# Appendix 2

Medford 2008 Emission InventoryAppendix 2

- 2015 Medford CO LMP

Page i 

## Appendix 2 To
Medford 2015 CO Limited Maintenance Plan

2008 Year Emission Inventory For Carbon Monoxide (CO)

Medford Urban Growth Boundary

June 2015

Oregon Department of Environmental Quality
Environmental Solutions Division Air Quality Technical Services Section

811 SW 6 th Avenue Portland, Oregon 97204Appendix 2

- 2015 Medford CO LMP

Page ii 

## Table of Contents

Table of Contents

................................ ................................ ................................ .................. ii Table of Figures

................................ ................................ ................................ ..................... v Table of Tables

................................ ................................ ................................ ...................... vi

1 Executive Summary

................................ ................................ ................................ ......... 2

2 Introduction

................................ ................................ ................................ .................... 6

2.1 Purpose of the Report

................................ ................................ ................................ ..... 6

2.2 Inventory Time Frame and Area Covered

................................ ................................ ....... 6

2.3 Report Contents

................................ ................................ ................................ .............. 9

2.4 Automated Systems

................................ ................................ ................................ ...... 10

2.5 So urces Not Inventoried

................................ ................................ ............................... 10

2.6 Guidance Documents

................................ ................................ ................................ .... 10

2.7 Contact Personnel

................................ ................................ ................................ ......... 11

3 Medf ord Carbon Monoxide Attainment Area Inventory

................................ ................. 13

3.1 Inventory Area Maps and Descriptions

................................ ................................ ........ 13

3.1.1 Inventory Area Maps

................................ ................................ .............................. 13

3. 1.2 Legal Descriptions

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

3.1.2.1 Legal Description of Medford Urban Growth Boundary / CO Inventory Area

17

3.1.2.2 Legal Description of Open Burning Control Areas

................................ ........ 18

3.1.2.3 Legal Description of Medford Area Woodstove Curtailment Ordinance /
Critical PM10 Control Area

................................ ................................ ............................... 19

3.1.2.4 Legal Description of the Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary

................................ ................................ ............. 19

3.2 Summary of Emissions Data

................................ ................................ .......................... 20

3.3 Stationary Permitted Point Sources

................................ ................................ .............. 23

3.3.1 Introduction

................................ ................................ ................................ ............ 23

3.3.2 Geographic Area and Sources Included

................................ ................................ .. 23

3.3.3 Point Source Determination

................................ ................................ ................... 23

3.3.3.1 2008 Point Source Determination

................................ ................................ 24

3.3.4 Methodology and Approach

................................ ................................ ................... 25

3.3.4.1 Data Collection

................................ ................................ .............................. 25

3.3.4.2 Emission Basis

................................ ................................ ............................... 25

3.3.4. 3 Activity Data

................................ ................................ ................................ .. 25Appendix 2

- 2015 Medford CO LMP

Page iii 3.3.4.4 Plant Site Emission Limits (PSELs)

................................ ................................ . 26

3.3.4.5 Annual Emissons Calculations

................................ ................................ ....... 26

3.3.4.5.1 Emissions Estimation Methodologies for TV Sources

................................ . 26

3.3.4.5.2 Emissions Estimation Methodlogies for ACDP Sources

.............................. 26

3.3.4.6 Seasonal Emissions Calculations

................................ ................................ ... 27

3.3.4.6.1 Seasonal Adjustment Factors

................................ ................................ ...... 27

3.3.4.6.2 Season Day Emissions Calculations

................................ ............................. 27

3.3.5 Summary of Stationary Point Source Emissions

................................ ..................... 29

3.3.6 Control Efficiency (CE) and Rule Effectiveness (RE)

................................ ................ 30

3.4 Stationary Nonpoint (Area) Sources

................................ ................................ ............. 31

3.4.1 Introduction and Scope

................................ ................................ ........................... 31

3.4.2 Methodology and Approach

................................ ................................ ................... 31

3.4.2.1 Source Category Identification and General Methodology Overview

......... 31

3.4.2.2 Reconciliation with Point Source Emissions (double count prevention)

...... 32

3.4.3 Discussion of Area Source Categories

................................ ................................ ..... 32

3.4.3.1 Waste Disposal, Treatment and Recovery

................................ .................... 32

3.4.3.1.1 Incineration

................................ ................................ ................................ . 32

3.4.3. 1.1.1 Industrial Incineration

................................ ................................ ........................ 32

3.4.3.1.1.2 Commercial/Institutional Incineration

................................ .............................. 33

3.4.3.1.1.3 Residential Incineration

................................ ................................ ..................... 33

3.4.3.1.2 Open Burning

................................ ................................ .............................. 33

3.4.3.1.2.1 Industrial Open Burning

................................ ................................ ..................... 33

3.4.3.1.2.2 Commercial/Institutional Open Burning

................................ ............................ 33

3.4.3.1.2.3 Residential Open Burning (back yard burning)

................................ .................. 34

3.4.3.2 Small Stationary Fossil Fuel and Wood Use

................................ .................. 35

3.4.3.2.1 Fuel Oil Combustion

................................ ................................ .................... 35

3.4.3.2.2 Natural Gas (NG) and Liquified Petroleum Gas (LPG)

................................ . 36

3.4.3.2.3 Coal and Biomass C ombustion

................................ ................................ .... 37

3.4.3.3 Residential Wood Combustion

................................ ................................ ..... 38

3.4.3.4 Miscellaneous Area Sources

................................ ................................ ......... 38

3.4.3.4.1 Forest Wildfires

................................ ................................ ........................... 38Appendix 2

- 2015 Medford CO LMP

Page iv 3.4.3.4.2 Prescribed Burning

................................ ................................ ...................... 38

3.4.3.4.3 Structure Fires

................................ ................................ ............................. 39

3. 5 Nonroad Vehicles and Equipment

................................ ................................ ................ 55

3.5.1 Introduction and Scope

................................ ................................ ........................... 55

3.5.2 Nonroad Vehicles and Equipment

................................ ................................ .......... 55

3.5.2.1 Vehicle Categories

................................ ................................ ........................ 55

3. 5.2.2 Methodology

................................ ................................ ................................ . 55

3.5.3 Aircraft and Airport Operations Emissions

................................ ............................. 56

3.5.4 Waterborne Vessels

................................ ................................ ................................ 56

3.5. 5 Rail

................................ ................................ ................................ ........................... 56

3.6 On

- Road Mobile Sources

................................ ................................ .............................. 72

3.6.1 Introduction and Scope

................................ ................................ ........................... 72

3.6.2 Spatial and Temporal Allocation of 2008 NEI Data

................................ ................. 72

3.6.2.1 Spatial Allocation

................................ ................................ .......................... 72

3.6.2.2 Temporal Allocation

................................ ................................ ...................... 72

3.6.3 Summary of On

- Road Mobile Source Emissions

................................ .................... 72

4 Quality Assurance and Quality Control

................................ ................................ .......... 78

4.1 Introduction

................................ ................................ ................................ .................. 78

4.2 Organization and Personnel

................................ ................................ .......................... 78

4.3 Data Collection and Analysis

................................ ................................ ......................... 79

4.3.1 Data Collection and Analysis

................................ ................................ ................... 79

4.4 DATA HANDLING

................................ ................................ ................................ ........... 79

4.5 Data Coding and Recording

................................ ................................ .......................... 79

4.6 Data Tracking

................................ ................................ ................................ ................ 79

4.7 QA/QC Procedures

- Checking and Correcting

................................ ............................. 80

4.7.1 Checking Data

................................ ................................ ................................ ......... 80

4.7.1.1 Inventory Completeness

................................ ................................ ............... 80

4.7.1.2 Missing Data

................................ ................................ ................................ .. 80

4.7.1.3 Incorrect Calculations

................................ ................................ ................... 80

4.7.1.4 Incorrect Information

................................ ................................ ................... 81

4.7.1.5 Reasonableness

................................ ................................ ............................. 81

4.7.1. 6 Emissions Summary Reasonableness

................................ ........................... 81Appendix 2

- 2015 Medford CO LMP

Page v 4.8 Data Reporting

................................ ................................ ................................ .............. 81

5 Referenc es

................................ ................................ ................................ .................... 82

6 Appendices to the Emission Inventory

................................ ................................ ........... 84



## Table of Figures

Executive Summary, Figure 1: 2008 Medford UGB annual CO emissions, percentage by source catego ry 3 Executive Summary, Figure 2: 2008 Medford UGB CO season day emissions, percentage by source
category

................................ ................................ ................................ ................................ ........................ 3 Executive Summary, Figure 3: Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008

.................... 4 Executive Summary, Figure 4: Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008

............. 5

Figure 1: Medford Urban Growth Boundary

................................ ................................ ................................ 7 Figure 2: 2008 Medford CO LMP, 25

- mile buffer and permitted point source locations

............................. 8 Figure 3: Open Burning Control Areas and Rog ue Basin Open Burning Control Area

................................ 14 Figure 4: Woodstove Curtailment Ordinance Area / Critical PM 10 Control Area

................................ ........ 15 Figure 5: Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary

........ 16 Figure 6: Distribution of 2008 Annual CO Emissions

................................ ................................ .................. 20 Figure 7: Annual CO Emissions by Percentage

................................ ............... Error! Bookmark not defined. Figure 8: Distribution of 2008 Season Day CO Emissions

................................ ................................ ........... 21 Figure 9: Season Day CO Emissi ons by Percentage

................................ ................................ ..................... 21 Figure 10: 2008 Commercial Open Burning Locations

................................ ................................ ................ 34 Figure 11: 2008 Residential Open Burning Locations

................................ ................................ ................. 35 Figure 12: Area Source Annual Emissions by Percentage

................................ ................................ ........... 40 Figure 13: Area Source Season Day Emission s By Percentage

................................ ................................ .... 40 Figure 14: Distribution of Medford UGB Annual Nonroad Source CO Emissions, 2008

............................. 58 Figure 15: Percentage of Medford Annual Nonroad CO Source Emissions, 2008

................................ ...... 58 Figure 16: Distribution of Medford CO Season Day Nonroad Source Emissions, 2008

.............................. 59 Figure 17: Percentage of Medford UGB CO Season Day Nonroad Source Emission, 2008

........................ 59

Appendix A, Figure A

- 1: 2008 Medford CO LMP Permitted Point Source Locations

................................ . 86

Append ix B, Figure B

- 1: Wildfire and Prescribed Burn Location and Date

................................ ................ 92Appendix 2

- 2015 Medford CO LMP

Page vi 

## Table of Tables

Executive Summary, Table 1 Medford UGB 2008 Estimated CO Emissions Contribution by Source Category.

................................ ................................ ................................ ................................ ....................... 2

Table 2.1: Summary of 2008 CO Emissions Data

................................ ................................ ........................ 22

Table 2.3. 1: 1993 Attainment Year Inventory List of Permitted Point Sources

................................ ......... 24 Table 2.3. 2: Medford UGB CO Season: Summary of Point Source Emissio ns by SIC

................................ . 29 Table 2.3. 3: Medford UGB CO Season, Summary of Top 5 :Point Source Emitters

................................ ... 30

Table 2.4. 1: Medford 2008 CO EI Summary of Estimation Procedures for Area Sources

......................... 41 Table 2.4. 2: Medford 2008 CO EI Summary of Emissions Estimates for Area Sources

............................. 41
Table 2.4. 3: Area Source Emissions From Fuel Oil Use

................................ ................................ .............. 42 Table 2.4. 4: Area Source Emissions From Natural Gas (NG) Use

................................ ............................... 43 Table 2.4. 5: Area Source Emissions From Liquified Petroleum Gas (LPG) Use

................................ .......... 45
Table 2.4. 6: Area Source Emissions From Residential Wood Combustion

................................ ................ 47
Table 2.4. 7 : Area Source Emissions From Wildfires

................................ ................................ ................... 48 Table 2.4. 8: Area Source Emissions From Prescribed (RX) Burning

................................ ........................... 49
Table 2.4. 9: Area Source Emissions From Structure Fires

................................ ................................ ......... 50 Table 2.4. 10: Area Source Emissions From Residential Open Burning

................................ ...................... 5 1 Table 2.4. 11: Area Source Emissions From Industrial Open Burning

................................ ......................... 52
Table 2.4. 12: Area Source Emissions From Commercial/Institutional Open BUrning

............................... 52
Table 2.4. 13: Area Source Emissions From Coal Use

................................ ................................ ................. 53 Table 2.4. 14: Area Source Emissions From Biomass Burning

................................ ................................ ... 54

Table 2.5. 1: Medford UGB 2008 CO Summary of Emissions from Nonroad Sources

................................ 60 Table 2.5. 2: Medford UGB 2008 CO, Summary of Emissions from Nonroad Gasoline Vehicles * Equipment, 2

- Cycle

................................ ................................ ................................ ................................ ..... 61 Table 2. 5. 3. 2008 Medford UGB CO: Summary of Emissions from Nonroad Gasoline Vehicles and Equipment, 4

- Cycle

................................ ................................ ................................ ................................ ..... 63
Tabl e 2. 5. 4. 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG/LPG Vehicles and Equipment

................................ ................................ ................................ ................................ ................... 65
Table 2. 5. 5. 2008 Medford UG B CO: Summary of Emissions from Nonroad Diesel Vehicles and Equipment

................................ ................................ ................................ ................................ ................... 67 Table 2.5. 6. 2008 Medford UGB CO: Summary of Emissions from Aircraft and Airport GSE

.................... 69 Table 2.5. 7. 2008 Medford UGB CO: Summary of Emissions from Railroads

................................ ............ 71

Table 2.6. 1. 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Vehicle Type

.............. 75 Table 2.6. 2. 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Road Type

.................. 77

Appendix A, Table A

- 1: Stationary Point Source Determination for 2008 CO Inventory

.......................... 87 Appendix A, Table A

- 2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory

........... 87 Appendix A, Table A

- 3: Stationary Point Source Emission Estimation Details

................................ ........... 89

Appendix B, Table B

- 1: GIS Allocation Results: Josephine County Zones, County

- Wide and by UGB

...... 93Appendix 2

- 2015 Medford CO LMP

Page ii 

## 1 Executive Summary

The Medford Carbon Monoxide (CO) Maintenance Area has met the National Ambient Air Quality Standards (NAAQS) for carbon monoxide. In accordance with the 1990 Federal Clean Air Act Amendments, the area has been redesignated to attainment status through the development of a Redesignation Request / Maintenance Plan. Th is limited maintenance plan inventory is for 2008, and is provided as part of the maintenance plan package to show compliance with published EPA requirements. The principal components for development and
documentation that have been addressed in this inven tory include stationary point sources, stationary area sources, non

- road sources, on

- road mobile sources, quality assurance implementation, and emissions summaries. The geographic focus for this 2008 emission inventory is the Medford CO Maintenance Area, which is defined as the Medford Urban Growth Boundary (UGB).

