# Puget Sound 8

- Hour Ozone

110(a)(1) Maintenance Plan

Puget Sound Clean Air Agency

1904 3 rd Ave, Ste 105

, Seattle, WA 98101



### John Anderson

Ma y 2007

### Puget Sound Ozone Maintenance Plan

Puget Sound 8

- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 2 5/1 8 /07

- 2 

### Summary

According to E nvironmental P rotection A gency (EPA) guidance 1 , the Puget Sound Clean Air Agency must prepare a federal Clean Air Act Section 110(a)(1) maintenance plan for the 8

- hour

ozone standard . The EPA requires the Agency to submit this plan by June 15, 2007.

The Agency has met all requirements for this 8

- hour maintenance plan as shown beginning on page

5 . Additionally, air monitoring within the Agency’s jurisdiction has not measured any violat ions of

EPA’s 8

- hour ozone standard since its adoption in 1998

. The Agency has conducted photochemical dispersion modeling for multiple ozone ep isodes, predicting attainment into future years up to 2015. This modeling has repeatedly shown that the Puget Sound area is likely to remain in attainment with

the current 8

- hour standard.



### General Background

Ozone is a summertime air pollution problem . It is formed when photochemical pollutants react with sunlight. Precursors include volatile organic compounds (VOC) and nitrogen oxides (NO

x ), with some influence by carbon monoxide (CO). These precursors come from anthropogenic

sources such as mobile sources
, industrial and commercial solvent use, as well as natural biogenic sources. Levels are usually highest in the summer afternoon s because of the intense sunlight and the time required for ozone to form. Ozone levels are highly affected by weather

. Atmospheric chemical dispersion modeling has repeatedly shown that the Puget Sound urban area is “VOC

limited,” which means that reducing VOC emissions most effectively reduces ambient concentrations of ozone at the locations of greatest concentration.

Elevated ozone concentrations can cause reduced lung function and respiratory irritation, and can aggravate asthma 2

. People with respiratory conditions should limit outdoor exertion if ozone levels are high. Ozone has also been linked to immune system e ffects and g round

- level ozone can also damage agricultural crops and forests, interfering with their ability to produce food and grow 3

. In the Puget Sound region, the hot sunny days favorable for ozone formation also tend to have light

north

- to

- northwest w inds. Ozone has typically been transported 10 to 30 miles downwind from the original source by the time the highest concentrations have formed in the afternoon and early evening. Highest ozone concentrations are measured in areas such as North Bend and E numclaw, the communities downwind of large urban areas.



### Ozone State Implementation Plan & Maintenance Plan History

The original " Plan for the Implementation, Maintenance and Enforcement of National Ambient Air Quality Standards in the State of Washing ton " was submitted in January 28, 1972 [40 CFR 52.2470 Subpart WW

-- Washington State Implementation Plan] . A Transportation Control Plan was submitted on April 13, 1973 and then revised May 13, 1973 [ 40 CFR 52.2470(7) and (8) ]. A

revision was made to the Seattle

- Tacoma ozone non

- attainment area plan on June 24, 1982 [40 CFR 52.2470(22)]. On July 16, 1982 the Seattle

- Tacoma ozone non

- attainment area plan was revised to include the then Puget Sound Air Pollution Control Agency's Regulation II adopted by the ir Board on March 13, 1980 to provide for control of photochemically reactive volatile organic compounds (VOC) and conformity procedures for evaluating federal projects for consistency with the Seattle

-

### Puget Sound Ozone Maintenance Plan

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- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 3 5/1 8 /07

- 2 Tacoma ozone plan [40 CFR 52.2470(27)]. Regulation II revisions through December 13, 1984 were incorporated into the SIP [40 CFR 52.2470(35)]

.

On November 15, 1990, the Clean Air Act Amendments of 1990 (CAA) were enacted. Under section 107(d)(1) of the CAA

, EPA designated , in conjunction with the Governor of Washington, the Puget Sound area as nonattainment for ozone because the area violated the 1

- hour ozone standard during the period from 1989

- 1991. The Puget Sound area was classified as "marginal" under section 181(a)(1) of the CAA. On January 28, 199 3 the State of Washington submitted a State Implementation Plan (SIP) for compliance with the ozone NAAQS. The Puget Sound Clean Air Agency Regulation II revisions through October 18, 1993 and December 8, 1994 were incorporated into the SIP [40 CFR 52.247 0(43) and (53)]. On March 4, 1996, t he State submitted the Central Puget Sound Redesignation Request and Ozone Maintenance Plan adopted February 6, 1996 including base year 1990 emission inventories of precursors of ozone for King, Pierce and

