## PLACER COUNTY AIR POLLUTION CONTROL DISTRICT



## Ozone Emergency Episode Plan

PREPARED IN COMPLIANCE WITH THE FEDERAL CLEAN AIR ACT

April 2015Ozone Emergency Episode Plan Placer County Air Pollution Control District Page 1 of 11

Purpose This Ozone Emergency Episode Plan provide s the basis for taking action to prevent ambient ozone concentrations from reaching levels which could endanger public health, or to abate such concentrations should they occu r. It identifies criteria for the four levels of emergency episodes, components for public announcements whenever an episode has been identified, and specifies em ission control strategies to be taken with each episode.

Legal Authority The Federal Clean Air Act (CAA) 1 gives the U.S. Environmental Protection Agency (U.S. EPA) the legal authority to halt the emission of air pollutants causing or contributing to the injury of the public or their welfare. Th e U.S. EPA is further authorized to either bring a lawsuit in federal cour t or, if such civil action cannot assure prompt protection of public health or welfare, to issue such orders as may be necessary to protect public health, welfare, or the environment. The authority granted to the U.S. EPA Administrator is
vested in the California Air Resources Bo ard (ARB) and the air districts under the California Health & Safety Code (H&SC) 2 . This section of Calif ornia law applies to a range of emissions violations and imposes pe nalties that are equivalent to or exceed federal penalties for comparable violations . These penalties include the imposition of fines and/or imprisonment.

Under the authority of the H&SC, the ARB is responsible for controlling emissions from mobile sources, while districts are responsib le for controlling emissions from non-mobile
sources. H&SC Section 41700 states that sources are prohibited from emitting any pollutant(s) that can cause injury, detriment, nuisance, or annoyance to the public, or that endanger the comfort, repose, health, or safe ty of the public. Furthermore, H&SC Section 42450, et seq., gives districts sp ecific authority to abate em issions from any source violating H&SC Section 41700 or any other orde r, rule, or regulation that prohibits or limits the discharge of pollutants, consistent with applicable notice and hearing requirements. Under H&SC Section 41509, the ARB or other local agency rules cannot infringe upon a district’s authority to de clare, prohibit, or abate a nuisance, and California’s Attorney General is authorized to enjoin any pollution or nuisance, either on his or her own, or by request.

In addition to the authority under H&SC, the lo cal air districts can work with the local governing body of a city, county, or city and county, pursuant to the California Emergency Services Act 3 , to proclaim a local emergenc y when there are conditions of disaster or of extreme peril to the safety of persons and property within the territorial

1 Federal Clean Air Act Section 110(a)(2)(G)

2 California Health & Safety Code Section 42400 et seq.

3 California Emergency Services Act, Calif ornia Government Code Section 8550-8668Ozone Emergency Episode Plan Placer County Air Pollution Control District Page 2 of 11

limits of a city, county, or both a city and county, caused by such conditions as air pollution 4 . When a local emergency is declared, c ities and counties sh all implement their emergency plans and take actions to mitigate or reduce the emergency threat. Actions may include deploying field-level emer gency response personnel such as law enforcement, activating emergency operation ce nters, and issuing orders to protect the public. Through a local emergency declarat ion, the air districts will obtain law enforcement aids from local governing bodi es to accomplish necessary actions for preventing ambient ozone concentration from reaching the harmful level.

Requirement of a Plan for the Prevention of Air Pollution Emergency Episodes Under the Code of Federal Regulations (CFR) 5 , areas that (1) do not attain the federal standards for ozone, and (2) have hourly ozone concentrations above 0.10 parts per million (ppm), are required to develop a cont ingency plan which must, at a minimum, provide for taking action necessary to prevent ambient ozone concentrations at any location in such region from reaching the significant harm level of 0.6 ppm, averaged over two hours. As set forth in CFR, three tr igger levels (stages) are established for the ozone pollution episodes: Al ert level (0.2 ppm), Warn ing level (0.35 ppm), and Emergency level (0.5 ppm) 6 . Corresponding actions for each specified trigger level would be identified and will be implemented when the ambient ozone hourly concentration measurements reach the speci fied trigger levels. These elements and actions should provide for rapid short-term em ission reductions at e ach trigger level, to avoid high ozone concentrations from reaching significant harm levels during an episode.