The following table summarizes contributions by source category for annual and seasonal CO
emissions within the Medford UGB for 2008.

Executive Summary, Table 1 Medford UGB 2008 Estimated CO Emissions Contribution by Source Category.



### Annual CO Season

Source Type tpy % of Category lbs/day % of Category

Stationary Point Sources 2,376.1 15% 13,159 16%
Stationary Area Sources 3,333.1 21% 30,399 37%

Non

- Road Mobile Sources 4,488.2 28% 10,061 12%

On

- Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%

During the average CO season 2008 day, on

- road mobile sources contribute 35% of the total
carbon monoxide (CO) air emissions in the Medford UGB. Gasoline vehicles contribute 97% of
the CO emissions within the on

- road mobile category, whereas diesel vehicles contribute 3% of
the on

- road mobile category.

Stationary area sources comprise 37% of the total CO air emissions in the Medford UGB on a CO season day. Within the area source category, residential wood combustion accounts for 49% of
the emissions. Wood combustion in non

- certified woodstoves and inserts accounts for 28% ofAppendix 2

- 2015 Medford CO LMP

Page 2 the total area source emissions. Prescribed burning accounts for 47% of the total area source emissions on a CO season day.

Non

- road mobile sources contribute 12% of the total CO on an average winter day. Within this category, 4

- cycle engines comprise 79% of the total emissions.

Permit ted stationary point sources comprise 16% of the CO air emissions in the Medford UGB on an average CO season day. This category includes permitted stationary sources with both federal TV and state ACDP permits. There are 37 point sources within the Medfo rd UGB and a

25

- mile buffer zone around the UGB.

Emissions summaries for CO have decreased for both annual and season day as compared to the 1993 attainment year EI. Emissions have decreased 24% annually, and 27% for a season day as compared to the 1993 attainment year EI.

Details of the Oregon 2008 Medford UGB CO Limited Maintenance Plan Emission Inventory from point, area, non

- road, and on

- road mobile sources are presented in the following document. The relative percentage of annual and seasonal CO em issions from stationary point, stationary area, non

- road mobile, and on

- road mobile sources are shown in the Ex ecutive Summary Figures 1 through 4Appendix 2

- 2015 Medford CO LMP

Page 3 Executive Summary, Figure 1 : 2008 Medford UGB annual CO emissions, percentage by source
category

Executive Summary, Figure 2 : 2008 Medford UGB CO season day emissions, percentage by
source categoryAppendix 2

- 2015 Medford CO LMP

Page 4 Executive Summary, Figure 3 : Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008Appendix 2

- 2015 Medford CO LMP

Page 5 Executive Summary, Figure 4 : Medford UGB Season Day CO Emissions Estimates, 1993 vs.

2008Appendix 2

– 2015 Medford CO LMP

6 

## 2 Introduction

2.1 Purpose of the Report

The Clean A ir Act Amendments (CAAA) of 1990 authorized the U.S. Environmental Protection Agency (EPA) to designate nonattainment areas with respect to the National Ambient Air Quality Standards (NAAQS). Under the 1990 CAAA, pre

- enactment carbon monoxide

nonattainmen t areas were classified according to the severity of nonattainment. Each state was required to submit a list designating nonattainment areas within the state.

Oregon submitted a list of areas that were in nonattainment to EPA on 15 March 1991. The

area within the Medford Urban Growth Boundary was listed as nonattainment for carbon monoxide (Medford UGB / NAA). The nonattainment area had a design value of 7.5 parts per million (ppm) for carbon monoxide, and exceeded the NAAQS in the period 1977 through 1 991. The NAAQS limit is 9 ppm, but it must reach 9.5 ppm to be considered an exceedance. The highest recorded CO value measured in Medford was 21.8 ppm at the Brophy building site in
1977. Previous nonattainment boundaries included the entire Medford Air Quality Maintenance Area (AQMA) under former Governor Straub in 1978. Due to hot spot problems
within the downtown region of Medford in 1982, the nonattainment area was revised to include only the central business district. The nonattainment area was ag ain modified in 1992 when the Federal Register promulgated the designation of the Medford UGB / NAA as nonattainment for CO on November 30, 1992 by letter from Governor Roberts.

The emission inventory area for the Medford CO nonattainment area was delinea ted as the
Medford UGB in the Inventory Preparation Plan (IPP) submitted September 15, 1997. The Oregon CO IPP was approved by EPA Region X on June, 10, 1998 by letter from Joan Cabreza. This document fulfills the EPA requirements for preparing the limit ed maintenance plan 2008

y ear emission inventory, specified in the provisions of the 1990 CAAA, and EPA guidance
documents.



### 2.2 Inventory Time Frame and Area Covered

The 2008 limited maintenance plan inventory covers carbon monoxide emissions for the
Medford Urban Growth Boundary (UGB) maintenance area. 2008 was chosen as the bse year because it is the most recent National Emission Inventory (NEI) year for which the DEQ has PM2.5 monitoring data for the Medford area. Emissions are reported in this inventory for two representative time periods: Annual Emissions (in units of “tons per year”) and Seasonal Emissions (in units of “pounds per day”). Annual emissions represent CO e missions generated
over the 2008 Maintenance Year. Seasonal emissions represent CO em issions generated on an

avera ge day in a three

- month period

- called the CO season

- when ambient CO accumulations are typically the highest. For the Medford UGB, the CO Season is defined as the period of three
consecutive months: December through February

.Appendix 2

– 2015 Medford CO LMP Page 7 The ge ographic area of the Medford UGB is shown in Figure 1

. Figure 2 shows boundaries used for the permitted point source section of the 2008 emission inventory

. As in the 1993 attainment year inventory, a 25

- mile buffer zone is the starting point f or point source boundary
definition. The 25

- mile extension to the UGB area includes incorporated and unincorporated Jackson County and a part of Josephine County. Populated areas within the 25 mile buffer included in this inventory are Medford, Rogue Riv er, Grants Pass, and White City.

Figure 1 : Medford Urban Growth BoundaryAppendix 2

– 2015 Medford CO LMP Page 8 Figure 2 : 2008 Medford CO LMP, 25

- mile buffer and permitted point source locationsAppendix 2

– 2015 Medford CO LMP Page 9 

### 2.3 Report Contents The Report is divided into the following components :

Part 1: Introduction to the Report

Part 2: Medford CO 2008 Limited Maintenance Plan Emission Inventory

Part 3: Quality Assurance and Quality Control

Part 4: References

Part 5: Appendices

 Part 1 provides an introduction to this Report and its purpose. Contents of the Report are briefly described. Information concerning automated systems is included. Sources not
inventoried for the inventory are described along with a rationale for the exclusio ns. EPA procedure and guidance documents used in preparing the inventory are described. Finally, information on the personnel responsible for the preparation of the inventory is outlined.  Part 2 describes in detail the methodologies and approaches taken to estimate emissions in
the Medford UGB for the 2008 Limited Maintenance Plan inventory. Part 2 is divided into sections describing the inventory process and the types of emission sources that are addressed in the inventory, as follows:  Section 1.0 p rovi des maps of open burning control areas and the Medford

Ashland Air Quality Maintenance Area / Vehicle Inspection Boundary. These maps are included for consistency with the 1993 Medford CO Attainment

Year I nventory . This section also provides legal descri ptions of the inventory and open burning control areas, as well as the AQMA/VIP boundary.

 Section 2.0 contains summary tables for stationary point, stationary area,

non

- road mobile, and on

- road mo bile sources in the Medford UGB.

 Section 3.0 contains a di scussion of the stationary point source emission category methodology and emissions estimate approach. Tables summarizing point source emissions estimates follow the discussion.

 Section 4.0 addresses stationary area sources and contains a discussion of

t he approaches used in estimating emissions. Each area source category inventoried is described in detail, including the methodology used in making the calculations. Tables summarizing stationary area source emissions
estimates follow the discussion.

 Section 5.0 provides a discussion of the approach and methodology used in evaluating emissions from non

- road mobile sources. Tables summarizing

non

- road mobile source emissions estimates follow the discussion.Appendix 2

– 2015 Medford CO LMP Page 10  Section 6.0 provides a description of the app roach and methodology used in evaluating emissions from on

- road mobile sources. Tables summarizing on

road mobile source emissions estimates follow the discussion.  Part 3 describes the quality assurance procedure s utilized in preparing the 2008 inventory.  Part 4 contains an extensive list of referen ces utilized for the Medford CO emission inventory.  Part 5 contains A ppendices with supplemental data used to estimate emissions.

Tables and figures for each emission category are located at the end of the di scussion section for that category. For example, summary emission tables for all stationary point source types in
the Medford UGB are located at the end of Part 2, Section 3. Please note that some references listed in the tables are numbered as ‘DEQ master references’ (See Part 5 for this classification at the end of each entry).



### 2.4 Automated Systems The inventory has been assembled by the staff of the Technical Services Section, Air Quality

Division of the Oregon Department of Environmental Quality (DEQ) , and by Sierra Research, a consulting firm specializing in air quality and pollution control . The point source emissions are specifically drawn from the DEQ Tracking Reporting and Administration of Air Contaminant Sources (TRAACS) database. The TRAACS data is used for tracking compliance with plant site emission limits and for reporting compliance status to the EPA EIS system. TRAACS is also used
to store actual emi ssion data also reported to EIS. TRAACS contains annual emission levels for each permitted point source as well as, emission factors, and annual activity levels (fuel use and production levels). Nonpoint emissions, except where indicated, were extracted from the EPA Emission Inventory Sy stem (EIS) EIS Gateway. The EPA EIS database houses National Emissions Inventory (NEI) data that includes submittals from states.



### 2.5 Sources Not Inventoried For consistency, the 1993 attainment year emission inventory was used as a reference, and all

sources in the 1993 inventory are addressed in the 2008 inventory. Calculations and methodology for sources emitting 0 emissions during a typical CO season day are included in the 2008 inventory as well.



### 2.6 Guidance Documents For consistency, DEQ and Sierra followed the format and outline of the 1993 Medford UGB CO Attainment Year Emission Inventory 1

. For those sources inventoried by DEQ, inventory methodology followed applicable EPA procedure and guidance documents. Two primary
documents utilized were Procedures fo r the Preparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone, Volume I 3 , and Emission Inventory Requirements for Carbon Monoxide State Implementation Plans 2

.Appendix 2

– 2015 Medford CO LMP Page 11 

### 2.7 Contact Personnel Due to existing workload and staffing commitments, DEQ entered into an agreement with the Rogue Valley Council of Governments (RVCOG) and Sierra Research for assistance with the Medford CO LMP emission inventory ( please see Appendix C for the work proposal from Sierra ).

The work breakdown was as follows:

 DE Q

o Permitted point sources

o Open burning

o Wildfires and prescribed burning

 RVCOG/Sierra Research

o Small, stationary fuel combustion (non

- permitted)

o Residential wood combustion

o Structure fires

o Aircraft and airport related

o Locomotives

o Recreational marine

o Nonroad vehicles & equipment

o On

- road mobile (exhaust)

The abbreviated list of those conducting this Medford 2008 Limited Maintenance Plan emission inventory is shown below:

DEQ Wendy Wiles
Environmental Solutions Division Administrator

Jeffrey Stocum

, Air Quality Technical Services Manager Emission Inventory Christopher Swab, Senior Emission Inventory Analyst Brandy Albertson , Emission Inventory Analyst Miyoung Park , Emission Inventory Specialist Wayne Kauzlarich, ACDP Permit Writer

Dan a Bailey, Permit Coordinator Quality Assurance Wesley Risher, Emission Inventory Analyst
David Collier

, Air Quality Planning Manager

Dave Nordberg

, Air Quality Planner

Sierra Research Tom Carlson, Principal ScientistAppendix 2

– 2015 Medford CO LMP Page 12 Wenxian Zhang, Associate En gineer

Starcrest Consulting Group, LLC Wayne Elson, Air Quality Planner and Mobile Source Emissions Expert

Rogue Valley Council of Governments Dan Moore, Planning Coordinator, AICPAppendix 2

– 2015 Medford CO LMP Page 13 

## 3 Medford Carbon Monoxide Attainment Area Inventory

3.1 Inventory Area Maps and Descriptions

3.1.1 Inventory Area Maps The following maps are presented here for consistency with the Medford CO 1993 Attainment Year SIP Emissions Inventory 1 :

 Figure 1 (previous): Medford UGB Carbon Monoxide Attainment Area

 Figure 2 (previous): Medford UG B with 25

- mile point source buffer zone

 Figure 3: Open Burning Control Areas as defined in (OAR) 340

- 264

- 0078(1) and Rogue Basin Open Burning Control Area as defined in 340

- 264

- 0078(3)

 Figure 4: Woodstove Curtailment Ordinance Area / Critical PM 10 Control Area

 Figure 5: Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program BoundaryAppendix 2

