, 18000wob_rev.alo, 26000wib_rev.alo, 26000wob_rev.alo, 39000wib_rev.alo, 39000wob_rev.alo, 55000wib_rev.alo and 55000wob_rev.alo. [“wib” stands for watercraft inboard and “wob” stands for watercraft outboard.]

Non-LADCO states: Minnesota provided revised watercraft inboard, watercraft outboard and snowmobile allo cation data. The revised NMIM files are saved as 27000wib_rev.alo, 27000wob_rev.alo and 27000snm_rev.alo. [“snm” stands for snowmobile.]

2.3 Emission Factor Data
All states: The brake specific fuel cons umption (BSFC) emissi on factor data have been revised to include Pechan’s data for diesel tampers/rammers (2270002006). The revised NMIM file is saved as revBSFC.EMF.9 2.4 Population Data LADCO states: The recreational marine and construction population data have been modified by Environ and Pechan respecti vely. The revised NMIM files are saved as 17000_rev.pop, 18000_rev. pop, 26000_rev.pop, 39000_rev.pop and 55000_rev.pop files.

2.5 Seasonality Data

LADCO states: The recreational marine and agricultural seasonality data have been modified by Environ and Pechan respecti vely. The revised NMIM files are saved as 17000_rev.sea, 18000_rev.sea, 26000_rev.sea, 39000_rev.sea and 55000_rev.sea.

Non-LADCO states: For Iowa, Minnesota and Missouri, the agricultural seasonality data have been modified by Pechan. The revised NMIM files are saved as 19000_rev.sea, 27000_rev.sea and 29000_rev.sea.

2.6 Growth Data
LADCO states: Pechan revised the growth file. The revised NMIM files are saved as five separate files: 17000_r ev.grw, 18000_rev.grw, 26000_rev.grw, 39000_rev.grw and 55000_rev.grw even though each file is identical. These duplicates are needed for the exter nal file structures in NMIM.

2.7 Fuel Data

LADCO states: Pechan revised four t ables (countyyear, countyyearmonth, datasource and gasoline) in the Nationa l County Database (NCD) used by NMIM to incorporate new fuel data. Additional revisions are incorporated into 2002 data for non-road Stage 2 controls. Depending on the year being modeled, different versions of the revised tables are used. Also, the countynrfile, countyyear and datasource tables are revis ed to reference the new activity, allocation, growth, population, and seasonality files describ ed above. NCD tables with names ending in “def” are default versions of the table. See Table 2-1 for the appropriate versions of the tabl es for the selected years.

Non-LADCO states: The countynrfile, countyyear and datasource tables are revised to reference the new activity, allocation and seasonality files described above. See Table 2-1 below for the appropriate versions of the tables for the selected years.10 Table 2-1 NMIM NCD Tables fo r Specific Years and States

States Year

2002 2007 – 2009, 2012 & 2018 LADCO states countynrfile_rev_all, countyyear_rev_2002, countyyearmonth_rev_all, datasource_rev_all, gasoline_rev_all countynrfile_rev_all, countyyear_rev_post_2002, countyyearmonth_rev_all, datasource_rev_all, gasoline_rev_all MN countynrfile_rev_all, countyyear_rev_2002, countyyearmonth_def, datasource_rev_all, gasoline_def countynrfile_rev_all, countyyear_rev_post_2002, countyyearmonth_def, datasource_rev_all, gasoline_def IA and MO countynrfile_rev_all, countyyear_def, countyyearmonth_def, datasource_rev_all, gasoline_def countynrfile_rev_all, countyyear_def, countyyearmonth_def, datasource_rev_all, gasoline_def

A more recent e-mail by Grant Heather ington on 5/26/2006, provides a synopsis of changes with no referenc es to the file names

Second e-mail mail from Grant Heat herington on NMIM Model and Input Descriptions 5/26/06

The NMIM model developed by U.S. EPA, was used to estimate emissions for all other non-road mobile categories. NM IM consolidates non-road mobile emissions and on-road emissions modeling into a single modeling system. Only the non-road emissions model ing portion of NMIM was used in the development of this emission inventory. NMIM uses the U.S. EPA’s non-road model to calculate non-road mobile emissions. The basic non-road algorithm for calculating emissions uses base year equipment populations, average load factors, available engine pow ers, activity hours and em ission factors. Before NMIM was run, modificati ons and additions were made to the NMIM input data and the non-road model.

a. Revised activity data for construction equipment using updates provided by E.H. Pechan & Associates, Inc. Activity data describes typical usage for different types of non-road mobile equipment.

b. Revised allocation data for re creational marine equipment using updates provided by ENVIRON International Corporation. Allocation data is used to spatially allocate emissions.11 c. Added emission factors for dies el tampers/rammers provided by E.H. Pechan & Associates, Inc. Diesel tampers/rammers are a type of construction equipment.

d. Revised seasonality data for construction and recreational marine equipment using updates provided by E.H. Pechan & Associates, Inc. and ENVIRON International Corporation respectively. Seasonality data is used to tempor ally allocate emissions across the months of the year.

e. Revised population data for cons truction and recreational marine equipment using updates provided by E.H. Pechan & Associates, Inc. and ENVIRON International Corporation respectively.

f. Revised growth rates using u pdates provided by E.H. Pechan & Associates, Inc. If equipment populations aren’t provided for the modeled year (e.g. 2002), growth rates and scrappage rates are used to adjust the available equi pment populations to the modeled
year.

g. Revised gasoline parameters usi ng updates provided by the state and E.H. Pechan & Associates, Inc. Gasoline parameters include Reid vapor pressure (RVP), oxyg enate content and sulfur content.

h. Replaced the default version of the non-r oad model included with NMIM with an improved version that generates a more complete estimate of permeation emissions. The new version of the nonroad model was provided by Air Im provement Resources, Inc. Permeation emissions are due to the permeation of hydrocarbon molecules through plastic and rubber equipment components.12 

### SECTION 3

AREA SOURCES

Area sources are those sources which are typically small, individual and numerous, and have not been in ventoried as specific poi nt, mobile, or biogenic sources. For inventory purposes, t hese sources are grouped with other like sources into area source categories to allow emissions to be calculated collectively using one methodology. Area sources have been traditionally defined at the county leve l and therefore, most area source methods are designed to estimate area source emissions at the county level.

Ohio EPA has either used published Em ission Inventory Improvement Program (EIIP) methodologies or selected other methodologies which ar e shared by other states. The decision of which methodolog y to use was largely based on Ohio’s data availability. Data which was not av ailable on a county-level is estimated by assigning a percentage of t he state’s total activity to each county based on the state’s population or empl oyment information.

The area sources discussed in this document are thos e that emit NO X and/or VOC into Ohio’s atmosphere. Table 3-1 lists the categories included in the 2002 area source inventory:

Table 3-1 Categories included in the 2002 area source inventory

VOC Emissions NO X & VOC Emissions NO X Emissions Agricultural Pesticides Residential Coal Combustion Human Cremation Architectural Surface Co atings Residential Distillate Oil Combustion Auto Body Refinishing Residential LPG Combustion Consumer & Commercial Solvents Residential Natural Gas Combustion Degreasing (Solvent Cleaning) Residential Wood Combustion Fuel Marketing Industrial Distillate Oil Combustion Graphic Arts Industrial Natural Gas Combustion Hospital Sterilizers Industrial Residual Oil Combustion Industrial Surface Coating Structure Fires Industrial Rubber & Plastics
Landfills
Portable Fuel Containers POTW Traffic Markings13 3.1 Agricultural P esticides (SCC 246850000) VOC
Ohio farmers use mostly Atrizine and 2, 4-D chemicals in pesticide formulations for the three main crops: corn, soy bean and wheat. According to Ohio’s Department of Agriculture, Ohio farmers use Atrizine pesticide with 42.6 percent active ingredient and 56.5 percent inert i ngredient. The 2, 4-D pesticide contains 46.8 percent active ingredi ent and 53.2 percent inert ingredient. While these percentages are not across t he board, they represent the majority of what is being used. Ohio farmers use Atrizine and 2, 4-D in a liquid solution formulation type which is mixed with water when r eady to use, and spray applied 90 percent of the time.

The emission factor of 700 lb/ton for surfac e application for Atrizine and 2, 4-D is applied. To estimate the VOC emissions for all pesticides for each crop, an alternative method from the EIIP document is used because Ohio lacked the level of detail needed to calculate emissi ons for each pesticide formulation.

E = VOC emissions

A= Harvested acres

R = Pounds of pesticide applied per year per harvested acre (see above).

I = Pounds of active ingredient per pound of pesticide (assume a factor of one)

ER = Evaporation rate (typ ically 0.9) (Wiens, 1977)

3.2 Architectural Surface Coatings (SCC 2401001000) VOC
Architectural surface coatings is typi cally considered to be a non-industrial category which homeowners an d painting contractors use for coating the interior and exterior of houses, buildings, and other surfaces. Two types of paint are used to categorize this area source: water-based and solvent-based paint. Solvent-based paint typically contains substantially higher volatile solvent contents than water-based paint.

Table 3-2 lists the emission factors in calculating the VOC emissions which are acquired from the “Documentation for the 2002 Non-point Source NEI for Criteria Air Pollutants (CAPS) and Hazardous Air Pollutants (HAPS)”, January 2004, by Pechan 1 and prepared for Emission Factor and Inventory Group (EFIG).

E(VOC) = A x R x I x ER x 2.4514 Table 3-2 VOC Emission Factors and Paint Usage Factors:

Paint Type VOC Emission Factor (lb/gal) Usage Factors (gal/person) Solvent-Based Paint 3.87 0.4158

Water-Based Paint 0.74 2.0444

The per capita usage factors are estimated by dividing the total volume of each type of coating shipped by the 2002 U.S. population 2 288,368,698.

3.3 Auto Body Refinishing (SCC 2401005000) VOC
The repairing of damaged vehicles to any coating applications which occur after those applied at the original manufacturers’ assembly plant are included in this category (only auto repair shops not coati ng of new cars). This area source includes paint and thinning solvents used as well as for surface preparation and clean-up. Since auto body repair shops may also be point sources, the area source emissions estimate will have to be adjusted by removing the total point source emissions. However, in Ohio, there are no point sources identified for this category so no such adjustment is made.

The methodology is based on the per capita emissions factor because it is considered a more reliable factor t hat the employment factor. The VOC emissions factor (EF) of 1.3 lb/person is applied to each county’s population. This EF includes a thirty-three (33) percent promulgated rule reduction.

3.4 Consumer & Commercial Solvents (SCC 2465000000)

VOC
This area source includes a wide array of products includ ing personal care products, household cleaning products and household pesticides. The majority of VOC emitted into the air from this ca tegory is a result of evaporation of the solvent contained in the product or from t he propellant released during use. This category includes household use as we ll as businesses, institutions, and industrial manufacturing operations.

Industrial solvent applications may also be point source s so adjustment must be made to the area source emissions by removing emissions due to point sources. However, in Ohio there are no point sources which contri buted VOC emissions from this category.

Ohio used the population 2 based methodology. A 7.3 lb/person EF is used to calculate VOC emissions.15 3.5 Solvent Cleaning (SCC 2415000000) VOC
This area source (also known as “degreasing”) includes two classifications:

• Solvent Cleaning – Cold Cleaning for Automobile Repair (2415360000) – Cold Cleaning for Manufacturi ng (2415345000) – Vapor/in-line Cleaning for El ectronics & Electrical (2415230000) – Vapor/in-line Cleaning for Other (2415245000)

• Solvent Cleanup – Wipe Cleaning of External Surfaces

Ohio utilizes the methodology requiring employment 3 data. Each solvent-cleaning SCC identified above has an EF as indicate d below in Table 3-4 which is used to calculate the VOC emissions by county. The resultant emissions are reduced by thirty (30) percent to account for t he Maximum Achievable Control Technology (MACT) rules and are also reduced to account for point source emissions.

