Appendix 2

Medford 2008 Emission Inventory
Appendix 2 - 2015 Medford CO LMP

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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 6th Avenue

Portland, Oregon 97204
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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 Sources Not Inventoried ............................................................................................... 10

2.6 Guidance Documents.................................................................................................... 10

2.7 Contact Personnel......................................................................................................... 11

3 Medford 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.................................................................................................. 25
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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 Combustion.................................................................... 37

3.4.3.3 Residential Wood Combustion ..................................................................... 38

3.4.3.4 Miscellaneous Area Sources......................................................................... 38

3.4.3.4.1 Forest Wildfires........................................................................................... 38
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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 ........................................................... 81
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4.8 Data Reporting.............................................................................................................. 81

5 References.................................................................................................................... 82

6 Appendices to the Emission Inventory ........................................................................... 84

Table of Figures

Executive Summary, Figure 1: 2008 Medford UGB annual CO emissions, percentage by source category 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 Rogue Basin Open Burning Control Area................................14

Figure 4: Woodstove Curtailment Ordinance Area / Critical PM10 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 Emissions 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 Emissions 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

Appendix B, Figure B- 1: Wildfire and Prescribed Burn Location and Date................................................92
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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 Emissions 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 ......................................................51

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

Table 2. 5. 4. 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG/LPG Vehicles and 

Equipment...................................................................................................................................................65

Table 2. 5. 5. 2008 Medford UGB 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......93
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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. This 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 inventory 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% of 
Appendix 2 - 2015 Medford CO LMP

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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.

Permitted 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 Medford 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 emissions from stationary point, 

stationary area, non-road mobile, and on-road mobile sources are shown in the Executive 

Summary Figures 1 through 4
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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 category

Stationary 

Point Sources

1 4%

Stationary 

Area Sources

2 6%

Non-Road 

Mobile 

Sources

2 6%

O n-Road 

Mobile 

Sources

3 4%

Stationary 

Point Sources

1 6%

Stationary 

Area Sources

3 7%

Non-Road 

Mobile 

Sources

1 2%

O n-Road 

Mobile 

Sources

3 5%
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Executive Summary, Figure 3: Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008

4,835

2,376

2,168

3,333

2,651

4,488

11,435

5,730

0

5,000

10,000

15,000

20,000

25,000

1993 2008

Emissions (tpy)

O n-road Mobile

Nonroad Sources

Area Sources

Permitted Point 

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

2008

28,516

13,159

19,748

30,399

6,536

10,061

57,342

28,731

0

20,000

40,000

60,000

80,000

100,000

120,000

1993 2008

Emissions (lbs/day)

O n-road Mobile

Nonroad Sources

Area Sources

Permitted Point 

Sources
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2 Introduction

2.1 Purpose of the Report

The Clean Air 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 

nonattainment 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 1991. 

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 again 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 delineated 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 limited maintenance plan 2008

year 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 emissions generated 

over the 2008 Maintenance Year. Seasonal emissions represent CO emissions generated on an 

average 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.
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The geographic 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 for 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 River, Grants Pass, and White City.

Figure 1: Medford Urban Growth Boundary
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Figure 2: 2008 Medford CO LMP, 25-mile buffer and permitted point source locations
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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 exclusions. 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 provides maps of open burning control areas and the MedfordAshland Air Quality Maintenance Area / Vehicle Inspection Boundary. These 

maps are included for consistency with the 1993 Medford CO Attainment 

Year Inventory. This section also provides legal descriptions 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 mobile sources in the Medford UGB.

 Section 3.0 contains a discussion 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 

the 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.
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 Section 6.0 provides a description of the approach and methodology used in 

evaluating emissions from on-road mobile sources. Tables summarizing onroad mobile source emissions estimates follow the discussion.

 Part 3 describes the quality assurance procedures utilized in preparing the 2008 inventory.

 Part 4 contains an extensive list of references utilized for the Medford CO emission 

inventory.

 Part 5 contains Appendices with supplemental data used to estimate emissions. 