Snohomish co unties [40 CFR 52.2470(63) and (66)]

. Regulation II revisions through August 6,

1996 were inco rporated into the SIP [40 CFR 52.2470(71)]. On September 25, 1996 the Puget Sound area ozone State Implementation Plan (SIP) was revised to incorporate the Puge t Sound area's centralized, test only, biennial vehicle inspection and maintenance program overseen by the Washington State Department of Ecology using its Systems Control contractor 4

. On September 26,

1996

, Puget Sound was re

- designated to attainment for ozone and the ozone maintenance plan was approved 5

.

On August 5, 2004 6 EPA approved Washington's demonstration that the Central Puget Sound area will maintain air quality standards for ozone through the year 2016. It also updated and enhanced

the Stat e Implementation Plan (SIP) by adding two ozone contingency measures, incorporated by reference: (1) Puget Sound Clean Air Agency (PSCAA) Regulation I, Section 8.06, Outdoor Burning Ozone Contingency Measure and (2) PSCAA Regulation II, Section 2.10, Gasol ine Station Ozone Contingency Measure 7

.


### Historic Monitoring & Federal Standards

The national ambient air quality standard in place during 1972 through 1978 was achieved when no more than one 1

- hour average of total photochemical oxidants concentration ex ceed ed 0.08 ppm. In the Puget Sound area the number of hours exceeding this standard during 1972 through 1978 ranged

from 0 to 37 annually

. The chart below shows that this standard was exceeded in 1972 , 1974

- 1976

and 1978.

### Puget Sound Ozone Maintenance Plan

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- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 4 5/1 8 /07

- 2 During 1979 through 199 7

, the ambient standard was changed by EPA

. The standard was achieved

when no more than one day

, annually, has 1

- hour average ozone concentration s above 0.12 ppm. The number of days , annually, exceeding this standard during 1979 through 1997 ranged from 0 to
3. 9. The chart below shows that this standard was exceeded during 1979

- 1983, 1985

- 1986, and

1990

- 1992.



### Current Monitoring & Federal Standards

From 1998 through 200 6 the ambient standard was changed to be achieved when the three

- year average of the annual fourth highest 8

- hour average ozone concentration at each monitor did not exceed 0.08 p arts p er m illion (ppm)

. This standard has not been violated from 1998 through 200 6

at any monitor in the Puget Sound region

. The chart below shows that this 8

- hour standard has

### Puget Sound Ozone Maintenance Plan

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- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 5 5/1 8 /07

- 2 never been exceeded . The chart shows maximum 8

- hour concentrations at the Enumclaw Mud Mountain monitoring , the highest ozone site in our jurisdiction. The pink line shows the design value, the 3

- year average of the 4 th highest concentr ation, while the dotted line shows the federal standard of 0.08 p pm

. This line has stayed relatively flat, ranging from 0.06 8 to 0.07 6 ppm. Note that EPA rounding conventions requires truncat ing both the hourly measurements and the resulting

8

- hour avera ges yielding the following results for the 1998 through 2006 time period:

### Puget Sound Ozone Maintenance Plan

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- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 6 5/1 8 /07

- 2 8

- hour Ozone Concentrations by Site

For further reference, see the Puget Sound Clean Air Agency's web site monitoring mapping tool at

< http://trendgraphing.pscleanair.org/Tre ndGraphing.aspx >

.

### Puget Sound Ozone Maintenance Plan

Puget Sound 8

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- 2 The circles on the map above represent ozone monitoring sites maintained by the Department of Ecology

- the two letters are codes used for identification. Highest ozone concentrations are typically recorded at th e DF (Enumclaw Mud Mountain) monitor

. The other monitoring site codes

are listed above in parentheses in the "8

- hour Ozone Concentrations by Site" graph.



### Required 8

- Hour Ozone Maintenance Plan

According to the May 20, 2005 EPA guidance

, the Puget Sound Clean Air Agency must prepar e a federal Clean Air Act Section 110(a)(1) maintenance plan for the 8

- hour ozone standard because all of Pierce County, all of King County except a small portion on the northeast corner and the western portion of Snohomish Coun ty were designated as unclassifiable/attainment for the 8

- hour ozone

standard and had an approved maintenance plan for the 1

- hour ozone standard on June 15, 2005. This plan is required to be submitted no later than June 15, 2007.