Development of the Ozone Emergency Episode Plan for Placer County Placer County is classified as non-attainment for the 2008 federal ozone eight-hour average standard 7 . Since Placer County has had more than one day with the maximum one-hour concentration gr eater than 0.10 ppm between 2011 and 2012, the Placer County Air Pollution Control District (PCA PCD) is required to prepare an ozone emergency episode plan (Plan).

Table 1 shows the number of days exceedi ng the 0.10 ppm threshold at the Placer County ozone monitoring sites from 2011 through 2014. During this time, the maximum ozone one-hour concentration was 0.11 ppm, with no site having more than three days in a year that exceeded 0.10 ppm after 2011. Fr om 2013 to 2014, there was only one day in each year that exceeded 0.10 ppm.

4 California Government Code Section 8558 (c).

5 40 CFR 51.150 and 51.151

6 40 CFR 51 Appendix L

7 Portions of Sacramento Valley and Mountai n Counties Air Basins in Placer County are classified as Ozone Nonattainment area.Ozone Emergency Episode Plan Placer County Air Pollution Control District Page 3 of 11

Table 1 Placer County Ozone Monitoring Sites Number of Days with Maximum one-hour Concentration Greater than 0.10 ppm*

2011 2012 2013 2014**

Colfax-City Hall # of Days 0 0 0 0

Max Conc. 0.104 0.097 0.083 0.089

Auburn-Dewitt-C Ave (relocated to Atwood Road

site in 2011 summer) # of Days 1 --- --- ---

Max Conc. 0.105 --- --- ---

Auburn-Atwood Rd # of Days 2 1 0 0

Max Conc. 0.107 0.107 0.097 0.097

Lincoln-L Street (relocated to 1445 1 st Street site at the end of 2012) # of Days --- 1 --- ---

Max Conc. --- 0.107 --- ---

Lincoln-1445 1 st
Street # of Days --- --- 0 1

Max Conc. --- --- 0.081 0.107

Roseville-N Sunrise Blvd # of Days 3 2 1 0

Max Conc. 0.109 0.108 0.111 0.097
*Values were rounded to 2 decimal places before comparing with 0.10 ppm to determine the number of exceedance days **Preliminary data downloa ded from ARB’s Aerometric Data and Management (ADAM) system on 12/13/14

The industrial abatement plan is a prep lanned document prepared by a permitted industrial source (facility) whic h contains the necessary acti ons to rapidly reduce that facility’s emitted ozone precursor emissions when an epis ode level is triggered. In order to require such a plan, an emission thres hold should be established for the industrial abatement plan requirement. Depending on th e ozone emergency plans approved by the
other air districts in California , the emission thresholds to re quire the industrial abatement plan are as low as 50 tons per year for both ROG and NOx emissions 8 . Table 2 shows the five highest facilities with emissions of ROG and NOx within Placer County 9 . The table
indicates that there are two facilities in Placer County that emit more than 50 tons per year of NOx, and no facility emitting more than 50 tons per year of ROG.

8 SMAQMD Rule 701

9 ARB online facility search engine http:// www.arb.ca.gov/app/emsinv/facinfo/facinfo.phpOzone Emergency Episode Plan Placer County Air Pollution Control District Page 4 of 11

Table 2 Five Highest ROG and NOx Emissions Facilities

Emissions from permitted facilities are identified as stationary source emissions. Although Placer County has two f acilities that exceed the 50 t ons per year threshold for NOx, permitted facilities comprise a very small portion of ROG and NOx countywide emission inventories. Figure 1 presents th e reactive organic gases (ROG) and nitrogen oxides (NOx) emission inventor ies in Placer County in 2012 10

.