– 2015 Medford CO LMP Page 14 Figure 3 : Open Burning Control Areas and Rogue Basin Open Burning Control AreaAppendix 2

– 2015 Medford CO LMP Page 15 Figure 4 : Woodsto ve Curtailment Ordinance Area / Critical PM 10 Control AreaAppendix 2

– 2015 Medford CO LMP Page 16 Figure 5 : Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program BoundaryAppendix 2

– 2015 Medford CO LMP Page 17 

### 3.1.2 Legal Descriptions

3.1.2.1 Legal Description of Medford Urban Growth Boundary / CO Inventory Area Legal description of the Medford Urban Growth Boundary Attainment Area as adopted by Oregon DEQ define the boundaries as shown in Figure 1 and can be found in the Oregon Administrat ive Rules (OAR) 340

- 204

- 0010(12):

(12) “Medfo rd UGB” means the area beginning at the line separating Range 1 West and Range 2 West at a point approximately 1/4 mile south of the northwest corner of Section 31, T36S, R1W; thence west approximately 1/2 mile; thence south to the north bank of Bear Creek ; thence west to the south bank of Bear Creek; thence south to the intersection with the Medford Corporate Boundary; thence following the Medford Corporate Boundary west and southwesterly to the intersection with Merriman Road; thence northwesterly along M erriman Road to the intersection with the eastern boundary of Section 10, T36S, R2W; thence south along said boundary line approximately 3/4 mile; thence west approximately 1/3 mile; thence south to the intersection with the Hopkins Canal; thence east alon g the Hopkins Canal approximately 200 feet; thence south to Rossanely Drive; thence east along Rossanely Drive approximately 200 feet; thence south approximately 1200 feet; thence west approximately 700 feet; thence south approximately 1400 feet; thence ea st approximately 1400 feet; thence north approximately 100 feet; thence east approximately 700 feet; thence south to Finley Lane; thence west to the end of Finley Lane; thence approximately 1200 feet; thence west approximately 1300 feet; thence north appro ximately 150 feet; thence west approximately 500 feet; thence south to Highway 238; thence west along Highway 238 approximately 250 feet; thence south approximately 1250 feet to a point even with the end of Renault Avenue to the east; thence east approxima tely 2200 feet; thence south approximately 1100 feet to a point even with Sunset Court to the east; thence east to and along Sunset Court to the first (nameless) road to the south; thence approximately 850 feet; thence west approximately 600 feet; thence s outh to Stewart Avenue; thence west along Stewart Avenue approximately 750 feet; thence south approximately 1100 feet; thence west approximately 100 feet; thence south approximately 800 feet; thence east approximately 800 feet; thence south approximately 1 000 feet; thence west approximately 350 feet to a point even with the north

- south connector street between Sunset Drive and South Stage Road; thence south to and along said connecting road and continuing along South Stage Road to Fairlane Road; thence sout h to the end of Fairlane Road and extending beyond it approximately 250 feet; thence east approximately 250 feet; thence south approximately 250 feet to the intersection with Judy Way; thence east on Judy Way to Griffin Creek Road; thence north on Griffin Creek Road to South Stage Road; thence east on South Stage Road to Orchard Home Drive; thence north on Orchard Home Drive approximately 800 feet; thence east to Columbus Avenue; thence south along Columbus Avenue to South Stage Road; thence east along Sout h Stage Road to the first road to the north after Sunnyview Lane; thence north approximately 300 feet; thence east approximately 300 feet; thence north approximately 700 feet; thence east to King’s Highway; thence north along King’s Highway to Experiment

S tation Road; thence east along Experiment Station Road to Marsh Lane; thence east along Marsh Lane to the northern boundary of Section 6, T38S, R1W; thence east along said boundary approximately 1100 feet; thence north approximately 1200 feet; thence east approximately 1/3 mile; thence north approximately 400 feet; thence east approximately 1000 feet to a drainage ditch; thence following the drainage ditch southeasterly approximately 500 feet; thence east to the eastern boundary of Section 31, T37S, R1W; th ence south along said boundary approximately 1900 feet; thence east to and along the loop off of Rogue Valley Boulevard, following that loop to the Southern Pacific Railroad Line (SPRR); thence following SPRR approximately 500 feet; thence south to South S tage Road; thence east along South Stage Road to SPRR; thence southeasterly along SPRR to the intersection with the west fork of Bear Creek; thence northeasterly along the west fork of Bear Creek to the intersection with U.S. Highway 99; thence southeaster ly along U.S. Highway 99 approximately 250 feet; thence east approximately 1600 feet; thence south to East Glenwood Road; thence east along East Glenwood Road approximately 1250 feet; thence north approximately 1/2 mile; thence west approximately 250 feet; thence north approximately 1/2 mile to the Medford City Limits; thence east along the city limits to Phoenix Road; thence south along Phoenix Road to Coal Mine Road; thence east along Coal Mine Road approximately 9/10 mile to the western boundary of Secti on 35, T37S, R1W; thence north to the midpoint of the western boundary of Section 35, T37S, R1W; thence west approximately 800 feet; thence north approximately 1700 feet to the intersection with Barnett Road; thence easterly along Barnett Road to the south east corner of Section 27, T37S, R1W; thence northAppendix 2

– 2015 Medford CO LMP Page 18 along the eastern boundary line of said section approximately 1/2 mile to the intersection with the 1800 foot contour line; thence east to the intersection with Cherry Lane; thence following Cherry Lane so utheasterly and then northerly to the intersection with Hillcrest Road; thence east along Hillcrest Road to the southeast corner of Section 23, T37S, R1W; thence north to the northeast corner of Section 23, T37S, R1W; thence west to the midpoint of the nor thern boundary of Section 22; T37S, R1W; thence north to the midpoint of Section 15, T37S, R1W; thence west to the midpoint of the western boundary of Section 15, T37S, R1W; thence south along said boundary approximately 600 feet; thence west approximately 1200 feet; thence north approximately 600 feet; thence west to Foothill Road; thence north along Foothill Road to a point approximately 500 feet north of Butte Road; thence west approximately 300 feet; thence south approximately 250 feet; thence west on a line parallel to and approximately 250 feet north of Butte Road to the eastern boundary of Section 8, T37S, R1W; thence north approximately 2200 feet; thence west approximately 1800 feet; thence north approximately 2000 feet; thence west approximately 500 feet; thence north to Coker Butte Road; thence east along Coker Butte Road approximately 550 feet; thence north approximately 1250 feet; thence west to U.S. Highway 62; thence north approximately 3000 feet; thence east approximately 400 feet to the 1340 f oot contour line; thence north approximately 800 feet; thence west approximately 200 feet; thence north approximately 250 feet to East Vilas Road; thence east along East Vilas Road approximately 450 feet; thence north approximately 2000 feet to a point

app roximately 150 feet north of Swanson Creek; thence east approximately 600 feet; thence north approximately 850 feet; thence west approximately 750 feet; thence north approximately 650 feet; thence west approximately 2100 feet; thence on a line southeast ap proximately 600 feet; thence east approximately 450 feet; thence south approximately 1600 feet; thence west approximately 2000 feet to the continuance of the private logging road north of East Vilas Road; thence south along said logging road approximately 850 feet; thence west approximately 750 feet; thence south approximately 150 feet; thence west approximately 550 feet to Peace Lane; thence north along Peace Lane approximately 100 feet; thence west approximately 350 feet; thence north approximately 950 fe et; thence west approximately 1000 feet to the western boundary of Section 31, T36S, R1W; thence north approximately 1300 feet along said boundary to the point of beginning.

3.1.2.2 Legal Description of Open Burning Control Areas In addition to the UGB, DEQ has specific rule s that address commercial, demolition, construction an d industrial open burning. The rules are identified for densely pop ulated locations in the state, including cities over 4,000 people in population and within three miles of the corporate ci ty limits of these cities . The boundaries defined by the rules are termed O pen Burning Control Areas. The rules pertaining to the Medford area may be found

in the Oregon Administrative Rules (OAR) 340

- 264

- 0078, summarized below.

Generally, areas around the more densely populated locations in the state and valleys or basins that restrict atmospheric ventilation are designated "Open Burning Control Areas". The practice of open burning may be more restrictive in open burning control areas than in other area s of the state. The specific open burning restrictions associated with these open burning control areas are listed in OAR 340

- 264

- 0100 through 340

- 264

- 0170 by county. The open burning control areas of the state are defined as follows:

(1) All areas in or within three miles of the incorporated city limit of all cities with a population of 4,000 or more.

(3) The Rogue Basin Open Burning Control Area is located in Jackson and Josephine Counties with boundaries as generally depicted in Figure 4 Rogue Basin Op en Burning Control Area. The area is enclosed by a line beginning at a point approximately 4

- 1/2 miles NE of the City of Shady Cove at the NE corner of T34S, R1W, Willamette Meridian, thence south along the Willamette Meridian to the SW corner of T37S, R1W ; thence east to the NE corner of T38S, R1E; thence south to the SE corner of T38S, R1E; thence east to the NE corner of T39S, R2E; thence south to the SE corner of T39S, R2E; thence west to the SW corner of T39S, R1E; thence NW along a line to the NW corn er of T39S, R1W; thence west to the SW corner of T38S, R2W; thence north to the SW corner of T36S, R2W; thence west to the SW corner of T36S, R4W; thence south to the SE corner of T37S, R5W; thence west to the SW corner of T37S, R6W; thence north to the NW corner of T36S, R6W; thence east to the SW corner of T35S, R1W; thence north to the NW corner of T34S, R1W; thence east to the point of beginning

.Appendix 2

– 2015 Medford CO LMP Page 19 3.1.2.3 Legal Description of Medford Area Woodstove Curtailment Ordinance / Critical PM10
Control Area
In order to s trengthen overall woodstove strategies in the Medford AQMA, local ordinances in the Medford area were unified in 1998, resulting in a Woodstove Curtailment Ordinance Area, also known as the Critical

PM 10 Control Area. The unified ordinance applies in Jack son County, as well as the cities of Ashland, Central Point, Jacksonville, Medford, Phoenix, and Talent. The legal description is as follows:

Beginning on I

- 5 and Tolo Road, crossover north on Tolo Road to Old Hwy 99. East on Old Hwy 99 to Kirtland Road

. Northeasterly on Kirtland Road to Tablerock Road. North on Tablerock Road to the Rogue River. Northeasterly along the southern bank of the Rogue River to the mouth of Little Butte Creek. Northeasterly along Little Butte Creek to Antelope
Creek. Sout heasterly along Antelope Creek to Dry Creek. Southeasterly on Dry Creek to Hwy 140. Southwesterly on Hwy 140 to Kershaw Road. South on Kershaw Road to Corey Road. West on Corey Road to Foothill Road. South on Foothill Road to Medford Urban Growth Boun dary (UGB) (near Delta Waters Road). Follow eastern UGB south to North Phoenix
Road. South on North Phoenix Road to Phoenix UGB. Follow eastern UGB south to I

- 5. Southeasterly on I

- 5 to Talent UGB. Follow the eastern, southern, and western UGB until i ntersection with Southern Pacific Railroad Track (which became Union Pacific / Central Oregon & Pacific Railroad in 1994). Southern Pacific Railroad track north to Hartley Lane (Road). West on Hartley Lane (Road) to Talent

- Phoenix Road (Colver Road). No rth on Talent

- Phoenix Road (Colver Road) to Phoenix UGB. West along southern boundary of Phoenix UGB to Camp Baker Road. West on Camp Baker Road to Coleman Creek Road. North on Coleman Creek Road to Carpenter Hill Road. West on Carpenter Hill Road to P ioneer Road. Northwest on Pioneer Road to Griffin Creek Road. North on Griffin Creek Road to Medford UGB. North along Medford UGB to South Stage Road. West on South Stage Road to Arnold Lane. North on Arnold Lane to Jacksonville Hwy. West on Jacksonv ille Hwy to Hanley Road. Northeast on Hanley Road to Ross Lane. West on Ross Lane to Redwood Drive. South on Redwood Drive to LaPine Avenue (which becomes Wendt Road). West on LaPine Avenue (Wendt Road) to Old Stage Road. North on Old Stage Road to Ol d Military Road. North on Old Military Road to Old Stage Road. Northwest on Old Stage Road to Scenic Avenue. Northwest on Scenic Avenue to Tolo Road. North on Tolo Road to Willow Springs Road. East on Willow Springs Road to Ventura Lane. North on Ven tura Lane to I

- 5. Northwest

on I

- 5 to crossover of Tolo Road.

3.1.2.4 Legal Description of the Medford

- Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary Vehicle owners residing within the Medford

- Ashland Air Quality Maintenance Area are s ubject to DEQ vehicle inspection per OAR 340

- 256

- 0300(2) and (3). The legal description of the Medford

– Ashland air quality
maintenance area is as follows:

340

- 204

- 0010(10) “Medford

- Ashland Air Quality Maintenance Area” (AQMA) means the area defined as beginning at a point approximately two and quarter miles northeast of the town of Eagle Point, Jackson County, Oregon at the northeast corner of Section 36, Township 35 South, Range 1 West (T35S, R1W); thence South along the Willamette
Meridian to the sout heast corner of Section 25, T37S, R1W; thence southeast along a line to the southeast corner of Section 9, T39S, R2E; thence south

- southeast along line to the southeast corner of Section 22, T39S, R2E; thence South to the southeast corner of Section 27, T3 9S, R2E; thence southwest along a line to the southeast corner of Section 33, T39S, R2E; thence West to the southwest corner of Section 31, T39S, R2E; thence northwest along a line to the northwest corner of Section 36, T39S, R1E; thence West to the southw est corner of Section 26, T39S, R1E; thence northwest along a line to the southeast corner of Section 7, T39S, R1E; thence West to the southwest corner of Section 12, T39S, R1W, T39S, R1W; thence northwest along a line to southwest corner of Section 20, T3 8S, R1W; thence West to the southwest corner of Section 24, T38S, R2W; thence northwest along a line to the southwest corner of Section 4, T38S, R2W; thence West to the southwest corner of Section 6, T38S, R2W; thence northwest along a line to the southwes t corner of Section 31, T37S, R2W; thence North and East along the Rogue River to the north boundary of Section 32, T35S, R1W; thence East along a line to the point of beginning.Appendix 2

– 2015 Medford CO LMP Page 20 

### 3.2 Summary of Emissions Data Summary tables of emission data that are presen ted here include stationary point sources, stationary

area sources, non

- road mobile sources, and on

- road mobile sources. Summary emissions are expressed as
charts in Figures 6 through 8

. Table 2.1 provides a summary of the 2008 emissions estimates.