Table 3-4 Solvent Cleani ng SCC Emission Factors

2415360000 270 lb/employee 2415345000 24 lb/employee 2415230000 29 lb/employee 2415245000 9.8 lb/employee

3.6 Fuel Marketing VOC

Truck Transit (SCC 2505030120)

Gasoline tank trucks in transit are considered an evaporat ive loss of VOC emissions. This category consists of the VOC losses durin g the transit of gasoline in the trucks. The VOC calculation formula came from EIIP. Because gasoline may go through bulk gasoline plant s before distribution to service stations, gasoline throughput figures are multiplied by 1.25 to estimate total gasoline transported. The total gasoline transported is multiplied with an EF of 5.5 E-03 lb/1000 ga llon transported for tank transit under loaded conditions and 5.5 E-02 lb/1000 gallon transported for tank transit under unloaded conditions.16 Filling Losses (SCC 2501060050)

This category consists of the VO C loading losses from underground storage tanks during the transfer of fuel from the trucks. VO C calculations are based on ninety-five (95) percent subm erged fill and five (5) percent splash for all counties. The VOC emissions calculation is also based on a ninety (90) percent rule effectiveness and a hundred (100) percent rule penetration.

Standing Losses (SCC 2501060201)

Breathing emissions losses from storage ta nks occur during diurnal changes in barometric pressure, temperature and from gasoline evaporation. To calculate VOC emissions from the st orage or breathing losses an EF of 1.000E+00 lb per 1000 gallon gas throughput is used for all c ounties except of t he 16 original nonattainment counties for ozone which em ploy a 1.000E-01 lb/ 1000 gallon of gas throughput. The value for the non-attain ment counties was discussed with Bill Juris, Ohio EPA-DAPC and familiar with Ohio’s gasoline dispensing facilities (GDF) VOC regulations and practices.

Gasoline Distribution Stag e 2 (SCC 2501060100 & 250106103)

Vehicles refueling at service stations ar e the source of VOC emissions as vapors are displaced from autom obile tanks during filli ng (2501060100) and from spillage (2501060103) of gasoli ne. The quantity of displa ced vapors is based on gasoline throughput and is affected by gaso line temperature, gasoline volatility and, most importantly, by the presence of vapor recovery equipment. Stage II vapor recovery equipment is required at al l service stations in the 16 original nonattainment counties for ozone that market in excess of 10,000 gallo ns per month. The VOC emissions factor for filling operat ions is 1.0E+01 lbs/1000 gallons. For the 16 counties that are subject to controls , a control efficiency of ninety-five (95) percent with ninety (90) perc ent rule effectiveness and a ninety (90) percent rule penetration is used in the ca lculation of emissions. The VOC emissions factor for spillage is 0.7 lbs/1000 gallons of gasoline for t he 72 unregulated counties and 0.4 lbs/1000 gallons of gasoline for the controlled counties.

Since the actual gallons of gasoline so ld in each county could not be obtained, the methodology uses the vehicle miles traveled (VMT) data and the State’s consumption of gasoline to apportion the gasoline consum ption within a county.

3.7 Graphic Arts (SCC 2425000000) VOC
This area source includes printing of newspaper, books, magazines, fabrics and other materials. VOC emissions from th is category are calculated using Ohio’s population 5 rather and the per capita emissions factor for VOC of 1.3 lb/year.17 3.8 Hospital Sterilizers (SCC 2850000010) VOC
Small amounts of ethylene oxide (EO) are us ed in sterilization of hospital surgical equipment and plastic devices that cannot be sterilized by steam. EO is used as a sterilizer because of it s potency and effectiveness in destroying pathogens without damaging the integrity of the device. The methodology used to calculate EO emissions in Ohio called for the numbe r of beds in each hospital size to use the appropriate EF. Based on national sales of EO in 2002, Ohio’s EO emissions are calculated to be 7.3 tons (based on Ohio’s share of hospital beds of 3.5 percent).

3.9 Industrial Rubber/Pl astics (SCC 2430000000) VOC
This category is calculated using employment 3 data for each county for the following North American Industry Cla ssification System (NAICS):

31332 32613 32614 32615 32616 32621 32622 316211 325991 326113 326121 326122 326191 326199 326291 326299 335121 339991

A VOC EF of 203 lbs/employee is re commended to estimate the area source VOC estimate. Even after subtracting the point source VOC contribution (1116 annual tons of VOC), this category would have been the highest category of emissions. After raising this issue with ot her states in the LADCO region, it is decided that the emissions factor has a high degree of uncertainty and it will significantly skew the overall VOC estimate from the area source categories. This category is left out from the emissions table but it is k ept here for documentation.

3.9 Industrial Surface Coating VOC
This area source contains several categor ies as listed below in Table 3-5. The appropriate NAICS codes are used for each category, shown in Table 3-6, to obtain employment data 3 from Bureau of Labor Statis tics for each county. Net VOC emissions are calculated by subtracting the portion of VOC contributed from point sources.18 Table 3-5 Categories included in Area Sources

CATEGORY SCC NAICS VOC EF

Factory Finished Wood 2401015000 321 131 Lb/employee/year Furniture and Fixtures 2401020000 337 944 Lb/employee/year Metal Containers 2401040000 332431 6029 Lb/employee/year Sheet, Strip and Coil 2401045000 332812 2877 Lb/employee/year Machinery & Equipment 2401055000 333 77 Lb/employee/year Large Appliances 2401060000 3352 463 Lb/employee/year Electrical Insulation 2401065000 334 290 Lb/employee/year Automobiles (new) 2401070000 3361 794 Lb/employee/year Other Transportation Equipment 2401075000 336 35 Lb/employee/year
Marine Coatings 2401080000 3366 308 Lb/employee/year Other Product Coatings 2401090000 339 0.6 Lb/person/year High Performance Coatings 2401100000 811 0.8 Lb/person/year

Other Special Purpose 2401200000 NOT DONE 0.8 Lb/person/year

Table 3-6 NAICS Codes Used for Area Sources

Automobile Repair 488490, 441110, 441120, 4471, 441222, 441210, 81111 Manufacturing 337, 331, 332, 333, 335, 336, 334, 339 Electronics and Electrical 335 Other 337, 337, 331, 332, 333, 335, 336, 334, 339, 488490, 441110, 441120, 4471, 441222, 441210, 8111

3.10 Municipal Solid Waste (SCC 2620030000) VOC
The methodology for methane gas emission s from landfills requires the tonnage deposited in the landfills for the last 25 years. However, Ohio EPA’s Division of Solid and Infectious Waste’s input data onl y spanned 20 years. Therefore, any landfill which did not record or report its waste intake for that period was not included in the database. Landfills with c ontrols are identified as having flares. The preferred method is used which is based on landfill capacity and tonnage input of waste and the number of years the landfill o perated and the number of19 years it has been closed. A seventy five (75) percent collec tion efficiency and a ninety-five (95) percent c ontrol efficiency are used per AP-42 Compilation of Air Pollutant Emission Factors.

The toxic pollutants are calculated usi ng the methane production rate and the EIIP calculation formula that involves the compound molecular weight and the co-disposal factor. The VOC emissions ar e equal to the emissions from all toxics minus methylene chloride, mercury, and perchloroethylene (PERC.)

3.11 Portable Fuel Containers VOC

RESIDENTIAL 2501011010 / COMMERCIAL 2501012010

This area source’s VOC is the sum of emissions obtained from both commercial and residential containers. The resi dential and commercial container total emissions for the year are based on 250 days per year and include losses from refueling vapor displacement, permeation, diurnal, equipment refueling spillage, and transport-spillage. Emissions estimates are based on population 2 and consistent with California’s approach. Although the California methodology generates rather high emissions estimates, it is the only available estimate at the time of generating the 2002 inventory.

3.12 POTW (SCC 2630020000) VOC

Ohio EPA’s Division of Surface Water does not review minor flows because they are not mandated by U.S. EPA. Therefore, Ohio’s wastewater flow data only represents eighty (80) percent of the tota l flow for this area source category. A twenty (20) percent increased flow is add ed to compensate for Publicly Owned Treatment Works (POTW) fac ilities which are not part of Ohio’s database. The VOC emissions factor is based on the P ennsylvania (PA) factor of the 1996 Protocol.

The 1996 EIIP methodology only offered EF for HAPs. Ohio’s VOC emissions for this category are calculated bas ed on an EF obtained from the PA 1996 Protocol which was the factor being used at the time of th is inventory.

3.13 Traffic Markings (SCC 2401008000) VOC
The number of lane miles per county is obtained from Ohio’s Department of transportation. The nationa l gallon of traffic markings are apportioned to the state using the ratio of state dollar di sbursements in rela tion to the national disbursement. The county level apportionment of paint 2 is made using the number of lane miles. The VO C factor (3.36 lb/gal) is ca lculated based on Ohio's assumption of ninety (90) percent wate r based and ten (10) percent oil based paint.20 3.14 Human Cremation (SCC 2810060100) NO X Not all Ohio counties possess a cr ematory so only those counties with crematories are used to calculate the number of cr emations. These numbers are adjusted to account for the cremation of bodies which are brough t in from out of county since the calculations are based on number of deaths per county 2 . Ohio has an eighteen (18) percent cremation ra te. Particular matter (PM) emissions are calculated for this category but the methodology did not call for the calculation of NO X emissions so they are not ca lculated. Furthermore, since current NOX EF in Ohio’s crematory permits vary significantly, the EIS program will develop a less variable one for future use in inventory NO X calculations.

3.15 Industrial Fuel Combustion VOC & NO X
Industrial Distillate Oil Combustion (SCC 2102004000)
Ohio’s fuel consumption is apport ioned per county based on the county’s population 5 . The area source VOC and NO X emissions are calculated and adjusted to subtract the emissions due to point sources. A heating value of 140 mmbtu/1000 gallon is used and 4,795,00 0 barrels are consumed in 2002. [MMBTU stand for Million British Thermal Units].

Industrial Residual Oil Combustion (SCC 2102005000)
Ohio’s fuel consumption is apport ioned per county based on the county’s population 5 . The area source VOC and NO X emissions are calculated and adjusted to subtract the emissions due to point sources. There are 1,806,000 barrels consumed and a heating value of 140 mmbtu/1000 gallon is used.

Industrial Natural Gas Combustion (S CC 2102006000)
Ohio’s fuel consumption is apport ioned per county based on the county’s population 5 . The area source VOC and NO X emissions are calculated and adjusted to subtract the emi ssions due to point sources.

3.16 Residential Fuel Combustion VOC & NO X

Residential Coal Combustion (SCC 2104001000)
Ohio’s household consumption of c oal is apportioned per county based on county population 5 . NO X and VOC emissions are calcul ated using EF of 9.1 and 10 lb/ton of coal respectively.

Residential Distillate Oil Combustion (SCC 2104004000)
Ohio’s household consumption of distillate oil is apportioned per county based on county population 5 . NO X and VOC emissions are calculated using EF of 18 and21 0.71 lb/1000 gallons distil late fuel respectively. A heating value of 140 mmbtu/1000 gallon is used.

Residential Liquid Petroleu m Gas Combustion (LPG) (SCC 2104007000)
Ohio’s household consumption of LP G is apportioned per county based on county population 5 . NO X and VOC emissions are calculated using EF of 13 and 0.49 lb/1000 gallons LPG respectively. T here are 11,432 barrels estimated to be used in 2002.

Residential Natural Gas Combustion (SCC 2104006010)
Ohio’s household consumption of LP G is apportioned per county based on county population 5 . NO X and VOC emissions are calculated using EF of 94 and 5.5 lb/MMSCF respectively. [MMSCF stands for Million Standard Cubic Feet].

Residential Wood Combustion

VOC and NO X emissions from this area source are estimated for seven types of equipment that may be used for residentia l heating involving wood. They are listed below with t he appropriate SCC:

Fireplaces without inserts 2104008001 Fireplaces with inserts cataly tic (non-U.S. EPA cert) 2104008002 Fireplaces with inserts non -catalytic 2104008003 Fireplaces with inserts catalytic (U.S. EPA cert) 2104008004 Wood stoves – Conventional 2104008010 Woodstoves – Catalytic 2104008030 Wood stoves – Non catalytic 2104008050

The number of Ohio homes with fireplaces are adjusted for thos e that burn wood. The following assumptions are applied to those adjusted homes:

92 percent of wood combust ed in non-certified units 5.7 percent of wood combusted in non-catalytic units 2.3 percent of wood combusted in catalytic units

A state consumption value is applied which is apporti oned to each county based on a county’s population. Table 3-7 shows the EF used for each of the seven types of wood burners which make-up this category:22 Table 3-7 Emission Factors Used fo r Wood Burners included in Area Sources

SCC 2104008002 210400 8003 2104008004 SCC 2104008010 210400 8050 2104008030 SCC 2104008001 RAPIDS Code Non-Certified N on-Catalytic Catalytic Units VOC 53 12 15 Lb/ton NOX 2.80E+00 2.80E+00 2.00E+00 Lb/ton

3.17 Structure Fires (SCC 2810030000) VOC & NO X
This area source is considered a combustion source for VOC and NO X emissions which is calculated using EF of 11 and 1.4 lb/ton burned respectively. The residential and commercial structures fi res for each county are tabulated and a fuel loading per fire EF of 1.15 ton/fire is applied.

