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 PM10 Limited Maintenance Plan

A Limited Maintenance Plan

for Particulate Matter (PM10)

The Grants Pass Urban Growth 

Boundary

State of Oregon Clean Air Act 

Implementation Plan

Adopted by the Environmental Quality Commission on

April 16, 2015

State of Oregon

Department of Environmental Quality

811 SW Sixth Avenue

Portland, OR 97204-1390
Table of Contents

Acknowledgments............................................................................................................................ i

Executive Summary........................................................................................................................ ii

Plan Structure................................................................................................................................. iii

1. Introduction.................................................................................................................................1

2. Geographic Area .........................................................................................................................1

3. History of PM10 Problem in Grants Pass....................................................................................2

4. Tracking Current PM10 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 PM10 Monitor.......................... 2

Figure 2. Grants Pass PM10 Trend 1987-2013............................................................................... 4

Figure 3. Grants Pass Parkside School PM10/PM2.5 Correlation................................................... 5

Figure 4. 2011 Grants Pass Annual PM10 Emissions.................................................................... 8

Figure 5. 2011 Grants Pass Worst Case Day PM10 Emissions...................................................... 8

Table of Tables

Table 1. Grants Pass Maximum 24-hour PM10 Highest Values 1987-2008.................................. 3

Table 2. 2011 Grants Pass UGB PM10 Daily and Annual Emission Inventory............................. 8

Table 3. Grants Pass PM10 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 PM10 Maintenance Areas, 2011

Appendix E: Inventory Preparation and Quality Assurance Plan

Grants Pass PM10 Limited Maintenance Plan
Acknowledgments

Principal Author: Brian Finneran, DEQ Air Quality Planning 

Principal Contributors:

Oregon Department of Environmental Quality

David Collier Air Quality Planning Manager

Aida Biberic 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 Governments

Other support:

Tom Carlson Sierra Research, Inc

Grants Pass PM10 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 (PM10). This State Implementation Plan (SIP) revision explains 

how this area will continue to meet this standard through 2025. 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 current 24-hour federal health standard for PM10, 

set in 1987, is 150 micrograms per cubic meter (μg/m3). To maintain compliance with the 

standard, monitored levels should not exceed the daily standard more than once a year over three 

consecutive years.

The 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 moderate nonattainment 

area in 1990, and an attainment plan was adopted, containing PM10 control measures for 

woodstoves, open burning, forestry burning, industrial growth, and others. The area was 

reclassified to attainment after DEQ adopted the PM10 maintenance plan in 2002 (see 68 FR 

61111). This plan was designed to maintain compliance with the daily PM10 standard through 

the year 2015. A second maintenance plan is now required, and once approved by EPA, will 

fulfill the final maintenance planning requirements under the Clean Air Act.

The 2002 PM10 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 PM10

emissions budget for future transportation projects, and a contingency plan in case of an 

exceedance or violation of the PM10 standard. 

Grants Pass qualifies for a Limited Maintenance Plan (LMP), which is an option EPA provides 

for areas at low risk of exceeding the PM10 standard (see EPA’s 2001 Wegman Memo, 

Appendix A). The design value is 49 μg/m3 (2004-2008) for the most recent 5-year average of 

PM10 monitoring data, and is the same value for most recent 5 years (2009-2013) based on 

estimated PM10 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/m3 for the 24-hour PM10 standard, 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 the Wegman Memo. 

PM10 monitoring began in Grants Pass in 1987, and was removed in 2008 (with EPA approval) 

due to measured PM10 levels being well below the 24-hour federal health standard for over 10 

years.1 Since then a surrogate method for estimating PM10 levels has been used based on PM2.5 

monitoring and applying an established correlation between PM10 and PM2.5. Under the Grants 

Pass LMP, DEQ has committed to continue operating the PM2.5 monitor and estimating PM10

levels in order to to demonstrate continued compliance with the PM10 NAAQS. Should it 

become necessary to remove the PM2.5 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 PM10

Maintenance Areas, October 2011. 

Grants Pass PM10 Limited Maintenance Plan Page ii

 
PM10 levels using a beta attenuation mass (BAM) monitor, approved by EPA as a Federal 

Equivalent Method for measuring PM10, in order to track PM10 levels for the remainder of the 

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

PM10 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 PM10 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 sources, 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. Describes the purpose of this second maintenance plan, and summary 

on the PM10 standard. 