This 8

- hour ozone mainte nance plan contain s the required elements :

(1) An actual summer day VOC and NOx emission inventory for calendar year 2002 8

. The documentation of this inventory is available from the EPA website 9 . A summary of two ozone modeling emission inventories an d average summer day estimates from two base year

annual emission inventories is shown below. After 1996

, the trend is downward for total

emissions of VOC , which is the controlling pollutant for ozone in the Puget Sound area

.

### Puget Sound Ozone Maintenance Plan

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- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 8 5/1 8 /07

- 2 The emission char ts above come from the following references:

1 996 Ozone Modeling for Maintenance Plan Revision for Puget Sound in Western Washington , pages 93

- 94, 7/13/96 10

This ozone summer day modeling inventory was used to construct hourly emission estimates over a 5 kilometer grid system to test ozone strategies in comparison with a July 11

- 14, 1996, ozone episode.

Link

- base vehicle miles traveled estimates came from the regional planning organization Puget Sound Regional Council and emission factor were derived fro m a modified EPA MOBILE5b model. Vehicle registration distribution was modified to track older than default vehicles in the Puget Sound area, based on data from the Washington State Department of Licensing. In addition, parameters were specified for two vehicle inspection and maintenance program scenarios

. Emissions were also projected to 2015.

1998 Modeling Analysis of Future Emission Scenarios for Ozone Impacts in the Puget Sound Area

, pages 77

- 78, 7/29/98 11

This ozone summer day modeling inventory w as used to construct hourly emission estimates over a 4 kilometer grid system to test ozone strategies in comparison with a July 22

- 28, 1998, ozone episode.

Link

- base vehicle miles traveled estimates came from the regional planning organization Puget Soun d Regional Council and emission factors were derived from the EPA MOBILE6.2 model. Vehicle registration distribution was modified to track older than default vehicles in the Puget Sound area, based on data from the Washington State Department of Licensing . In addition, parameters were specified for six vehicle inspection and maintenance program scenarios. Emissions were also projected to 2015 to analyze expected growth in the marine sector and the eventual removal of the voluntary gasoline low Reid Vapor Pressure gasoline program.

2002 2002 Emission Inventory Appendix

-- Seasonal, 12

The 2002 National Emission Inventory was prepared by EPA headquarters except for data submitted by the Puget Sound Clean Air Agency on point sources, fireplace/woodstove emiss ions and land clearing burning. A final version of this inventory and documentation may be found on EPA's

website 9 . For this ozone 110 maintenance plan a spreadsheet was prepared that seasonally adjusts

each sour ce category of emissions to yield average summer day emissions in 2002. On

- road mobile estimates were made using MOBILE6.2 based on EPA's default NMIM inventory and non

- road emission estimates were made using the NONROAD model

.

2005 All Air Pollution So urces 2005

-- Seasonal 13

### Puget Sound Ozone Maintenance Plan

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- 2 (2) A maintenance demonstration 10 was conducted in 2001 which show ed that the Puget

Sound area would remain in compliance with the 8

- hour ozone standard by ensuring that

VOC and NOx emi ssions will remain below attainment levels for calendar years 2005 through

2015

. In 2006 another ozone modeling exercise was conducted 11 , which confirms the previous modeling results indicating that the region is likely to maintain attainment with the current ozone national ambient air quality standard. It is expected that total on

- road mobile sources emissions may decrease, while emission from the maritime

- related sources may increase from 2006 through

2015. Even with a small increase in total NOx emissions in the final time period segment between 2005 and projected 2015, the downward trend in VOC emissions leads to lower ozone

concentrations and confirm continued compliance with the existing 8

- hour standard of 0.08 ppm

. This latest modeling ozone effort focused on an ozone episode which occurred in Puget Sound during July 22

- 28, 1998. This episode recorded the highest ozone levels in recent history in the Puget Sound area and had the most extreme meteorolog y available. During this episode the 8

- hour average ozone concentrations observed downwind of Seattle reached 111 ppb. Air quality during this period was simulated using the Mesoscale Meteorology model version 5/Sparse Matrix Operator Kernel Emissions Mo deling System/Community Multi

- scale Air Quality modeling System (MM5/SMOKE/CMAQ). Future design values, used to compare to the federal 8

- hour ozone standard, were calculated at values less than 84 ppb and demonstrated that Puget Sound monitoring

sites rem ain in federal attainment status in 2015. The highest design value was 68 ppb for the Enumclaw Weyerhaeuser Mill and Pack Forest monitoring sites. Sensitivity analysis model runs were made to insure the validity of the conclusions. In addition the modeli ng system was used to test the difference between continuing and discontinuing the voluntary low RVP gasoline program and found the increase to be less than 0.3 ppb in predicted daily maximum 8

- hour ozone

concentrations. Given the overall decease in on

- ro ad mobile VOC emissions, the voluntary low RVP gasoline program impact is considered inconsequential in future years.