3.18 Miscellaneous Categories
Although the area sources described above are the categories which contribute VOC & NO X emissions into Ohio’s ambient air, other area sources are calculated as well. These additio nal sources are listed below and contribute the associated pollutants into Ohio’s air.

Dry Cleaning Perchloroethylene Lamp breakage Mercury

The following area sources are attempted to be calculated but due to insufficient Ohio data available or unreliable emissi ons factors, they remain incomplete.

Asphalt Paving VOC Forest Fires VOC & NO X Gas & Oil Production VOC Open Burn VOC

3.19 References

1. Documentation For the 2002 Non-Poin t Source National Emission Inventory For CAPS and HAPS. U.S. Environment al Protection Agency. Emissions Factor and Inventory Group. E.H Pechan and Associates, Inc. January 2004.

2. United States Census Bureau. Population Division. http://eire.census.gov/popest/dat a/counties/tables/CO-EST2002/COEST2002-01-39.php (Accessed 2003)23 3. United States Census Bureau. County Business Patterns. http://censtats.census.gov/cbpnaic/cbpnaic.shtml (Accessed 2003)

Pesticides - Agricultural and Non-Agricult ural. U. S. Environmental Protection Agency. Emissions Inventory Improvement Program. East ern Research Group, Volume III. Chapter 9, June 2001.

Agricultural Chemical Use. U. S. Department of Agriculture. National Agricultural Statistics Service. http://usda.mannlib.cornell.edu/reports /nassr/other/pcu-bb/agcs0503.txt (Accessed 2003)

Telephone conversation with Diane Roll. Ohio Department of Agriculture, Columbus, Ohio. Percentage of active ingredients and met hod of application.

Daily Vehicle Miles Traveled Reports. Oh io Department of Tr ansportation, Office of Technical Services. http://dot.state.oh.us/techservsite/availpro /Road_ Infor/KDVMT/kDVMT.htm (Accessed 2003)

Motor Vehicle Fuel Tax. Ohio Department of Taxation. www.state.oh.us/tax (Accessed 2003)

Advancing Health in America Guide. Health Forum. American Hospital Association. 2001-2002

Documentation for the Draft 1999 National Emissions Inventory (Version 3.0) For Criteria Air Pollutants and A mmonia. Area Sources. E. H. Pechan & Associates, Inc. March 3, 2003

Compilation of Air Pollutant Emission Factors, Fourth Edition and Supplements, AP- 42, U.S. Environmental Protection Agency, Research Triangle Park, NC, September 1985 landfill.

Landfills. U. S. Envir onmental Protection Agency. Emissions Inventory Improvement Program. Eastern Research Group Volume III: Chapter 15. January 2001.

Ohio EPA, Division of Solid & Infectious Waste. Columbus, Ohio.

California’s Portable Gasoline Container Emissions Inventory. Air Resources Board Mobile Source Contro l Division. California Ai r Resource Board Inventory method (September 23, 1999). http://www.arb.ca.gov/homepage.htm . (Accessed 2003).24 Spreadsheet formulation provided by “B uzz” David Asselmeier, Air Quality Planning Section, Inventory Group, Springfield, Illinois.

Ohio EPA Division of Surface Water. Columbus, Ohio.

Paint and Allied Products: 2002. U.S. C ensus Bureau. U.S. Department of Commerce. Economics and Statistics Administration. http://www.census.gov /industry/1/ma325f02.pdf (Accessed 2003)

Highway Statistics 2002. Federal Highway Ad ministration. U. S. Department of Transportation. http://www.fhwa.dot.gov/ policy/ohim/hs02/sf2.htm (Accessed 2003)

Ohio Department of Transportation. Columbus, Ohio.

Cremation Association of North America. http://www.cremationassociat ion.org/docs/Web01Prelim.pdf (Accessed 2003)

State of California Air Res ources Board Test Report http://www.arb.ca.gov/homepage.htm (Accessed 2003)

Industrial Sector Energy Price and Ex penditure Estimate s, 1970-2001, Ohio. Energy Information Administration. U. S. Department of Energy. http://www.eia.doe.gov/emeu/st ates/sep_prices/ind/pr_ind_oh.html http://www.eia.doe.gov/emeu/aer/pdf/pages/sec1_27.pdf (Accessed 2003)

Ohio Department of Commerce. State Fi re Marshal Division. Columbus, Ohio. http://www.com.state.oh. us/odoc/sfm/firecont.htm (Accessed 2003)25 

### SECTION 4

MARINE, AIRCRAFT and RAIL (MAR) SOURCES

MAR sources are those non-road sources which are significant enough in terms of emissions to be considered separately from the rest of the non-road sources. The MAR inventory consists of comme rcial marines, aircraft and locomotive sources. The marine and locomotive inventory is generated by Environ 1 under contract with LADCO and the aircraft in ventory is generated by U.S. EPA.

4.1 Marine Vessel Sources
Commercial marines consist of several different categories of vessel types and for each category there are unique acti vity data sources, engine types and emissions rates. A summary of commerc ial marine activity categories and data sources is shown at Table 4-1.

Table 4-1 Summary of Commercial Mari ne Activity Categories and Data Sources

Commercial Marine Activity Spatial Range Activity Estimation Data Source

Large Deep Draft Near Port Port s and Army Corps of Engineers Large Deep Draft Mid Lake Army Corps of Engineers Barge Traffic Inland Rivers T ennessee Valley Authority Fuel Consumption Estimation Barge Traffic Lake Traffic Army Corps of Engineers Freight Carried Tug Near Port Coast Guard Vessel List and Selected Surveys Ferries Regular Route C oast Guard Vessel List and Selected Surveys Excursion Near Home Port Coast Guard Vessel list Dredging Area by Contract Army Corps of Engineers Contracts Commercial Fishing Dock State Registration Military Near shore and Mid-Lake Coast Guard Fuel Purchases

The procedure that is followed in estimating emissions for each commercial marine category or boat type is documented by Environ 1 . The summary of commercial marine emissions estimate fo r Ohio is 248 tons of VOC and 10,307 tons of NO X . This is significantly lower than what is estimated by NEI for 1999 which was 1376 tons of VOC and 44,020 tons of NO X

.26 4.2 Locomotive Sources
Locomotives are usually the mo st important source of NO X from non-road engines. This category is especially impor tant for Ohio because the State is an important rail center. Rail activity is ty pically broken into five subcategories. These subcategories are listed in Table 4.2.

Table 4.2 Rail Categories

SCC Description Comment 2285002006 Class I operations No rfolk Southern (NS), CSX 2285002007 Class II/III operations R egional and local railroads 2285002008 Passenger Trains AMTRAK 2285002009 Commuter Lines METRA 2285002010 Yard Operations Class I yard rail and small switching railroads

Because the Class I railroads are expect ed to be the most significant rail operations in most areas, every Class I ra ilroad is asked for information about its rail operation. Norfolk Southern (NS) and CSX provided estimates for their fuel consumption by rail line fo r line-haul estimates but are unable to detail their switching rail activity. They provided activi ty by county in terms of ton-mile of freight movement and estimated fuel cons umption using typical system-wide fuel consumption per ton-mile. The Class II rail estimate which is of lesser importance than the Class I rail is ba sed on national consumption and an employee emissions factor of 10,000 gallons per employ ee. The passenger rail estimate is based on information provid ed by AMTRAK on the weekly schedule of trains and emissions are based on 2.35 gallons per train-mile fuel consumption. Emissions factors and detailed calculation procedures are documented on the Environ 1 study and it is referenced at the end of this section.

4.3 Aircraft Vessel Sources

U.S. EPA contracted wit h ERG Consulting Firm http://www.erg.com/ to generate this inventory. The estimate is based on information collected by the Federal Aviation Administration (FAA) on publish ed (landing and take-off) LTO cycle by engine type for each airline and major airport in the state. The LTO is multiplied by emissions factors developed by the In ternational Civil Aviation Organization (ICAO). Finally, the LTO data are comb ined and entered into the FAA Emissions and Dispersion Modeling System (EDMS), wh ich is designed to calculate aircraftspecific emissions.

For all of the above three categories, LA DCO processed the data in EMS 2003 to calculate summer day emissions for VOC and NO X . The tables are provided as an attachment.27 4.4 References

LADCO Non-road Emissions Inventory Project for Locomotive, Commercial Marine and Recreational Marine Emission Sources, prepared by Christian E. Lindhjem, ENVIRON International Co rporation, September 8. 2004.28 

### SECTION 5

ON-ROAD SOURCES

A mobile source of air pollution is a self-propelled or portable emitter of air pollutants, and mobile source emissions are those generated by the engines or motors that power such sources. Most mobile sources, exc ept jet or turboprop aircraft, are powered by in ternal combustion (IC) piston engines, and nearly all use liquid fuels.

Gaseous fuels, such as compressed nat ural gas (CNG) or liquefied petroleum gas (LPG), had only a very small fraction of the motor fuel market in Ohio in 2002. Solid fuels have not b een used by mobile sour ces in significant amounts since railroads retired their coal- powered steam locomotives in the 1950s.

5.1 Categories of Mobile Sources For inventory and planning pur poses, mobile sources ar e divided into two major categories.

1. On-highway mobile sources, i.e., mo tor vehicles such as cars, vans, trucks, buses and motorcycles used for transportation of goods and passengers on roads and streets.

2. Off-highway (usually referred to as non-road) mobile sources including:

• Modes of powered transportation that do not use roads, such as aircraft, trains, ships and boats, and motor vehicles used off-road.

• Self-propelled or portable motorized machines or equipment not used for transportation, ranging from construction equipment and farm tractors to lawnmowers and hand-held power weed choppers.

Mobile Sources: All on-highway mobile sour ces are self-propelled.

Non-road Mobile Sources: Some non-road mobile sour ces (e.g., farm tractors), are self-propelled, but many non-road sources are not. A gasoline-powered chain saw is a familiar example of a non-se lf-propelled non-road mobile source.

Stationary Sources: Not all movable or portabl e emission sources are mobile sources, however. A small truck-port able cement or hot-mix asphalt plant, for example, may be set up near a constructi on or road-building site. Such plants are classified as stationary s ources, not mobile sources for two reasons: (1) they may operate for weeks or months at a single location, and (2) the trucks that move the plants do not supply power for them.29 NOTE: Not all IC or turbine e ngines are mobile sources. Fixed IC engines, such as those that power pipeline compressors or standby generators in electricity plants and elsewhere, are also cl assified as stationary sources.

5.1.1 Categories and Component s of Mobile Source Emissions

There are three categories of mobile source emissions:

• Exhaust or tailpipe emissions , which result from the combustion of fuel in the source’s engine

• Evaporative emissions , which result from evapor ation of fuel from the engine or it’s fuel system

• Refueling emissions

Exhaust Emissions: Are the result of fuel co mbustion and occur only when the engine is running.

Evaporative emissions: Are VOC based only a nd are continuously emitted from an engine’s fuel system , whether the engine is runni ng or not. Gasoline is a very volatile fuel, so total VOC emissi ons from gasoline power ed vehicles have a large evaporative component. Diesel and jet fuels are of very low volatility, so evaporative emissions from diesel and turbine engines are a much smaller part of their total VOC emissions. Evaporat ive emissions for CNG or LPG powered vehicles are negligible because their f uel tanks and systems are of necessity, sealed.

Evaporative and exhaust VOC emissions can be calculated separately for most mobile source categories, but in this inventory these two components are combined into total VOC. Evaporative emissions do not in clude VOC emissions that occur during refueling.

Refueling Emissions: Are the third category of mobile source emissions. Refueling emissions are entir ely VOC. Although they re sult from the evaporation of fuel, they are distinct from, and not directly rela ted to, evaporative emissions as defined above.