Section 2 – Geographic Area. Describes the geographic area covered by the maintenance plan,

Section 3 – History of the PM10 Problem. Summarizes Grants Pass PM10 compliance history and 

past monitoring PM10 data and trends.

Section 4 – Tracking Current PM10 Levels in Grants Pass. Shows how future PM10 monitoring

will take place, using the correlation of PM10 to PM2.5, and justification for using this surrogate 

monitoring method.

Section 5 – Limited Maintenance Plan Option. Describes the criteria an area must meet to

qualify for this option and how Grants Pass qualifies.

Section 6 – Emission Inventory. Includes historical information on the most significant PM10

emission categories from the original maintenance plan and an updated inventory on these

categories.

Section 7 – Continuing Control Measures. Lists the measures that were in the original

maintenance plan, and how these measures will be continued under this LMP. 

Section 8 – Contingency Plan. Describes the contingency plan should a violation occur in the 

future.

Grants Pass PM10 Limited Maintenance Plan Page iii
Section 9 – Commitment to Continued Monitoring and Verification of Continued Attainment. 

Describes how monitoring will be continued and how compliance will be confirmed.

Appendices – Supporting documentation for this LMP. 

Grants Pass PM10 Limited Maintenance Plan Page iv
1. Introduction

This State Implementation Plan revision explains how the Grants Pass PM10 maintenance area, 

as defined in OAR 340-204-0010 (the Grants Pass UGB) will continue to meet the National 

Ambient Air Quality Standard (NAAQS) for particulate matter ten microns or smaller (PM10) 

through 2025. 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 PM10, or particulate matter 

that is ten microns is size or less. Particulate in this size range can 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, concentration, 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 wood 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 PM10 standard at 150 micrograms per cubic meter (μg/m3) for the 24-hour 

average and 50μg/m3 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 PM10 standard, EPA adopted the PM2.5 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/m3 for the 24-hour average and 

12μg/m3 for the annual average. Grants Pass has never violated the PM2.5 standard.

2. Geographic Area

The City 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 2013 population was 35,076. 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 plan. 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 PM10 Limited Maintenance Plan Page 1
Figure 1. Grants Pass UGB and location of the Parkside School PM10 Monitor

3. History of PM10 Problem in Grants Pass

DEQ began monitoring PM10 in Grants Pass in 1987. The monitor was located at 11th and K 

Streets in downtown Grants Pass for 14 years, until 1999. A second PM10 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 

PM10 levels being measured and resource/budget considerations.

2 Prior to removal, in 2006 a 

PM2.5 monitor was co-located at Parkside School with the PM10 monitor, from which estimated 

PM10 values could be derived. Since then, this PM2.5 monitor and a continuous non-FRM

monitor (nephelometer) have been in operation. 

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

Maintenance Areas”, October 2011

Grants Pass PM10 Limited Maintenance Plan Page 2

 
A violation of the 24-hour PM10 standard occurs when there are more than three exceedances of 

the standard within three years. The highest 24-hour PM10 concentration recorded in Grants 

Pass occurred in 1987 at a level of 268 μg/m3

. 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 

PM10 standard of 50 μg/m3

.

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

hour PM10 standard, based on a design value of 171 μg/m3

. 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 PM10 nonattainment boundary. 

Monitoring data shows that Grants Pass area has been in attainment of the 24-hour standard since 

1989. In 2003, the area was reclassified to attainment for the 24-hour PM10 standard, when EPA 

approved the first maintenance plan designed to maintain compliance with the 24-hour PM10

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 industrial growth, established a PM10 emissions budget for future transportation 

projects, and a contingency plan in case of an exceedance or violation of the PM10 standard. 

This limited maintenance plan is the second and final maintenance plan required, designed to 

ensure compliance through 2025.

The maximum 24-hour PM10 concentrations measured for the years 1987 to 2008 is provided in 

Table 1. The trend in PM10 concentrations over the same time period is shown in Figure 2, using

the second highest 24-hour PM10 concentration rather than the maximum, based on how 

compliance with the standard is determined.