Tables and figures for each emission category are located at the end of the discussion 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 emission 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 System (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 Inventory1. For those sources inventoried by DEQ, inventory 

methodology followed applicable EPA procedure and guidance documents. Two primary 

documents utilized were Procedures for the Preparation of Emission Inventories for Carbon 

Monoxide and Precursors of Ozone, Volume I3, and Emission Inventory Requirements for Carbon 

Monoxide State Implementation Plans2.
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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:

 DEQ

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

Dana 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 Scientist
Appendix 2 – 2015 Medford CO LMP

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Wenxian Zhang, Associate Engineer

Starcrest Consulting Group, LLC

Wayne Elson, Air Quality Planner and Mobile Source Emissions Expert

Rogue Valley Council of Governments

Dan Moore, Planning Coordinator, AICP
Appendix 2 – 2015 Medford CO LMP

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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 Inventory1:

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

 Figure 2 (previous): Medford UGB 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 PM10 Control Area

 Figure 5: Medford-Ashland Air Quality Maintenance Area / Vehicle Inspection Program 

Boundary
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Figure 3: Open Burning Control Areas and Rogue Basin Open Burning Control Area
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Figure 4: Woodstove Curtailment Ordinance Area / Critical PM10 Control Area
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Figure 5: Medford-Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary
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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 Administrative Rules (OAR) 340-204-

0010(12):

(12) “Medford 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 Merriman 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 along 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 east 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 approximately 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 approximately 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 south 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 1000 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 south 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 South 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 

Station 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; thence 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 Stage 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 southeasterly 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 Section 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 southeast corner of Section 27, T37S, R1W; thence north 
Appendix 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 southeasterly 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 northern 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 foot 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 

approximately 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 approximately 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 feet; 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 rules that address commercial, demolition, construction and industrial 

open burning. The rules are identified for densely populated locations in the state, including cities over 4,000 

people in population and within three miles of the corporate city limits of these cities. The boundaries defined 

by the rules are termed Open 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 areas 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 Open 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 corner 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

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

Control Area

In order to strengthen 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 

PM10 Control Area. The unified ordinance applies in Jackson 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. Southeasterly 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 Boundary (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 intersection 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). North 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 Pioneer 

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 Jacksonville 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 Old 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 Ventura 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 subject 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 southeast 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, T39S, 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 southwest 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, T38S, 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 southwest 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

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3.2 Summary of Emissions Data

Summary tables of emission data that are presented 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 Percentage

0

2,000

4,000

6,000

Stationary 

Point 

Sources

Stationary 

Area 

Sources

Non-Road 

Mobile 

Sources

On-Road 

Mobile 

Sources

CO Emissions, tpy

Stationary 

Point Sources

1 4%

Stationary 

Area Sources

2 6%

Non-Road 

Mobile 

Sources

2 6%

O n-Road 

Mobile 

Sources

3 4%
Appendix 2 – 2015 Medford CO LMP

Page 21

Figure 8: Distribution of 2008 Season Day CO Emissions

Figure 9: Season Day CO Emissions by Percentage

0

1 5,000

3 0,000

4 5,000

Stationary 

Point 

Sources

Stationary 

Area 

Sources

Non-Road 

Mobile 

Sources

On-Road 

Mobile 

Sources

CO Emissions, lbs/day

Stationary 

Point Sources

1 6%

Stationary 

Area Sources

3 7%

Non-Road 

Mobile 

Sources

1 2%

O n-Road 

Mobile 

Sources

3 5%
Appendix 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 Attainment Year inventory

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 annual and seasonal emission estimates that establish 

both short and long term CO trends from industrial sources during 2008. This write up details the steps 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-mile 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.

Grants Pass industrial sources were not included in the Medford 1993 inventory because they were already 

inventoried for the 1993 Grants Pass State Implementation Plan9. 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 include both industrial and non-industrial 

sources. Industrial sources are included under Part 2.3 Stationary Point Sources of this inventory and nonindustrial sources are covered under Part 2.4 Stationary AREA Sources. This is a discussion on the point source 

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 were 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, Point Source Data and Table A-1 Individual Stationary Point Source 

Determinations. 
Appendix 2 – 2015 Medford CO LMP

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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 pollutant. 

