# Grants Pass PM10 Limited
Maintenance Plan

Submitted to: U.S. Environmental Protection Agency

By: State of Oregon Department of Environmental Quality

April 2015

DEQ Environmental
Solutions Air Quality Program

811 SW 6th Avenue Portland, OR 97204

Phone: (503) 229

- 5696 (800) 452

- 4011

Fax: (503) 229

- 6762

Contact: Brian Finneran www.oregon.gov/DEQ

DEQ is a leader in restoring, maintaining and enhancing the quality of Oregon’s air, land and

water.

## State Implementation Plan Revision
Grants Pass PM 10 

## Limited Maintenance Plan



# A Limited Maintenance Plan
for Particulate Matter ( PM 10 

# )

T he Grants Pass Urban Growth Boundary

State of Oregon Clean Air Act Implementation Plan

Adopted by the Environmental Quality Commission on April 16 , 201 5

State of Oregon Department of Environmental Quality
811 SW Sixth Avenue Portland, OR 97204

- 1390

### Table of Contents

Acknowledgments

................................ ................................ ................................ ............................ i

Executive Summary

................................ ................................ ................................ ........................ ii

Plan Struc ture

................................ ................................ ................................ ................................ . iii

1. Introduction

................................ ................................ ................................ ................................ . 1

2. Geographic Area

................................ ................................ ................................ ......................... 1

3. History of PM 10 Problem in Grants Pass

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

4. Tracking Current PM 10 Levels in Grants Pass

................................ ................................ ........... 4

5. Limited Maintenance Plan Option

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

6. Emission Inventory

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

7. Continuing Control Measures

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

8. Contingency Measures

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

9. Commitment to Continued Monitoring and Verification of Continued Attainment

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



### Table of Figures

Figure 1. Grants Pass UGB and location of the Parkside School PM 10 Monitor

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

Figure 2. Grants Pass PM 10 Trend 1987

- 2013

................................ ................................ ............... 4

Figure 3. Grants Pass Parkside School PM 10 /PM 2.5 Correlation

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

Figure 4. 2011 Grants Pass Annual PM 10 Emissions

................................ ................................ .... 8

Figure 5. 2011 Grants Pass Worst Case Day PM 10 Emissions

................................ ...................... 8



### Table of Tables

Table 1. Grants Pass Maximum 24

- hour PM 10 Highest Values 1987

- 2008

................................ .. 3

Table 2. 2011 Grants Pass UGB PM 10 Daily and Annual Emission Inventory

............................. 8

Table 3. Grants Pass PM 10 Continuing Control Measures

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



### Appendices

Appendix A: EPA 2001 Wegman Memo

Appendix B: Grants Pass 2011 Emission Inventory

Appendix C: Motor Vehicle Regional Analysis Test

Appendix D: DEQ Report: Justification for Discontinuation of Monitoring in Carbon Monoxide

and PM 10 Maintenance Areas , 2011

Appendix E: Inventory Preparation and Quality Assurance Plan

Grants Pass PM10 Limited Maintenance Plan

### A cknowledgments

Principal Author: Brian Finneran, DEQ Air Quality Plann ing

Principal Contributors:

Oregon Department of Environmental Quality

David Collier Air Quality Planning Manager

Aida Bi beric Air Quality Planning Anthony Barnack Air Quality Planning

Wes Risher Air Quality Technical Services

Chris Swab Air Quality Technical Services

Environmental Protection Agency

Lucy Edmondson EPA Region X Claudia Vaupel EPA Region X

Bob Kotchenruther EPA Region X

Grants Pass

Dan Moore Rogue Valley Council of Governments

Jonathan David Rogue Valley Council of Governme nts

Other support:

Tom Carlson Sierra Research, Inc

Grants Pass PM 10 Limited Maintenance Plan Page i

### Executive Summary

The City of Grants Pass and surrounding area currently meets the federal standard for Particulate Matter 10 microns and smaller ( PM 10 ). This State Implementation Plan (SIP) revision explains how this area will continue to meet this standard through 202 5 . EPA sets standards for particle pollution because smaller particles such as soot, dust, and unburned fuel can penetrate deeply into the lungs and cause health problems. The c urrent 24

- hour federal health standard for PM 10 , set in 1987, is 150 micrograms per cubic meter (μg/m 3 ). To maintain compliance with the standard, monitored levels should not exceed the daily standard more than once a year over three consecutive years.

Th e Grants Pass area, defined as the Urban Growth Boundary (UGB), last violated the daily standard in 1988. Smoke from woodstoves and fireplaces were the major contributing sources. As a result of this violation, EPA formally designated Grants Pass as a mode rate nonattainment area in 1990, and an attainment plan was adopted, containing PM 10 control measures for woodstoves, open burning, forestry burning, industrial growth, and others. The area was reclassified to attainment after DEQ adopted the PM 10 maintena nce plan in 2002 (see 68 FR 61111) . This plan was designed to maintain compliance with the daily PM 10 standard through the year 2015. A second maintenance plan is now required, and once approved by EPA, will fulfill the final maintenance planning require ments under the Clean Air Act.

The 2002 PM 10 maintenance plan allowed for some future growth while ensuring continued protection of public health. It replaced the most stringent emission control requirements for new or expanding major industry with some flexibility for industrial growth, established a PM 10 emissions budget for future transportation projects, and a contingency plan in case of an

exceedance or vio lation of the PM 10 standard.

Grants Pass qualifies for a Limited Maintenance Plan (LMP), which is an option EPA provides for areas at low risk of exceeding the PM 10 standard (see EPA’s 2001 Wegman Memo

, Appendix A ). The design value is 49 μg/m 3 (2004

- 20 08 ) for the most recent 5

- year average of

PM 10 monitoring data, and is the same value for most recent 5 years (2009

- 2013) based on

estimated PM 10 levels , which is well below the daily standard. According to the LMP guidance,

EPA will consider the maintenance demonstration satisfied if the monitoring data shows the design value is at or below 98 μg/m 3 for the 24

- hour PM 10 standard, and if the area expects only limited growth in on

- road motor vehicle emissions. The Grants Pass UGB passes the Motor

Ve hicle Regional Analysis outlined in the Wegman Memo

.

PM 10 monitor ing began in Grants Pass in 198 7, and was removed in 2008 (with EPA approval)

due to me asured PM 10 levels being well below the 24

- hour federal health standard for over 10

years. 1 Since then a surrogate method for estimating PM 10 levels has been used based on PM 2.5 monitoring and applying an established correlation between PM 10 and PM 2.5

. U nder the Grants

Pass LMP

, DEQ has committed to continue operating the PM 2.5 monitor and estimating PM 10 levels in order to to demonstrate continued compliance with the PM 10 NAAQS

. Should it become necessary to remove the PM 2.5 monitor during the period of the LMP, DEQ will estimate

1 See Appendix D: DEQ Report: Justification for Discontinuation of Monitoring in Carbon Monoxide and PM 10 Maintenance Areas , October 2011.