3 

Table 1. Grants Pass Maximum 24-hour PM10 Highest Values 1987-2013

Year Max PM10

μg/m3

Max 

date

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 PM10 standard allows one exceedance per year at any given location (averaged over a consecutive three-year 

period).

Grants Pass PM10 Limited Maintenance Plan Page 3

 
2000 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 06/29

estimated PM10 using PM2.5 data

2009 49 11/09

2010 46 12/04

2011 41 12/23

2012 25 01/04

2013 111* 08/02

2013 45 11/24

*wildfire smoke impact

Figure 2. Grants Pass PM10 Trend 1987-2013

2nd highest 24-Hr Average

4. Tracking Current PM10 Levels in Grants Pass

As noted above, in 2008 the PM10 monitor in Grants Pass was removed with EPA approval, due 

to very low levels being measured. Comparable Federal Reference Method PM10 and PM2.5

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 μg/m3

Second Highest Value used for showing 

compliance with PM10 Standard

Estimat

ed

PM10

Grants Pass PM10 Limited Maintenance Plan Page 4
reliable PM10 estimation methodology was developed, using the equation in Figure 3. It is 

expected if current low PM10 levels continue, budget considerations may lead to the removal of

the PM2.5 monitor and its relocation to another community. Should this occur, DEQ would then 

install a beta attenuation mass (BAM) monitor, approved by EPA as a Federal Equivalent 

Method for measuring PM10, in order to track PM10 levels for the remainder of the limited 

maintenance plan. EPA approval will be obtained prior to removing the PM2.5 monitor and 

installing a FEM BAM for PM10. See Section 9 for additional information.

PM10/PM2.5 Correlation

A linear regression analysis was performed on the PM10 and PM2.5 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 PM10 levels. 

Figure 3. Grants Pass Parkside School PM10/PM2.5 Correlation

5. Limited Maintenance Plan Option

The EPA developed the Limited Maintenance Plan (LMP) option for areas with little risk of reviolating the PM10 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 area should be attaining the PM10

standard, the second that the average PM10 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 meets all three

criteria. As noted in Section 3, PM10 monitored data over the last 15 years have been well below 

the 24-hour standard. 

Grants Pass PM10 Limited Maintenance Plan Page 5
EPA’s PM10 SIP Development Guideline outlines four approaches to determining the PM10

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 PM10 design values for Grants Pass are provided here. The first is 49 μg/m3, 

based on the most recent 5 years of FRM monitoring data (2004-2008) prior to removal of the

PM10 monitor. The second design value is also 49 μg/m3

, based on the most recent 5 years of 

estimated PM10 levels (2009-2013) using the equation in Figure 3. Both are well below the 98

μg/m3 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 the 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 PM10 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 

County, 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 were calculated. 

Historically, exceedences of the 24-hr PM10 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 emissions are summed 

for all sources/categories, i.e. assumed to occur on the same day. This 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 allocated 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 PM10

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 PM10 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 PM10 Limited Maintenance Plan Page 6

 
Grants Pass PM10 Limited Maintenance Plan Page 7
Table 2. 2011 Grants Pass UGB PM10 Daily and Annual Emission Inventory

Source Category

PM10 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 PM10 Emissions

 

Figure 5. 2011 Grants Pass Worst Case Day PM10 Emissions

Grants Pass PM10 Limited Maintenance Plan Page 8
7. Continuing Control Measures

To qualify for the LMP option, the control measures from the first PM10 maintenance plan must 

remain in place and unchanged. The measures in Table 3 below were adopted in the first 

maintenance plan. They included 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 transportation conformity 

emissions budget, which is not required for a LMP.

Table 3. Grants Pass PM10 Continuing Control Measures

Control Measure

Effective

Date DEQ rule authority

Voluntary Woodstove Curtailment 1991 OAR 340-200-0040

Wood stove Certification 1990 OAR 340-262-0600

Ban on sale of used woodstoves 1991 OAR 340-262-0600

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 340-240-0110OAR 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 PM10

emissions in the Grants Pass UGB. The home wood heating curtailment program has been the 

most effective PM10 emission reduction strategy for Grants Pass. As noted in Table 3, woodstove 

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. 

Open 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 PM10 Limited Maintenance Plan Page 9
Community 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 rules, large new or expanding sources (greater than 15 tons 

per year of PM10) inside the Grants Pass UGB are required to install Best Available Control 

Technology (BACT), and provide PM10 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 PM10

emissions, when combined with other PM10 emissions in the area, will not result in an air quality 

impact greater than120 μg/m3. 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 PM10 standard violations have occurred. 