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 determination 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 boundary 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 sources 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 PSEL 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 they 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 and 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 using existing TV emissions data submitted by DEQ to EPA’s 2008

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 collection is necessary to gather information used to calculate both annual and seasonal emissions. 

Information such as a source’s emission basis, activity/throughput data, operating schedules, and Plant Site 

Emission Limits (PSELs) were collected for the inventory. This data was 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 and 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 obtained from ACDP permits and/or annual reports. 

3.3.4.3 Activity Data

Activity data, also called throughput, was collected from 2008 annual reports for Title V and ACDP sources. 

Activity data consists of fuel use, production activity, or other annual throughput 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 to 
Appendix 2 – 2015 Medford CO LMP

Page 26

verify existing 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 Calculations

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 methodologies 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-42, 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 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

Some CO emission estimates were derived via CEMS which is the most accurate representation of emissions at 

a source. Permit conditions may require direct measurement of stack emissions and recordkeeping for 

reporting hourly or daily CO emitted at a facility. Emission factors and CEMS are the most common estimation 

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

3.3.4.5.2 Emissions Estimation Methodologies 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 emission 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 operating 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 calculated 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 

allocation and development methods and data components 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 Sparse 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))

An 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 1st through end of February the following year). The following 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 order 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 tons

 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 and 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 distributed 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 manufacturing 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 contributing 
Appendix 2 – 2015 Medford CO LMP

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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 lists 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 the 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 minimal. 

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 the 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 

control 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 its 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; 

therefore, control efficiency and rule effectiveness also do not apply in the 2008 inventory. 
Appendix 2 – 2015 Medford CO LMP

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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 area 

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 

the area source category are three groups 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); and 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) for 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 December 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 Identification 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 

Procedures Document3 and the Emissions Inventory Requirements for CO1. These area sources were 

compared to sources evaluated in the 1993 Attainment Year CO SIP Emission Inventory618, 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 data 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). Data 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 Document2, the 

FIRE Version 5 SCC’s and Emission Factors10, 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 

environmental 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 number of approaches: 1) using alternative multiplier values when possible; 
Appendix 2 – 2015 Medford CO LMP

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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 Document2 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 methodology 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, emission 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 summary 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 applied1,3. 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, infectious 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 Medford UGB does not contain any industrial incineration sources and as such this category has not been 

inventoried
Appendix 2 – 2015 Medford CO LMP

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3.4.3.1.1.2 Commercial/Institutional Incineration

The 1993 attainment year emission inventory considered this category (given as “Commercial/Instititional OnSite 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 UGB except by special letter permit issued by DEQ’s 

Western Region Office. No industrial open burning was permitted within the Medford UGB in 2008 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 National 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 office12,14 and City of Medford Fire 

District13,15, and burn days and type of burn were based on the information.

Latitude 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

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Figure 10: 2008 Commercial Open Burning Locations

There were no CO emission in the CO season because there were no permitted commercial 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 municipal 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 2008 National 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 #9: Residential Lawn & Garden: Residential Zoning).

Burn permits and complaints were provided by the DEQ Medford office12,14 and City of Medford Fire District

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

Latitude 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

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Figure 11: 2008 Residential Open Burning Locations

Weekly activity values use based on EPA’s document16. Open burning can be expected 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 includes burning complaints (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. Use 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

Fuel 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 emission sources are primarily from 

fuel consumption in furnaces, heaters, and other heating devices. For this inventory, industrial and 
Appendix 2 – 2015 Medford CO LMP

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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 are from the EPA 2008 NEI database. Since industrial and 

commercial fuel 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 codes 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 every 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 Emissions (tons/year) * (UGB employee or population / 

Jackson County employee 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 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 

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 (NG) 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 population data from the US Census Bureau and developing a ratio of 
Appendix 2 – 2015 Medford CO LMP

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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 population 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 County 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 emissions 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 

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

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 data 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 employee)

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 EI3, 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 (weeks/yr))

Coal and biomass emission estimates are detailed in Table 2.4.14 and Table 2.4.15. 
Appendix 2 – 2015 Medford CO LMP

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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 months when residential wood combustion is at its height, 

emissions from residential wood burning are considered, and have been estimated, to be significant in the 

UGB.