2015 Modeling Analysis of Future Emission Scenarios for Ozone Impacts in the Puget Sound Area 11

, pages 77

- 78, 7/29/98

Projections were made to 2015 based on the base year 1999 emission inventory.

### Puget Sound Ozone Maintenance Plan

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- 2 (3) A commitment to continue adequate ozone monitoring to demonstrate compliance with

the 8

- hour ozone standard

. Ecology commits t o continuing to monitor for 8

- hour ozone concentrations and to show comparisons of these values to the 8

- hour ozone standards.

(4) A contingency plan is in place that will ensure that any violation of the 8

- hour ozone standard would be promptly address e d

. The Puget Sound Clean Air Agency regulations for two contingency measures were adopted December 19, 2002 and were included in the revised State Implementation Plan on August 5, 2004 6

. Both the outdoor burn ing and the gasoline marketing contingency measure regulations are triggered by a written finding from EPA of a quality assured

violation of the standard and that future violations can reasonabl y be addressed through implementation of the regulations

.

O utdoor Burning Ozone Contingency Measure ( PSCAA Regulation I, Section 8.06) :

Step 1

-- EPA, in consultation with the Puget Sound Clean Air Agency and Ecology,

make s a written finding that a quality

- assured ozone standard violation has occurred and

that prev ention of future violations can be reasonably addressed through implementation of Regulation I, Section 8.06

.

Step 2

-- Puget Sound Clean Air Agency provides public notice of EPA's written finding by November 1 st

.

Step 3

- - Effective July 1 st following the p ublic notice of the written finding o utdoor burning is unlawful within King, Kitsap, Pierce or Snohomish counties during the months

of July through August

.

Gasoline Station Ozone Contingency Measure ( PSCAA Regulation II, Section 2.10 ) :

Step 1

-- EPA, i n consultation with the Puget Sound Clean Air Agency and Ecology, makes a written finding that a quality

- assured ozone standard violation has occurred and that prevention of future violations can be reasonably addressed through implementation of Regulation II, Section 2.10.

Step 2

-- Puget Sound Clean Air Agency provides public notice of EPA's written finding by November 1 st

.

Step 3

- - Effective May 1 st following the public notice of the written finding i t shall be unlawful for any person to cause or allow th e transfer of gasoline from a transport tank into a stationary storage tank at a gasoline station that use s coaxial Stage 1 vapor recovery systems and dispense s 600,000 gallons or more of gasoline per year unless a California Air Resources Board (CARB) Sta ge I system, approved after July 1, 2002, is

installed within one year of the May 1 st date and operated in accordance with CARB system certification requirements

.

### Puget Sound Ozone Maintenance Plan

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- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 11 5/1 8 /07

- 2 (5) Puget Sound Clean Air Agency is required by EPA to update the VOC and NOx emission

inv entories for 2008, 2011 and 2014. Puget Sound Clean Air Agency commits to preparing summer day emission inventories for the interim years of 2008, 2011 and 2014 and comparing these emission inventory results with the modeling emission inventories to ensu re continued compliance

with the 8

- hour ozone ambient air quality standard. If values in the total VOC and NOx emissions for 2008, 2011 or 2014 exceed linearly interpolated values between 1998 and 2015 used in the ozone modeling, an analysis will be made by the Puget Sound Clean Air Agency to determine the probability of continued compliance with the ozone 8

- hour standard. Even though the comparison is made in the total emissions, emissions by major source category are listed below to show the trends by c ategory. Rounding differences have caused some column totals to show slight variances.

The VOC e missions in tons per summer day calculated from interpolation between 1998 and 2015 ozone modeling values are shown below :

VOC Emission Source Category 1998 tpd 2005 tpd 2008 tpd 2011 tpd 2014 tpd 2015 tpd

Area 155 158 162 165 169 172

Point 17 17 17 17 17 17

Non

- road 128 116 105 93 82 70

On

- road 2 40 207 177 147 117 87 Biogenic 433 433 433 433 433 433

Total 973 934 896 857 819 780

The VOC emissions in tons per summer day from the seasonally adjusted draft 2005 emission inventory are :

VOC Emission Source Category 2005 tpd

Area 176

Point 11

Non

- road 81

On

- road 154 Biogenic 433

Total 855

Note that t otal the 2005 VOC emissions in the draft emission inventory of 855 tons per day are less that the interpolated 934 tons per day so that no additional determination in 2005 of continued compliance with the 8

- hour ozone standard would be required, even though the draft inventory area source category of 176 tpd exceeds the interpolated 158 tpd.