Refueling emissions have two subcomponents:

• Displacement emissions. These occur when new fuel is transferred into a partly filled tank--be it a service station storage tank, a portable fuel container (gas can), or a vehicle or engine’s fuel t ank; displacing the air in the tank and forcing that vapor-rich air out the inlet pipe or other vent. There are two stages of displacement emissions:30 o “Stage I” emissions occur when the underground storage tanks at a service station are being refilled;

o “Stage II” emissions occur when a motor vehicle (or gas can) is being refueled.

NOTE: These emissions are covered in , “Area Sources,” section 3.6.

• Spill emissions. These occur when dr ops of fuel drip or splash on the ground during or after ref ueling and evaporate away.

5.2 Ohio On-Highway Mobile Source Inventory

The inventory of on-highway mobile source emissions was developed in conjunction with the Ohio Department of Transpor tation (Ohio DOT), LADCO, U.S. EPA, and the Ohio EPA. Estimates of the amounts of NO x and VOC are reported by county in tons per day. Emissions are reported for a typical ozone season weekday in the summer of 2002.

5.2.1 Emission Inventories D eveloped with MOBILE6.2 Model

MOBILE6.2 Overview:

MOBILE6.2 is a computer program that estimates hydrocarbon (HC), carbon monoxide (CO), NO x , exhaust particulate matter (w hich consists of several components), tire wear particu late matter, brake wear par ticulate matter, sulfur dioxide (SO 2 ), ammonia (NH 3 ), six hazardous air pollutant (HAP), and carbon dioxide (CO 2 ) emission factors for gasoline- fueled and diesel highway motor vehicles, and for certain specialized vehicles such as natural-gas-fueled or electric vehicles that may replace t hem. The program uses the calculation procedures presented in te chnical reports posted on U.S. EPA's MOBILE6.2 Web page http://www.epa.gov/otaq/models.htm

.

MOBILE6.2 emission factor estimate s depend on various conditions, such as ambient temperatures, travel speeds, op erating modes, fuel volatility, and mileage accrual rates. Many of the vari ables affecting vehicl e emissions can be specified by the user. MOBILE 6.2 will estimate emission factors for any calendar year between 1952 and 2050, inclusive. Vehi cles from the 25 most recent model years are considered to be in ope ration in each calendar year.

5.2.2 MOBILE6 Defaults:

MOBILE6.2 includes default values for a wide range of conditions that affect emissions. These defaults are designed to represent “national average” input data values. Users who desire a more prec ise estimate of local emissions can substitute information that more specifically reflects local conditions. Use of local31 input data will be particularl y common when the local emi ssion inventory is to be constructed from separate estimates of roadways, geographic areas, or times of day, in which fleet or traffic conditions vary considerably.

A list of MOBILE6.2 input par ameters is provi ded below. Most of these inputs are optional because the model will supply default values unless alternate data are provided.

5.2.3 MOBILE6 Input Parameters

• Calendar year

• Month (January, July)

• Hourly Temperature

• Altitude (high, low)

• Weekend/weekday

• Fuel characteristics (Reid va por pressure, sulfur content, oxygenate content, etc.)

• Humidity and solar load

• Registration (age) dist ribution by vehicle class

• Annual mileage accumulation by vehicle class

• Diesel sales fractions by vehicle class and model year

• Average speed distribution by hour and roadway

• Distribution of vehicle miles traveled by roadway type

• Engine starts per day by vehicl e class and distribution by hour

• Engine start soak time distribution by hour

• Trip end distribution by hour

• Average trip length distribution

• Hot soak duration

• Distribution of vehicle miles traveled by vehicle class

• Full, partial, and multiple diurnal distribution by hour

• Inspection and maintenance ( I/M) program description

• Anti-tampering inspection program description

• Stage II refueling emissions inspection program description

• Natural gas vehicle fractions

• HC species output

• Particle size cutoff

• Emission factors for PM and HAPs

• Output format specific ations and selections

5.2.4 MOBILE6 References

The following publications provide much of the guidan ce for the preparation of the on-highway inventory.32 EPA-450/4-81-026d (Revised), now EPA/450-R-92-009, Procedures for Emission Inventory Preparation , Volume IV: Mobile Sources , December 1992. Hereafter “Procedures Vol. IV”. The 1992 version is still the definitive document on inventories. If a previous edition is referred to, the fact will be noted as, for example, “the 1989 Procedur es Vol. IV” or “Volume IV, 1989 edition”.

EPA420-R-03-010, User’s Guide to MOBILE6. 1 and MOBILE6.2: Mobile Source Emission Factor Model
, August 2003. This is the User’s Guide for the official MOBILE6.2.03 on-highway mobile source emission factor model and will usually be referred to as the M6.2 (or simply M6) User’s Guide (UG). The M6 model in its various ve rsions was developed and published by Assessment & Modeling Division (AMD) of the National Vehicle & Fuels Emissions Laboratory (NVFEL) in Ann Arbor, Michigan. The NVFEL is part of U.S. EPA’s Office of Transportation & Ai r Quality (OTAQ), formerly the Office of Mobile Sources (OMS).

Technical Guidance on the Use of MOBILE6 for Emission Inventory Preparation , August 2004. Hereafter the M6 “Technical Guidance [Document]” or “TGD”. The TGD is t he primary source of guidance on M6 inputs and an invaluable adjunct to the M6 User’s Guide.

U.S. EPA document “Frequently Asked Questions on MOBILE6” , 16 January 2002. Hereafter [M6] “FAQ”. This document was published along with the M6 TGD.

U.S. EPA memo, “Policy Guidance on the Use of MOBILE6 for SIP Development and Transportation Conformity” , dated 18 January 2002, from John Seitz, Director of OAQPS, and Margo Oge, Director of OTAQ, to Regional Air Division Directors.

5.3 Ohio’s Alternate Data for MOBILE6.2

5.3.1 Vehicle Registra tion Distribution by Age

Overview:

The vehicle age distribution determines the fraction of v ehicles operating within each emissions control requirement standard and the deter ioration of the emission control technology.

Emission rates vary widely between new and older vehicles. Thus, even small changes in fleet age, particularly for older vehicles, may result in large changes in emission totals.33 The MOBILE6.2 model requires estimates of a distribution of registered vehicles by age and vehicle category for current and future years. MOBILE6.2 default values were developed using national leve l vehicle registrati on data by age and class for July 1, 1996. U.S. EPA developed a methodology to convert the July 1, 1996 registration profile into a general re gistration distribution by age and by vehicle category for some six composite ( gasoline and diesel) vehicle types plus motorcycles. To project future changes, U.S. EPA evaluated general sales growth and vehicle scrappage trends for the total light-duty vehicle in-use fleet and the total heavy duty vehicle in-use fleet, and made minor adjustments, where possible, to reflect some of the differences between vehicle categories.

Description: The MOBILE6.2 model requires estimates of a distribution of registered vehicles by age and vehicle ca tegory for current and future years. Ohio EPA chose to use local vehicle re gistration data provided by the Ohio Bureau of Motor Vehicles (BMV) to LADCO to develop these inputs.

Method Applicability: This approach is most appl icable in areas where there are significant differences in the local vehi cle fleet age distribution relative to the national average.

Data Sources and Procedures: This approach involves using local vehicle registration data. This is typically availa ble at the county level, but may also be applied using statewide data from the state motor vehi cle registration office. The fleet age should be representative of the vehicle fleet over the small urban or rural area under question. If the pollutants of concern are ozone precursors.

Advantages:

• Uses locally specific r egistration data, which is likely more representative of the local area than the national default.

• Requires minimal additional resour ces, particularly if data is readily available at the county or local leve l from the State d epartment of motor vehicle registration.

• Recommended by U.S. EPA and genera lly is encouraged as a preferred approach over the national default approach.

Details:

Meredith Weatherby of ERG, a subcontract or to LADCO, sent Ohio EPA the files that completed the Ohio registra tion distribution calculations.

These files contained the registration dist ribution fractions for each county code as well as for the entire state. Each c ounty file was in a format that was directly34 useable in the MOBILE 6.2 model runs. Additional fi les contained the fractions as well as the numbers of vehicles for eac h county in a space-delimited file.

5.3.2 Daily Vehicle M iles Traveled (DVMT)

Overview:

Ohio DOT provided the Daily Vehicle Mile s Traveled (DVMT) data. DVMT is a simple mechanism to measure how much traffic is flowing along a roadway during an average 24 hour period. This si mple formula multip lies Average Annual Daily Traffic (AADT) by the length of the roadway. For example; if a roadway was 2 miles in length and the AAD T was 4000 vehicles per day the DVMT would be computed by multiplying 2*4,000 =8,000 or 8,000 DVMT.

County-by-county DVMT is computed usin g Ohio DOT roadway information files and the annual Highway Performance Monitoring System (HPMS) summary reports. DVMT’s are computed for all of the Federal Functional Class (FC) categories within each of Ohio’s 88 counties.

The AADT and roadway length information are very accurate for the state highway system (interstate, highway and state routes, ). For roadways that are not part of the state highw ay system, various represent ative counts were used, such as: railroad crossing counts, HPMS sa mple section counts etc. All traffic count data that was not co llected during the current y ear has had a statewide growth factor applied that accounts for systematic growth.

Given the previously ment ioned methodologies, the DVMT data is more accurate on roads functionally classified as collector or above.

Functional class categories:

01 - Rural Interstate 02 - Rural Principal Arterial 06 - Rural Minor Arterial 07 - Rural Major Collector 08 - Rural Minor Collector 09 – Rural Local 11 - Urban Interstate 12 - Urban Freeway & Expressway 14 - Urban Principal Arterial 16 - Urban Minor Arterial 17 - Urban Collector 19 - Urban Local

For PDF web based tables of DVMT by county see:

www.dot.state.oh.us/techservsite/ava ilpro/Road_%20Infor/KDVMT/vmt2002.pdf35 Disclaimer by Ohio DOT:

The above PDF web based tables contain the State of Ohio's adjusted county DVMT's and road mileage for the years 1990 - 2004. Please be aware that the numbers are estimates only. The fact oring process used annu al, estimated, and statewide ADT (average daily traffic) growth factors, derived from the output of a limited number of traffic c ounting stations around the stat e. Although the growth factors are available by functional class, they are more reliable for major roads such as interstates or expressways, wh ich are relatively well-sampled, than for local roads or collectors. The numbers al so do no allow for periodic, large-scale functional reclassification actions wh ich reassign selected roads or road segments from one functional class to another. Ohio DOT therefore does not warrant the accuracy, completeness, or reliability of these estimates for your research. We also do not assume resp onsibility for any incorrectness that may

occur.

5.3.3 Speed Distribution Profile

Overview:

According to Mark Byram of Ohio DOT, the speeds that have been used to date for air quality analysis were developed by Chuck Gebhardt of Ohio DOT and Harry Judson of OHIO EPA for addressing “1 hour standards” conformity rules established due to 1990 emissions exceedances. No documentation was found in Ohio DOT’s files on the origin of thes e average speed values or how they were estimated. Therefore, st aff believed that it was bes t to use the most recent available data to estimate average speeds. Year 2002 speed data was obtained from Ohio DOT’s Traffic Monitoring Sectio n’s automatic traffi c recorder data and summarized for comparison with space mean speeds from Ohio DOT’s travel time study done in 2001 (Statewide Travel Time Study, May 2001 by Greg Giaimo, Ohio DOT.) These speeds we re compared with those developed for addressing the one hour standards. The graph below shows the comparison.

Speeds Comparison

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0

FC01 FC 0

6 F C0 8 F C1 1 FC1 4 FC1 7

Functional ClassSpeed Average Speed

1990 Analysis Speeds 2001 Speed Study36 CAUTION 

### : It should be noted that speeds on fac ilities falling in any one of the federal functional classifications vary gr eatly between roadways, between hour of the day, and day of the week. So these provide only very rough estimates of speed and should be used with caution. In addition, it is expected that theseaverage statewide speeds are higher than the average speeds in the nonattainment areas because the non-atta inment counties tend to be more populated and more congested. The document “Highway Vehicle Speed Estimation Procedures for Use in Emissi on Inventories”, September 1991 by Earl Ruiter or Cambridge System atics Inc. is referenced by U.S. EPA’s documented procedures for emission inventory preparat ion. This document suggests post processing travel demand model traffic assignment results to estimate average speeds.