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 following 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 tons 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 Wildfires

DEQ staff analyzed EPA 2008 NEI fire event data17, 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. Forest 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 Department of Forestry pursuant to OAR 477.515. To 

estimate prescribed burning emissions, DEQ staff analyzed EPA 2008 NEI fire event data17, 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. 

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

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3.4.3.4.3 Structure Fires

Josephine County structure fires emissions are from DEQ’s 2008 county-wide emissions submitted to the EPA 

National Emissions Inventory (NEI).

Annual CO Medford UGB emissions are estimated by multiplying county-wide emissions by the ratio of the 

2008 UGB population to county population (population data taken from the US Census 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 document2. 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 Typical 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

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Area Source Emissions Summaries and Estimates

Figure 12: Area Source Annual Emissions by Percentage

Figure 13: Area Source Season Day Emissions By Percentage

Prescribed 

Burning

4 6%

RWC: NonCertified 

Devices

2 9%

RWC: Certified 

Devices

1 2%

RWC: Fireplaces

6%

All other 

sources

7%

Prescribed 

Burning

4 7%

RWC: NonCertified 

Devices

2 9%

RWC: Certified 

Devices

1 2%

RWC: Fireplaces

7%

All other 

sources

5%
Appendix 2 – 2015 Medford CO LMP

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

Table 2.4. 2: Medford 2008 CO EI Summary of Emissions Estimates for Area Sources
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Table 2.4. 3: Area Source Emissions From Fuel Oil Use
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Table 2.4. 4: Area Source Emissions From Natural Gas (NG) Use
Appendix 2 – 2015 Medford CO LMP

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(1) (2) (3) (4) (5) (6)

SCC and Category Description

County 

Emissions 

Spatial 

factor

Annual UGB 

Emissions Activity 

Seasonal 

Adjustment 

Factor

CO Typical Season Day 

Emissions

(tons/year

)

(%) (tons/year) (days/week) (SAF) (lbs/day)

SCC 21-02-006-000 69.70 31% 21.6 6 1.0 139

Industrial: NG ------- -------

ACDP Emissions (7) 29.5 219

------- -------

Reconciled Emissions Estimate (8) 0 0

SCC 21-03-006-000 55.10 79% 43.5 6 1.4 391

Comm/Inst. NG ------- -------

ACDP Emissions (7) 18.7 104

------- -------

Reconciled Emissions Estimate (8) 24.8 287

SCC 21-04-006-000 45.56 38% 17.3 7 1.7 162

Residential: NG

-------- --------

Total CO UGB Emissions 42.1 448

(tpy):

Total CO UGB Typical 

Season Day Emissions 

(lbs/day):
Appendix 2 – 2015 Medford CO LMP

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Table 2.4. 5: Area Source Emissions From Liquified Petroleum Gas (LPG) Use
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Table 2.4. 6: Area Source Emissions From Residential Wood Combustion
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Table 2.4. 7: Area Source Emissions From Wildfires
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Table 2.4. 8: Area Source Emissions From Prescribed (RX) Burning
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Table 2.4. 9: Area Source Emissions From Structure Fires
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Table 2.4. 10: Area Source Emissions From Residential Open Burning
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Table 2.4. 11: Area Source Emissions From Industrial Open Burning

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

(1) (2) (3) (4) (5) (6)

SCC and Category 

Description

County 

Emission 

Spatial 

factor

Annual UGB 

Emissions

Activity 

Seasonal 

Adjustment 

Factor

CO Typical 

Season Day 

Emission

(tons/year) (%) (tons/year) (days/week) (SAF) (lbs/day)