Grants Pass PM 10 Limited Maintenance Plan Page iiPM 10 levels using a beta attenuation mass (BAM) monitor

, approved by EPA as a F ederal

E quivalent Method for measuring PM 10 , in order to track PM 10 levels for the remainder of the limited maintenance plan

. EPA approval will be obtained prior to this change. To quantify

PM 10 emission sources in Grants Pass

, the EPA 2011 National Emission Inventory (NEI) was used for this plan.

The control and contingency measures from the first Grants Pass PM 10 maintenance plan remain in place. To qualify for the LMP approach, these measures must remain unchanged. The control strategies include a residential woodstove curtailment program, ban on the use of uncertified woodstoves, BACT controls for large new or expanding industrial sour ces, outdoor open burning restrictions, and prescribed forestry burning smoke management protection. As noted in the Wegman Memo , while federal conformity rules still apply, an emissions budget and regional emissions analysis will no longer be needed.



### Plan Structure

This SIP revision includes the compliance history for Grants Pass and describes how the

area met and will continue to meet the standard.

This document is organized as follows:

Section 1

– Introduction . D escribes the purpose of this second maintenance plan , and summary

on the PM 10 standard

.

Section 2

– Geographic Area. Describes the geographic area covered by the maintenance plan,

Section 3

– H istory of the PM 10 Problem. Summarizes Grants Pass PM 10 compliance history and past monitoring PM 10 data and trends

.

Section 4

– Tracking Current PM 10 Levels in Grants Pass

. Shows how future PM 10 monitoring will take place, using the correlation of PM 10 to PM 2.5 , and justification for using this surrogate monitoring method

.

Section 5

– Limited Maintenance Plan Option . D escribes the criteria an area must meet to qualify for this option and how Grants Pass qualifies.

Section 6

– Emission Inventory . I ncludes historical information on the most significant PM 10 emission categories from the original maintenance plan and an updated inventory on these categories

.

Section 7

– Continuing Control Measures . L ists the measures that were in the original maintenance plan

, and how these measures will be continued under th is LMP.

Section 8

– Contingency Plan

. Describes the contingency plan should a violation occur in the

future.

Grants Pass PM 10 Limited Maintenance Plan Page iiiSection 9

– Commitment to Continued Monitoring and Verification of Continued Attainment

. D escribes how monitoring will be continued and how compliance will be confirmed

.

Appendices

– Supporting documentation for this LMP.

Grants Pass PM 10 Limited Maintenance Plan Page iv

### 1. Introduction

This State Implementation Plan revision explains how the Grants Pass PM 10 maintenance area

, as defined in OAR 340

- 204

- 0010 (the Grants Pass UGB) w ill continue to meet the National Ambient Air Quality Standard (NAAQS) for particulate matter ten microns or smaller ( PM 10 ) through 202 5

. This plan represents a “limited” maintenance plan, developed in accordance with the federal Clean Air Act and the policies of the U.S. Environmental Protection Agency (EPA) (see Appendix A “ Wegman Memo ”)

.

The Clean Air Act requires EPA to set air quality standards to protect public health for six common air pollutants, including particulate matter. On July 1, 1987, EPA revised the particulate matter NAAQS from total suspended particulate (TSP) to PM 10 , or particulate matter

that is ten microns is size or less

. Particulate in this size range c an be inhaled deeply into the lungs where they can remain for weeks to years and aggravate respiratory conditions, such as bronchitis, asthma, emphysema, and similar diseases. Health effects caused by particulate matter vary based upon the size, concentra tion, and chemical composition of the particles. In addition, there may be several potential carcinogens present on particulate matter. Of particular concern are the condensed organic compounds released from low temperature combustion processes such

as w ood stoves. Sensitive groups that appear to be at greatest risk to these effects include the elderly, individuals with cardiopulmonary disease, and children.

EPA established the PM 10 standard at 150 micrograms per cubic meter (μg/m 3 ) for the 24

- hour average and 50μg/m 3 for the annual average. If an area is in violation of the standard, EPA designates it as a nonattainment area. State and federal restrictions are placed on nonattainment areas as needed to improve air quality and meet standards.

In addition to the PM 10 standard, EPA adopted the PM 2.5 standard in 1997, for smaller or fine particulate matter 2.5 microns in size or less , since the smaller inhalable particles have been found to pose a greater health risk

. This standard is set at 35 μg/m 3 for the 24

- hour average and

12 μg/m 3 for the annual average. Grants Pass has never violated the PM 2.5 standard.



### 2. Geographic Area

The C ity of Grants Pass is located in southwestern Oregon, on the western side of the Cascade Mountains, in the Rogue Valley, northwest of Medford and along the Rogue River. The city is approximately 11 sq. miles in area, and the US Census 201 3 population was 3 5

, 076

. The surrounding hills can trap air pollution under stable meteorological conditions (inversions ). These conditions exist most frequently during the late fall and winter and are associated with the majority of the particulate matter violations.

Figure 1 depicts the Grants Pass UGB, which is the geographic area subject to this limited maintenance pl an. The map also shows the location of the Grants Pass Parkside School Air Quality Monitoring Station (2002

- 2008)

, located at the corner of SW Wagner and M streets, at an elevation of 277 meters (801 ft).

Grants Pass PM 10 Limited Maintenance Plan Page 1Figure 1

. Grants Pass UGB and location of the Park side School PM 10 Monitor



### 3 . History of PM 10 

### Problem in Grants Pass

DEQ began monitoring PM 10 in Grants Pass in 198 7 . The monitor was located at 11th and K

Streets in downtown Grants Pass for 14 years, until 1 999. A second PM 10 monitor was located at

720 NE 11th Street from 1993 to 1999. Due to the loss of property access, both monitors were

removed in 1999 and a new monitor was established at the sewage treatment plant at 1200 SW

Greenwood Ave. This monitor was moved in 2002 to Parkside School at SW Wagner and M

streets

. In 2008, that monitor was permanently removed with EPA approval, due to very low

PM 10 levels being measured and resource/budget considerations

. 2 Prior to removal, in 2006 a

PM 2.5 monitor was co

- located at Parkside School with the PM 10 monitor, from which estimated

PM 10 values could be derived. Since then, this PM 2.5 monitor and a continuous non

- FRM

monitor (nephelometer) ha ve been in operat ion

.