Figure 1 Placer County 2012 Emission Inventory

According to Figure 1, 23% of ROG emissi ons and 16% of NOx emissions are from stationary sources in Placer County. Within stationary source emissions, only 11% of
ROG emissions and 27% of NOx emissions are from permitted industrial sources. Therefore, permitted industrial sources are responsible for approximately 2.7% and 4.3% of the countywide ROG emissions and NOx emissions, respectively. The major

10 ARB Emission Almanac (published in 2013) Air Basin Facility ID Facility Name City Facility SIC ROG (tons/yr)

Sacramento Valley Air Basin 233 Capital Drum Inc. Roseville 3412 15

Sacramento Valley Air Basin 183 Pacific MDF Product Inc. Rocklin 2431 11

Sacramento Valley Air Basin 1731 Progressive Vanguard Corporation Rocklin 7699 9

Sacramento Valley Air Basin 730 Energy 2001 Inc. Lincoln 7389 6

Sacramento Valley Air Basin 184 Colledgewood Lincoln 2431 6

Air Basin Facility ID Facility Name City Facility SIC NOx (tons/yr)

Sacramento Valley Air Basin 188 Sierra Pacific Industries Lincoln 2421 135

Sacramento Valley Air Basin 212 Rio Bravo Lincoln 4911 119

Sacramento Valley Air Basin 2046 Roseville Energy Park Roseville 4911 14

Sacramento Valley Air Basin 730 Energy 2001 Inc. Lincoln 7389 7

Sacramento Valley Air Basin 403 City of Roseville Roseville 9199 7 Five Highest NOx Emissions Facilities Five Highest ROG Emissions Facilities

* This is the latest complete inventory including mobile sources emissions from ARB. ** It is the latest update from the District permit database based on the actual 2012 throughput data reported by permitted fac ilities in 2013. Off-road mobile 27% On-road mobile 23% Area-wide 27%

District Permit** 11% Stationary

23% 2012 ROG Emissions (21 tpd)*

Off-road mobile 25% On-road mobile 55% Area-wide 4%

District Permit** 27% Stationary

16% 2012 NOx Emissions (23 tpd)*Ozone Emergency Episode Plan Placer County Air Pollution Control District Page 5 of 11

contributions of the ROG and NOx inventorie s are from mobile and unpermitted area and stationary sources, with mob ile source emissions more responsible for ozone formation than permitted industrial s ources in Placer County.

Health Advisory Level The PCAPCD proposes 0.15 ppm as a Health Advisory level to initiate emergency actions. The Health Advisory level (0.15 ppm) is lower than the Alert level (0.2 ppm), which is the lowest of three trigger levels required by the CFR. Figure 2 represents the
annual maximum one-hour ozone concentration measured in Placer County since 1978, when air monitoring began. It also contai ns the red line showing the proposed Health Advisory level at 0.15 ppm.

Figure 2 Annual Maximum one-hour Ozone Concen tration in Placer County since 1978

*Preliminary data downloaded from ARB ADAM on 12/13/14

Figure 2 shows that the 0.2 ppm level was last reached in 1978, which was the first year of air monitoring for ozone in Placer Count y. The ozone concentration trend shows a generally consistent decrease over time, and there has not been an exceedance over 0.15 ppm in the last thirteen years (2000-2013) . Accordingly, Figure 2 shows that the
maximum ozone one-hour concentration in Pl acer County has been s ubstantially reduced and would need a high ozone concentration to trigger the Alert level, and therefore initiate the ozone emergency episode plan implementation.