Legal Burning - Permitted

SCC: 26-10-000-500

Commercial / 

Institutional Open 

Burning

166 50.3% 8 4 5 0 0

Notes:

(1). The MS Access application used to query both databases is located at : 

\\deqhq1\EI_FILES\2008_Medford_Second_LMP_CO\Final_EI\2008_NEI\Final_Data_ForBrian.accdb

(2) Spatial Factor (%), using Josephine County land use zoning acreage GIS Allocation Results were 

created to approximate both the location and magnitude of emissions. County-Wide emission 

estimates were allocated by UGB percentage taken from Appendix X, Table C-X, 

(ID 8 = Commercial Lawn & Garden: Commercial Zones) GIS Allocation Results:

Josephine County Zones, County-Wide and by UGB. Spatial surrogates are typically used to approximate 

emissions inside smaller boundaries from larger boundaries.

(3) Annual UGB Emissions: (tons/year)= County Emissions (tons/year)*Spatial Factor (%)

(4) Activity values used in the 1993 EI : Activity is based on the assumption that an individual commercial 

 employee works 5 days per week even if the commercial source's operation runs 7 days per week.

 This employee activity is important because the emissions are based on employee population numbers.

(5) Seasonal Adjustment Factor (SAF)= (0 peak season activity * 12 months)/(173 annual activity * 3 months) 0

Burn days include complaint(illegal) burn data and permitted burns (DEQ Ref.951, 952 and 946)

(6) CO Typical Season Day Emissions [lb/day] =

((Annual Emissions [tons/year]) * (2000 [lb./ton]) * (SAF))/ ((Activity [days/wk]) * (52 [wk./year]))
Appendix 2 – 2015 Medford CO LMP

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Table 2.4. 13: Area Source Emissions From Coal Use
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Table 2.4. 14: Area Source Emissions From Biomass Burning
Appendix 2 – 2015 Medford CO LMP

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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 source 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 IPP.

Table 2.5.1 summarizes the nonroad mobile source emission inventory for the major nonroad source 

categories in terms of both annual and daily emissions (adjusted for activity during the CO season). Figures 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 includes the following 

vehicle categories: Recreational Equipment, Construction Equipment, Industrial Equipment, Lawn/Garden 

Equipment, Agricultural Equipment, Light Commercial Equipment, and Logging Equipment. 

3.5.2.1 Vehicle Categories

The nonroad vehicles and equipment category includes 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

SCC: 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 Emissions (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 per 

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

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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 equipment (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. Spatial factors for general aviation and air taxi were calculated by 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 located 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 sufficient water bodies and inland 

location to support such activity. As such, waterborne vessel emissions within the Medford UGB were set to 

zero.

3.5.5 Rail

Railroad emissions encompass both locomotive operation and railway maintenance as shown by individual 

SCC category 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 allocated 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 emissions for Jackson County; therefore, emissions for these SCC 

categories were set to zero for the Medford UGB.

Typical Season Day emissions 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 emissions 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 sector.
Appendix 2 – 2015 Medford CO LMP

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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

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

Figure 15: Percentage of Medford Annual Nonroad CO Source Emissions, 2008
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Figure 16: Distribution of Medford CO Season Day Nonroad Source Emissions, 2008

Figure 17: Percentage of Medford UGB CO Season Day Nonroad Source Emission, 2008
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Table 2.5. 1: Medford UGB 2008 CO Summary of Emissions from Nonroad Sources

CO Annual UGB 

Emissions 

(tons/yr)

CO Typical 

Season Day 

Emissions 

(lbs/day)