The Ohio DOT Modeling & Forecasting Se ction recommends that Ohio’s travel demand forecasting models and Ohio DO T’s conformity analysis methods be used to establish the roadway mobile s ource portion of Ohio’s SIP budget to assure consistent methods are used for transportation conformity analysis and budgets.

Research:

Time Mean Sped-- Summarizing Automa tic Traffic Recorder (ATR) Speed Data by Functional Class

Year 2002 speed data for July 2002 was prov ided by the Traffic Monitoring (TM) Section as requested by the Mode ling & Forecasting Section (MF).

The TM section generated reports for each ATR in the state of Ohio, grouped the reports by federal functi onal class and provided the su mmary reports to the MF section. The report includes average s peed for each day in July 2002, a 31 day period. The data was imported to a spreadsheet where a minimum speed, maximum speed and average sp eed over the 31 day period for all ATR’s located on a given functional class was computed, see Table 1

Table 1 – Comparison of Average Daily sp eeds from ATR Data with Daily 1990 Air Quality Speeds

Average Min. Avg Max. Avg. 1990 AQ Speed Speed Speed Speeds FC01 68.33810 53.9 76.3 57.3 FC02 60.14802 36.2 71.8 45.3 FC06 58.05665 53.5 62.1 39.9 FC07 57.06160 52.9 60.9 35.1 FC08 57.45161 55.2 59.3 30.5 FC09 57.45161 55.2 59.3 28.0 FC11 65.64372 49.7 73.0 46.337 FC12 63.89579 50.3 73.2 43.3 FC14 48.97748 31.3 70.1 18.9 FC16 34.52353 30.6 53.2 19.6 FC17 34.52353 30.6 53.2 19.6 FC19 _- _- _- 19.6

The ATR speeds represent our best estimate of “time mean spee d”. The speeds represent the speed at a poi nt in the middle of a roadway se ction and does not account for slowdowns and del ays created by vehicles turning into driveways, stopping at intersections, slowing due to incidents, etc.

Estimating SPACE MEAN SPEED by Functional Class

Greg Giaimo generated average speed by urban and rural area facility types as shown in Table 2 Below.

Table 2 Speed by Facility Type

Information from Table 2 was used to es timate space mean speed by functional class by assigning federal functional classes as shown in Table 3 with consultation with Giaimo. Some speed classes were ignored based on Facility Type Facility Type Description Average Speed 1rural freeway 64 2rural arterial 53 3rural 4+ lane collector 42 4rural 2 lane collector, flat 47 5rural 2 lane collector, hilly 44 6rural local, flat 46 7rural local, hilly 37 8rural local, township, flat 40 9rural local, township, hilly 30 11urban freeway 63 12urban arterial 30 13urban collector 30 16urban local 25 21cbd freeway 50 22cbd arterial 23 23cbd collector 21 26cbd local 12 41rural ramp, off 36 42rural ramp, on 44 51urban ramp, off 32 52urban ramp, on 4638 recommendation by Giaimo because of the small number miles of those types of roadways.

Table 3 – Functional Class Equivalents

FT Facility Type Speed (mph) FunClass Equiv 1 rural freeway 64 01 Rural Interstate 2 rural arterial 53 02 06 - Principal & 06Minor Arterial 3 rural 4+ lane collector 42 Ignore 4 rural 2 lane collector, flat 47 07 08- Major Collector, Minor 5 rural 2 lane collector, hilly 44 Ignore 6 rural local, flat 46 09 - local 7 rural local, hilly 37 ignore 8 rural local, township, flat 40 09 - local 9 rural local, township, hilly 30 ignore 11 urban freeway 63 11Urban Interstate & 12 EXPY 12 urban arterial 30 14,16 Princ, Major, Minor Art 13 urban collector 30 17 - Collector 16 urban local 25 19 - local 21 cbd freeway 50 11 &12 urban interstate, 50-55mph 22 cbd arterial 23 14,16 - Major&minorArt 23 cbd collector 21 17 - Collector 26 cbd local 12 19 – local

The following formulas were used to estimate the speed:

Where: S=Speed FT=Facility Type FC=Functional Class

S(FC01) = S(FT1) S(FC02) = S(FT2) S(FC06) = S(FT2) S(FC07) = AVERAGE(FT3,FT4,FT8) S(FC08) = AVERAGE(FT3,FT4,FT8) S(FC07) = AVERAGE(FT6,FT8) S(FC09) = AVERAGE(FT6,FT8) S(FC11) = 0.91*S(FT1 1)+0.09*S(FT21) S(FC12) = 0.91*S(FT1 1)+0.09*S(FT21) S(FC14) = 0.94*S(FT1 2)+0.06*S(FT22) S(FC16) = 0.94*S(FT1 2)+0.06*S(FT22) S(FC17) = 0.94*S(FT1 3)+0.06*S(FT23) S(FC19) = 0.93*S(FT1 6)+0.07*S(FT26)39 Percentage splits for the urban federal functional classes (11trhu 19) were derived by summarizing VMT by Facility Ty pes 1 to 26 using the statewide travel demand model. The results are shown in Table 4 along with speeds previously used for comparison purposes.

Table 4 – Speed by Federal Functional Class 1990 Analysis 2001 Speed Study Speeds Speeds NOACA* FC01 57.3 64.0 54.7 FC02 45.3 53.0 43.7 FC06 39.9 53.0 38.7 FC07 35.1 43.1 34.2 FC08 30.5 43.1 29.4 FC09 28 43.1- FC11 46.3 61.6 44.9 FC12 43.3 61.6 42 FC14 18.9 29.3 18.4 FC16 19.6 29.3 19.6 FC17 19.6 29.2 19 FC19 19.6 23.8- * From informal documentation found in file s, labeled “Speeds From Bill Davis”

Figure 1 - Speed Comparison Graphs



### Speeds Comparison

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0FC01FC02FC06FC07FC08FC09FC11FC12FC14FC16FC17FC19

Functional ClassSpeed Average Speed

1990 Analysis Speeds

2001 Speed Study Speeds

2001 Speed Study Speed from Bill Davis40 Speeds Comparison

0 20 40 60 80 100

FC 0

1 FC 0

6 FC 0

8 FC 1

1 FC 1

4 FC 1

7

RAMPS

Functional ClassSpeed Average Speed

Min. Avg Speed

Max. Avg. Speed

Gebhardt's Speeds

Spd Study Est Speeds Spd Study Greg Est

In discussions with James McQuirt, Greg Giaimo and Ansen Wu, it was decided that because there is no record of the origin of the speeds established for the 1990 exceeded emissions/one hour emissions standard, Ohio DOT would be best served to use the speeds estimated from the speed study if the origin is well documented.

Conclusion:

It was decided by mutual agreement am ong individuals in the Modeling & Forecasting Section that these new space mean speed based average speed estimates were reproducible and defens ible if documented and should therefore be the speeds used with HP MS VMT if any year 2002 emissions budget work is done using only HPMS VMT.

Results:

Speeds used in the speed distribution files from Ohio DOT for the 2002 inventory were taken from the 2001 space m ean speed study. (See Table 4)

Reference:

“Draft Technical Memorandum Estimati on of Average Speed by Functional Class for MOBILE6 Runs,” by Mark Byram, Ohio DOT, Office of Technical Services, May 26, 200441 5.4 Ohio’s Non-Alternate (D efault) Data for MOBILE6.2

Per conversation with Mark Janssen at LADCO on 5/14/04, he recommended Ohio use the national defaults for the re st of the MOBILE6.2 inputs with the exception of providing an RVP value for Ohio.



### 5.4.1 Ohio’s Fuel Characteristics

Background:

Tom Darlington of Hyper Anemo was cont racted by LADCO to evaluate the fuel parameters at the co unty level. In a memo to Mike Koerber, at LADCO he states;

“As a part of our project to evaluate the benefits of lowe r RVP in various nonattainment areas in the LADCO 5- state area, we obtained the LADCO county-by-county MOBILE6. 2 inputs and reviewed the various fuel input commands. This memo reviews plots of those inputs, and requests that the various states verify these inputs. The inputs that we have selected to review have a direct bearing on the bas eline RVP of the fuel in each of the counties, and thus the benefits of any lower RV P proposal such as 7 RVP.”

Tom summarized his study saying, “Evaluation of the fuels inputs for the LADCO modeling system has shown perhaps a need to reevalua te some of the fuels inputs, so that the baselin e VOC inventories are corre ct, and so that the benefits of RVP control will be accurately estimated.

In particular, ethanol market fractions fo r Michigan, Wisconsin, Indiana, and Ohio should be developed by the stat es or LADCO and utilized. This will also involve a change in the July RVP waiv er for these states. In addition, areas with RFG should be checked to ensure that the appropriate counties have RFG.”

Process:

Fuel data parameters were collected fr om Ohio’s MPOs and analyzed. Variations in data suggested the need to determine the source of input values. After considerable effort it was determined that the origins of input values were unclear. The reevaluation process re sulted in establishing the following guidelines.

Guidelines:

• No MTBE (ether oxygenated fuel) in Ohio

• 40 percent of Ohio's fuel is eth anol oxygenated with 10 percent oxygen content by volume42 • Reid Vapor Pressure (RVP) is 9.0

• RVP waiver switch is 1.0 psi

5.5 LADCO Data Processing



### LADCO processed Ohio ’s data using the Emissions Modeling System (EMS-2003). A description of LADCO’s methodol ogy should be forthcoming from LADCO in the near future.

# SIP INVENTORY MOBILE-EMISSIONS ESTIMATE (OZONE)

FOR STARK COUNTY, OHIO

May, 2012

Revised August, 2012

Prepared By:

STARK COUNTY AREA TRANSPORTATION STUDY

201 Third Street NE, Suite 201

Canton, Ohio 44702

This report is the product of a study financed in part by the US Department of Transportation, Federal Highway Administration, Federal Transit Administration and the Ohio Department of Transportation. The contents of this report reflect the views of the Stark C ounty Area Transportation Study, which is responsible for the facts and the accuracy of the data presented herein. The contents do not nece ssarily reflect the official vi ews or policy of the U. S. Department of Transportation. This report does not constitute a standar d, specification, or regulation.

### Table of Contents

1. O verview 3 2. Urban Travel Demand Models 5 3. Em ission Factor Generation 7 4. P ost Processing 15

Appendix A Interagency Consulta tion Documentation

SCATS Ozone SIP Emmissions Estimates Page 2

### 1. Overview

This memorandum is intended to document the ai r quality analysis and underlying assum ptions performed by the Ohio Department of Trans portation (ODOT), Divisi on of Transportation System Development-Modeling and Forecas ting Section and the Stark County Area Transportation Study (SCATS) for the 8-hour ozone on-road mobile -source emissions inventories for the Canton-Massillon Metropolitan Statistocal Area (MSA) State Implementation Plan (SIP) revision in coordina tion with the Ohio Environmental Protection Agency (OEPA).

The Canton-Massillon MSA is comprised of Star k County in northeastern Ohio. Although the MSA area also includes Carroll County, OEPA a nd USEPA c oncurred that only Stark County is needs to be analyzed within the MSA as Carroll County is rural in nature with a population of less than 30,000. Stark County is designated as attainme nt for the 8-hour Ozone Standard. SCATS serves as the Metropolitan Planning Organization (MPO) for Stark County.

The ODOT Modeling and Forecasting section perfor med the MOVES runs to generate traveldemand-model-based emission factors as well as the air-quality analysis for Stark County.

Latest Planning Assumptions

The ozone inventory runs meet the latest plan ning assum ption requirement. As discussed in Section 2 of this report, the modeling process us ed to develop the MPO emissions is calibrated using the latest population and land-use data av ailable and is validated using corresponding traffic-count data. Currentl y, the travel demand model is validated for the year 2000.

U.S. EPA’s most recent emissions software, M OVES, is used for all m obile-source emission analyses with MOVES inputs being established at various interagency consultations between January, 2012, and May, 2012, (See Appendix A)

Finally, the regional emissions analysis includes em issions for Hydrocarbons (HC) and Nitrogen Oxides (NO X ).

SCATS Ozone SIP Emmissions Estimates Page 3On-Road Mobile Emission Summary

Table 1 presents a summary of emissions for th e SCATS Region for the required precursors HC and NO X for the requested scenarios: 2002 base year, 2004 attainment year, 2009 interim-budget year, and 2018 maintenance-budget year. The remainder of the document focuses on the assumptions behind the analysis.