Conformity requirements

Federal 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 area under a LMP can 

demonstrate conformity without submitting an emissions budget, and as 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 PM10 monitor registers a value of 

120 μg/m3 or higher, or if a violation of the 24-hr PM10 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 considered 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 Wegman Memo in Appendix A for additional information on conformity requirements. 

Grants Pass PM10 Limited Maintenance Plan Page 10

 
section, EPA has approved a surrogate method for estimating PM10 levels for tracking and 

NAAQS compliance purposes. 

9. Commitment to Continued Monitoring and Verification of 

Continued Attainment

As described in this plan, PM10 levels in the Grants Pass UGB have steadily declined over the 

last 15 years, and are not expected to increase or threaten compliance with the daily or annual 

PM10 standards.

As noted in Section 3, the Grants Pass PM10 monitor was removed in 2008 with EPA approval, 

and since then a surrogate method for estimating PM10 levels has been approved using a colocated FRM PM2.5 monitor. DEQ will comply with Title III, Section 319 of the Clean Air Act, 

and will continue to operate the PM2.5 monitor until the end of the maintenance period, and use 

the equation identified in Section 4 for calculating and tracking PM10 levels. In the event DEQ 

needs to remove the PM2.5 monitor, DEQ will first obtain EPA approval, and then install a Beta 

Attenuation Mass monitor, approved by EPA as a Federal Equivalent Method for measuring 

PM10, in order to track PM10 levels for the remainder of the limited maintenance plan. In the 

unlikely event that after exceptional events are discounted, the second highest PM10

concentration in a calendar year based on the PM2.5 monitor or BAM FEM monitor exceeds the 

LMP threshold of 98μg/m3, DEQ and EPA will discuss reestablishment of direct monitoring 

using an FRM PM10 monitor.

Grants Pass PM10 Limited Maintenance Plan Page 11
Appendix A

EPA 2001 Wegman Memo

Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 1
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 2
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 3
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 4
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 5
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 6
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 7
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 8
Grants Pass PM10 Limited Maintenance Plan Appendix A, Page 9
Appendix B

Grants Pass 2011 PM10 Emission Inventory

Grants Pass PM10 Limited Maintenance Plan Appendix B, Page 1
Grants Pass PM10 Limited Maintenance Plan Appendix B, Page 2
Grants Pass PM10 Limited Maintenance Plan Appendix B, Page 3
Grants Pass PM10 Limited Maintenance Plan Appendix B, Page 4
Grants Pass PM10 Limited Maintenance Plan Appendix B, Page 5
Grants Pass PM10 Limited Maintenance Plan Appendix B, Page 6
Grants Pass PM10 Limited Maintenance Plan Appendix B, Page 7
Appendix C

Motor Vehicle Regional Analysis Test

To qualify for the PM10 LMP option, an area should expect only limited growth in on-road 

motor vehicle PM10 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 forecast 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/m3 x 0.43 = 21.07 μg/m3

Step 4: Calculate the margin of safety

DV + VMTpi x DVmv = MOS

49 μg/m3 + 0.15 x 21.07 μg/m3 = 52 μg/m3

Grants Pass PM10 Limited Maintenance Plan Appendix C, Page 1
Since 52 μg/m3 is much less than 98 μg/m3 the area passes the motor vehicle regional analysis 

and qualifies for the LMP approach. 

Grants Pass PM10 Limited Maintenance Plan Appendix C, Page 2
Appendix D

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

PM10 Maintenance Areas, 2011

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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 PM10 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

OREGON DEPARTMENT OF ENVIRONMENTAL 

QUALITY

Air Quality Division Technical Services Section

Grants Pass PM10 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 PM10 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 PM10 Seasonal Worst-Case Day Emissions by Category .............................................................. 6

Table 2.2. 1993 PM10 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 PM10 ........................... 12

Grants Pass PM10 Limited Maintenance Plan Appendix E, Page 3
1. INTRODUCTION

The Grants Pass PM10 maintenance area was classified as a “Group 1 Planning Area” in 1987 by 

the Environmental Protection Agency (EPA) for violating the 24-hour PM10 standard. In 1990, EPA 

formally designated Grants Pass as a moderate nonattainment area for the 24-hour standard, 

150μg/m3. 

