T ec hnic a l S uppo r t D o c u ment

for the

Chico Nonattainment Area (Partial Butte County )

2011 Daily Winter

- Time Emissions Inventory

Base Year 2005

- Grown and Controlled in Tons p er Day

S ubm i t t e d to EPA on November 15, 2012 b y the California Air Resources Board ( C ARB)

December 20 , 2013I. I n t r o duc tion

The pur p ose o f this doc u ment is to supplement the technical information provided in the direct final federal register notice approving the Chico, CA/Butte County (partial) Planning Area 201 1 P M 2.5 Emission Inventory sub m i t ted to EPA on November 15, 2012 by the California Air Resources Board (CARB) on behalf of the Butte County Air Quality Management District (District or BCAQMD )

. 1 A n y
q ue st i ons p e rt a in i ng to t his technical support document (T SD) should be d irec ted to Nancy Levin at 415

- 972

- 3848 or levin.nancy@ epa.gov

.

II. Procedural Requirements for Adoption and Submittal of SIP Revisions

Sections 110(a)(1) and 110(l) of the Act require states to provide reasonable notice and public hearing p rior to adoption of SIP revisions. Section 110(k)(1)(B) requires EPA to determine whether a SIP submittal is complete within 60 days of receipt. Any plan that we have not affirmatively determined to be complete or incomplete will become complete six months after the day of submittal by operation of law. A finding of completeness does not approve the submittal as part of the SIP nor does it indicate that the submittal is approvable. It does start a 12

- month clock for EPA to act on the SIP submittal. See CAA section 110(k)(2).

a. Reasonable notice and public hearing

CARB’s submittal documents the public review process followed by Butte County Air Quality Management District (BCAQMD) and CARB in adopting the Chico emission s inventory prior to submittal to EPA. CARB’s submittal includes a copy of the notice to the public published on August 17, 2012, announcing a public hearing to be held on September 27, 2012. The notice for the public hearing was published in the Chico Enterprise

- Record and the Oroville Mercur y

- Register, newspapers of general circulation, on August 17, 2012. The PM 2.5 emissions inventory was also made available for viewing on the District's website and at the District office on and after August 17, 2012. CARB’s submittal includes

a letter date d August 17, 2012 from W. James Wagoner, Air Pollution Control Officer to the Board of Directors for the BCAQMD recommending that the Board consider comments at the public hearing and approve the resolution adopting the proposed PM 2.5 emission inventory an d forward it to CARB

. The documentation provides evidence that reasonable notice of a public hearing was provided to the public and that a public hearing was conducted prior to adoption

. CARB’s submittal documents the adoption of the emission s inventory by the BCAQMD Board of Directors. On September 27, 2012, the BCAQMD Board of Directors approved the emission s inventory and directed BCAQMD staff to forward the Chico emission s inventory to CARB, the Governor of California’s designee for SIP matters. 2 CARB’ s submittal includes a public hearing notice for October 18, 2012, 3 a transcript, 4 and its October 18, 2012

1 CARB adopted the 2011 PM2.5 Emission Inventory for the Chico nonattainment area in 2012; therefore, CARB refers to it as the “2012 PM2.5 Emission Inventory Submittal to the State Implementation Plan for the Chico, CA/Butte County (partial) Planning Area.” However, the actual inventory in the CARB submittal (Appendix D) is titled “Chico Nonattainment Area (Partial Butte County) 2011 Daily Winter

- Time Emissions Inventory (Base Year 2005

- Grown and Controlled in Tons Per Day.” For purposes of this action, any reference to the 2012 PM2.5 Emissions Inventory is equivalent to the Chico 2011 winter

- time PM2.5 emission inventory.
2 BCAQMD Revised Resolution No. 2012

- 12, September 27, 2012

. 3 CARB Notice of Public Meeting to Consider Approval of the 2012 PM 2.5 Emiss ion Inventory Submittal to the StateBoard resolution regarding the Chico emission s inventory. 5 On November 15, 2012 , CARB submitted the inventory to EPA for approval as a revision to the California SIP.