Table 1 – SCATS Region On-Road Mobile Emissions

VMT or HC NO X TYPE YEAR # Vehicles (tons) (tons)

LINK 2002 8,196,644 8.401 27.788 VEHICLE 2002 474,615 15.862 7.200 INTRA-ZONAL 2002 48,465 0.075 0.197
TOTAL 8,245,109 24.339 35.185

LINK 2004 8,462,377 7.304 25.595 VEHICLE 2004 477,279 15.192 7.367 INTRA-ZONAL 2004 48,934 0.064 0.178
TOTAL 8,511,311 22.559 33.141

LINK 2009 8,544,607 4.071 17.657 VEHICLE 2009 483,940 12.560 6.867 INTRA-ZONAL 2009 52,473 0.039 0.135
TOTAL 8,597,080 16.671 24.659

LINK 2018 8,864,133 1.416 6.084 VEHICLE 2018 495,933 6.413 3.761 INTRA-ZONAL 2018 51,921 0.013 0.044
TOTAL 8,916,054 7.842 9.888

SCATS Ozone SIP Emmissions Estimates Page 42. Urban Travel Demand Models

SCATS maintains regional travel demand forecasti ng m odels for use in the urban transportation planning process. The models employ the tradi tional four step modeli ng process to project existing and future traffic volumes and travel patterns on the regional tr ansportation network. The four step process consists of trip gene ration, trip distribution, modal split, and route assignment. Output from the urban models is link-by-link directiona l 24-hour traffic volumes.

In 2000 SCATS, in cooperation with the Ohio Departm ent of Trans portation (ODOT), updated its travel demand model. The new model incl udes changes to the m odel interface to Cube Voyager, and improves model f unctionality. The changes primar ily affected trip generation distribution functions in the SCATS region.

Networks

The SCATS modeled network accurately reflects projects in the Transpo rtation Improvement Program (TIP) and Long-Range Transportation Plan (LRTP). Project lists can be found online as listed below:

TIP http://www.co.stark.oh.us/internet/docs/rpc/SCATS%202012%20- 15%20TIP%20Final%20Draft.pdf

Long-Range Transportation Plan http://www.co.stark.oh.us/internet/docs/rp c/2030%20Transportation%20Plan%20Update. pdf

Landuse and Socio-economic Data

The SCATS socio-economic variables reflect the cu rrent and expected future regional land uses.

The socio-economic variables were develope d f or the May 2009, 2030 LRTP Update and are based on 2000 Census variables and 2030 county- level Ohio Department of Development population projections.

Independent variables are available for the 3 analysis years (2004, 2009, and 2018) and the travel dem and model has the ability of in terpolating data for any year be tween available data sets. A summary of SCATS’ socio-economic data is availabl e in Table 2. As can be seen from the table, population, households, and employme nt are expected to make modest gains between 2004 and 2018.

SCATS Ozone SIP Emmissions Estimates Page 5Table 2 – SCATS Socio-Economic Variables
2002 2004 2009 2018 Population 384,889 385,483 386,965 389,728 Households 150,643 145,290 133,763 157,447 Employment 168,699 177,196 197,518 214,350

SCATS Ozone SIP Emmissions Estimates Page 6

### 3. Emission-Factor Generation

Attainment and Budget Years

Using MOVES, emission factors were genera ted for the attainm ent year, 2004, the interimbudget year, 2009, and the maintenance-budget y ear, 2018, to represent the programs being implemented in the SCATS Region. Program s and corresponding MOVES parameters were developed in consultation with the OEPA.

Technical Details

Table 3 summarizes the settings used in th e MOVES run specification file and the MOVES County-Data Manager. Further de tails in specific i nputs that are not using default values are provided below.

Table 3 – MOVES Inputs RunSpec Parameter Settings
MOVES Version MOVES2010A
Scale Custom Dom ain MOVES Modeling Technique Emission Factor Method Rates per Profile (grams/vehicle) Rates per Distance (grams/mile) Rates per Vehicle (grams/vehicle) Time Span Time Aggregation: Hour 1 Month representing average summer temperatures All hours of day selected 16 speed bins Weekdays only Geographic Bounds Stark County Vehicles/Equipment All source types, gasoline and diesel Road Type All road types including off-network
Pollutants and Processes Total Gaseous Hydrocarbons, Non-Methane Hydrocarbons, Volitile Org anic Compounds, NO x , NO, NO 2, Total Energy Consumption Strategies Default values with assumed CNG buses removed General Output Units = grams, joules and miles Output Emissions Time = hour, Location = custom area, on-road emission rates by road type and source use type. Advance Performance None County Data Manager Sources Source Type Population Combinatio n of local and default data Local data (2010) ODOT from motor vehicle registration Default data used for source types 41, 51, 54, 61, and 62 Future year growth rate based on MPO m odel Household growth rate.

SCATS Ozone SIP Emmissions Estimates Page 7Vehicle Type VMT Combination of local and default data HPMSVTypeYear VMT = daily VMT from travel demand model monthVMTFraction = default dayVMTFraction=default hourVMTFraction=local I/M Program None
Fuel Formulation Default Fuel Supply Default Metereology Data Local data obtained fr om NOAA National Climatic Data Center. Data will co nsist of monthly high and low temperatures and daily relative humidity for 2002. Ramp Fraction Using the base year tr avel dem and model for VHT fractions. Future fractions will be assumed constant Road Type Distribution Use ODOT count y summ ary VMT categorized by federal functional classes Age Distribution Combination of local and default data. Local data (2010) ODOT from motor vehicle registration Default data used for source types 41, 51, 54, 61, and 62 The same age distribution will be used for all analysis years Average Speed Distribution Default Alternative Fuel Type Default

SCATS Ozone SIP Emmissions Estimates Page 8Temperature and Relative Humidity

Temperatures used for the single season appro ach are representative of July 2004 based on NOAA data f rom the National Climate Data Cent er webiste. Data fo r Akron-Canton Airport was also used. The EPA provided a spreadshee t to convert Mobile6 data into a format compatable with MOVES. The average July hourly temperature and relative humidity distribution profile can be seen in Table 4.

Table 4 – Temperature and Relative Humidity Data Hour Average Average Temperature Relative Humidity

1 60.8

2 57.2

3 57.2

4 60.8

5 60.8

6 62.6

7 62.6

8 64.4

9 66.2

10 66.2 72

11 68.0 68

12 69.8 64

13 69.8 64

14 71.6 60

15 69.8 60

16 69.8 60

17 69.8 64

18 66.2 68

19 66.2 63

20 66.2 68

21 66.2 68

22 64.4 72

23 64.4 72

24 60.8 82 82

9 3

93

82

87

82

82

77

72

SCATS Ozone SIP Emmissions Estimates Page 9Ramp Fraction

Ramp fractions were derived using the base ye ar travel dem and model VHT fractions. Ramp fractions can be seen in Table 5. Base year fractions were assumed to apply to future years.

Table 5 – Ramp Fractions
roadTypeID roadDesc rampFraction

2 Rural Restricted Access 0.05

4 Urban Restricted Access 0.13

Source-Type Population

Source-type population is based on a com bination of local and MOVES default data. Local data was provided by ODOT based on 2010 motor vehicle registration. Default data is used for source types 41, 51, 54, 61, and 62. Table 6 shows source-type population for Stark county in 2004.

Table 6 – Source-Type Population for year 2004 Source-Type Source-Type Source-Type
ID Name Population 11 MotorCycle 24,132 21 Passenger Car 282,125 31 Passenger Truck 128,769 32 Light Commercial Truck 2,908 41 Intercity Bus 129
42 Transit Bus 19
43 School Bus 742
51 Refuse truck 86 52 Single Unit Short-haul Truck 181 53 Single Unit Long-haul Truck 138
54 Motor Home 416 61 Combination Short-haul Truck 1,060 62 Combination Long-haul Truck 1,220

Vehicle-Age Distribution

Vehicle-age distribution information was deri ved using Ohio Bureau of Motor Vehicle registration data. The data was given to OE PA which supplied a VIN decoder that allowed ODOT to create correctly for matted MOVES inputs . MOVES default data is used for source types 41, 51, 54, 61, and 62. The vehicle-age distri bution for Stark County is shown in Table 7. The same age distribution will be used for all analysis years

SCATS Ozone SIP Emmissions Estimates Page 10Table 7 – Vehicle-Age Distribution Year Source-Type Age Age Year Source-Type Age Age
ID Fraction ID Fraction

2004 11 0 0.0015 2004 21 0 0.006
2004 11 1 0.0214 2004 21 1 0.0238
2004 11 2 0.0508 2004 21 2 0.0362
2004 11 3 0.0633 2004 21 3 0.044
2004 11 4 0.079 2004 21 4 0.0471
2004 11 5 0.0733 2004 21 5 0.051
2004 11 6 0.0719 2004 21 6 0.0491
2004 11 7 0.0794 2004 21 7 0.053
2004 11 8 0.0576 2004 21 8 0.0562
2004 11 9 0.053 2004 21 9 0.0545
2004 11 10 0.0446 2004 21 10 0.0624
2004 11 11 0.0365 2004 21 11 0.0613
2004 11 12 0.026 2004 21 12 0.0562

2004 11 13 0.0217 2004 21 13 0.0543
2004 11 14 0.0203 2004 21 14 0.0487
2004 11 15 0.021 2004 21 15 0.05
2004 11 16 0.0167 2004 21 16 0.0398
2004 11 17 0.0114 2004 21 17 0.0337
2004 11 18 0.0087 2004 21 18 0.0282
2004 11 19 0.0077 2004 21 19 0.0215
2004 11 20 0.0073 2004 21 20 0.0178
2004 11 21 0.0088 2004 21 21 0.015
2004 11 22 0.0091 2004 21 22 0.0111
2004 11 23 0.0103 2004 21 23 0.0082
2004 11 24 0.0177 2004 21 24 0.0069
2004 11 25 0.0159 2004 21 25 0.0057
2004 11 26 0.0135 2004 21 26 0.0045
2004 11 27 0.0162 2004 21 27 0.0026
2004 11 28 0.0241 2004 21 28 0.0017
2004 11 29 0.0186 2004 21 29 0.0017
2004 11 30 0.0927 2004 21 30 0.0478

SCATS Ozone SIP Emmissions Estimates Page 11Road-Type Distribution

Road-type distribution is based on the 2008 ODOT county summary, HPMS VMT data catego rized by federal functional class for the SC ATS area. Road-type distribution can be seen in Table 8.

Table 8 – Road-Type Distribution Source-Type Road-Type Road-Type Source-Type Road-Type Road-Type
ID ID VMT Fraction ID ID VMT Fraction

11 1 0.00 43 4 0.19
11 2 0.01 43 5 0.62
11 3 0.18 51 1 0.00
11 4 0.19 51 2 0.01
11 5 0.62 51 3 0.18
21 1 0.00 51 4 0.19
21 2 0.01 51 5 0.62
21 3 0.18 52 1 0.00
21 4 0.19 52 2 0.01
21 5 0.62 52 3 0.18
31 1 0.00 52 4 0.19
31 2 0.01 52 5 0.62
31 3 0.18 53 1 0.00

31 4 0.19 53 2 0.01
31 5 0.62 53 3 0.18
32 1 0.00 53 4 0.19
32 2 0.01 53 5 0.62
32 3 0.18 54 1 0.00
32 4 0.19 54 2 0.01
32 5 0.62 54 3 0.18
41 1 0.00 54 4 0.19
41 2 0.01 54 5 0.62
41 3 0.18 61 1 0.00
41 4 0.19 61 2 0.01
41 5 0.62 61 3 0.18
42 1 0.00 61 4 0.19
42 2 0.01 61 5 0.62
42 3 0.18 62 1 0.00
42 4 0.19 62 2 0.01
42 5 0.62 62 3 0.18
43 1 0.00 62 4 0.19
43 2 0.01 62 5 0.62
43 3 0.18

SCATS Ozone SIP Emmissions Estimates Page 12Vehicle-Type VMT and VMT Fractions

The first component of the VMT inputs is the Ye arly HPMS VMT, but the travel dem and model was used instead of ODOT’s HMPS data since it was felt that the model would better predict future year VMT. ODOT’s CMS post-processor was run for each year to generate congestion reports, which includes total daily VMT. The ve hicle-type percentages of the total VMT were based on ODOT’s weigh-in-motion (WIM) data. Since there are not enough WIM stations for lower class facilties in the area, a statewide aver age of all ODOT WIM data collectors was used. Daily VMT was then converted to yearly VMT. Yearly HPMS VMT for 2004 can be seen in Table 9. The same method was to ge nerate all other analysis years

Table 9 – Yearly HPMS VMT for 2004 HPMS Vtype Year HPMS Base-Year Base-Year
ID VMT Off-Net VMT 10 2004 11,106,492 0 20 2004 1,980,755,140 0 30 2004 611,157,640 0 40 2004 6,246,845 0 50 2004 46,180,207 0 60 2004 109,640,294 0

SCATS Ozone SIP Emmissions Estimates Page 13Monthly and daily VMT fractions used MOVES default data. The hourly VMT fractions were derived from ODOT WIM data. Hourly VMT frac tions vary for each of the five MOVES road types but do not change for each of the 16 MOVES source types. A representative sample of the hourly-VMT-fraction input f ile can be seen in Table 10, the entire file is too large to include in this document.