GAS, 2-Cycle

 Recreational Equipment 2.5.2 22-60-001-xxx 0.0 0.0

 Construction Equipment 2.5.2 22-60-002-xxx 12.2 36.2

 Industrial Equipment 2.5.2 22-60-003-xxx 0.1 0.3

 Lawn / Garden Equipment 2.5.2 22-60-004-xxx 225 12

 Agricultural Equipment 2.5.2 22-60-005-035 0 0

 Light Commercial Equipment 2.5.2 22-60-006-xxx 17 93

 Logging Equipment 2.5.2 22-60-007-005 0 0

Category Subtotal 254 142

GAS, 4-Cycle

 Recreational Equipment 2.5.3 22-65-001-xxx 0 0

 Construction Equipment 2.5.3 22-65-002-xxx 63 138

 Industrial Equipment 2.5.3 22-65-003-xxx 32 172

 Lawn / Garden Equipment 2.5.3 22-65-004-xxx 2,322 127

 Agricultural Equipment 2.5.3 22-65-005-xxx 0 0

 Light Commercial Equipment 2.5.3 22-65-006-xxx 1,378 7,476

 Logging Equipment 2.5.3 22-65-007-xxx 0 0

Category Subtotal 3,795 7,914

CNG/LPG

 Recreational Equipment 2.5.4 22-67,68-xxx-xxx 0 0

 Construction Equipment 2.5.4 22-67,68-xxx-xxx 2 4

 Industrial Equipment 2.5.4 22-67,68-xxx-xxx 190 1,031

 Lawn / Garden Equipment 2.5.4 22-67,68-xxx-xxx 2 0

 Agricultural Equipment 2.5.4 22-67,68-xxx-xxx 0 0

 Light Commercial Equipment 2.5.4 22-67,68-xxx-xxx 0 0

 Logging Equipment 2.5.4 22-67,68-xxx-xxx 0 0

Category Subtotal 194 1,036

Diesel

 Recreational Equipment 2.5.5 22-70-001-xxx 0 0

 Construction Equipment 2.5.5 22-70-002-xxx 65 146

 Industrial Equipment 2.5.5 22-70-003-xxx 12 60

 Lawn / Garden Equipment 2.5.5 22-70-004-xxx 4 0

 Agricultural Equipment 2.5.5 22-70-005-xxx 0 0

 Light Commercial Equipment 2.5.5 22-70-006-xxx 20 123

 Logging Equipment 2.5.5 22-70-007-xxx 2 0

Category Subtotal 104 329

VEHICLE SUBTOTAL Category Subtotal 4,348 9,421

AIRCRAFT

Military Aircraft 2.5.6 22-75-001-000 2 4

Aircraft: Commercial Aircraft 2.5.6 22-75-020-000 17 86

Aircraft: General Aviation 2.5.6 22-75-050-xxx 48 155

Aircraft: Air Taxi 2.5.6 22-75-060-xxx 7 37

Aircraft Auxillary Power Unit 2.5.6 22-75-070-000 2 12

Airport GSE 2.5.6 22-xx-008-005 61 330

Category Subtotal 138 624

RAILROADS

Locomotives: Line-Haul 2.5.7 22-85-002-007 0 1

Locomotives: Yard 2.5.7 22-85-002-010 3 15

Category Subtotal 3 16

MARINE VESSELS

Commercial Marine Vessels 2.5.8 22-80-004-000 0 0

Pleasure Craft-Diesel-Inboard/Sterndrive2.5.8 22-82-020-005 0 0

Pleasure Craft-Diesel-Outboard 2.5.8 22-82-020-010 0 0

Pleasure Craft-Gasoline 2-Stroke-Outboard 2.5.8 22-82-005-010 0 0

Pleasure Craft-Gasoline 2-Stroke-Personal Water Craft 2.5.8 22-82-005-015 0 0

Pleasure Craft-Gasoline 4-Stroke-Inboard/Sterndrive 2.5.8 22-82-010-005 0 0

Category Subtotal 0 0

(tons/yr) (lbs/day)

TOTAL NON-ROAD 4,488 10,061

2008 EI

Source Description Table # SCC Code
Appendix 2 – 2015 Medford CO LMP

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

Cycle
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Table 2. 5. 3. 2008 Medford UGB CO: Summary of Emissions from Nonroad Gasoline Vehicles and 