Ozone concentrations in Placer County have been substantially reduced through the implementation of existing control regulati ons and programs. Place r County is located
within the Sacramento Federal Ozone Nonattainment Area (SFONA), which is designated as nonattainment for the fede ral ozone standards. Two ozone StateOzone Emergency Episode Plan Placer County Air Pollution Control District Page 6 of 11

Implementation Plans (SIP) have been develope d to identify emission control strategies
for mobile and non-mobile sources within the SFONA. Based on the SIP commitments, the PCAPCD adopted or amended rules an d developed programs to facilitate the SFONA’s progress towards attaining the federal ozone standards. The air districts within the Sacramento Region continue to work on the development of control strategies to fulfill the attainment requirement by CAA. Since the current federal ozone eight-hour average standard (0.075 ppm) is more stringen t than the previous one-hour standard, the PCAPCD believes that the development and implementation of control regulations and programs identified by the ozone SIPs will ensure that the ozone one-hour maximum concentrations in Placer County will cont inue decreasing, and would not reach the proposed Healthy Advisory level of 0.15ppm.

In addition, the PCAPCD also regulates various types of open burning, including residential, land development, fire hazard reduction, vegetation management, prescribed fire, and agricultural 11 . For the Sacramento Valley Air Basin, the PCAPCD works cooperatively with the ARB year round, and in the fall, with the Sacramento Valley Air Basin Agricultural Burn Coordinator, to provide daily burn day allocations and notifications based on meteorological condi tions and air quality forecasts. For the
Mountain Counties and Lake Tahoe Air Basins , the District works cooperatively with the ARB on the daily burn day information. The burn day information is broken down into burn day types to help indicate the qua lity of a burn day. Through the existing burn programs, the PCAPCD works carefully to balance the public health impacts from air pollution, along with the open bu rning activities wh ich exist in the county, especially since much of the county is considered a high fire hazard area.

Furthermore, the PCAPCD, along with the ot her air districts within the Sacramento Region, fund the regional “Spare the Air” pr ogram that is managed by the Sacramento Metropolitan Air Quality Manage ment District. This is an air pollution forecasting program which provides notifications to th e public on the daily ozone concentration forecasts, along with advisories with an ep isodic ozone reduction element, during the summer ozone season. It is designed to prot ect public health by in forming people when air quality is unhealthy, and by encouraging the public to reduce vehicle trips to achieve emission reductions. The program’s notifica tion includes current ozone concentration measurements from all monitoring stations within the SFONA, including Placer County, and forecasts, based on the meteorological cond itions from the national weather service advisories and local agencies. When atmos pheric stagnation conditi ons are forecasted, the public will be notified through em ail, text, or the media, that a “Spare the Air Day” is issued. The participation of the Sacramen to regional “Spare the Air” program will

11 PCAPCD Rule 301~306, http://www.placer.ca.gov/departments/air/rulesOzone Emergency Episode Plan Placer County Air Pollution Control District Page 7 of 11

promote the acquisition of forecasts of the atmospheric stagnation conditions, pursuant to the CFR requirements 12

.

In conclusion, the PCAPCD believes that th e proposed Health Advisory level at 0.15 ppm will be an appropriate and logical c ondition, in addition to the required ozone emergency episode levels set forth in the C AA, to initiate and fulfill the air pollution emergency episode actions proposed by the Plan.

Emergency Episode Criteria Table 3 summarizes the four emergency epis ode trigger levels pr oposed by the PCAPCD
for the one-hour ozone concentration meas urement in Placer County. The following section identifies the corresponding actions fo r each trigger level, when that one-hour
ozone concentration is reached.

Table 3 Trigger Levels of Ozone Emergency Episodes in Placer County

Health Advisory Alert (Stage 1) Warning (Stage 2) Emergency (Stage 3)
Ozone (one-hour average) 0.15 ppm 0.20 ppm 0.35 ppm 0.50 ppm

Proposed Actions for Ozone Emergency Episodes: The actions identified for each trigger leve l of the ozone emergency episodes include public notification and emissions mitigati on for industrial and mobile sources. The purposes of these actions are 1) to provide notification to the public when atmospheric stagnation conditions would result in su bstantially high ozone concentration measurements, and 2) to reduc e the ozone precursor emissions rapidly in order to lower
the ozone concentration below the tr iggered emergency episode level.