2 See Appendix D: DEQ report “ Justification for Discontinuation of Monitoring in Carbon Monoxide and PM10

Maintenance Areas ”, October 2011

Grants Pass PM 10 Limited Maintenance Plan Page 2A violation of the 24

- hour PM 10 standard occurs when there are more than three exceedances of the standard within three years. The highest 24

- hour PM 10 concentration recorded in Grants

Pass occurred in 1987 at a level of 268 μg/m 3

. There were three exceedances of the 24

- hour standard in that year. By the early 1990’s , maximum levels were closer to the public health standard, and there have been no violations since 1987. Grants Pass has never violated the annual

PM 10 standard of 50 μg /m 3

.

In 1987, Grants Pass was categorized as a “Group 1 Planning Area” by EPA for violating the 24

- hour PM 10 standard

, based on a design value of 171 μg/m 3 . In 1990, EPA formally designated

Grants Pass as a moderate nonattainment area for the 24

- hour standard. The UGB was

established at that time as the PM 10 nonattainment boundary

.

Monitoring data shows that Grants Pass area has been in attainment of the 24

- hour standard since

1989. In 2003, th e area was reclassified to attainment for the 24

- hour PM 10 standard

, when EPA approved the first maintenance plan designed to maintain compliance with the 24

- hour PM 10 standard through the year 2015 (see 68 FR 61111)

. The maintenance plan allowed for some future growth while ensuring continued protection of public health. It replaced the most stringent emission control requirements for new or expanding major industry with some flexibility for indust rial growth, established a PM 10 emissions budget for future transportation projects, and a contingency plan in case of an exceedance or violation of the PM 10 standard.

T his limited maintenance plan is the second and final maintenance plan required, design ed to ensure compliance through 2025.

The maximum 24

- hour PM 10 concentrations measured for the years 198 7 to 2008 is provided in

T able 1. The t rend in PM 10 concentrations over the same time period is shown in Figure 2

, using the second highest 24

- hour PM 10 concentration rather than the maximu m, based on how compliance with the standard is determined

. 3

Table 1

. Grants Pass Maximum 24

- hour PM 10 Highest Values 1987

- 20 13

Year Max PM 10

μ g/m 3 Max

d ate

1987 268 09/06

1988 136 01/27

1989 151 01/27

1990 113 01/20

1991 141 01/03

1992 104 11/12

1993 132 12/27

1994 92 02/01

1995 77 11/04

1996 65 11/12

1997 89 01/15

1998 62 12/23

1999 43 11/11

3 The PM 10 standard allows one exceedance per year at any given location (averaged over a consecutive three

- year period).

Grants Pass PM 10 Limited Maintenance Plan Page 32000 43 01/29

2001 55 11/12

2002 45 11/09

2003 56 11/14

2004 36 02/12

2005 48 07/27

2006 39 12/31

2007 41 02/05

2008 43 0 6 / 29

estimated PM 10 using PM 2.5 data

200 9 49 11 / 09

20 10 46 12/ 04

20 11 4 1 1 2/ 23

20 12 25 0 1 /0 4

20 13 111* 0 8 / 02

20 13 45 11/24 *wildfire smoke impact

Figure 2 . Grants Pass PM 10 Trend 1987

- 20 13

2 nd highest 24

- Hr Average



### 4. Tracking Current PM 10 

### Levels in Grants Pass

As noted above, in 2008 the PM 10 monitor in Grants Pass was removed with EPA approval, due to very low levels being measured

. Comparable Federal Reference Method PM 10 and PM 2.5 monitors were co

- located at Parkside School in Grants Pass from 2006

- 2008 , from which a 0 50 100 150 200 250

1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014(μg/m3)

Year NAAQS 150 μ g/m 3

Second Highest Value used for showing
compliance with PM10 Standard Estimat

ed

PM10

Grants Pass PM 10 Limited Maintenance Plan Page 4reliable PM 10 estimat ion methodology was developed , using the equation in Figure 3 . It is expected if current low PM 10 levels continue, budget considerations may lead to the removal of

t he PM 2.5 monitor and its relocat ion to another community

. Should this occur, DEQ would then

install a beta attenuation mass (BAM) monitor , approved by EPA as a F ederal E quivalent Method for measuring PM 10 , in order to track PM 10 levels for the remainder of th e limited maintenance plan

. EPA approval will be obtained prior to removing the PM 2.5 monitor and installing a FEM BAM for PM 10

. See Section 9 for additional information.

PM 10 /PM 2.5 Correlation

A l inear regression analysis was performed on the PM 10 and PM 2.5 data

, as shown in Figure 3.

This shows the correlation has an R Squared of 0.94

, which is very high and shows that the linear regression equation of y = 1.2x + 2.6 can be used for calculating PM 10 levels

.

Figure 3

. Grants Pass Parkside School PM 10 / PM 2.5 Correlation



### 5

. Limited Maintenance Plan Option

The EPA developed the Limited Maintenance Plan (LMP) option for areas with little risk of re

violating the PM 10 standard (see 2001 Wegman Memo , Appendix A)

. EPA allows states to use this policy to prepare the required second 10

- year maintenance plans, if the area meets three criteria in the EPA LMP Option Guidance. The first is that an ar ea should be attaining the PM 10 standard, the second that the average PM 10 design value based on the most recent 5 years of air quality data should be at or below 98μg/m3 , and the third that the area should expect only limited growth in on

- road motor vehicle emissions and pass a motor vehicle regional emissions analysis

test , in accordance with Appendix B of the LMP Guidance

. The Grants Pass area meet s all th ree criteria

. As noted in Section 3, PM 10 monitor ed data over the last 15 years have been well below

the 24

- hour standard.

Grants Pass PM 10 Limited Maintenance Plan Page 5EPA’s PM 10 SIP Development Guideline outlines four approaches to determining the PM 10 design value. DEQ relied upon the table look

- up procedure, as noted in Table 6

- 1 of the guidance. 4 Calculating the design value using this method provides the most conservative design value. Two PM 10 design values for Grants Pass are provided here . The first is 49 μg/m 3

, based on the most recent 5 years of FRM monitoring data ( 2004

- 2008 ) prior to removal of the

PM 10 monitor . The second design value is also 49 μg/m 3 , based on the most recent 5 years of

estimated PM 10 levels ( 2009

- 2013) using the equation in Figure 3

. Both are well below the 98 μg/m 3 value stipulated in the LMP Guidance. The area expects very limited growth in on

- road

motor vehicle emissions , as demonstrated by passing the Motor Vehicle Regional Analysis

. 5



### 6

. Emission Inventory

This section presents the emissions inventory for th e second 10

- year maintenance plan and briefly describes its development. The LMP Guidance requires that the maintenance plan include an inventory with emission levels consistent with attainment of the PM 10 standard. An inventory preparation plan, including a quality assurance plan, for the Grants Pass UGB was submitted to EPA in March 2014, and is provided in Appendix E . EPA reviewed the plan and agreed that the inventory be developed using EPA’s 2011 National Emission Inventory (NEI) data for Josephine

Co unty, as the most recent, complete, readily available emission inventory . This approach is

consistent with the 1993 emission inventory developed for the first maintenance plan. In accordance with requirements for the LMP option, no emission projections we re calculated.