Figure 6 : Distribution of 2008 Annual CO Emissions

Figure 7 : Annual CO Emissions by PercentageAppendix 2

– 2015 Medford CO LMP Page 21 Figure 8 : Distribution of 2008 Season Day CO Emissions

Figure 9 : Season Day CO Emissions by PercentageAppendix 2

– 2015 Medford CO LMP Page 22 Table 3

. 1 : Summary of 2008 CO Emissions Data



### Annual CO Season

Source Type tpy % of Category lbs/day % of Category

Stationary Point Sources 2,376.1 15% 13,159 16%
Stationary Area Sources 3,333.1 21% 30,399 37%

Non

- Road Mobile Sources 4,488.2 28% 10,061 12%

On

- Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%Appendix 2

– 2015 Medford CO LMP Page 23 

### 3.3 Stationary Permitted Point Sources

3.3.1 Introduction The following section is an overview and summary of the 2008 CO Point Source Emission Inventory developed for the Medford CO Limited Maintenance Plan (LMP) due in 2015. The 2008 CO inventory is an update to the original 1993 Atta inment Year inventor y 1 . However , 1993 and 2008 emission results were not compared because of discrepancies caused by a significant lapse in time between inventories and the change in point source determination methodology. This inventory includes both ann ual and seasonal emission estimates that establish both short and long term CO trends from industrial sources during 200 8. This write up details the step s used to develop the 2008 Medford Point Source Emission Inventory and is a discussion of the results.



### 3.3.2 Geographic Area and Sources Included The geographic focus for this inventory is the former Medford CO nonattainment area which is the Urban Growth Boundary (UGB) for the city. The UGB is represented by the red outline above in Section 1, Figure 1 . A

25

- mi le buffer zone was also added to Medford’s UGB to include industrial sources from other cities such as White City, Central Point, Ashland, Grants Pass, and Rogue River. Section 1, Figure 2 shows the UGB and 25

- mile buffer zone as the inventory boundary.

G rants Pass industrial sources were not included in the Medford 1993 inventory because they were already
inventoried for the 1993 Grants Pass State Implementation Plan 9 . The 1993 inventory for the Grants Pass SIP was updated in July 2014. Industrial sources from Grants Pass will be included in the 2008 CO inventory for
Medford.



### 3.3.3 Point Source Determination

Point sources within the Medford UGB and 25

- mile buffer zone incl ude both industrial and non

- industrial
sources. Industrial sources are included under Part 2.3 Stationary Point Sources of this inventory and non

industrial sources are covered under Part 2.4 Stationary AREA Sources . This is a discussion on the point sour ce determination for industrial sources included in both the 1993 Attainment Year Inventory and the 2008 Point Source CO Inventory for Medford.

Point sources for the 1993 Attainment Year Inventory were defined as stationary industrial sources that
emitted more than 100 tons CO within the Medford UGB and a 25

- mile buffer zone. Smaller stationary
industrial sources that emitted less than 100 tons we re included with non

- industrial sources under Part 2.4 Stationary AREA Sources in the 1993 inventory.

Table 2.3.1 is the original list of large stationary industrial sources included in the 1993 inventory. See
Reference 618 , Appendix A, P oint Source Dat a and Table A

- 1 Individual Stationary Point Source

Determinations.Appendix 2

– 2015 Medford CO LMP Page 24 Table 2.3. 1 : 1993 Attainment Year Inventory List of Permitted Point Sources

Source
Number Source Name Permit Type CO

PSEL Current Operating

Status SIC

15

- 0004 Boise Cascade Corporation TV 2974 Active 2436

15

- 0012 U.S. Forest Industries ACDP 99 Active 2435

15

- 0014 Medite Corporation ACDP 99 Active 2436

15

- 0020 Boise Cascade Corporation TV 796 Active 2436

15

- 0025 Timber Products Company TV 237 Active 2436

15

- 0041 Dyno Polymers Incorporated ACDP 1900 Closed 2861

15

- 0048 Medford Corporation ACDP 947 Closed 2493

15

- 0058 Royal Oak Enterprises, Inc. ACDP 613 Closed 2861

15

- 0073 Medford Corporation TV 235 Active 2493

15

- 0159 Biomass One, L.P. TV 570 Active 4961

Three facilities have since closed and the other seven operated in 2008 so they were added to the 2008
Medford CO EI.

3.3.3.1 2008 Point Source Determination Point sources included in the 2008 CO Inventory are defined as stationary industrial sources that have a state or federal air operating permit and are located within the UGB and 25

- mile buffer for Medford. These stationary industrial sources would fall under one of two permit programs that DEQ administers:

 Air Contaminant Discharge Permit (ACDP) : a state operating permit for small industrial sources that emit 99 tons or less per year of any criteria pollutant, or

 Title V Permit (TV): a federal operating permit for large industrial sources that emit 100 tons or greater per year of any criteria pol lutant.

One major change for the 2008 inventory was to include ACDP sources, reported as Area Sources in 1993, with the TV sources. DEQ has better data now to estimate CO emissions from ACDP sources.

The conditions used in 1993 for point source determ ination no longer apply and so the new conditions for inclusion in the 2008 inventory are as follows:

 Sources are located within the UGB and 25

- mile buffer,

 Sources had an active ACDP or Title V permit in 2008

 Sources operated in 2008,

 Sources actually emit CO emissions

All ACDP and TV sources in Jackson and Josephine Counties were mapped using ArcGIS 10 in order to eliminate
sources located outside the UGB and 25

- mile buffer zone. The remaining ACDP and TV sources that fell within the inventory bounda ry were compared against the other conditions listed above to determine if they would
be included in the 2008 CO EI for Medford. The list was narrowed down to 28 ACDP and 9 TV sources that met
all the conditions above. Table A

- 1 is the final list of 37 sou rces by source number, name, site location, permit types, operating status, CO PSEL, and standard industrial classification codes (SIC) included in the 2008 inventory. Section 1 , Figure 2 provides the geographical locations for the Medford sources included in 2008 CO inventory.Appendix 2

– 2015 Medford CO LMP Page 25 Appendix A, Table A

- 1.1 provides a list of 37 sources that were excluded from the 2008 inventory because they did not meet one or more of the conditions listed above. Ten sources were not included because, although they had a CO PS EL in their permit, they did not actually operate equipment that emits CO. This is fairly common with General ACDPs because they list all possible emission units and processes based on a source category and assign a facility based on the type of business t hey operate. An example of this is when a source is assigned to a General permit for millwork and the emission units/processes identified in the permit are boilers, veneer dryers, kilns, cyclones, target boxes, etc. The source may only operate cyclones a nd target boxes and nothing else in the list that may emit CO emissions.

27 sources were closed sometime between 1993 and 2008; therefore, they were not included in the 2008 CO
EI for Medford



### 3.3.4 Methodology and Approach The Medford inventory was developed us ing existing TV emissions data submitted by DEQ to EPA ’s 200 8
National Emission Inventory (NEl) and by putting together estimates for ACDP sources where no data was readily available. Since ACDP sources are typically reported to the NEI as Area Sources by county and source classification, CO emission estimates needed to be calculated down to individual source levels. The following is the methodology and approach used to develop the 2008 Medford Point Source CO Emission inventory.

3.3.4.1 Data Collection
Data collec tion is necessary to gather information used to calculate both annual and seasonal e missions.
Information s uch as a source’s emission basis, activity/throughput data, operating schedules, and P lant Site Emission Limits (P SELs ) were collected for the inventory. This data w as collected from 2008 annual reports, permits, or retrieved electronically from a permitting database. Most emissions and compliance information for TV sources is already stored in DEQ’s Tracking Reporting an d Administration of Air Contaminant Sources (TRAACS) permitting database. However, some information for ACDP sources such as emission basis and
emission estimates are stored in an external database.

3.3.4.2 Emission Basis
Emission basis details the emission units and processes permitted at a source. The basis is developed by using information from emission detail sheets found in permits or permit review reports. For TV sources emission basis is organized in a workbook, a delivery mechanism for importing data into TRAACS. The workbook contains emission source and process descriptions, activity data, emission factors or other data used in estimating emissions, and potential to emit emissions used to develop Plant Site Emission Limits (PSELs). The workbook imports the emission basis into TRAACS where this information is used in preparing emission inventories. Further, the emission basis and emissions are submitted to EPA’s EIS database annually.

ACDP emission basis is collected and stored by inventory project in an MS Access database, known as Final
ACDP EI database . This database stores the same type of information as TRAACS such as the emission units/process descriptions, emission factors, and other data necessary for calculating emissions. The
information is o btained from ACDP permits and/or annual reports.

3.3.4.3 Activity Data Activity data , also called throughput, w as collected from 2008 annual reports for Title V a nd ACDP sources

. Activity data consists of fuel use, production activity, or other annual throug hput types used to estimate

emissions. Sources must fulfill permit conditions for annual reporting by submitting annual activity information, emissions factors, and emission estimates for criteria air pollutants. The activity data is used toAppendix 2

– 2015 Medford CO LMP Page 26 verify existin g emissions estimates from the reports as well as to calculate emissions not typically reported by
the sources themselves

3.3.4.4 Plant Site Emission Limits (PSELs)

PSELs were found in the DEQ TRAACS database (see Section 1.4) or permits

3.3.4.5 Annual Emissons Calculatio ns Point source annual emissions were estimated at the process level for each source. Emission basis and activity data used to estimate process level emissions were collected from ACDP and TV permits and 2008 annual reports. Below are the estimation meth odologies used to prepare TV source annual emissions for the 2008 NEI and ACDP source emissions for the Medford inventory.

3.3.4.5.1 Emissions Estimation Methodologies for TV Sources

Emissions for this inventory were estimated 1 of 2 ways using:

 emission factors, or

 Continuous Emissions Monitoring System (CEMS)

Emission factors, the most common methodology, are derived by the source and permit writer to determine PSELs and compliance. Emission factors are developed using such resources as AP

- 4 2, industry standards, or by source testing. Emission factors relate the quantity of a pollutant to its activity such as lb of pollutant per gallon of fuel oil. Emission factors may be based on assumptions or conversions not likely defined in the permit or emission detail sheets. These assumptions include capture efficiencies, control efficiencies, conversion constants, %LEL (lower explosive limit), and transfer efficiency.

Most of the CO emission estimates were developed using emission factors from p ermits and activity from 2008 annual reports. The following formula was used to estimate annual CO emissions:

2008 Annual CO Emissions (tpy) = (2008 Activity * Emission Factor)/2000 lbs/ton

Some CO emission estimates were derived via C EMS which is the mos t accurate representation of emissions at

a source. Permit conditions may require direct measurement of stack emissions and recordkeeping for reporting hourly or daily CO em itted at a facility. Emission factors and CEMS are the most common estimation

met hodologies used to develop large industrial point source emissions for the 2008 CO inventory.

3.3.4.5.2 Emissions Estimation Method o logies for ACDP Sources Emissions from ACDP sources are generally not reported as point sources to the NEI but as AREA sources at
the county

- level and source classification code (SCC). Since ACDP sources were reported on a county

- level to the 2008 NEI, emission estimates had to be developed for each individual source for this inventory. CO emission estimates were developed using emiss ion factors from permits and activity from 2008 annual reports. The following formula was used to estimate annual CO emissions:

2008 Annual CO Emissions (tpy) = (2008 Activity * Emission Factor)/2000 lbs/ton

See Appendix A, Table A

- 2 Stationary Point Source Emission Estimation Details. The table provides annual emission details down to process

- level for both ACDP and TV sources. This table includes emission unit level information such as annual activity, emission factors, and operati ng details. The 2008 annual emissions for both
ACDP and TV sources were used next to calculate seasonal emissions.Appendix 2

– 2015 Medford CO LMP Page 27 3.3.4.6 Seasonal Emissions Calculations Emissions are generally not static and fluctuate during different times of the year for various reasons such as changes in source activity or temperature. For example, CO emissions may peak during winter months in urban areas due to incomplete combustion of carbon

- based fuels (i.e. automobiles, woodstove, open

- burning, fuel combustion of industrial boilers, etc. ). The winter months of December through February is defined as the CO season, the period for which emissions are more likely to peak. The reason for this is cooler temperatures during these months prevent complete combustion of the fuel which may result in excess CO emissions trapped near the ground by atmospheric inversions.

2008 annual CO emissions were temporally allocated from annual to seasonal emissions for the CO season. Typical Season Day (TSD) emissions are average daily CO emissions calculat ed over the CO season and recorded in pounds per day (lbs/day). To complete seasonal emission estimates data components such as
annual emissions (tpy), seasonal adjustment factors, and annual activity days are required. The following is the
allo cation and development methods and data comp onents needed to calculate seasonal emissions.