Based on the documentation included in CARB’s submittal, we find that the submittal of the Chico , CA/Butte County (partial) Emissions Inventory as a SIP revision satisfies the procedural requirements of sections 110(l) of the Act for revising SIPs.

b. Completeness review

A completeness review allows us to determine if the submittal includes all the necessary items and informatio n we need to act on it. We make completeness determinations using criteria we have established in 40 CFR part 51, Appendix V. These criteria fall into two categories: administrative information and technical support information. The administrative informat ion provides documentation that the State has followed basic administrative procedures during the SIP

- adoption process and thus we have a legally

- adopted SIP revision in front of us. The technical support information provides us the information we need to determine the impact of the proposed revision on attainment and maintenance of the air quality standards. We notify a state of our completeness determination by letter unless the submittal becomes complete by operation of law. The Chico , CA/Butte County (p artial) Emissions Inventory became complete by operation of law on May 15 , 2013.

III. Summary of SIP Revisions

The SIP revision submitted by CARB on November 15, 2012 for the Chico/Butte County (partial) Planning Area provides a 2011 daily winter

- time emis sions inventory (“Base Year 2005

- Grown and Controlled in Tons per Day”) , with emission estimates for PM 2.5 , volatile organic compounds (VOCs 6 ), nitrogen oxides (NO x ), sulfur dioxide (SO 2 ) and ammonia (NH 3 ) . The Chico/Butte County (partial) Planning Area 2 011 daily winter

- time emissions inventory for PM 2 .5 is attached

. The federal register notice approving this inventory provides a summary of the inventory and the procedural and technical basis for approval . In addition to the information provided in the federal register notice, we provide information in the following sections IV and V.

I V. Clarification Regarding Calculation of PM 2.5 Emissions from Paved Roads

The 2011 emissions inventory for the Chico no nattainment area submitted by CARB estimates
PM 2.5 emissions from paved roads to be approximately 0.2 tons per day. CARB estimated annual PM 10 emissions using the Jan uary 2011 AP

- 42 paved road dust emission factor equation with California

specific silt loa dings. Historical days of rain were used for the rainfall adjustment factor. CARB used California speciation profile #471 to calculate PM 2.5 from PM 10 (PM 2.5 = 0.15 * PM 10 ). http://www.arb.ca.gov/ei/speciate/dnldoptvv10001.php#specprof

. This differs from t he 25% particle size fraction for PM 2.5 / PM 10 given in the AP

- 42. Emissions estimates used 2008 annualized VMT per

Implementation Plan for the Chico Planning Area, October 1, 2012.
4 Meeting, State of California, Air Resources Board, Sacramento, California, October 18, 2012.
5 CARB Resolution 12

- 31, October 18, 2012.
6 BCAQMD uses t he term Reactive Organic Gas (ROG) rather than VOC. EPA formerly defined the regulated organic compounds in outdoor air as ROG. However, EPA later changed that terminology to “VOC.”average weekday from EMFAC

- 2011SG, apportioned to road category using 2008 Caltrans HPMS travel fractions. The 2008 base year emissions for t he Chico nonattainment a rea were projected to 201 1 using centerline miles. 7

EPA has reviewed CARB’s methodology for estimating PM 2.5 emissions from paved roads and determined that the methodology used for calculat ing the 2008 base year is acceptable ; however, use of centerline miles to project the 201 1 inventory has not been approved by EPA. Because the paved road emissions estimate is not being used to create a motor vehicle emissions budget (MVEB) for the Chico
PM 2.5 nonattainment area and because th e difference in emissions between 2008 and 2011 is expected to not be significant , EPA is not requiring at this time that CARB revise the PM 2.5 emissions es timate for paved roads . If in the future a MVEB and a maintenance plan for the area are submitted to EPA, the paved road PM 2.5 emissions estimate would need to be derived by a method approved by EPA.

V. Attachment

Chico Nonattainment Area (Partial Butte County) 2 011 Daily Winter

- time Emission Inventory (Base Year 2005

- Grown and Controlled in Tons per Da y ) , Appendix D.

7 December 11 and 12, 2013 emails from Janet Spencer, CARB, to John Ungva rsky, EPA Region 9,