Historical ly, exceedences of the 24

- hr PM 10 standard in Grants Pass have occurred during the

winter months

, or between November 1 and the end of February. As such, in addition to annual

emissions

, typical season day and worst

- case season day emissions are included in the inventory.

The term “worst

- case day” describes the maximum activity/emissions that have occurred or could occur on a season day, for each emissions source. Worst

- case day emission s are summed for all sources/categories, i.e. assumed to occur on the same day. Th is assumption is the basis

for what would be needed to cause an exceedence of the 24

- hr standard . The unit of measure for

annual emissions is in tons per year (tpy), while the unit of measure for season day emissions is

in pounds per day (lb/day). In addition, the county

- wide EI data was spatially allocate d to the
Grants Pass UGB, and to buffers around the UGB or monitor, depending on emissions category.

At noted in Table 2 and Figures 5 and 6 below, the most significant categories of PM 10 emissions in the Grants Pass UGB are area sources (mostly home wood

- heating), on

- road mobile sources (mostly re

- entrained road dust )

, point sources (industry), and non

- road ( engine and equipment) sources

. A detailed breakdown of the 2011 PM 10 Emission Inventory is provided in Appendix B.

4 PM

- 10 SIP Development Guideline, publication EPA 450/2 86

- 001, Table 6

- 1, pp.6

- 5

5 See Appendix C: Motor Vehicle Regional Analysis Test.

Grants Pass PM 10 Limited Maintenance Plan Page 6Grants Pass PM 10 Limited Maintenance Plan Page 7Table 2

. 2011 Grants Pass UGB PM 10 Daily and Annual Emission Inventory

Source Category PM 10 Emissions

Annual

Tons / Year Annual

percent Season Lbs / Day Season

percent Worst Case Day (lbs/day) Worst Case

percent Stationary Point Sources 27.5 4% 187 3.9% 1,357 19.3% Stationary Area Sources 431.6 64% 3,540 73.4% 4,477 63.7%

Non

- Road Engine Sources 4.9 1% 20 0.4% 20 0.3%

On

- Road Mobile Sources 209.7 31% 1,078 22.3% 1,177 16.7%

Total 673.8 100% 4,826 100% 7,031 100%

Figure 4

. 2011 Grants Pass Annual PM 10 Emissions

Figure 5

. 2011 Grants Pass Worst Case Day PM 10 Emissions

Grants Pass PM 10 Limited Maintenance Plan Page 8

### 7

. Continuing Control Measures

To qualify for the LMP option, the control measures from the first PM 10 maintenance plan must
remain in place and unchanged. The measures in Table 3 below were adopted in the first maintenance plan. The y include d a residential woodstove curtailment program, a ban on the use of uncertified woodstoves, outdoor open burning restrictions, prescribed forestry burning smoke

management protection, and certain industrial requirements. The following table summarizes the primary control measures that will be retained under this limited maintenance plan , and the rule authority for each measure

. The only measure not continued is the transpor tation conformity emissions budget

, which is not required for a LMP.

Table 3

. Grants Pass PM 10 Continuing Control Measures

Control Mea s ure Effective

Date DEQ rule authority

Voluntary Woodstove Curtailment 1991 OAR 340

- 200

- 0040

Wood stove Certification 1990 OAR 340

- 262

- 0 60 0

Ban on sale of used woodstoves 1991 OAR 340

- 262

- 0 60 0

Open Burning ventilation index 1991 OAR 340

- 264

- 0070

New Source Review: BACT & offsets exemption 1981 OAR 340

- 224

- 0060

Industrial controls on veneer dryers/wood

- fired

boilers 1989 OAR 340

- 240

- 0110

OAR 340

- 240

- 0120

Forest Smoke Management Plan 1990 OAR 340

- 200

- 0040

Wood Heating Measures

Various measures were implemented to reduce wood

- heating emissions in Grants Pass. As noted in the previous section, residential wood

- heating emissions make up most of the stationary area source emissions, which represent well over 60 percent of the total annual and daily PM 10 emissions in the Grants Pass UGB. The home wood heating curtailment program has been the

most effective PM 10 emission reduction strategy for Grants Pass. As noted in Table 3, w oodstove emission control efforts include the emission certification standards for new stoves, change

- out

programs to encourage removal of non

- certified stoves, and a local voluntary curtailment program to reduce wood burning during stagnant weather periods.

O pen Burning

The Grants Pass UGB is wholly contained within the Rogue Basin Open Burning Control Area. Within this area, Oregon Administrative Rules prohibit commercial and industrial open burning, and limit domestic open burning to days with adequate ventilation. The City of Grants Pass prohibits open burning year round. The Josephine County Department of Health and

Grants Pass PM 10 Limited Maintenance Plan Page 9Community Action apply the wood heating curtailment and open burning restrictions to a broader area surrounding the UGB as a voluntary program.

Industrial Sources

Under the major New Source Review r ules, large new or expanding sources (greater than 15 tons per year of PM 10 ) inside the Grants Pass UGB are require d to install Best Available Control Technology (BACT)

, and provide PM 10 offsets (an equivalent reduction in emissions within the UGB)

. BACT allows a source to consider cost in determining the best available emission

controls. An exemption to offsets is allowed if modeling demonstrates that the new PM 10 emissions , when combin ed with other PM 10 emissions in the area, will not result in an air quality impact greater than 120 μg/m 3

. Specific industrial controls for veneer dryers and wood

- fired

boilers will continue to apply within the Grants Pass UGB

.

Forest Prescribed Burning

The Oregon Department of Forestry’s Smoke Management Plan restricts prescribed burning on poor air quality days on forested lands surrounding the Grants Pass UGB. This program is administered by the Department of Forestry. Grants Pass receives additional smoke management protection as a designated “Smoke Sensitive Receptor Area”, which means that any burning conducted in the region must avoid causing a smoke impact in Grants Pass , including during the winter months when historically 24

- hr PM 10 standard vio lations have occurred.