Air Pollution Forecast
The PCAPCD continues to use the Sacramen to regional “Spare th e Air” program to provide public notification for air quality forecasts when atmospheric stagnation conditions would result in substantially high ozone concentrati on measurements. The notification with episodic ozone reduction strategies is to encourage the public to take voluntary actions to reduce ozone precursor emissions.

Emergency Episode Declaration Whenever the ozone one-hour concentration, measured at any location within Placer County, reaches or is predicted to reach any of the episode trigger levels as shown in

12 40 CFR 51.152 “Contingency Plans”Ozone Emergency Episode Plan Placer County Air Pollution Control District Page 8 of 11

Table 3, the PCAPCD shall declare that an emergency episode is in effect in Placer County.

In addition, should the Air Pollution Control O fficer (APCO) of a district adjacent to the PCAPCD declare a stage 1, 2, or 3 episode within that district and re quest assistance, the APCO of PCAPCD may implement measures as described in this Plan as if such episode
level has been measured within the District.

Notification of an Emergency Episode
The PCAPCD shall establish a nd periodically update and re view an emergency episode notification list (List). When any emergency episode is declared, the APCO shall notify
the officials on the List. The Li st shall include, and is not limited to, the following public agencies and organizations:

1. California Air Resources Board,
2. The Placer County Executive Officer, chief ex ecutive officers of the incorporated municipalities within Placer County, poli ce chiefs, fire chiefs, and any other public safety officers as deemed appropriate by the APCO,
3. The Placer County Health Officer,
4. The Placer County Office of Emergency Services,
5. The Placer County Office of Education Superintendent, school districts’ superintendents , and priv ate schools’ principals,

6. All air pollution control districts w ithin the Sacramento Valley, Mountain Counties and Lake Tahoe Air Basins, as well as all upwind districts.

7. Major newspapers in daily circulation a nd major television and radio stations (including those who are part of the em ergency broadcast system) broadcasting within Placer County for appropriate warning, notices, and advisories,
8. Sacramento Regional Spare the Air Program,

9. PCAPCD permitted facilities, and
10. PCAPCD Staff who are respons ible for public outreach.

Content of Notification Notification of an emergency episode sha ll include information on the predicted or current episode level, the expected durati on of the episode, the expected geographic boundaries of the affected area, a statement fo r the public on the health significance of the air quality during the epis ode, and the appropriate voluntary or mandatory control actions proposed for each episode level.Ozone Emergency Episode Plan Placer County Air Pollution Control District Page 9 of 11

Termination of an Emergency Episode The PCAPCD shall declare an episode as terminated when the one-hour ozone
concentration measurements from all monito ring sites within Placer County fall below the level of the Alert episode and the meteorological data indicates the ozone concentration is expected to continue decreasing.

Notification of the Termination of an Episode Upon the declaration of the te rmination of an episode, the PCAPCD shall notify those agencies and organizations specified in the List.

Actions for Each Emergency Episode When an emergency episode is declared, the PCAPCD shall implement the following
control actions:
1. Health Advisory Episode: a) Prepare the emergency episode notification; b) Notify those public agencies and organiza tions identified in the List that a health advisory episode has been declared; c) Advise the Placer County Office of Edu cation Superintendent that sustained strenuous activities by stude nts (for both public and private schools) lasting longer than one hour sh ould be discontinued; d) Through the Placer County Office of Em ergency Services, notify the news media to broadcast the appropriate warn ing to the public, which will include a recommendation that the public curtail unnecessary motor vehicle operation; e) Work with the industry to identify targ eted facilities w ith possible emission
control actions to reduce the relative emissions; and f) Coordinate with the Placer County Offi ce of Emergency Serv ices to identify possible actions which shall be taken when Placer County declares a local emergency for an air pollution emergenc y, which might include, for example, ceasing painting, construction, lawn mo wing, pesticide application, and charcoal grilling.