3.3.4.6.1 Seasonal Adjustment Factors Seasonal Adjustment Factors ( SAF ) were calculated using temporal files of peak season activity by source classification code (SCC) from EPA’s Spars e Matrix Operator Kernal Emissions (SMOKE) modeling program. The data components from these files are used in the following equation to calculate SAF:

SAF = ((Sum of Peak Season Activity) (12 months)) / ((Annual Activity) (Peak Season Activity Months))

A n example of how this calculation works is: Use SCC 10200502, Determine the peak season months and % activity for the peak season months : Peak Season Activity Months: % Activity During Peak Season
Months

December 83 January 83 February 83
Total Annual Activity: 996 Insert information into pertinent components of SAF calculation : SAF = ((83+83+83) (12 months)) / ((996) (3 months)) = 1.00

Both ACDP and TV sources required SAFs to complete seasonal calculations

. See Appendix B, Table B

- 1 : Seasonal Adjustment Factors by SCC Used for 2008 CO Inventory.

3.3.4.6.2 Season Day Emissions Calculations Typical Season Day (TSD) emissions are average daily CO emissions calculated over the CO season (i.e.
December 1 st through end of February the following year). The foll owing data components are needed to
calculate TSD emissions:

 2008 Annual CO Emissions (AE)

 SAF

 Activity Days (AD) TSD emissions = (AE*SAF*2000 lb/ton) / (AD)Appendix 2

– 2015 Medford CO LMP Page 28 The following is an example calculation for natural gas fuel combusted in a veneer dryer. In o rder to complete the TSD calculation 2008 annual CO emissions, seasonal adjustment factor by SCC and annual activity days are needed. This formula breaks the annual emissions down to lbs/day over the CO season.

Dryer Emissions (SCC 30700716):

 AE = 140 to ns

 SAF = 1.00

 AD = 365 days/yr

TSD Emissions = (140*1.00*2000) / (365) = 767 lbs/day

TSD emission calculations were performed for all 37 ACDP and TV sources. TSD emission estimates for TV and
ACDP sources cannot be calculated nor stored in TRAACS. TV an d ACDP seasonal emissions were calculated and
housed in MS Access Final _SIP_MP_PSD_EITool database. Appendix A, Table A

- 2 Stationary Point Source Emission Estimation Details also provides TSD emission estimates down to the process

- level for both ACDP
and TV sources.Appendix 2

– 2015 Medford CO LMP Page 29 

### 3.3.5 Summary of Stationary Point Source Emissions Inventory results were organized into tables summarizing 2008 annual and seasonal CO emissions by source industrial classification (SIC) and at source and process levels. Appendix C, Tables 2.3.1, 2.3.2, and 2.3.3 summarize stationary point source CO emissions for the 2008 Medford inventory. See Figures 8 through 11 for how stationary point source annual and season day emissions are distribut ed amongst the other source categories of the inventory

.

Total 2008 annual and seasonal CO emissions for industrial sources located within the Medford UGB and 25

- mile buffer are 2,376.1 tons per year and 13,159 lbs per day, respectively. The major industries permitted in Medford and the surrounding cities are wood products manufacturing, concrete production, steam supply for operating processes or heating dwellings, sewer systems, crematories, and landfills.

Table 2.3.2 summarizes 2008 CO annual and seasonal emissions by SIC for the Medford UGB and 25

- mile buffer area. The table reveals three industrial classifications that contribute over 96% of total point source CO

emissions in 2008.

Table 2.3. 2 : Medford UGB CO Season: Summary of Point Source Emissions by SIC

(1) (2)

CO Emissions

SIC
Code SIC Name Annual and TSD

Emissions

tpy lbs/day

2048 OTHER PREPARED FEEDS 0.1 1

2421 SAWMILLS AND PLANING MILLS 2.4 20

2431 MILLWORK 1.2 9

2434 WOOD KITCHEN CABINETS 0.2 1

2435 HARDWOOD VENEER AND PLYWOOD 22.4 123

2436 SOFTWOOD VENEER AND PLYWOOD 1803.6 9943

2439 STRUCTURAL WOOD MEMBERS 0.3 2

2493 RECONSTITUTED WOOD PRODUCTS 36.3 207

2951 PAVING MIXTURES AND BLOCKS 12.3 74

3272 OTHER CONCRETE PRODUCTS 5.2 37

3861 PHOTOGRAPHIC EQUIPMENT & SUPPLY 3.8 21

4952 SEWERAGE SYSTEMS 10.7 59

4953 REFUSE SYSTEMS 211.1 1160

4961 STEAM SUPPLY 266.6 1501

Pollutant Total 2376.1 13159

Softwood veneer and plywood (SIC 2436) contributes 75.9% while steam supply (SIC 4961) and refuse systems (SIC 4953) only emit 11.2% and 8% of total CO emissions, respectively. This leaves a wide margin between softwood veneer and plywood products manufact uring and other industrial classifications.

Further evaluation required identification of sources in each SIC. Table 2.3.3 in Appendix C, is a list of sources
with annual and seasonal CO emissions for each SIC

. This table reveals which sources are cont ributingAppendix 2

– 2015 Medford CO LMP Page 30 significantly to CO emissions in the three primary SIC’s listed above. A 100 tpy annual emissions cut

- off was applied to these sources to determine the top emitters of CO emissions for this inventory.

Table 2.3.3 list s five sources that contribute the most CO emissions within the Medford UGB and 25

- mile
buffer . These five sources emit together 88% of the total annual and seasonal CO emissions. Boise Cascade Wood Products, L.L.C. (15

- 0004) produces over half the 2008 CO emissions out of t he five sources. CO emissions for these sources occur because of fuel combustion activities such as the operation of boilers, landfill engines, and veneer dryers. All other source contributions to 2008 annual and seasonal CO emissions
are considered minim al.

Table 2.3. 3 : Medford UGB CO Season, Summary of Top 5 :Point Source Emitters

(1) (2)

CO Emissions

Emission

Year SIC

Code Source
Number Source Name Annual

Emissions Typical

Season Day
tpy lbs /day

2008 2436 15

- 0004 Boise Cascade Wood Products, L.L.C. 1087.6 5943

2008 2436 15

- 0020 Boise Cascade Wood Products, L.L.C. 513.1 2812

2008 4961 15

- 0159 Biomass One, L.P. 232.7 1278

2008 4953 15

- 0026 Dry Creek Landfill, Inc. 162.6 891

2008 2436 17

- 0030 TP Grants Pass, LLC 111.4 598
Pollutant Total 2,107.4 11,521 (1) And (2), see Appendix A, Table A

- 2

In summation, wood product companies (Boise Cascade (15

- 0004) and (15

- 0020)) and TP Grants Pass L.L.C (17

- 0030) account for 81% of total CO emissions during 2008. Biomass One, L.P. (15

- 0159) and Dry Creek Landfill (15

- 0026) only account for 19% of t he industrial source CO emissions in 2008. These sources contributed 2107.4 tpy out of 2376.1 tpy and 11521 lbs/day out of 13159 lbs/day over the CO season. All
these sources are still in operation today.



### 3.3.6 Control Efficiency (CE) and Rule Effectiveness (RE) EPA requires control efficiency and rule effectiveness to be calculated for SIPs. According to EPA’s Air Emissions Reporting Requirements (AERR) rule (40 CFR Part 51) these concepts are defined as:

 Control Efficiency (CE): the capture and reduction efficiency of primary control devices

 Rule effectiveness (RE): a generic term for identifying and estimating the uncertainties in emission

contr ol programs. Rule effectiveness adjusts the control efficiency from what could be realized under ideal conditions to what is actually emitted in practice due to less than ideal conditions. It is a measure of the extent to which a rule actually achieves it s desired emission reductions.

The 1993 baseline control efficiencies were zero and rule effectiveness did not apply because no CO controls were installed back then for any source. No controls for CO have been installed since 1993 for any source;
there fore, control efficiency and rule effectiveness also do not apply in the 2008 inventory.Appendix 2

– 2015 Medford CO LMP Page 31 

### 3.4 Stationary Nonpoint (Area) Sources

3.4.1 Introduction and Scope This section describes the development of the emissions inventory for carbon monoxide for stationary are a sources located in the Medford UGB in 2008. Area sources included in this inventory are stationary and collectively represent relatively small and numerous individual sources within the inventory area. Included in

t he area source category are three grou ps of distinct area source emission contributors: Waste disposal, treatment and recovery (including residential, industrial, and commercial open burning); Small stationary fuel and wood use (including residential, industrial, and commercial combustion); an d Miscellaneous (forest fires, structural fires, and slash burning). A fourth group of sources, small permitted point sources, originally included in the 1993 attainment year inventory, are included in the permitted point source inventory (Section 2.3) fo r this emission inventory.

All tables referred to in this section of the report are shown at the end of the section.

Table 2.4.1 lists the procedures used to develop the emission estimates for the various categories of area
source CO emissions included in the Medford UGB inventory. Estimated area source emissions represented in this inventory occur on an average weekday during the three

- month CO season of January 1 through February 28, and Dec ember 1through December 31, 2008.

Stationary area sources are currently referred to as nonpoint sources by EPA, however the term area sources is used in this document for consistency with the 1993 attainment year EI.



### 3.4.2 Methodology and Approach

3.4.2.1 Source Category Identificat ion and General Methodology Overview
Discussion of guidance documents and broad methodology used to calculate stationary area source emissions can be found in Part I. The list of stationary area sources included in the inventory was based on the EPA

Proce dures Document 3 and the Emissions Inventory Requirements for CO 1 . These area sources were compared to sources evaluated in the 1993 Attainment Year CO SIP Emission Inventory 618 , and the annual inventory of point source categories.

The starting point for emissions estimates for many area source categories was the EPA 2008 National Emission Inventory

. All data from the 2008 NEI was retrieved from the EPA EIS Gateway (See Part 1, Section 1.4 of this report). The 2008 NEI CO emissions estimates consist of d ata generated by both DEQ and EPA, depending upon source category. The DEQ data for specific categories, such as Residential Wood Combustion, were submitted to EPA through the EIS CERS XML process as required by the Air Emissions Reporting Rule (AERR). D ata and documentation for the 2008 NEI may be found at the following website: http://www.epa.gov/ttnchie1/net/2008inventory.html

For DEQ generated emission estimates, emission factors were taken from the EPA Procedures Document 2 , the
FIRE Version 5 SCC’s and Emission Factors 10 , the Compilation of Air Pollution Emission Factors (AP

- 42) 11

, various EPA Surveys, and local studies conducted by the Oregon Department of Environmental Quality or

en vironmental consulting firms. Errors in estimated emissions could occur in the multiplier values used, in the accuracy of calculations, or in mistakes in the construction of equations. Therefore, estimated emissions were checked for reasonableness by a n umber of approaches: 1) using alternative multiplier values when possible;Appendix 2

– 2015 Medford CO LMP Page 32 2) comparing estimates with the results of earlier area source inventories; and 3) performing independent checks on the accuracy of the multiplier values, the methodologies, and the emission calculations.

Seasonal activity factors were taken from the EPA Procedures Document 2 or were derived by DEQ and based upon season specific activity levels following guidelines in the Procedures Document

. All sources were considered to be uncontrolled with the exception of open burning; for details on how controls were incorporated into the open burning categories, please see Section 2.4.3.1.2 and associated tables.

3.4.2.2 Reconciliation with Point Source Emissions (double count prevention) Double counted emissions were removed from area source fuel combustion emissions by subtracting emissions from point source fuel burning processes, broken down by the specific type of fuel, as shown in Appendix A, Table A

- 2. However, point source emissions to be removed were selected with the following two
parameters:

 ACDP source emissions only, since the 2008 TV source double

- count was resolved by the DEQ for the
2008 NEI submittal.

 Jackson County sources only, excluding those sources inventoried in the Grants Pass area, since area sources inventoried were for the Medford UGB only



### 3.4.3 Discussion of Area Source Categories Each of the major area source categories is comprised of area source types. Detailed descriptions of the

emission estimation met hodology for each source type are included in Tables 2.4.3 through 2.4.14 and in Appendix B . The applicable appendix table number is included in the annotations, which accompany the summary table. Discussion of data sources, emissi on factors, seasonal adjustment factors, and activity levels which affect the area source are included for each area source type. Applicable state regulations affecting a specific area source emission category are included in the notes on each category sum mary table. If specific area source type emissions were affected by state regulations during the inventory year, control efficiency, rule effectiveness, and rule penetration have been applied 1,3 . Example calculations for emissions estimates
are included on individual spreadsheets. The following sections describe these major categories; subsections corresponding to individual area source types are included.

Summary charts and tables, along with emissions estimates tables by category, are shown following this

section.

3.4.3.1 Waste Disposal, Treatment and Recovery This category includes disposal, treatment, recovery and clean up of solid and liquid wastes by incineration and open burning.

3.4.3.1.1 Incineration This category consists of the disposal of solid waste, infectio us waste, or crematory incinerator waste from industrial and commercial/institutional sources by combustion. Combustion occurs in a structure or furnace for the purpose of reduction in volume or weight of the waste material.

3.4.3.1.1.1 Industrial Incineration
The Me dford UGB does not contain any industrial incineration sources and as such this category has not been
inventoriedAppendix 2

– 2015 Medford CO LMP Page 33 3.4.3.1.1.2 Commercial/Institutional Incineration
The 1993 attainment year emission inventory considered this category (given as “Commercial/Instititional On

Site Incineration) as an Area source

. In 2008 this category was treated under point sources; Please see Part 2.3 of this document for point source methodology.

3.4.3.1.1.3 Residential Incineration
Residential on

- site solid waste incineration activity is assumed to be zero. DEQ rules outlining structural requirements, source tests, and continuous emission monitoring, as well as associated permit costs, preclude individual residential construction of incineration devices. Destruction of solid waste and yard debris at residential sites is included in residential open burning calculations.

3.4.3.1.2 Open Burning This category includes waste material disposal from industrial, commercial / institutional, and residential sources in open outdoor fires, burn barrels or incinerators which do not meet DEQ emission limits, or burn in a manner in which combustion air is not effectively controlled and combustion products do not vent through a stack or chimney.

3.4.3.1.2.1 Industrial Open Burning Industrial open burning is prohibited in the Medford UG B except by special letter permit issued by DEQ’s Western Region Office. No industrial open burning was permitted within the Medford UGB in 200 8 945, 946

. Industrial Open Burning emissions estimates are detailed in Table 2.4.11.