### Puget Sound Ozone Maintenance Plan

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- Hour Ozone 110(1)(a) Maintenance Pl an .doc page 12 5/1 8 /07

- 2 The NOx emissions in tons per summer day calculated from interpolation between 1998 and 2015 ozone modeling values are shown below:

NOx Emission Source Category 1998 tpd 2005 tpd 2008 tpd 2011 tpd 2014 tpd 2015 tpd

Area 14 14 14 13 13 13

Point 27 27 27 27 27 27

Non

- road 211 223 235 247 259 271

On

- road 312 270 227 185 142 100 Biogenic 2 2 2 2 2 2

Total 567 536 506 475 445 414

The NOx Emissions in tons per summer day from the seasonally adjusted draft 2005 emi ssion inventory:

NOx Emission Source Category 2005 tpd

Area 7

Point 21

Non

- road 111

On

- road 232 Biogenic 2

Total 373

Note that total 2005 NOx emissions in the draft emission inventory of 373 tons per day is less that the interpolated 536 tons per day so that no additional determination in 2005 of continued compliance with the 8

- hour ozone standard would be required.

Therefore, as noted above, the Puget Sound Clean Air Agency has met the requirements of the ozone 110 SIP guidance document and shows continued compliance of the existing 0.08 ppm 8

- hour ozone National Ambient Air Quality Standard through 2015

.

### Puget Sound Ozone Maintenance Plan

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- 2 References

1 EPA. "Maintenance Plan Guidance Document for Certain 8

- hour Ozone Areas Under Section 110(a)(1) of Clean Air Act."

Research Tria ngle Park, N.C.: 20 May 2005.

2 EPA

. “Ozone and Your Health,” http://www.airnow.gov/index.cfm?action=stat ic.ozone2#3

3 EPA

. “Health and Environmental Effects of Ground

- Level Ozone,” http://www.epa.gov/ttn/oarpg/naaqsfin/o3health.html

4 Federal Register. September 25, 1996. Approval and Promulgation of Air Quality Implementation Plans; Washington; Revision to the State Implementation Plan Vehicle Inspection and Maintenance Programs. Pages 50235

- 50238, effective 9

- 25

- 96

.

5 Federal Register. September 2 6 , 1996. Approval and Promulgati on of Implementation Plans and Redesignation of Puget Sound, Washington for Air Quality Planning Purposes: Ozone. Pages 50 438

- 50443 , effective 11

- 25

- 96

.

6 Federal Register. August 5, 2004. Approval and Promulgation of State Implementation Plans: State of Washington; Central Puget

Sound Carbon Monoxide and Ozone Second 10

- Year Maintenance Plans. Pages 47365

- 47366, effective 9

- 7

- 04

.

7 Puget Sound Clean Air Agency. Regulation I, Section 8.06 and Regulation II, Section 2.10. Seattle, WA: 19 December 2 002

.

8 Puget Sound Clean Air Agency. "Ozone Summer Day Emission Inventories" spreadsheet. Seattle, WA: 2 May 2007. [Ozone Summer Day Emission Inventories.xls]

9 EPA. 2002 National Emission Inventory, ftp://ftp.epa.gov/EmisInventory/2002finalnei

10 Lamb, Brian et al

. of Washington State University; Sally Otterson et al

. of Washington State Department of Ecology

and Naydene Maykut of Puget Sound Clean Air Agency. Ozone Modeling for Maintenan ce Plan Revision for Puget Sound in Western Washington. Pullman, Lacey and Seattle, WA: 15 October 2001.

11 Lamb, Brian et al

. of Washington State University; Sally Otterson et al

. of Washington State Department of Ecology and Kathy Himes et al

. of Puget Sound Clean Air Agency. Modeling A nalysis of F uture Emission Scenarios for Ozone Impacts in the Puget Sound Area. Pullman, Lacey and Seattle, WA: August 20 06.

12 Anderson, John of Puget Sound Clean Air Agency. "2002 Emission Inventory Appendix

-- Seasonal " spreads heet. Seattle, WA

, 1 May 2007.

13 [ In preparation ]