Conformity requirements

F ederal transportation conformity rules (40 CFR parts 51 and 93) and general conformity rules (58 FR 63214) continue to apply under a limited maintenance plan . However, as noted in the Wegman Memo

, these requirements are greatly simplified. An ar ea under a LMP can demonstrate conformity without submitting an emissions budget , and a s a result emissions do not need be capped nor a regional emissions analysis (including modeling) conducted

. 6



### 8

. Contingency Measures

Section 175(A) of the Clean Air Act requires a maintenance plan include contingency measures

necessary to ensure prompt correction of any violation of the standard that may occur after redesignation. The first Grants Pass maintenance plan contained contingency measures that would be implemented under two scenarios

– if the official PM 10 monitor registers a value of

120 μg/m 3 or higher , or if a violation of the 24

- hr PM 10 standard were to occur. These two contingency scenarios will be continued under the limited maintenance plan. If the former, DEQ would initiate a study of the cause of the elevated level, and convene a planning group to evaluate the findings and identify strategies to be consider ed for implementation. If the later, DEQ would reinstate the New Source Review requirement for Lowest Achievable Emission Rate for new and expanding industry, and remove the offsets exemption. As described in the next

6 See W egman Memo in Appendix A for additional information on conformity requirements

.

Grants Pass PM 10 Limited Maintenance Plan Page 10section, EPA has approv ed a surrogate method for estimating PM 10 levels for tracking and NAAQS compliance purposes.



### 9

. Commitment to Continued Monitoring and Verification of
C ontinued Attainment

As described in this plan, PM 10 levels in the Grants Pass UGB have steadily declined over the last 15 years, and a re not expected to increase or threaten compliance with the daily or annual

PM 10 standard s

.

As noted in Section 3, the Grants Pass PM 10 monitor was removed in 2008 with EPA approval, and since then a surrogate method for estimating PM 10 levels has been approved using a co

located FRM PM 2.5 monitor. DEQ will comply with Title III, Section 319 of the Clean Air Act,

and will continue to operate the PM 2.5 monitor until the end of the maintenance period, and use the equation identified in Section 4 for calculating and tracking PM 10 levels. In the event DEQ

needs to remove the PM 2.5 monitor, DEQ will first obtain EPA approval, and then install a B eta

A ttenuation M ass monitor , approved by EPA as a F ederal E quivalent Method for measuring

P M 10 , in order to track PM 10 levels for the remainder of the limited maintenance plan

. In the unlikely event that after exceptional events are discounted, the second highest PM 10 concentration in a calendar year based on the PM 2.5 monitor or BAM FEM monitor exceeds the

LMP threshold of 98 μg/m 3 , DEQ and EPA will discuss reestablishment of direct monitoring using an FRM PM 10 monitor.

Grants Pass PM 10 Limited Maintenance Plan Page 11

### A ppendix A

EPA 2001 Wegman Memo

Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 1Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 2Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 3Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 4Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 5Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 6Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 7Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 8Grants Pass PM 10 Limited Maintenance Plan Appendix A, Page 9

### A ppendix B

Grants Pass 2011 PM10 Emission Inventory

Grants Pass PM 10 Limited Maintenance Plan Appendix B, Page 1Grants Pass PM 10 Limited Maintenance Plan Appendix B, Page 2Grants Pass PM 10 Limited Maintenance Plan Appendix B, Page 3Grants Pass PM 10 Limited Maintenance Plan Appendix B, Page 4Grants Pass PM 10 Limited Maintenance Plan Appendix B, Page 5Grants Pass PM 10 Limited Maintenance Plan Appendix B, Page 6Grants Pass PM 10 Limited Maintenance Plan Appendix B, Page 7

### A ppendix C

Motor Vehicle Regional Analysis Test

To qualify for the PM 10 LMP option, an area should expect only limited growth in on

- road

motor vehicle PM 10 emissions (including fugitive dust) and pass a motor vehicle regional emissions analysis test, found in Appendix B of the LMP Guidance.

The following methodology was used to determine whether increased emissions from on

- road mobile sources could, in the next 10 years, increase concentrations in the Grants Pass UGB and threaten the assumption of maintenance that underlies the LMP Guidance.

DV + (VMTpi x DVmv) < MOS

Where:

DV = the area’s design value based on the most recent 5 years of data, μg/m3 VMTpi = The projected percent increase in vehicle miles traveled (VMT) over the next 10

years DVmv = Motor vehicle design value based on on

- road mobile portion of the attainment

year inventory, μg/m3 MOS = Margin of safety for 24

- hour PM

- 10 standard is 98 μg/m3

Step 1: Determine DV

The maximum from five complete years of data (2004

- 2008) is 49 μg/m3

Step 2: Determine the projected percent increase in VMT over the next 10 years

The VMT data for the Grants Pass for 2011 and 2021 was supplied by Oregon Department of Transportation, Transportation Planning Analysis Unit. Based on the Grants Pass OSUM Model (Years 2002 and 2025), the percentage increase in the 10

‐ year daily VMT between 2011 and 2021 is estimated to be 15%, and 2011 base year daily VMT is f orecast to be 700,675.

Step 3: Calculate motor vehicle design value based on on

- road mobile portion of the attainment year inventory

The 1996 Grants Pass maintenance plan identified that re

- entrained road dust represented 42%

and on

- road mobile portion represented 1.4% of the attainment year inventory.

DVmv = DV x % Onroad Emissions DVmv = 49 μg/m 3 x 0.43 = 21.07 μg/m 3

Step 4: Calculate the margin of safety

DV + VMTpi x DVmv = MOS 49 μg/m 3 + 0.15 x 21.07 μg/m 3 = 52 μg/m 3

Grants Pass PM 10 Limited Maintenance Plan Appendix C, Page 1Since 52 μg/m 3 is much less than 98 μg/m 3 the area passes the motor vehicle regional analysis and qualifies for the LMP approach.