Equipment, 4-Cycle
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Table 2. 5. 4. 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG/LPG Vehicles and

Equipment
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Table 2. 5. 5. 2008 Medford UGB CO: Summary of Emissions from Nonroad Diesel Vehicles and Equipment
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Table 2.5. 6. 2008 Medford UGB CO: Summary of Emissions from Aircraft and Airport GSE
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Table 2.5. 7. 2008 Medford UGB CO: Summary of Emissions from Railroads

(1) (2) (3) (5)

SCC and Category Description

County 

Emission 

Spatial 

factor

Annual UGB 

Emissions

CO Typical Season Day 

Emissions

(tons/year) (%) (tons/year) (lbs/day)

SCC 22-85-002-007 6.66 3 % 0.22 1.21

Locomotives: Line-Haul

SCC 22-85-002-010 8.01 33% 2.67 14.63

Locomotives: Yard

-------- --------

 Total CO UGB Emissions (tpy) : 3 1 6

Notes for Table 2.5.7

(1) The data are from the 2008 NEI, summarized in the file "MedfordCOLMP_2008NEI_Jackson_County.xlsx." (References 5 and 18)

 https://gis.odot.state.or.us/transGIS/

Jackson 

County

Medford UGB Spatial Factor

Line-haul 138.3 4.6 3.33%

Yard 3 1 33.33%

(3) Annual UGB CO Emissions (tons/year) = County Emissions (tons/year)*Spatial Factor (%).

(4) Seasonal Adjustment Factor (SAF) is obtained from Table 2.5.6 of Oregon 1993 Medford UGB Carbon Monoxide Attainment year SIP Emission Inventory

(5) CO Typical Season Day Emissions [lbs/day] = ((Annual Emissions [tons/yr] * 2000 [lbs/ton]) * SAF) / (365 [days])

Total CO UGB Season Typical 

Day Emissions (lbs/day):

(2) Spatial factor (%) allocates county-wide emissions to UGB. The spatial surrogates for line-haul and yard emissions are track miles and yard locations, 

respectively. Track miles were obtained from 2008 NEI railway shapfile, and yard locations were identified by using ODET TransGIS: 

(4)

Seasonal Adjustment Factor

(SAF)

1

1
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3.6 On-Road Mobile Sources

3.6.1 Introduction and Scope

This section describes the development of the emission inventory for CO from on-road mobile 

sources in the Medford UGB for the 2008 CO LMP 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 2008 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 estimated 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 were allocated to the Medford 

UGB using spatial surrogates based on vehicle miles traveled (VMT). The spatial factor was 

calculated by dividing the Medford UGB annual VMT by the Jackson County annual VMT in 

2008. Medford UGB annual VMT was calculated from the model output of the RVMPO “Models 

Version 3.0” travel demand model.8 Jackson County annual VMT was calculated from the 

monthly VMT provided in the 2008 NEI supporting “4c” archive file3 database for transportation 

activity. Table 2.6.1 and Table 2.6.2 detail spatial allocation of data for on-road mobile sources. 

The 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 EI1. 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 Figures 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 EI1. Although these SAFs gave the same 

 

3

ftp://ftp.epa.gov/EmisInventory/2008v3/doc. 
Appendix 2 – 2015 Medford CO LMP

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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 

Type

LDGV

32%

LDGT2

36%

LDGT4

19%

HDDV

3%

ALL OTHER 

TYPES

10%

LDGV

32%

LDGT2

36%

LDGT4

19%

HDDV

3%

ALL OTHER 

TYPES

10%
Appendix 2 – 2015 Medford CO LMP

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Figure 20: Percentage of 2008 Medford Annual Onroad CO Source Emissions, by Roadway 

Type

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

Type

Interstate

14%

Arterial

Collector 17%

7%

Local

Parking Area 5%

57%

Interstate

16%

Arterial

Collector 17%

6%

Local

5%

Parking Area

56%
Appendix 2 – 2015 Medford CO LMP

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Table 2.6. 1. 2008 Medford UGB CO: Summary of On-Road Mobile Emissions by Vehicle Type
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Table 2.6. 2. 2008 Medford UGB CO: Summary of On-Road Mobile Emissions by Road Type
Appendix 2 – 2015 Medford CO LMP