3.4.3.1.2.2 Commercial/Institutional Open Burning This category is specific to the clearing of land for new construction and the burning of organic material (i.e. trees, shrubs and other vegetation). Jackson County Commercial and Institutional Open Burning emissions are
from the EPA 2008 Nat ional Emissions Inventory (NEI) database. Using Jackson County land use zoning acreage, GIS allocations were created to approximate both the location and magnitude of emissions, see Appendix B, Table B

- 1. Annual CO Medford UGB Emissions were estimated by multiplying the county emissions by the GIS allocation (%) for the appropriate land use zoning classification (ID #8: Commercial Lawn & Garden: Commercial Zones).

Burn permits and complaints were provided by the DEQ Medford office 12,14 and City of Medfor d Fire

District 13,15 , and b urn days and type of burn were based on the information.

L atitude and longitude data obtain from the permits were used in Google earth to determine which burn
locations were inside the UGB area. Figure 10 shows all commercial open burning location from permits and complaints within Medford UGB area.Appendix 2

– 2015 Medford CO LMP Page 34 Figure 10 : 2008 Commercial Open Burning Locations

There were no CO emission in the CO season because there were no permitted com mercial burns and no record of illegal burns.

3.4.3.1.2.3 Residential Open Burning (back yard burning) Residential open burning includes the outdoor burning of wood, leaves, land clearing debris, and household

waste. Household waste often referred to as residential m unicipal solid waste (MSW), is a term for nonhazardous refuse produced by households (e.g. paper, plastics, metals, wood, glass, rubber, leather, textiles, and food wastes).

Jackson County residential open burning emissions are from the EPA 20 08 Nat ional Emissions Inventory (NEI)
database. Using J ackson County land use zoning acreage, GIS allocations were created to approximate both the location and magnitude of emissions, see Appendix B , Table B

- 1. Annual CO Medford UGB emissions were estimated by multiplying the county emissions by the GIS a llocation (%) for the appropriate land use zoning classification ( ID # 9 : Residential Lawn & Garden: Residential Zoning )

.

Burn permits and complaints were provided by the DEQ Medford office 12,14 and City of Medford Fire District

13,15 , and b urn days and type of burn were based on the information.

L atitude and longitude data obtain from the permits were used in Google earth to determine which burn
locations were inside the UGB area. Figure 11 shows all residential open burning location from permits and complaints within Medford UGB area.Appendix 2

– 2015 Medford CO LMP Page 35 Figure 11 : 2008 Residential Open Burning Locations

Weekly activity values use based on EPA’s document 16

. Open burning can be expe cted to take place seven days a week. Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by the Seasonal Adjustment Factor (SAF)

, which include s burning complain ts (violations record) and permitted burning during peak Season and total burning days annual activity , divided by activity days per week, multiplied by 52 weeks per year using the following formula:

CO Typical Season Day (lbs/day) = (Annual UGB Emissions (tons/year) *2000 (lb/ton)* SAF)/ (Activity (days/wk)

* 52 (wk/year))

Residential Open Burning emissions estimates are detailed in Table 2.4.10

3.4.3.2 Small Stationary Fossil Fuel and Wood Use This category includes small furnaces, heaters, heating units, and cooking devices that emit fewer than 100

tons of CO per year. Four main types of fuel are used within the Medford UGB by industrial, commercial/institutional, and residential sources: fuel oils, natural gas, liquefied petroleum gas (LPG), and
wood. Wood fuel use is evaluated only for residential sources

, where wood use is primarily in fireplaces, wood stoves, furnaces , and for cooking; fossil fuel use by residential sources is evaluated for space heating or cooking purposes only. U se of these fuels by industrial and commercial sources for other purposes is included in the point source inventory.

3.4.3.2.1 Fuel Oil Combustion

F uel oil emissions from industrial/commercial/institutional sources are from fuel consumption in large or small boilers, furnaces, heaters, and other heating devices. Residential fuel oil em ission sources are primarily from fuel consumption in furnaces, heaters, and other heating devices

. For this inventory, industr ial andAppendix 2

– 2015 Medford CO LMP Page 36 commercial fuel oil use includes residual oil, distillate oil, and kerosene use; residential fuel oil consumption includes distillate and kerosene use only.

Jackson County emissions for fuel oil combustion a re from the EPA 2008 NEI database . Since industrial and
commercial fue l use emissions were not inventoried in the 2008 NEI, the respective 2011 NEI emissions were
used. EPA county

- wide industrial and commercial emissions were allocated to the Medford UGB using the 2008 employee population data from the US Census Bureau and developing a ratio of UGB employees to county employees

. The 2008 US Census employee population was downloaded from the following location: http://www.census.gov/econ/cbp/index.html

. Two zip code s were used to represent the Medford UGB:
97501 and 97504

. The residential emissions were allocated to the UGB by a ratio of the 2010 Medford UGB population to the county

- wide population

. The Medford UGB population was determined by mapping the

census blocks with population and housing unit counts to the Medford UGB boundary using the GIS spatial analysis tool. The census block data with population and housing unit counts are from the 2010 Tiger/Line shapefiles. This type of shapefile is released ever y 10 years, so the 2010 shapefile was selected as the closest to year 2008. The following formula was used for spatial allocation :

Annual UGB emissions, tpy = Annual Jackson County Emissio ns (tons/year) * (UGB employee or population / Jackson County empl oyee or population )

The employee data were used to allocate industrial and commercial fuel use, and the population data were
used to allocate residential fuel use. Weekly activity and the SAF were taken from the 1993 EI

. 3 Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF, divided by activity days per week, multiplied by 52 weeks per year, using the following formula.

CO Typical Season Day Emission (lbs/day) = (Annual UG B Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (Activity (days/wk) *52 ( weeks/yr))

Area source fuel combustion emissions were reconciled with permitted point source emissions by subtracting emissions from point source fuel burning processes, broken down b y the specific type of fuel, as shown in Appendix A, Table A

- 2. However, point source emissions to be removed were selected with the following two
parameters:

 ACDP source emissions only, since the 2008 TV source double

- count was resolved by the DEQ for the
2008 NEI submittal.

 Jackson County sources only, excluding those sources inventoried in the Grants Pass area, since area sources inventoried were for the Medford UGB only

Fuel Oil Combustion emissions estimates are detailed in Table 2.4.3.

3.4.3.2.2 Natural Gas (N G) and Liquified Petroleum Gas (LPG) Natural Gas (NG) and Liquefied Petroleum Gas (LPG) emissions from industrial and commercial sources are from fuel consumption in large or small boilers, furnaces, heaters, and other heating devices. Residential NG/LPG emission sources are primarily from fuel consumption in furnaces, heaters, and other heating devices.

Jackson County emissions for NG and LPG were first extracted from the EPA 2008 NEI database . Since industrial and commercial NG/LPG use emissions were not inventoried in the 2008 NEI, the respective 2011
NEI emissions were used. EPA county

- wide industrial and commercial emissions were allocated to the Medford UGB using the 2008 employee popula tion data from the US Census Bureau and developing a ratio ofAppendix 2

– 2015 Medford CO LMP Page 37 UGB employees to county employees

. The residential emissions were allocated to the UGB by the ratio of the 2010 Medford UGB population data divided by the county

- wide population

. The UGB popul ation was determined using the same method and data described in section 2.4.3.3.1

. The following formula was used for spatial allocation:

Annual UGB emissions, tpy = (Annual Jackson County Emissions (tons/year)) * (UGB employee or population /
Jackson C ounty employee or population )

The employee data were used to allocate industrial and commercial NG/LPG use, and the population data were used to allocate residential NG/LPG use. Typical Season Day emissions were calculated by multiplying
the UGB annual e missions tons by the SAF , divided by activity days per week, and multiplied by 52 weeks per year. Weekly activity and SAFs were taken from the 1993 EI

. 3

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ ( Activity (days/wk) *52 ( weeks/yr))

Area source fuel combustion emissions were reconciled with permitted point source emissions by subtracting emissions from point source fuel burning processes, broken down by the specific type of fuel, as shown in Appendi x A, Table A

- 2. However, point source emissions to be removed were selected with the following two
parameters:

 ACDP source emissions only, since the 2008 TV source double

- count was resolved by the DEQ for the
2008 NEI submittal.

 Jackson County sources only , excluding those sources inventoried in the Grants Pass area, since area sources inventoried were for the Medford UGB only

NG and LPG emission estimates are detailed in Table 2.4.4 and Table 2.4.5

.

3.4.3.2.3 Coal and Biomass Combustion Jackson County emissions for coal and biomass were extracted from the EPA 2011 NEI since they were not
inventoried in the 2008 NEI. EPA county

- wide industrial and commercial emissions were allocated to the Medford UGB using the 2008 employee population da ta from the US Census Bureau and developing a ratio of UGB employees to county employees

. The following formula was used for spatial allocation:

Annual UGB emissions, tpy = (Annual Jackson County Emissions (tons/year)) * (UGB employee / Jackson County em ployee )

The employee data were used to allocate industrial and commercial coal and biomass use. Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF , divided by activity days per week, and multiplied by 52 weeks per year. Weekly activity and SAFs were not provided in the 1993 EI 3 , so the same values as the fuel oil use were used.

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (Activity (days/wk) *52 ( wee ks/yr))

Coal and biomass emission estimates are detailed in Table 2.4. 1 4 and Table 2.4. 1 5

.Appendix 2

– 2015 Medford CO LMP Page 38 3.4.3.3 Residential Wood Combustion Wood is an important residential space

- heating source in Oregon. As a heating source, wood contributes a significant percentage of pollutants to an airshed when compared to fuel oil and NG/LPG. Because the CO season in Medford occurs during the winter mo nths when residential wood combustion is at its height, emissions from residential wood burning are considered , and have been estimated, to be significant in the

U GB

.

Jackson County emissions for Residential Wood Combustion were extracted from the EPA 2008 NEI database. Annual UGB emissions were estimated by multiplying county

- wide emissions by the ratio of the UGB population to county population

. The UGB population was determined using the same method and data
described in section 2.4.3.3.1

. The fol lowing formula is used for spatial allocation:

Annual UGB emissions, tpy = Annual Jackson County Emissions (tons/year) * (UGB population / Jackson County population)

Typical season day emissions were calculated by multiplying the UGB annual emissions ton s by the SAF

, divided by activity days per week, and multiplied by 52 weeks per year. The SAFs were obtained from the

1993 EI

. 1 Weekly activity is 7 days per week based on the need for heating from this fuel source, which is
consistent with the 1993 EI

. 1

Residential Wood Combustion emissions estimates are detailed in Table 2.4.6

.

3.4.3.4 Miscellaneous Area Sources
The area sources described in this section are combustion sources and include forest wildfires, prescribed burning, and structural fires.

3.4.3.4.1 Forest Wildfi res DEQ staff analyzed EPA 2008 NEI fire event data 17

, to determine wildfire emissions for the Medford UGB and a

10

- mile buffer around the UGB. The 10

- mile buffer was chosen because it captured most of the northern valleys in the area that might drain towards Medford. Since EPA NEI fire event emission data is specific to date, direct estimation of annual and seasonal emissions is possible without relying on an SAF from other reference sources. Seasonal emissions were determined to be 0 lbs/day. Fores t wild fire emissions estimates
and references are detailed in Table 2.4.7.

3.4.3.4.2 Prescribed Burning By definition, “prescribed burning ” means forest debris or woody vegetation to be burned under the Oregon Smoke Management Plan administered by the Oregon Depart ment of Forestry pursuant to OAR 477.515. To estimate prescribed burning emissions, DEQ staff analyzed EPA 2008 NEI fire event data 17

, for the Medford
UGB and a 10

- mile buffer around the UGB. The 10

- mile buffer was chosen because it captured most of the

n orthern valleys in the area that might drain towards Medford . Since EPA NEI fire event emission data is specific to date, direct estimation of annual and seasonal emissions is possible without relying on an SAF from
other reference sources.

Use of the EPA data resulted in a significant increase in prescribed burning emissions estimates

- two orders of magnitude larger than the estimate for the 1993 attainment year plan. However, emission inventory staff for the attainment year plan did not have access to the considerably more exact prescribed burning data currently available from EPA for 2008. Prescribed burning emission estimates and details are found in Table 2.4.8

.Appendix 2

– 2015 Medford CO LMP Page 39 3.4.3.4.3 Structure Fires Josephine County s tructure f ires emissions are from DEQ’s 2008 county

- wide emissions submitted to the EPA National Emissions Inventory (NEI).