Grants Pass PM 10 Limited Maintenance Plan Appendix C, Page 2

### Appendix D

DEQ Report: Justification for Discontinuation of Monitoring in Carbon Monoxide and

PM10 Maintenance Areas , 2011

Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 1Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 2Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 3Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 4Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 5Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 6Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 7Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 8Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 9Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 10Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 11Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 12Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 13Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 14Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 15Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 16Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 17Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 18Grants Pass PM 10 Limited Maintenance Plan Appendix D, Page 19

### Appendix E

Inventory Preparation and Quality Assurance Plan

for the Grants Pass Urban Growth Boundary Limited PM10 Maintenance Plan



# Inventory Preparation

and Quality Assurance Plan

for the
Grants Pass Urban Growth Boundary

Limited PM 10 

# Maintenance Plan

March 2014

 Oregon Department of the Environmental Quality
Environmental Solutions Division, Technical Services Section

811 SW Sixth Avenue
Portland, Oregon 97204

Phone 503.229.5359 • Fax 503.229.5675 

## O REGON 

## D EPARTMENT OF 

## E NVIRONMENTAL


## Q UALITY

Air Quality Division Technical Services Section

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 1

## TABLE OF CONTENTS

TABLE OF CONTENTS

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

TABLE OF FIGURES

................................ ................................ ................................ ................................ .................. 3

TABLE OF TABLES

................................ ................................ ................................ ................................ .................... 3

1 INTRODUCTION

................................ ................................ ................................ ................................ ............... 4

1.1 Geographic Area

................................ ................................ ................................ ................................ ..... 4

1.2 Temporal Resolution

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

2 INVENTORY DEVELOPMENT

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

2.1 Data Categories

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

2.2 Emission Sectors

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

3 SPATIAL ALLOCATION METHODS

................................ ................................ ................................ .................... 7

4 TEMPORAL ALLOCATION METHODS

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

4.1 Permitted Point

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

4.2 Aircraft and Locomotives

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

4.3 Nonpoint (area) and Nonroad Vehicles & Equipment

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

4.3.1 Open Burning

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

4.3.2 Small Stationary Fossil Fuel Combustion

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

4.3.3 Residential Wood Combustion

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

4.3.4 Wildfires and Prescribed Burning

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

4.3.5 Structure Fires

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

4.3.6 Commercial Food Preparation

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

4.3.7 Fugitive Dust

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

4.3.8 Nonroad Vehicles & Equipment Excluding Aircraft and Locomotives

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

4.4 On

- Road Mobile

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

5 QUALITY ASSURANCE AND QUALITY CONTROL

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

6 EXTERNAL AUDITS

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

7 PERSONNEL

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

8 SCHEDULE

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

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 2

## TABLE OF FIGURES

Figure 1

- 1. Grants Pass UGB and Location of the Air Quality Monitoring Station

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



## TABLE OF TABLES

Table 2.1. 1993 PM 10 Seasonal Worst

- Case Day Emissions by Category

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

Table 2.2. 1993 PM 10 Seasonal Worst

- Case Daily Emissions by Source Category

................................ ................ 7 Table 3.1. Data Sources, Spatial Surrogates and Boundaries

................................ ................................ ................ 8 Table 8.1. Draft Project Schedule: Grants Pass Limited Maintenance Plans for CO and PM 10

........................... 12

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 3

## 1. INTRODUCTION

The Grants Pass PM 10 maintenance area was classified as a “Group 1 Planning Area” in 1987 by the Environmental Protection Agency (EPA) for violating the 24

- hour PM 10 standard. In 1990, EPA formally designated Grants Pass as a moderate nonattainment area for the 24

- hour standa rd, 150μg/m 3

.

Monitoring data shows that Grants Pass area has been in attainment of the standard since 1989. Full compliance for the area was achieved by 1990 with no exceedances recorded at the PM 10 monitor for three consecutive years. The area was recl assified to attainment for the 24

- hour

PM 10 standard in December 2003 when EPA approved the first maintenance plan designed to
maintain compliance with the 24

- hour PM 10 standard through the year 2015. The second
maintenance plan is due in 2015. Once approv ed by EPA, the second maintenance plan will fulfill the final maintenance planning requirements of the Clean Air Act. This Inventory Preparation
Plan is in support of the development of the required second PM 10 maintenance plan.

The Grants Pass Urban Growth Boundary (UGB) is the maintenance area for PM 10 . A PM 10 monitor was located at 11 th and K Streets in downtown Grants Pass from 1985 until 1999. Due to
loss of property access in 1999, the monitor was relocated to the sewage treatment plant within

t he UGB. Measured PM 10 levels were so low that the monitor was removed with EPA approval at
the end of 2008. Since then, both continuous, non

- reference method monitoring and Federal Reference Method (FRM) monitoring of PM 2.5 has been conducted in Grants Pas s, which has

been correlated with a co

- located PM 10 monitor to provide estimated PM 10 values. Figure 1

- 1 shows the Grants Pass UGB and the present location of the monitor.

The Grants Pass UGB qualifies for the Limited Maintenance Plan (LMP) approach becau se the area satisfies all criteria outlined in the Limited Maintenance Plan Option for Moderate PM 10 Nonattainment Areas (Wegman memo, 2001). The design value for 2004

- 2008 was 49 μg/m 3

, and the risk to the community of exceeding the PM 10 standard is low. According to the LMP guidance, EPA will consider the maintenance demonstration satisfied if the monitoring data show the design value to be at or below 98 μg/m 3 for the 24

- hr PM 10 NAAQS, and if the area expects
only limited growth in on

- road motor vehicle emissions. The Grants Pass UGB passes the Motor Vehicle Regional Analysis outlined in Appendix B of the Wegman memo (Appendix B attached).
Oregon DEQ proposes using existing information from the EPA 2011 National Emission Inventory (NEI) to create the e missions inventory for PM 10 sources in Grants Pass. This document describes the planned approach to the LMP EI and the basis for selecting that approach.



### 1.1 Geographic Area

The city of Grants Pass is located in the Rogue Valley, northwest of Medford and along the Rogue River. The city is approximately 11 sq. miles in area, and the US Census 2011 population was
34,533. The Grants Pass Parkside School Air Quality Monitoring Station is located at the corner of SW Wagner and M streets, at an elevation o f 277 meters (801 ft). Figure 1

- 1 shows the geographic area of the Grants Pass UGB, along with the location of the monitor.

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 4Figure 1

- 1 . Grants Pass UGB and Location of the Air Quality Monitoring Station



### 1.2 Temporal Resolution

Historical exceedences of the 24

- hr PM10 standard have occurred during the PM season, which is
defined as four consecutive months, November 1 st through the end of February. As such, in
addition to annual emissions typical season day and worst

- c ase season day emissions will be included in the inventory. The term “worst

- case day” describes the m aximum activity/emissions
that have occurred or could occur on a season day, for each emissions source. Worst

- case day

emissions are summed for all source s/categories, i.e. assumed to occur on the same day. The
assumption: A “perfect storm” of emissions that could cause an exceedence. The unit of measure for annual emissions will be tons per year (tpy), and the unit of measure for season day

emissions wil l be pounds per day (lb/day).



## 2. INVENTORY DEVELOPMENT

The DEQ will develop an emission inventory using EPA 2011 National Emissions Inventory (NEI) data for Josephine County. We will temporally allocate the EI data to PM season, and spatially

allocate the county

- wide NEI data to the Grants Pass UGB, or to buffers around the UGB or
monitor, depending on emissions category. All data sources and allocation methods will be
documented. The emission inventory will be consistent with the 1993 inventory.