Table 10 – Hourly VMT Fractions Source-Type Road-Type Day Hour Hourly- VMT
ID ID Fraction

11 1 5 1 0.0089
11 1 5 2 0.0056
11 1 5 3 0.0042
11 1 5 4 0.0043
11 1 5 5 0.0070
11 1 5 6 0.0180

11 1 5 7 0.0381
11 1 5 8 0.0570
11 1 5 9 0.0577
11 1 5 10 0.0554
11 1 5 11 0.0555
11 1 5 12 0.0556
11 1 5 13 0.0558

11 1 5 14 0.0605
11 1 5 15 0.0677
11 1 5 16 0.0776
11 1 5 17 0.0843
11 1 5 18 0.0797
11 1 5 19 0.0601
11 1 5 20 0.0452
11 1 5 21 0.0365
11 1 5 22 0.0291
11 1 5 23 0.0214
11 1 5 24 0.0149

SCATS Ozone SIP Emmissions Estimates Page 14

### 4. Post Processing

Total emissions were computed with the aid of several custom program s by ODOT. The process uses data on daily and directiona l traffic distributions as well as more up-to-date volume/delay functions from the 2000 Highway Capacity Manual (H CM). This process, described below, also uses rewritten codecompatable with the newe r model network formats and MOVES-generated emission factors.

The first step in the the process involves runn ing postcm s.exe to calculate hourly link volumes based on the percentage of the daily volume (travel demand model output) determined by a link’s facility and area type. Link speeds from the travel dema nd model are not used in the analysis. The speeds are estimated as a post-pr ocess to the model based on HCM methods using a link’s volume-to-capacity ra tio and link-group code.

The second step (movesnet.exe) uses a combin ation of the MOVES e mission factors and the hourly link volumes that are out put of the postcms.exe progra m. The hourly volumes are multiplied by the MOVES emission factor fo r the corresponding hour of day, speed bin, and roadtype to calculate emissions for every network link for each hour. The final total for link onroad vehicle emissions for the area is the sum of all individual link-hour emissions.

The third step, (movesveh.exe), calculates vehi cle-based em issions (using a combination of the Rate per Distance and Rate per Profile files) fo r each source type for eac h hour of the day. The vehicle source type is based on a combination of local and default data. The final vehicle emissions are the sum of all individual hourly emissions for all vehicle types.

Intrazonal trips are not loaded onto the network, so the fourth step in the process requires a separate m ethod to account for those trips that us e local roads to travel within a zone. The movesintra.exe program uses intrazonal trips to estimate VMT using the area in square miles and intrazonal trips of each zone . The zone is assumed circular and th e radius of the circle is used as the average trip length for these intrazonal trips. Intrazonal emissions are then calculated by combining MOVES-generated emissions with estim ated intrazonal VMT. The emission rates are the same as those used to calculated link-based emissions.

The final step is to summarize link, vehicle, a nd intrazonal em issions for each county, pollutant, and analyzed year.

SCATS Ozone SIP Emmissions Estimates Page 15

### Appendix A

Interagency Consultation Documentation>>> "Moore, Dave" <Dave.Moore1@dot.s tate.oh.us> 1/30/2012 9:17 AM >>> All,

The current Ohio Oz one SIP budgets were developed using US EPA’s MOBILE software. Effective March 2, 2012 US EPA’s AQ software of record will be MOVES. Post March 2 nd all new SIP and Transportation Conformity actions will be required to use MOVES. In order to assure ongoing positive Ohio MPO T

‐ Plan/TIP conformity actions, the Ohio Ozone SIP budgets need updated to reflect MOVES outputs.

Updating th e Ozone SIP budgets to MOVES requires new MOVES based mobile emission inventories for
the SIP attainment year and budget years, consistent with the attached pdf. Please contact your ODOT
CO travel demand modeling liaison to coordinate needed transportation network, modeling runs, and
emission factor post processing to establish these new SIP mobile emission inventories. Our goal is to submit the new inventories and documentation to OEPA on or before April 1, 2012.

We have a w orking agreement with OEPA to establish SIP budgets, assuming sufficient safety margin is available, at 15% above the emission inventory. As you are developing the new MOVES based budget

year inventories, it may be a good idea to compare the resulting inventories plus 15% to MOVES based

T

‐ Plan interim and horizon year emissions as a check to assure positive future year conformity findings.

Thanks

DM>>> "Brunello, Nino" <Nino.Brunello@ dot.state.oh.us> 4/2/2012 9:19 AM >>> Jeff/Dan,

I forgot to send these files that summarize the yearly emission totals that will be needed for your air quality document.

I’ve incl uded the Dayton document that can be used as a starting point if desired, and I’ve created tables
for SCATS that would correspond to that document.

You may already know most of what is needed to put together your SIP, but questions can be directed

to Dave Moore, or to me if they are more technically related.

Thanks,Nino

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Nino Brunello, P.E. Modeling & Forecasting Section Division of Planning Ohio Department of Transportation (614) 752-5742

From: Durham, William F [mailto:William.F.Durham@wv.gov] Sent: Friday, April 06, 2012 8:50 AM To: Brunello, Nino Cc: Dines, Jennifer Subject: Ozone Summer Day Factors

Nino: I spoke with Jenn this morning and outlined th e issue of Summ er day VMT v. Average daily
VMT. We agreed that Pat Morris may be able to shed som e light on the question. Jenn & my calendars are open next Mon. and Tues . afternoon. Please give me a call & I’ll patch Jenn in. Fred

From: Brunello, Nino Sent: Monday, April 09, 2012 12:59 PM To: Dines, Jennifer; Durham, William F Subject: RE: Ozone Summer Day Factors

Jennifer/Fred,

There is another item that needs to be discussed. Since we now calculate emission rates for both VMT
and number of vehicles, does there need to be a summer adjustment factors for vehicles as well? This

was not done with MOBILE, so we have nothing to follow. If I had to guess, I would think that there
would be an increase, but I couldn’t guess as to how many or what factor to use. Maybe just use 1.08 in
absence of anything better? Thoughts?

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Nino Brunello, P.E. Modeling & Forecasting Section Division of Planning Ohio Department of Transportation (614) 752-5742From: Dines, Jennifer Sent: Thursday, April 12, 2012 9:04 AM To: Brunello, Nino; Durham, William F Cc: Moore, Dave Subject: RE: Ozone Summer Day Factors

Nino and Fre d, talked to Pat and she agrees that BOTH VMT and number of vehicles should have the
1.08 factor applied.

Pat suggeste d we should have consultation on this. I told her ODOT is taking the lead on this project and
I’d let Dave know........she says email is fine.

Thanks,

Jennifer Dines Manager, State Implementation Plan and Rulemaking Section
Division of Air Pollution Co ntrol
Ohio Environment al Protection Agency
Wk (614 ) 644

‐ 3696
Fax (614) 644

‐ 3681

>>> "Brunello, Nino" <Nino.Brunello@d ot.state.oh.us> 4/19/2012 2:30 PM >>>
All:

After dis cussions with ODOT, OEPA, WVDEP, and USEPA, we are of the opinion that there needs to be an additional seasonal factor for summer when calculating ozone pollutants.

There is curr ently an adjustment for increasing average daily VMT (+ 8%) which was used in previously
when using Moblie6 to generate emission factors. With MOVES, there is a vehicle component used in
addition to VMT, so there needs to be an adjustment from average number of vehicles to the number of
vehicles in summer day. We propose to use the same 8% increase.

We ne ed to have an inter

‐ agency agreement on this, and would prefer to do it via email (to make it
easier on all of us). Please respond with your approval and/or questions.

Thanks,

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Nino Brunello, P.E. Modeling & Forecasting Section Division of Planning Ohio Department of Transportation (614) 752-5742

>>> Jeffrey Dutton 4/19/2012 3:43 PM >>>SCATS concurs

Jeff

Jeff Dutton SCATS Technical Director Stark County Regional Planning Commission 201 3rd Street NE, Suite 201 Canton, Ohio 44702

>>> "Moore, Dave" <Dave.Moore1@dot .state.oh.us> 4/20/2012 7:53 AM >>>

Dan,

Responses be low.

Thanks

DM

From: Dan Slicker [mailto:dkslicker@co.stark.oh.us] Sent: Thursday, April 19, 2012 2:32 PM To: Moore, Dave Subject: Ozone SIP and PM2.5

Dave,

I can't stand air-quality stuff, whenever I see anythi n g having to do with it, my brain partially shuts down. Until today, I didn't realize that we were deal ing with two separate air-quality issues. Whenever I see "ozone", "PM2.5", "conformity", or "redesignation " my brain files it under "air quality", and I make I note that I'll have to send some networks down to Nino and plagiarize an air-quality document in the near future.

So, I have a few questions that need a nswers, so I can set my priorities.

1. When i s the 8-Hour Ozone SIP document due? We’ve missed a number of due dates for submitting this documentation to OEPA. The most recent date was April 1 st . OEPA is ready to move (pun intended) on the MOVES based budget SIP revisions. As you know, SCATS’ T-Plan conformity lapse date is 6/15/13. Conformity for the Plan Update will need to be coordinated with the new 2014-2017 TIP. Considering standard review/approval schedules the T-Plan Update and Conformity Determination docume ntation will need to be submitted to US DOT/EPA by 5/1/13. This conformity work n eeds to be MOVES based. So, the SIP revision must be fully approved or have budget adequa cy finding in time for SCATS’ T-Plan/TIP approval/conformity findings. So backing up some more, OEPA needs a minimum 45 days to incorporated SCATS’ results in the SIP revision for submission to US EPA. US EPA needs aminimum 90 days to process the revision thro ugh the Federal Register process. The schedules/dates identified above put us so mewhere in the Winter 2012/2013 timeframe. Accordingly, there’s still time to accomplish th e work, but schedules have a way of slipping.

Should we even discuss the matter of the new .075 Ozone standard, potential revocation of
the exiting 8

‐ Hour standard, the matter of Stark attaining the new standard and whether any of the above matters if the new standard is implemented? 2. When is the PM2.5 Redesignatio ns for Stark County document due? Similar schedules as above. Note, Stark County is a PM2.5 nonattainment area for both the 1997 annual and 2006 daily standards. Based on recent OEPA streams it appears the intent is for the 1997 and 2006 standard budgets to be exactly the same. 3. Do we need to do an interagenc y c onsultation for either of these? Interagency consultation on the current Stark County aq SIP efforts is warranted just to make sure everyone is on the same page. 4. Besides the TIP and T-Plan air-quality analyses, are there any other air-quality issues we need to deal with in the next 2 year s?

Once the SIPs are updated, likely just Plan/TIP conformity.

There are tw o other matters:

• OEPA is upda ting the “Conformity SIP”. SCATS may want to review the conformity SIP MOU
that was prepared circa 2008

‐ 2009 to re

‐ familiarize themselves with this topic.

• Not really air quality SIP/Conformity related, but SCATS should review its current suballcated
funds CMAQ projects to assure they all have affirmative CMAQ eligibility findings.