Annual CO Medford UGB e missions are estimated by multiplying county

- wide emissions by the ratio of the

2008 UGB population to county population ( population data taken from the US Cen sus Bureau ) using the following formula:

Annual UGB emissions, tpy = UGB Emissions (tons/year) * (UGB population / Josephine county population) The Seasonal Adjustment Factors (SAF) was estimated from Oregon Fire Marshal data specific to Medford. Weekly activity are taken from the EPA procedures document 2

. Typical Season Day emissions were calculated by multiplying the UGB annual emission tons by the SAF, divided by activity days per week, multiplied by 52 weeks per year using the following formula:

CO T ypical Day Emissions (lb/day) = (Annual UGB Emissions (tons/year) *2000 ( lb/ton ) * SAF)/ (Activity (days/wk) * 52 (wk/year))

Structure Fires emissions estimates are detailed in Table 2.4.9.Appendix 2

– 2015 Medford CO LMP Page 40 

## Area Source Emissions Summaries and Estimates

Figure 12 : Area Source Annual Emissions by Percentage

Figure 13 : Area Source Season Day Emissions By PercentageAppendix 2

– 2015 Medford CO LMP Page 41 Table 2.4. 1 : Medford 2008 CO EI Summary of Estimation Procedures f or Area Sources

Table 2.4. 2 : Medford 2008 CO EI Summary of Emissions Estimates for Area SourcesAppendix 2

– 2015 Medford CO LMP Page 42 Table 2.4. 3 : Area Source Emissions From Fuel Oil UseAppendix 2

– 2015 Medford CO LMP Page 43 Table 2.4. 4 : Area Source Emissions From Natural Gas (NG) UseAppendix 2

– 2015 Medford CO LMP Page 44Appendix 2

– 2015 Medford CO LMP Page 45 Table 2.4. 5 : Area Source Emissions From Liquified Petroleum Gas (LPG) UseAppendix 2

– 2015 Medford CO LMP Page 46Appendix 2

– 2015 Medford CO LMP Page 47 Table 2.4. 6 : Area Source Emissions From Residential Wood CombustionAppendix 2

– 2015 Medford CO LMP Page 48 Table 2.4. 7 : Area Source Emissions From WildfiresAppendix 2

– 2015 Medford CO LMP Page 49 Table 2.4. 8 : Area Source Emissions From Prescribed (RX) BurningAppendix 2

– 2015 Medford CO LMP Page 50 Table 2.4. 9 : Area Source Emissions From Structure FiresAppendix 2

– 2015 Medford CO LMP Page 51 Table 2.4. 10 : Area Source Emissions From Residential Open BurningAppendix 2

– 2015 Medford CO LMP Page 52 Table 2.4. 11 : Area Source Emissions From Industrial Open Burning

Table 2.4. 12 : Area Source Emissions From Commercial/Institutional Open BUrningAppendix 2

– 2015 Medford CO LMP Page 53 Table 2.4. 13 : Area Source Emissions From Coal UseAppendix 2

– 2015 Medford CO LMP Page 54 Table 2.4. 14 : Area Source Emissions From Biomass BurningAppendix 2

– 2015 Medford CO LMP Page 55 

### 3.5 Nonroad Vehicles and Equipment

3.5.1 Introduction and Scope

This section describes the development of the emission inventory for carbon monoxide for nonroad mobile

sources located in the Medford UGB in the 2008 CO Limited Maintenance Plan year

. Sources inventoried
within the nonroad mobile sector include off

- road gasoline and diesel

- powered vehicles and equipment, aircraft, and railroads as well as recreational and commercial waterborne vessels.

As with most of the area s ource categories, emissions within the Medford UGB were developed by applying

SCC

- specific spatial and temporal scaling factors to county

- wide estimates of annual emissions for Jackson County from the 2008 NEI pursuant to the methodology outlined in the IP P.

Table 2.5.1 summarizes the nonroad mobile source emission inventory for the major nonroad source categories in terms of both a nnual and daily emissions (adjusted for activity during the CO season). Figure s 2

- 1 through 2

- 4 compare emissions of the nonroad emission subcategories.



### 3.5.2 Nonroad Vehicles and Equipment This category encompasses 2

- stroke gasoline, 4

- stroke gasoline, Compressed Natural Gas (CNG) / Liquefied Petroleum Gas (LPG), and diesel vehicles and equipment. Each of the sub

- categories include s the following vehicle categories: Recreational Equipment, Construction Equipm ent, Industrial Equipment, Lawn/ Garden Equipment, Agricultural Equipment, Light Commercial Equipment, and Logging Equipment

.

3.5.2.1 Vehicle Categories
The nonroad vehicles an d equipment category include s the following gasoline, CNG/LPG, and diesel sources:

SCC: 22

- xx

- 001

- xxx: Recreational Equipment

SCC: 22

- xx

- 002

- xxx: Construction Equipment

SCC: 22

- xx

- 003

- xxx: Industrial Equipment

SCC: 22

- xx

- 004

- xxx: Lawn / Garden Equipment

SC C: 22

- xx

- 005

- xxx: Agricultural Equipment

SCC: 22

- xx

- 006

- xxx: Light Commercial Equipment

SCC: 22

- xx

- 007

- xxx: Logging Equipment

3.5.2.2 Methodology The starting point for emissions estimates for sources in this category was the county

- wide, annual CO
emissions from the EPA 2008 NEI

. Using Jackson county land use zoning acreage

, 7 GIS

- based spatial allocation factors were created to estimate the fraction of county

- wide emissions from each of the vehicle types (Appendix A, Table A

- 1 ) occurring within the Medford UGB

. Annual Medford UGB emissions were estimated by multiplying the county

- wide emissions by the spatial factor (%) for the appropriate zoning ID. The following formula was used for spatial allocation:

Annual UGB emissions [tpy] = Annual Jackson County Emissi ons (tons/year) * Spatial Allocation Factor

Typical CO Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF) divided by 365 days per year. SAFs were taken from the 1993 EI

. 3 The activity is assumed to be 7 days pe r week across all vehicle types to be consistent with the 1993 EI

. 3

CO Typical Season Day Emission [lbs/day] = (Annual UGB Emissions (t/yr) * 2000(lb/ton) *SAF)/ (365 days/yr))Appendix 2

– 2015 Medford CO LMP Page 56 Nonroad vehicle and equipment emissions are detailed in Tables 2.5.2 through 2.5.5.



### 3.5.3 Aircraft and Airport Operations Emissions The aircraft and airport operation emission source categories inventoried include commercial and military aircraft, general aviation, air taxi, airport auxiliary power unit, and airport ground service equipm ent (GSE). Annual Jackson County CO emissions from aircraft and airport operation were obtained from the 2008 NEI

. * Annual Medford UGB CO emissions were estimated by multiplying the county

- wide emissions by appropriate spatial allocation factors. Spatia l factors for general aviation and air taxi were calculated b y dividing the total
aircraft

- related emissions by those of the Jackson County. The military and commercial aircraft, auxiliary power unit, and GSE were assigned a 100% spatial allocation factor since all these sources occur at the Rouge Valley International Medford Airport l ocated within the UGB, which is the sole commercial airport operating in Jackson County. The details of these calculations and a summary of aircraft and airport emissions are given in
Table 2.5.6.



### 3.5.4 Waterborne Vessels

Waterborne vessels fall under two categories: commercial/military marine vessels and recreational pleasure craft. Although pleasure craft emissions occur in other areas of Jackson County, neither category of waterborne vessel has any activity within the Medford UGB due to lack of suffici ent water bodies and inland location to support such activity. As such, waterborne vessel e missions within the Medford UGB w ere set to

zero.



### 3.5.5 Rail Railroad emissions encompass both locomotive operation and railway maintenance as shown b y individual

SCC cat egory below.

SCC: 22

- 85

- 002

- 007 : Locomotives: Line

- Haul

SCC: 22

- 85

- 002

- 010 : Locomotives: Yard

County

- wide annual emissions for railroads were taken from the EPA 2008 NEI database

. † Jackson County
annual emission estimates for locomotive emissions were a llocated using only active track miles within the Medford UGB and locating railroad yard activity within the Medford UGB using the railway GIS shapefiles in the 2008 NEI supporting data.

The 2008 NEI had no railway maintenance e missions for Jackson Coun ty; therefore, emissions for these SCC categories were set to zero for the Medford UGB.

Typical Season Day e missions were calculated by multiplying the UGB annual emissions tons by the SAF

, divided by 365 days per year. To be consistent with the 1993 EI

, 3 seasonal activity is assumed to be uniform
and the SAF is equal to 1.0

.

* Aircraft and airport operations have traditionally been classified within the Nonroad Mobile Source sector. Although their SCC classifications have not changed, EPA grouped them within the Point Source sector beginning with the 2008 NEI. To maintain consistency with previous Medford air quality plans and emission inventories, these emiss ions continue to be reported within the
Nonroad sector.

† Railroad have traditionally been classified within the Nonroad Mobile Source sector. Although their SCC classifications have not changed, EPA grouped them within the Non

- Point (Area) Source sector beginning with the 2008 NEI. To maintain consistency with previous Medford air quality plans and emission inventories, these emissions continue to be reported within the Nonroad secto r.Appendix 2

– 2015 Medford CO LMP Page 57 CO Typical Season Day Emission [lbs/day] = (Annual UGB Emissions (t/yr) * 2000(lb/ton) *SAF)/ (365 days/yr))

Railroad emission estimates are detailed in Table 2.5.7.Appendix 2

– 2015 Medford CO LMP Page 58 Figure 14 : Distribution of Medford UGB Annual Nonroad Source CO Emissions, 2008

Figure 15 : Percentage of Medford Annual Nonroad CO Source Emissions, 2008Appendix 2

– 2015 Medford CO LMP Page 59 Figure 16 : Distribution of Medford CO Season Day Nonroad Source Emissions, 2008

Figure 17 : Percentage of Medford UGB CO Season Day Nonroad Source Emission, 2008Appendix 2

– 2015 Medford CO LMP Page 60 Table 2.5. 1 : Medford UGB 2008 CO Summary of Emissions from Nonroad SourcesAppendix 2

– 2015 Medford CO LMP Page 61 Table 2.5. 2 : Medford UGB 2008 CO, Summary of Emissions from Nonroad Gasoline Vehicles * Equipment, 2

- CycleAppendix 2

– 2015 Medford CO LMP Page 62Appendix 2

– 2015 Medford CO LMP Page 63 Table 2. 5. 3 . 2008 Medford UGB CO: Summary of Emissions from Nonroad Gasoline Vehicles and Equipment, 4

- CycleAppendix 2

– 2015 Medford CO LMP Page 64Appendix 2

– 2015 Medford CO LMP Page 65 Table 2. 5. 4 . 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG/LPG Vehicles and EquipmentAppendix 2

– 2015 Medford CO LMP Page 66Appendix 2

– 2015 Medford CO LMP Page 67 Table 2. 5. 5 . 2008 Medford UGB CO: Summary of Emissions from Nonroad Diesel Vehicles and EquipmentAppendix 2

– 2015 Medford CO LMP Page 68Appendix 2

– 2015 Medford CO LMP Page 69 Table 2.5. 6 . 2008 Medford UGB CO: Summary of Emissions from Aircraft and Airport GSEAppendix 2

– 2015 Medford CO LMP Page 70Appendix 2

– 2015 Medford CO LMP Page 71 Table 2.5. 7 . 2008 Medford UGB CO: Summary of Emissions from RailroadsAppendix 2

– 2015 Medford CO LMP Page 72 

### 3.6 On

- Road Mobile Sources

3.6.1 Introduction and Scope This section describes the development of the emission inventory f or CO from on

- road mobile
sources in the Medford UGB for the 2008 CO L MP analysis year. On

- road emission estimates from Version 3 of the 2008 NEI database were used to represent countywide emissions. (The

on

- road emission estimates in Version 3 of the 20 08 NEI were developed using EPA’s MOVES2010b vehicle emissions model.) On

- road sources included in this inventory were grouped by both vehicle type and road type . Separate sets of on

- road CO emissions categorized by vehicle type and by road type were esti mated and reported

.



### 3.6.2 Spatial and Temporal Allocation of 2008 NEI Data

3.6.2.1 Spatial Allocation County

- wide 2008 on

- road exhaust emissions from the 2008 NEI w ere allocated to the Medford UGB using spatial surrogate s based on vehicle miles traveled (VMT). The spatial factor was calculated by dividing the Medford UGB ann ual VMT by the Jackson County annual VMT in
2008. Medford UGB annual VMT w as calculated from the model output of the RVMPO “ Models

Version 3. 0 ” travel demand model. 8 Jackson County annual VMT w as calculated from the monthly VMT provided in the 2008 NEI supporting “4c” archive file 3 database for transportation activity . Table 2.6.1 and Table 2.6.2 detail spatial allocation of data for on

- road mobile sources.

T he following formula was used for spatial allocation:

Annual UGB emissions, tpy = Annual Jackson County Emissions (tons/year) * (UGB Annual VMT / Jackson County Annual VMT)

3.6.2.2 Temporal Allocation Typical Season Day CO emissions were calculated by multiplying the UGB annual emissions tons by the SAF , divided by 365 days per year. The SAFs for on

- road emissions grouped by vehicle type were calculated using the values in Table 2.6.5 in the 1993 EI

. 1 The SAFs for on

- road emissions grouped by road type were taken from Table 2.6.3 in the 1993 EI

, 1 and the weekly adjustment factors were taken from Table 2.6.4 in the 1993 EI 1 . The following formula was used for temporal allocation:

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (365 days/year)



### 3.6.3 Summary of On

- Road Mobile Source Emissions

On

- road mobile emissions have been summarized by vehicle type and roadway type for annual and season day emissions in F igures 19 through 21 , and Tables 2.6.1 and 2.6.2 respectively.

The CO Season daily emissions are nominally different in Tables 2.6.1 and 2.6.2 because of the SAFs, which were taken from the 1993 Attainment Year EI 1 . A lthough these SAFs gave the same

3 ftp://ft p.epa.gov/EmisInventory/2008v3/doc

.Appendix 2

– 2015 Medford CO LMP Page 73 CO Season daily emissions in respective tables in the 1993 EI, they result in slightly different CO season daily emissions when applied to the 2008 NEI

.