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 PM10

monitor for three consecutive years. The area was reclassified to attainment for the 24-hour 

PM10 standard in December 2003 when EPA approved the first maintenance plan designed to 

maintain compliance with the 24-hour PM10 standard through the year 2015. The second 

maintenance plan is due in 2015. Once approved 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 PM10 maintenance plan. 

The Grants Pass Urban Growth Boundary (UGB) is the maintenance area for PM10. A PM10

monitor was located at 11th 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 

the UGB. Measured PM10 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 PM2.5 has been conducted in Grants Pass, which has 

been correlated with a co-located PM10 monitor to provide estimated PM10 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 because the 

area satisfies all criteria outlined in the Limited Maintenance Plan Option for Moderate PM10

Nonattainment Areas (Wegman memo, 2001). The design value for 2004-2008 was 49 μg/m3, 

and the risk to the community of exceeding the PM10 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/m3 for the 24-hr PM10 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 emissions inventory for PM10 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 of 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 PM10 Limited Maintenance Plan Appendix E, Page 4
Figure 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 1st through the end of February. As such, in 

addition to annual emissions typical season day and worst-case season day emissions will be 

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 

emissions are summed for all sources/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 will 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 PM10 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 PM10 emissions in the Grants Pass UGB are re-entrained road dust, residential 

wood combustion, small stationary fossil fuel combustion, and permitted point source fossil fuel 

combustion. Table 2.1 shows the breakdown by category for worst-case day PM10 emissions in 

1993.

Table 2.1. 1993 PM10 Seasonal Worst-Case Day Emissions by Category

Emission Inventory Category Emissions per Day 

(lb/day)

Percent of WorstCase 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 breakdown by source 

category of average daily PM10 emissions in 1993 inventory; DEQ will use the same emission 

source categories as in the 1993 inventory.

Grants Pass PM10 Limited Maintenance Plan Appendix E, Page 6
Table 2.2. 1993 PM10 Seasonal Worst-Case Daily Emissions by Source Category

Emission Source Category Emissions per Day 

(lb/day)

Percent of WorstCase 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 verify 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:

EUGB = ECOUNTY * SurrogateUGB / SurrogateCOUNTY

Where EUGB = emissions in UGB, 

ECOUNTY = county-wide emissions

SurrogateUGB = surrogate activity in UGB

SurrogateCOUNTY = surrogate activity in county

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

in Table 3-1.

Grants Pass PM10 Limited Maintenance Plan Appendix E, Page 7
Table 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 EDEQ 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 PM10 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

Typical 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 emissions 

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 Nonpoint (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 the 

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 SAF 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 typical 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 worst-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 PM10 Limited Maintenance Plan Appendix E, Page 9
4.3.4 Wildfires and Prescribed Burning

As wildfires and prescribed burning are date-specific 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 assumed 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 Preparation

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 Grants 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 covered 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, completeness, and representativeness on the spatial and 

temporal allocation of emissions from the existing inventory.

Grants Pass PM10 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 PM10 Limited Maintenance Plan inventory 

include:

Wendy Wiles, DEQ Environmental Solutions Division Administrator

Jeffrey Stocum, Air Quality Technical Services Section Manager

Emission Inventory 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 Assurance Plan.

Grants Pass PM10 Limited Maintenance Plan Appendix E, Page 11
Table 8.1. Draft Project Schedule: Grants Pass Limited Maintenance Plans for CO and PM10

Define Scope

SIP Development Plan

SIP Development Phase

Rulemaking Phase

EQC Adoption

Submit the final SIP to EPA

30-Dec-13

13-Jan-14

27-Jan-14

10-Feb-1424-Feb-1410-Mar-1424-Mar-147-Apr-1421-Apr-145-May-14

19-May-142-Jun-1416-Jun-1430-Jun-14

14-Jul-1428-Jul-1411-Aug-1425-Aug-148-Sep-1422-Sep-146-Oct-1420-Oct-143-Nov-1417-Nov-141-Dec-14

15-Dec-14

29-Dec-14

12-Jan-15

26-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 PM10 Limited Maintenance Plan Appendix E, Page 12