Dan Slicker

>>> "Dines, Jennifer" <Jennifer.Dines@ epa.state.oh.us> 4/20/2012 8:02 AM >>> I will offer that the PM2.5 redesignations is listed as on e of the top priorities by our director and this is the last area to be done. I will also add that if we do not do the redesignation and update mobiles numbers via that mechanism we will have to do the same work to update old mobile6 to MOVES numbers for Stark county for PM2.5 via the previous attainme nt SIP. So it has to be done either way. I believe Nino completed all the modeling in accordance with all procedures used across the state for all other redesignations and all that needs done is the write-up, which he provided a template for. So I don't think it will take much effort to complete th at piece of the puzzle so the redesignation can move forward quickly. But if this is a problem please let me know as I am being asked routinely on the status and will need to be able to provide my management with an update. Until I crunch the numbers from Nino's modeling I won't be able to have much of a meaningful consultation process on that issue. Typically we cons ult after I incorporate mobile numbers in with all the other pollutant sectors to determine our possible safety margin options if budgets are necessary. Then we typically discuss if that is agreeable. Thanks, Jennifer Dines Manager, State Implementation Plan and Rulemaking Section Division of Air Pollution Control Ohio Environmental Protection Agency Wk (614) 644-3696 Fax (614) 644-3681From: Dan Slicker [mailto:dkslicker@co.stark.oh.us] Sent: Thursday, April 26, 2012 3:18 PM To: Brunello, Nino Subject: Re: Ozone emissions for SIP document

Nino,

Now I'm moving on to ozone. In the table that sho ws the emissions, what is the VMT/VEH column supposed to mean? VMT per ve hicle doesn't make sense.

What are the different analysis years called? 2004 is the base year. What are 2009 and 2018?

That's all for now.

Dan

From: Dan Slicker [mailto:dkslicker@co.stark.oh.us] Sent: Thursday, April 26, 2012 3:19 PM To: Brunello, Nino Subject: Re: Ozone emissions for SIP document

One more question. The Dayton-Springfield doc refers to an I/M program. What is that?

Dan

>>> "Brunello, Nino" <Nino.Brunello@ dot.state.oh.us> 4/27/2012 7:59 AM >>> Hey Dan,

Yeah, that table was put together by Greg, so I didn’t mess with any of the formatting, but it’s a little confusing. The header on the third column should really be VMT or VEH. So the units for links and
intrazonals are in miles, and VEH is number of vehicles.

The analysis years are: 2004

– Attainment Year
2009

– In terim Budget Year
2018

– Maintenance Budg et Year

I/M is short for inspection and mai ntenance. Akron and Cleveland have it. It’s where you are required

to take your vehicle to a service station and they do some testing like putting a sensor on the tailpipe,
check the gas cap, make sure the catalytic converters aren’t missing, etc. You have to do it before you

can get new tags for your car. There’s also things like vapor recovery, where there is a rubber funnel at the gas pumps that capture fumes while refueling.

Nino>>> "Brunello, Nino" <Nino.Brunello@ dot.state.oh.us> 5/18/2012 1:32 PM >>> Ok, I need to update the emission totals (Table 1). I’ll get to you by Monday, maybe later today if nothing else comes up.

>>> "Brunello, Nino" <Nino.Brunello@ d ot.state.oh.us> 5/21/2012 2:08 PM >>> Attached is the latest spreadsheet with updated emission totals. I had to rerun some assignments, and I have also adjusted the VMTs to reflect summer traffic.

From: Dines, Jennifer Sent: Wednesday, June 13, 2012 8:17 AM To: Moore, Dave Cc: Brunello, Nino; Fetty, Erica Subject: RE: Ozone SIP budgets

Dave, we nee d to make sure all the MPOs know the numbers we need to complete our analysis. There
should be 4 years for everyone (nonattainment/base, attainment, interim and maintenance years, using
the years in the first tab of the attached sheet. Note that for Dayton there is an asterisk showing that
2005 was the interim budget year but 2009 was modeled...so we need both 2004 and 2009 years remodeled (with all four years being 2002, 2005, 2009, 2018)

Jennifer Dines Manager, State Implementation Plan and Rulemaking Section
Division of Air Pollution Co ntrol
Ohio Environment al Protection Agency
Wk (614 ) 644

‐ 3696
Fax (614) 644

‐ 3681

>>> "Moore, Dave" < Dave.Moore1@dot.state.oh.us > 6/13/2012 9:36 AM >>> All,

See below, OEPA Ozone SIP Update message. Please review your region’s Ozone SIP update subm issions to OEPA to assure it includes base year mobile emissions inventory (see attached spreadsheet – 2002 is the base year for most regions).

Thanks
DM

From: Dan Sl icker [mailto:dkslicker@co.stark.oh.us] Sent: Wednesday, June 13, 2012 9:56 AM To: Jeffrey Dutton Cc: Moore, Dave; Brunello, Nino Subject: Re: Fwd: FW: Ozone SIP budgets

Ours does not include the base year 2002.Nino, do you have our 2002 network or should I send it to you?

Dan

>>> "Brunello, Nino" <Nino.Brunello@ d ot.state.oh.us> 6/13/2012 10:37 AM >>> Dan,

I looked at what I used in the past, and we had used the base 2000 network for running 2002. I think
that would still be okay.

Also, last week you had sent 2010 ne twork and prohibitor files. Is there a new transit line file?

Nino

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Nino Brunello, P.E. Modeling & Forecasting Section Division of Planning Ohio Department of Transportation (614) 752-5742

>>> "Brunello, Nino" <Nino.Brunello@ d ot.state.oh.us> 7/27/2012 2:54 PM >>> Jeff/Dan,

The a ttached file has the ozone emission estimates needed for the SIP. The 2002 run has been added,
and I also reran the other years because there was a problem with a seasonal adjustment process that

we had done earlier.

If you need anything else or have any questions, please let me know.

Thanks,

NinoPublic Notice Ohio Environmental Protection AgencyRedesignation and Maintenance Plan for the Ohio Portion of the CantonMassillon Area

Stark County

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, (Ohio EPA) is requesting that the United States Environment al Protection Agency (U.S. EPA) revise the current maintenance plan for the Canton-Massillon Area, including Stark County, with respect to the 1997 ei ght-hour ozone national ambient air quality standard (NAAQS). Ohio EPA s ubmitted a redesignation request and maintenance plan for this area on June 20, 2006 Subsequently, U.S. EPA approved this requests on May 16, 2007. Air quality monitoring data collected in the region demonstr ated attainment of the NAAQS and there was evi dence that the improved air quality is due to permanent, enforceable emission reductions. In addition, existing requirements are sufficient to maintain the 1997 eight-hour ozone standard in this area throughout the maintenance period.

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budget s based on emission rates generated from U.S. EPA’s latest mobile emissions model , the Motor Vehicle Emission Simulation (MOVES) 2010. In December 2009, MOVES r eplaced MOBILE6.2 as the U.S. EPA’s official emission factor model.

These actions must be noticed to allow public comment and to satisfy U.S. EPA requirements for public involvem ent in SIP related activities. This notice addresses Ohio EPA’s reliance on the emission projec tions as evidence of attainment and maintenance and the commitment to institute contingen cy measures if ambient exceedances or violations trigger the cont ingency plan requirements. Written comments will be received on or before November 08, 2012 at the following address: E-mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty Ohio Environmental Protection Agency, DAPC Lazarus Government Center P.O. Box 1049 Columbus, Ohio 43216-1049 Phone: (614) 644-2310

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this redesignation request will be c onducted as follows: Thursday November 08, 2012 at 2:00P.M., at Stark County District Library North Branch located at 189 25th St. NW Canton, Ohio.

All interested persons are entitled to att end or be represented at the hearings and givewritten or oral comments on these changes. All oral comments presented at the hearing, and all written statements submitted at the hearing or to the above address by the close of business on November 08, 2012 will be considered by Ohio EPA prior to final action on this redesignat ion. Written statements subm itted after November 08, 2012 may be considered as time and circumst ances permit, but will not be part of the official record of the hearing.

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web page for electronic downloading at: http ://www.epa.ohio.gov/dapc/SIP/1997.aspx. Questions regarding accessing the web site should be directed to Arunee Niamlarb at 614-728-1342; other questions or comments about this document should be directed to either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at (614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer Dines at the above address.1

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### OHIO ENVIRONMENTAL PROTECTION AGENCY

PUBLIC HEARING

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### 5 In Re:

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### Redesignation and Maintenance Plan for Ozone Basic 7 Nonattainment Area Stark County, Ohio

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### 10

11 Transcript of proceedings

12 held before the Ohio Environmental Protection 

### PClbe 1

13 Agency, at the Stark County Library, North Branch,

14 189 25th Street, N.W., Canton, Ohio 44709,

15 on November 8, 2012, commencing at 2:00 p.m.

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### 17

18 APPEARANCES:

19 Mary McCarron, Ohio EPA Public Interest Center

20 Erica Fetty, Ohio EPA, Division of Air Quality

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## PCJ8e 2

PROCEEDINGS

MS. McCARRON: My name is Mary

McCarron. I am the public involvement manager

for Ohio Environmental Protection Agency's

Public Interest Center. I will be presiding

over today's public hearing.

Thank you for taking the time to attend

this hearing before the Ohio Environmental

Protection Agency. The purpose of the hearing

today is to obtain comments from any

interested person regarding Ohio EPA's

proposed action.

The State of Ohio is requesting that

U.S. EPA revise the current maintenance plan

for the Canton-Massillon area, including Stark

County, with respect to the 1997 eight-hour

ozone national ambient air quality standard.

Ohio EPA is now requesting a revision

to the maintenance plan to update mobile

emission projections and conformity budgets

based on emission rates generated from U.S.

EPA's latest mobile emissions model, the Motor

Vehicle Emission Simulation 2010. In December

2009, MOVES replaced MOBILE6.2 as the U.S.

EPA's official emission factor model.



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### All interested persons are entitled to

attend or be represented, and to present oral

and/or written comments concerning the

proposed action. All written and oral

comments received as part of the official

record will be considered by the Director of

Ohio EPA.

To be included in the official record,

written comments must be received by Ohio EPA

by close of business, today, November 8, 2012.

These comments may be filed with me today or

e-mailed to erica.fetty®epa.ohio.gov. All

written comments submitted for the record

receive the same consideration as oral

testimony given today.

Written statements submitted after

today may be considered as time and

circumstances permit, but will not be part of

the official record of the hearing.

If you wish to present oral testimony

at this hearing today and have not already

signed the registration sheet, please do so at

this time. The sheet is available at the

registration table. Persons will be called in

the order in which they have registered.



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### There is no cross-examination of

speakers or of representatives of Ohio EPA in

public hearings such as this. Ohio EPA

hearings such as this afford citizens the

opportunity to provide comments on the

official record. Therefore, we will not be

able to answer questions during the public

hearing. However, members of the panel may

ask clarifying questions of those providing

testimony to make sure it is as complete as
possible.

What I am going to do is I'm going to

read the names of folks who have signed-in.

If you want to put anything on the record at

this time, just go ahead and state your name

and spell it for our court reporter. If you

don't, go ahead and say "pass". After that,

if nobody wants to provide testimony we'll go

off the record until 2:30 and then we will

reopen the hearing at 2:30 to see if anybody

has any comments and then close out the

hearing.

The first person who has registered at

this time, is Renee

MS. BOGUE: Bogue.



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### MS. McCARRON:

MS. BOGUE:

MS. McCARRON:

Annie Shimko.

MS. SHIMKO:

MS. McCARRON:

MS. LOWRY:

MS. McCARRON:

MS. TOLOE:

MS. McCARRON:

MS. TOLOE: Bogue.

At this time, no.
Okay.

No.

Jennifer Lowry.

Pass.

Sylvia

Toloe.

Toloe.

No. 

## Paoe?

MS. McCARRON: At this time, we will

go off the record until 2:30.

(Recess taken.)

At this time, there isn't anyone who

wishes to testify. Just a reminder, we will

accept written comments by the close of

business today. The time is now 2:30 and we

will adjourn the hearing.

Thanks for coming.

(Hearing concluded at 2:30p.m.)



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25 C E R T I F I C A T E

This certifies that the foregoing is a true

and correct transcript of the proceedings had

before the State of Ohio, Environmental

Protection Agency, at the Stark County

Library, North Branch, 189 25th Street, N.W.,

Canton, Ohio 44709, on Thursday,

November 8, 2012, commencing at
2:00p.m.

In Re:

Redesignation and Maintenance Plan for Ozone Basic Nonattainment Area Stark County, Ohio.

FINCUN-MANCINI COURT REPORTERS 1801 East Ninth Street Suite 1720 Cleveland, Ohio 44114 (216) 696-2272 (216) 696-2275 FAX



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