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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 November 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 2008 NEI v.3 generated using MOVES2010b 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 Nordberg, Air Quality Planner

Sierra Research

Tom Carlson, Principal Scientist

Wenxian Zhang, Associate Engineer
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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 point1. The listing of sources in the 1993 

inventory was generated using EPA's Quality Assurance Plan guidance document1 and EPA’s 

Procedures for the Preparation of Emissions for Carbon Monoxide And Precursors Of Ozone2 were 

used. The inventoried sources are marked under the appropriate pollutant category. Only those 

sources that had been determined to operate in the inventory areas were included

Inventory source categories were divided into Stationary 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 stationary 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 at annual, county-wide levels were

taken from previously compiled EPA and DEQ estimates that were subjected to QA/QC protocols5. 

Many of the stationary area sources and non-road mobile sources were allocated to UGB by 

applying 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, in 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) QA/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 Recording

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 agencies, 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 emission 
Appendix 2 – 2015 Medford CO LMP

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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 Correcting

The QC of all source category emissions included: 

1. Checking input data for inventory completeness, missing data, incorrect calculations, 

incorrect information, and reasonableness, and

2. Correcting the calculation sheets, summary sheets, and Appendices where needed.

The QA of the emission estimates include:

1. Reviewing the emission summary for reasonableness, and

2. Ensuring that the data transferred between 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 also 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 to 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 necessary, 

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 publications. 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 sources 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 they were used correctly, followed by review of electronic equations in 
Appendix 2 – 2015 Medford CO LMP

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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 sheets, 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 reasonableness check was performed on the estimated emissions, activity levels, and 

emission factors using the 1993 Medford Attainment Year CO SIP emission inventory1 as a 

background comparison.

Stationary point source estimated emissions associated with the Air Contaminant 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 Medford Attainment Year CO SIP emission inventory1. 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 Emissions 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.
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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 

Quality, 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, EPA450/4-91-011, U.S. EPA, Research Triangle Park, NC. March 1991. (DEQ AQ-TS Ref. 1a)

4. Inventory Preparation Plan/Quality Assurance Plan for the Medford Urban Growth 

Boundary 2008 Carbon Monoxide (CO) Limited Maintenance Plan, Oregon Department of 

Environmental Quality, February 2015: Please see Appendix C.

5. http://www.epa.gov/ttnchie1/net/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 ODOT/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 1995. (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

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13. Email from Greg G. Kleinberg, City of Medford , Deputy Chief - Fire Marshal, Medford FireRescue 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 burning 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 FireRescue 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 AQ-TS Ref. 947)

17. E-mail from Venkatesh Rao (EPA) to C. Swab. EPA 2008 Oregon/California prescribed 

burning and wildfire emissions estimates, EIS event format. August 3, 2011. (DEQ AQTS 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

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6 Appendices to the Emission Inventory
Appendix 2 – 2015 Medford CO LMP

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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 Details
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Appendix A, Figure A- 1: 2008 Medford CO LMP Permitted Point Source Locations
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Appendix A, Table A- 1: Stationary Point Source Determination for 2008 CO Inventory

Appendix A, Table A- 2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory
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Appendix A, Table A- 3: Stationary Point Source Emission Estimation Details

(cont’d on next page)
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Appendix A, Table A-3 Continued
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APPENDIX B: STATIONARY AREA SOURCES

 Figure B-1: Wildfire and Prescribed Burning Locations

 Table B-1: GIS Allocation Results: Josephine County Zones, County-Wide and by UGB
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Appendix B, Figure B- 1: Wildfire and Prescribed Burn Location and Date
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Appendix B, Table B- 1: GIS Allocation Results: Josephine County Zones, County-Wide and by UGB
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Notes for Table B-1