Figure 18 : Percentage of 2008 Medford Annual Onroad CO Source Emissions, by Vehicle Type

Figure 19 : Percentage of 2008 Medford Season Day Onroad CO Source Emissions, by Vehicle TypeAppendix 2

– 2015 Medford CO LMP Page 74 Figure 20 : Percentage of 2008 Medford Annual Onroad CO Source Emiss ions, by Roadway Type

Figure 21 : Percentage of 2008 Medford Season Day Onroad CO Source Emissions, by Roadway TypeAppendix 2

– 2015 Medford CO LMP Page 75 Table 2.6. 1 . 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Vehicle TypeAppendix 2

– 2015 Medford CO LMP Page 76Appendix 2

– 2015 Medford CO LMP Page 77 Table 2.6. 2 . 2008 Medford UGB CO: Summary of On

- Road Mobile Emissions by Road TypeAppendix 2

– 2015 Medford CO LMP Page 78 

## 4 Quality Assurance and Quality Control

4.1 Introduction The Oregon DEQ is responsible for overall quality and accuracy of this inventory of Carbon Monoxide (CO) sources and emissions for the Medford urban growth boundary (UGB) for the 2008
Limited Maintenance Plan

. As presented in the IPP delivered to EPA in N ovember 2014, DEQ used existing data that has already been quality checked. DEQ staff performed quality assurance for accuracy, completeness, and representativeness on the spatial and temporal allocation of emissions from the existing inventory. DEQ and Sierra Research used EPA county database
estimates from the 200 8 NEI v.3 generated using MOVES 2010b modeled emissions rates

. 5,18



### 4.2 Organization and Personnel Wesley Risher, an emission inventory analyst at the DEQ , was appointed Quality Assurance
Coordinator

. DEQ staff Brandy Albertson, Christopher Swab, and Miyoung Park, along with Wenxian Zhang at Sierra Research, performed the bulk of the required source calculations. The abbreviated organizational hierarchy for carrying out the Quality Assurance Program is shown
below.

Oregon Department of Environmental Quality Air Quality Division

Wendy Wiles , Administrator

– Environmental Solutions Division Jeffrey Stocum, Manager

– Air Quality Technical Services Section Emission Inventory Christopher Swab, Senior Emission Inventory Analyst Brandy Albertson , Emission Inventory Analyst Miyoung Park , Emission Inventory Specialist Quality Assurance Wesley Risher, Emission Inventory Analyst

David Collier

, Air Quality Planning Manager

Dave Nordbe rg , Air Quality Planner

Sierra Research Tom Carlson, Principal Scientist Wenxian Zhang, Associate EngineerAppendix 2

– 2015 Medford CO LMP Page 79 

### 4.3 Data Collection and Analysis

4.3.1 Data Collection and Analysis To ensure the comprehensive nature of the emission inventory, a source listing from the 1993 attainment year inventory was used as a starting point 1 . The listing of sources in the 1993 inventory was generated using EPA's Quality Assurance Plan guidance document 1 and EPA’s Procedures for the Preparation of Emissions for Carbon Monoxide And Precursors Of Ozone 2 were used. The inventoried sources are marked under the appropriate pollutant categor y. Only those
sources that had been determined to operate in the inventory areas were included

Inventory source categories were divided into Station ary Point Sources, Stationary Area Sources,

Non

- Road Mobile and On

- Road Mobile Sources , the details of which are discussed in Parts 2.3 through 2.6 of this report

. Permitted s tationary point source information is maintained by DEQ for
sources with annual emissions of at least 5 tons per year, so a questionnaire/survey was not necessary to identify stationary area and point sources. Emissions from permitted point sources

were calculated on the basis of 2008 production levels and the best available emission factors (from TV source tests or from the permits). Point sources considered in this inventory are listed in Appendix A, Table A

- 1

.

The majority of the area and nonroad source emissions data a t annual, county

- wide levels were taken from previously comp iled EPA and DEQ estimates that were subjected to QA/QC protocols 5

. Many of the stationary area sources and non

- road mobile sources were allocated to UGB by

ap plying a spatial surrogate developed using ArcGIS and zoning shapefiles . Zoning and railway line GIS work was reviewed for completeness and accuracy by DEQ staff familiar with the Medford UGB region and activity. Population, fuel use, and employee data was reviewed by DEQ staff as part of the QA/QC protocols outlined here. Additionally, i n all cases, the source of the information and validation for its use was documented in the calculation spreadsheets and checked at the time of QC for reliability and appropriateness.



### 4.4 DATA HANDLING Data handling by DEQ staff included: 1) data tracking, and 2 ) Q A/QC (which included data checking, data correcting, and handling corrected data). Specific additional procedures included checking data after conversion to the inventory format, checking for missing data, and reviewing
the estimates.



### 4.5 Data Coding and Reco rding No air dispersion modeling was performed for this SIP so coding the source emissions for entry into the model was not necessary.



### 4.6 Data Tracking
Information obtained from source files, other divisions of the DEQ, other State, Federal, and local agencie s, and private companies used in compiling the emission inventories were recorded in reference files, in appendices, and documented on the calculation spreadsheets. The appendices and calculation spreadsheets were also stored electronically. All emissionAppendix 2

– 2015 Medford CO LMP Page 80 factors, throughputs, seasonal adjustment factors, and activities were documented on the calculation spreadsheets in both hard copy and electronic copy. All of the above mentioned information is kept at DEQ Headquarters.



### 4.7 QA/QC Procedures

- Checking and Cor recting The QC of all source category emissions include d : 1. Checking input data for inventory completeness, missing data, incorrect calculations, incorrect information, and reasonableness, and

2. Correcting the calculation sheets, summary sheets, and Appendic es where needed.

The QA of the emission estimates include:

1. Reviewing the emission summary for reasonableness, and

2. Ensuring that the data transferred betw een agencies and consultants was intact.



### 4.7.1 Checking Data

4.7.1.1 Inventory Completeness Completeness of the inventory was determined by checking against the EPA QA Plan guidance source listings and the 1993 attainment year inventory . Double counting of sources was
reviewed to ensure that source categories included in stationary point source category were
not al so included in area or non

- road mobile categories. Double

- count removal is detailed in
Tables 2.4.3 and 2.4.4 of this document

.

4.7.1.2 Missing Data In order to ensure that all the necessary data was submitted for each stationary point source,
forms were created t o identify all the data elements required by EPA to be reported for each stationary point source. Any parameter left blank during the initial completion of the form was considered a missing data element. Further review of the source files and, as necessa ry, contact with facility personnel were procedures used to obtain the missing information. If these steps did not result in supplying a missing data element, estimates were made based on similar point sources or from information contained in EPA publicat ions. Written documentation of the source of the data were recorded in the Emission Inventory notebook on the Data Error Report and Correction form as well as in the Audit Trail notebook.

Missing data for stationary area sources and non

- road mobile sourc es can usually be identified by the inability to calculate emissions. If the appropriate data was missing, a reasonable effort was made to acquire it. If this was unsuccessful, estimates were made based on data of recent years or on information contained in EPA documents. Missing data were recorded on the QC
area and non

- road mobile correction forms.

4.7.1.3 Incorrect Calculations In order to ensure that all the calculations were done correctly, the calculations were first
reviewed to ensure that the y were used correctly, followed by review of ele ctronic equations inAppendix 2

– 2015 Medford CO LMP Page 81 order to make sure that they were entered correctly. Any improperly used or incorrect
calculations were noted on the calculation sheet

.

4.7.1.4 Incorrect Information
In order to ensure that the information on summary s heets, calculations sheets, and Appendices for this report are correct, all the explanations, titles, and reference were checked for accuracy and clarity. Any changes were documented either directly on the sheet.

4.7.1.5 Reasonableness
A reasonablenes s check was performed on the estimated emissions, activity levels, and emission factors using the 1993 Medford Attainment Year CO SIP emission inventory 1 as a background comparison.

Stationary point source estimated emissions associated with the Air Conta minant Discharge Permit, Title V Permit, or Title V draft for each identified point source were reviewed in relation to similar sources. In addition, the stationary point source production levels source tests, and permitted emission factors were rechecked . The source’s current operational status was also reviewed using notices of construction, permit addendums, and DEQ source inspector information. Stationary area source and non

- road mobile estimated emissions were compared, when possible to the 1993 Med ford Attainment Year CO SIP emission inventory 1

. The references from which the emission factors and activity levels were taken were confirmed for the appropriateness of their use. Any reasonableness errors were documented in the correction
forms.

4.7.1.6 Emission s Summary Reasonableness Emissions summaries were reviewed against the 1993 attainment year, as shown in Executive Summary Figures 3 and 4 of this document.



### 4.8 Data Reporting An electronic copy of this report will be provided to EPA Region X in June 2015. Electronic copies of the summary and calculations spreadsheets will be made available to EPA upon
request.Appendix 2

– 2015 Medford CO LMP Page 82 

## 5 References

1. State of Oregon 1993 Attainment Year SIP Emission Inventory: Medford UGB Carbon Monoxide, Appendix D3

- 4 . Air Quality Division, Oregon Department of Environmental Qual ity, Portland, OR, March 9, 2001

. (DEQ AQ

- TS Ref. 618)

2. Procedures Document for National Emission Inventory, Criteria Air Pollutants 1985

- 1999

, EPA

- 454/R

- 01

- 006, U.S. EPA, Research Triangle Park, NC. March 2001. (DEQ AQ

- TS Ref. 2)

3. Emission Inventory Requirements for Carbon Monoxide State Implementation Plans , EPA

450/4

- 91

- 01 1 , U.S. EPA, Research Triangle Park, NC. March 1991. (DEQ AQ

- TS Ref. 1a)

4. Inventory Preparation Plan/Quality Assurance Plan for the Medfor d Urban Growth Boundary 2008 Carbon Monoxide (CO) Limited Maintenance Plan , Oregon Department of

Envir onmental Quality, February 2015: Please see Appendix C

.

5. http://www.epa.gov/ttnchie1/ne t/2008inventory.html

.

6. 2008 National Emissions Inventory, Version 3, Technical Support Document, Draft

, U.S. EPA, Research Triangle Park, Sep 2013.

7. The Jackson County zoning data were downloaded from http://gis.jacksoncounty.org/Portal/gis

- data.aspx

.

8. Technical Memorandum: Modeling to Support the RVMPO 2015

- 2018 TIP Air Quality Conformity Determination (AQCD) , prepared by Jin Ren with OD OT/TPAU, June 2014.

9. Grants Pass SIP Appendices for Carbon Monoxide. Appendix D4

- 4: Grants Pass UGB and CO NAA: 1993 Base Year and 2015 Forecast Year Emission Inventory and Forecast. Oregon DEQ. September 13, 2002. (DEQ AQ

- TS Ref. 933)

10. Internet: http://www.epa.gov/ttnchie1/software/fire/index.html

11. Compilation of Air Pollutant Emission Factors , Fifth Edition and Supplements, AP

- 42, U.S. EPA, Research Triangle Park, NC. January 199 5. (DEQ AQ

- TS Ref. 8)

.

12. Email from Wayne Kauzlarich, DEQ WR Medford, AQ Permit Writer/Inspector to Miyoung Park. City of Medford burn information (2008year). November 28, 2014 (DEQ AQ

- TS Ref. 945)

.Appendix 2

– 2015 Medford CO LMP Page 83 13. Email from Greg G. Kleinberg, City of Medford , Deputy Chief

- Fire Marshal, Medford Fire

Rescue to Miyoung Park. City of Medford burn Information (2008 year). November 25, 2014 (DEQ AQ

- TS Ref. 946).

14. Email from Meghan Fagundes, DEQ WR Medford, AQ Permit Writer/Inspector to Miyoung Park. Complaint open burni ng locations for Jackson County in 2008. March 12, 2015 (DEQ
AQ

- TS Ref. 951).

15. Email from Greg G. Kleinberg, City of Medford , Deputy Chief

- Fire Marshal, Medford Fire

Rescue to Miyoung Park. City of Medford, illegal burn information (2008 year). March 12, 2015 (DEQ AQ

- TS Ref. 952).

16. Open Burning Emission factor: Emission Inventory Improvement Program (EIIP), EPA, Office of Air Quality Planning and Standards, Emission Factor and Inventory Group, Research Triangle Park, NC. Volume III: Chapter 16 (DEQ A Q

- TS Ref. 947)

17. E

- mail f rom Venkatesh Rao (EPA) to C. Swab. EPA 2008 Oregon/California prescribed burning and wildfire emissions estimates, EIS event format. August 3, 2011. (DEQ AQ

TS Ref. 762)

18. E

- mail from Wenxian Zhang to C. Swab. Medford UGB 2008 CO LMP

- Draft Emission Inventory. April 27, 2015. (DEQ AQ

- TS Ref. 961).Appendix 2

– 2015 Medford CO LMP Page 84 

## 6 Appendices to the Emission InventoryAppendix 2

– 2015 Medford CO LMP Page 85 

## APPENDIX A: STATIONARY PERMITTED POINT SOURCES

 Figure A

- 1: Point Source Locations

 Table A

- 1: Stationary Point Source Determination for 2008 CO Inventory Determination

 Table A

- 2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory

 Table A

- 3: Stationary Point Source Emission Estimation DetailsAppendix 2

– 2015 Medford CO LMP Page 86 Appendix A, Figure A

- 1 : 2008 Medford CO LMP Permitted Point Source LocationsAppendix 2

– 2015 Medford CO LMP Page 87 Appendix A, Table A

- 1 : Stationary Point Source Determina tion for 2008 CO Inventory

Appendix A, Table A

- 2 : Exclusion of 1993 and some 2008 Facilities from CO Emission InventoryAppendix 2

– 2015 Medford CO LMP Page 88Appendix 2

– 2015 Medford CO LMP Page 89 Appendix A, Table A

- 3 : Stationary Point Source Emission Estimation Details

(cont’d on next page)Appendix 2

– 2015 Medford CO LMP Page 90 Appendix A, Table A

- 3 ContinuedAppendix 2

– 2015 Medford CO LMP Page 91 

## APPENDIX B: STATIONARY AREA SOURCES

 Figure B

- 1: Wildfire and Prescribed Burning Locations

 Table B

- 1: GIS Allocation Results: Josep hine County Zones, County

- Wide and by UGBAppendix 2

– 2015 Medford CO LMP Page 92 Appendix B, Figure B

- 1 : Wildfire and Prescribed Burn Location and DateAppendix 2

– 2015 Medford CO LMP Page 93 Appendix B, Table B

- 1 : GIS Alloca tion Results: Josephine County Zones, County

- Wide and by UGBAppendix 2

– 2015 Medford CO LMP Page 94 Notes for Table B

- 1