2. Alert (Stage 1) Episode: a) Prepare the emergency episode notification; b) Notify those public agencies and organiza tions identified in the List that an Alert episode has been declared; c) Request the Placer County Office of E ducation Superintendent contact the School Superintendents and coordinate with private scho ols, to suspend students’ strenuous activities;Ozone Emergency Episode Plan Placer County Air Pollution Control District Page 10 of 11

d) Through the Placer County Office of Em ergency Services, notify the news media to broadcast the appropriate warn ing to the public, which will include a request that the public to curtail any unnecessary motor vehicle operation; e) Request targeted facilities to initiate specified emission control actions to
reduce relative emissions and to reco mmend employees refrain from using their vehicles until the episode is terminated; f) Conduct on-site inspection of targeted facilities to ascertain accomplishment of applicable emission control actions; and g) Prohibit all open burning, including ag ricultural burning, and incineration throughout the affected area, except in an emergency situation as provided
for in Section 41862 of the H&SC.

3. Warning (Stage 2) Episode: In addition to the actions associated with the Stage 1 Alert episode, the following actions should be implemented in a Warning episode. a) Request that those agencies and organizat ions in the List, within the scope of their authority:
i. Prohibit all types of open burni ng, including agricultural waste;
ii. Close all non-essential public agen cy facilities, except emergency
facilities and those facil ities necessary in emerge ncies to protect national security or national defense; and
iii. Request that employees of closed n on-essential public agency facilities refrain from using vehicles unt il the episode is terminated. b) Request closure of all public and priv ate schools, colleges , and universities within Placer County; c) Request targeted facili ties to shut down; d) Request that employees of facilities which close refrain from using vehicles until the episode is terminated; e) Conduct on-site inspection of facilities to ascertai n the accomplishment of applicable emission control actions; f) Request the suspension of all indoor and outdoor events at parks or recreational facilities open to the public; g) Request the suspension of all sc heduled athletic events; and h) Request that the Placer County Ex ecutive Officer and Health Officer consider declaring a local emergency fo r air pollution, pursuant to the Placer County Code 13 , and implement emergency control measures, pursuant to the California Emergency Services Act, wh en the ambient ozone concentration continues rising and reac hes the level at 0.45 ppm.

13 Placer County Code Article 2.88 Emergency ServicesOzone Emergency Episode Plan Placer County Air Pollution Control District Page 11 of 11

4. Emergency (Stage 3) Episode: In additi on to the actions associated with the Stage 2 Warning episode, the following actions should be implemented in the Emergency episode. a) Request that the Placer County Executiv e Officer declare a local emergency for air pollution and initiate it s emergency operations plan; b) Request the media to broadcast to the publ ic that a local emergency exists for air pollution, due to high ozone concentrations; c) Through the Placer County Office of Emergency Service operations, the following actions shall be conducted, but are not limited to:
i. Close all government facilities whic h are not immediately necessary for public health and safety, national security or national defense;
ii. Close all recreational facilities, including but not limited to those servicing boating and off-road vehicles;
iii. Close all non-emergency commercia l and industrial facilities;
iv. Request implementation of emerge ncy carpooling, or the use of mass transportation;

v. Request that the public use only mass transit; and
vi. Hospitals within the affected area shall be notified of the alert level to prepare for the possible increase in the number of patients seeking

treatment. d) Close principal streets, as deemed necessary by the Placer County Executive Officer, Health Officer, APCO, and local law enforcement agencies, in order to protect the health and we lfare of the general public; e) Request that the Placer County Office of Emergency Services engage with the State agency for necessary actions pursuant to the California Emergency Services Act, which includes prohibiting the use of all motor vehicles except for emergencies, or any othe r action deemed warranted; f) Restrict all non-essential construction and painting; and g) Restrict all lawn care and mowing activities and stop the use of lawn and garden chemicals.

The PCAPCD commits to implementing the proposed actions associated with each episode identified in this Plan. The implement ation of the Plan shall prevent the ambient
ozone concentration from reachi ng the harmful level at 0.60 ppm.