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 5

### 2.1 Data Categories
From the base year (1993) emission inventory for the maintenance plan, the most significant
categories of PM 10 emissions in the Grants Pass UGB are re

- entrained road dust, residential
wood combustion, small stationary fossil fuel combustio n, and permitted point source fossil fuel

combustion . Table 2.1 shows the breakdown by category for worst

- case day PM 10 emissions in

1993.

Table 2

. 1 . 1993 PM 10 Seasonal Worst

- Case Day Emissions by Category

Emission Inventory Category Emissions per Day (lb/day) Percent of Worst

Case Day Emissions

Re

- Entrained Road Dust 4,512 42%

Residential Wood Combustion 4,064 38% Small Stationary Fossil Fuel Combustion (a) 1,064 10%

Permitted Point Sources 591 6%

All other sources 470 4%

------- ------Total 10,701 100%
(a) Non

- permitted stationary residential, industrial, commercial, and institutional fuel use



### 2.2 Emission Sectors

We propose 14 emission inventory sources be included in this LMP for the Grants Pass

maintenance area. The sectors are based on a review of emission sectors listed in the 1993
maintenance plan, and an analysis of 2011 NEI data. Table 2.2 shows the breakdow n by source category of average daily PM 10 emissions in 1993 inventory; DEQ will use the same emission
source categories as in the 1993 inventory.

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 6Table 2

. 2 . 1993 PM 10 Seasonal Worst

- Case Daily Emissions by Source Category

Emission Source Category Emissions per Day (lb/day) Percent of Worst

Case Day Emissions

Permitted Point Sources 591 5.52%

Open Burning 101 0.95%

Small Stationary Fossil Fuel Combustion (a) 736 9.94%

Residential Wood Combustion 4,064 37.98%

Wildfires & Prescribed Burning 45 0.42%
Commercial Food Preparation (b) 46 0.43%
Fugitive Dust 58 0.54%

Structure Fires 12 0.12%
Aircraft & Airport Related 0 (c) 0%

Locomotives 2 0.02%

Recreational Marine 1 0.01%
Nonroad Vehicles & Equipment 53 0.50%

Onroad Mobile: Exhaust + Brake + Tire 148 1.40%

Re

- Entrained Road Dust 4,512 42.16%

------- -------Total 10,701 100%

(a) Non

- permitted stationary residential, industrial, commercial, and institutional fuel use
(b) Particulate emissions from the cooking process only; fuel used by restaurants is covered under small
stationary fossil fuel combustion.
(c) Grants Pass Airport located outside the Grants Pass UGB, so emissions are not included. However, DEQ

staff will verif y that no additional airports/heliports are located within the UGB for the 2011 EI.



## 3. SPATIAL ALLOCATION METHODS

For emissions sources with specific coordinates, emissions will be mapped to either the UGB or to a

buffer zone around the monitor or other boundary, depending on emissions source category. For
sources without specific coordinates, spatial surrogates will be used to approximate both the
location and magnitude of emissions. Spatial surrogates are typically used to approximate

emissions inside smaller boundaries from larger boundaries. For sources without specific
coordinates, county

- wide emissions will be spatially allocated to UGB using the formula:



### E UGB 

### = E COUNTY 

### * Surrogate UGB 

### / Surrogate COUNTY

Where E UGB = emissions in UGB,

E COUNTY = county

- wide emissions
Surrogate UGB = surrogate activity in UGB
Surrogate COUNTY = surrogate activity in county

Data sources, spatial surrogates or boundaries used for each category of emissions are detailed

in Table 3

- 1.

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 7Table 3

. 1 . Data Sources, Spatial Surrogates and Boundaries

Sector and Category EI Data Source Spatial Surrogate or Boundary Surrogate Data Source Comment

Permitted Point 2011 NEI + DEQ within UGB (consistent with 1993 E DEQ GIS data Source coordinates used

Nonpoint (Area)

Open Burning 2011 NEI zoning and burn ban boundary DEQ and Josephine County residential (BBB) and other (zoning)
Small Stationary Fossil Fuel Combustion 2011 NEI zoning Josephine County zoning non

- permitted source fuel use

Residential Wood Combustion 2011 NEI Census block group US Census Census data used for allocation

Wildfires and Prescribed Burning 2008 & 2011

NEI within a 15

- km buffer of the

monitor (a) 2008 & 2011 NEI Fire coordinates used: Average of two year's

worth of data from the NEI

Structure Fires 2011 NEI population US Census 2011 Census data
Commercial Food Preparation 2011 NEI zoning Josephine County zoning Particulate from cooking meat

Fugitive Dust
Road Sanding 1993 SIP EI UGB N/A Growth using population as a surrogate
Aggregate storage piles 1993 SIP EI UGB N/A Growth using population as a surrogate

Nonroad
Aircraft & Airport related 2011 NEI Grants Pass airport located

outside UGB 2011 NEI (airport location) DEQ staff will verify via GIS mapping whether or
not any additional airports/heliports are located

within the UGB

Locomotives
Line-Haul (Road) 2011 NEI track miles DEQ GIS Active track miles only
Switching (Yard) 2011 NEI yard location (polygon) DEQ GIS
Marine (recreational) 2011 NEI boat use days by waterbody Oregon State Marine Board 2011 Recreational boat use days from OSMB

2011 NEI zoning Josephine County zoning EPA Nonroad Model categories

Onroad Mobile

Exhaust, Brake, Tire 2011 NEI road miles DEQ GIS

Re

- Entrained Road Dust

Paved Roads 2011 NEI paved road miles DEQ GIS paved road mileage

Unpaved Roads 2011 NEI unpaved road miles DEQ GIS unpaved road mileage (b)

(a) Fire spatial and temporal data has become increasingly sophisticated since the 1993 EI. The date, emissions, and coordinates of

specific fires are now available in the 2008 and 2011 NEIs. As such, a 15

- km buffer around the monitor was chosen, as in the 2008

Klamath Falls PM2.5 Attainment Plan.

(b) estimated to be 0 miles; no unpaved roads within the UGB Nonroad Vehicles & Equipment

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 8

## 4. TEMPORAL ALLOCATION METHODS

Annual emissions will be adjusted from tons per year to lbs per typical season and worst

- case season day for each source category. Methods for each category are described below, and all

methods are consistent with the 1993 EI.



### 4.1 Permitted Point

Typi cal day emissions estimates will be calculated from annual emissions utilizing facility
operating schedules taken from source permits. Worst

- case day emissions will be actual emissions calculated from permits, source annual reports, and DEQ point source e missions
estimation reports.



### 4.2 Aircraft and Locomotives

Aircraft and locomotive activity will be considered uniform throughout the year. Annual emissions will be divided by 365 days to estimate typical season day and worst

- case day

emissions.



### 4.3 No npoint (area) and Nonroad Vehicles & Equipment

For nonpoint (area) and nonroad vehicles and equipment (excluding aircraft and locomotive),
temporal allocation to season will follow the formula:

Annual to Typical Season Day = (Annual Emissions * SAF) / (weekly activity * 52 weeks/yr)

Where SAF = Seasonal Adjustment Factor =

= (Season Activity * 12 months) / (Annual Activity * Season Months)
(Reference: EPA

- 450/4

- 91

- 016, p. 5

- 22)



### 4.3.1 Open Burning
Open burning will be temporally allocated using SAF values and activity in days per week taken
from the 1993 EI. Open burning is prohibited during low

- ventilation days; however a worst

- case scenario will be calculated using estimates for illegal open burning activity as determined in th e

1993 EI.



### 4.3.2 Small Stationary Fossil Fuel Combustion
Annual emissions from small stationary fossil fuel combustion will be temporally allocated using SAF values and activity in days per week taken from the 1993 EI. However, the residential
heating S AF will be developed from base year (2011) heating degree day (HDD) data. Worst

- case day for industrial/commercial/institutional fuel use will be assumed equal to typical season day.

However, worst

- case day for residential heating will be allocated from t ypical season day using a “multiplier” (scalar) calculated from HDD data.



### 4.3.3 Residential Wood Combustion
Residential wood combustion annual emissions will be allocated to season using SAF values calculated from 2011 heating degree day (HDD) data. A w orst

- case “multiplier” (scalar) based on

2011 HDD data will be used to estimate worst

- case day emissions. Activity in days per week will

be taken from the 1993 EI.

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 9

### 4.3.4 Wildfires and Prescribed Burning
As wildfires and prescribed burning are date

- speci fic events, DEQ will temporally allocate
emissions from these sources using fire date data, available in the EPA National Emission Inventory (NEI). SAF values will be calculated using annual and seasonal fire dates. Worst

- case day emissions will be assum ed to be equal to typical season day emissions.



### 4.3.5 Structure Fires

As structure fires are date

- specific events, DEQ will temporally allocate emissions from these sources using fire date data. Fire data used by DEQ to estimate structure fire emissions for the NEI is supplied by the state fire marshal. A seasonal adjustment factor (SAF) will be estimated
using annual and seasonal fire dates. Worst

- case day emissions will be assumed equal to typical
season day emissions.



### 4.3.6 Commercial Food Preparat ion
Emissions from commercial food preparation will be temporally allocated using SAF values and weekly activity taken from the 1993 EI. The SAF and weekly activity in the 1993 EI were estimated from a Commercial Food Preparation Survey conducted in Grant s Pass specifically for
the emission inventory.



### 4.3.7 Fugitive Dust
Fugitive dust emissions will be temporally allocated using SAF values and activity in days per week taken from the 1993 EI. Fugitive dust within the UGB was determined to come from road sanding and aggregate storage piles. The 1993 SAF and weekly data is based on aggregate
storage pile disturbance by month, obtained from municipal records.



### 4.3.8 Nonroad Vehicles & Equipment Excluding Aircraft and Locomotives

Sources of emissions cover ed by the Nonroad model include the following categories:

• Recreational marine 

### • Railway maintenance

• Agricultural 

### • Lawn & garden

• Construction 

### • Industrial

• Light commercial 

### • Logging

• Airport Ground Support Equipment (GSE)

Emissions from these categories will be temporally allocated to season using SAFs and weekly
activity taken from the 1993 emission inventory.



### 4.4 On

- Road Mobile

Emissions from on

- road mobile, including re

- entrained road dust, will be temporally allocated to

season using SAF data and weekly activity taken from the 1993 emission inventory.



## 5. QUALITY ASSURANCE AND QUALITY CONTROL

DEQ will be using existing data that has already been quality checked. DEQ staff will perform
quality assurance for accuracy, completenes s, and representativeness on the spatial and temporal allocation of emissions from the existing inventory.

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 10

## 6. EXTERNAL AUDITS

DEQ is willing to be audited by the EPA, and make changes to this inventory preparation and quality assurance plan if warranted.



## 7. PERSONNEL

DEQ personnel responsible for the Grants Pass PM 10 Limited Maintenance Plan inventory

include:

Wendy Wiles, DEQ Environmental Solutions Division Administrator Jeffrey Stocum, Air Quality Technical Services Section Manager

Emission Invento ry and Air Quality Information Systems Christopher Swab, Senior Emission Inventory Analyst
Brandy Albertson, Emission Inventory Analyst
Wesley Risher, Emission Inventory Analyst
Miyoung Park, Emission Inventory Specialist
Quality Assurance
Anthony Barnack, Air Monitoring Coordinator
David Collier, Air Quality Planning & Development Manager
Aida Biberic, Air Quality Planner



## 8. SCHEDULE

Table 8.1 shows the draft schedule for document submittal to EPA Region 10 and other tasks to
be completed. DEQ will submit a draft inventory to EPA upon their request, and will submit a
final inventory to EPA according to this Inventory Preparation and Quality Assuranc e Plan.

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 11Table 8

. 1 . Draft Project Schedule: Grants Pass Limited Maintenance Plans for CO and PM 10

Define Scope SIP Development Plan SIP Development Phase Rulemaking Phase EQC Adoption Submit the final SIP to EPA30-Dec-1313-Jan-1427-Jan-1410-Feb-1424-Feb-1410-Mar-1424-Mar-147-Apr-1421-Apr-145-May-1419-May-142-Jun-1416-Jun-1430-Jun-1414-Jul-1428-Jul-1411-Aug-1425-Aug-148-Sep-1422-Sep-146-Oct-1420-Oct-143-Nov-1417-Nov-141-Dec-1415-Dec-1429-Dec-1412-Jan-1526-Jan-159-Feb-15

Define Scope SIP Development Plan Approve work on this SIP Fast Track Checklist SIP Developmnet Plan IPP Timeline Submitt SIP Dev. Plant to EPA and GP MPO SIP Development Phase Emissions Inventory Development Drafting the Plan Review Draft SIP Rulemaking Phase Draft the SIP, Fact Sheet, Notice Review Final SIP, Fact Sheet, Notice Draft plan submitted to EPA, DOJ, Andrea Rulemaking documents due to DA for... Public Involvement Finalize the SIP Review the SIP Finalized staff report due to directors office EQC adoption Submit the final SIP to EPA Draft Project Schedule: Grants Pass Limited Maitenance Plans for PM10

Grants Pass PM 10 Limited Maintenance Plan Appendix E, Page 12