Bryan W. Shaw, Ph.D., Chainnan
Carlos Rubinstein, Commissioner Toby Baker, Commissioner
Zak Covar, Executive Director 

## RECEIVED- 6POL AIR PLANNING SEC.



## 12 JUL -5 PH 5: 23

TEXAS COMMISSION ON ENVIRONMENTAL QUALITI

Protecting Texas by Reducing and Preventing Pollution



### June 28, 2012



### Mr. Samuel Coleman Acting Regional Administrator Environmental Protection Agency, Region 6 Fountain Place 12th 

### Floor, Suite 1200
1445 

### Ross Avenue Dallas, Texas 75202-2733


### Subject: Request for Parallel Process Review of the Draft Beaumont-Port Arthur Attainment Area On-Road Mobile Source Emissions Invento:ry and Motor Vehicle Emissions Budget Update State Implementation Plan Revision

Dear Mr. Coleman:

The Texas Commission on Environmental Quality (TCEQ) submits the enclosed draft Beaumont-Port Arthur (BPA) Attainment Area On-Road Mobile Source Emissions Invento:ry and Motor Vehicle Emissions Budget (MVEB) Update State Implementation Plan (SIP) Revision. MVEBs are being revised to comply with mandato:ry use of the United States Environmental Protection Agency's Motor Vehicle Emission Simulator (MOVES) model in future transportation conformity determinations. We are requesting parallel processing to assist BPA-area transportation partners in shortening an impending conformity lapse.

The current BPA transportation plan does not conform to the MVEBs set by the most recently approved ozone SIP revision for the BPA area. Because the transportation plan cannot conform, it will "lapse" starting September 25, 2012, 

### which means no new transportation projects or project phases may advance until the problem is fixed. This SIP revision provides MOVES-based MVEBs to which the BPA transportation plan may conform, ending the lapse. To allow EPAarea transportation partners to conduct a conformity determination as quickly as possible, the TCEQ requests that the EPA parallel process its review of this draft submission for approval into the Texas SIP.

This SIP revision is an update to the 1997 

### Eight-Hour Ozone Redesignation Request and Maintenance Plan for the BPA Ozone Nonattainment Area (2008 

### BPA maintenance plan), which was approved by the EPA effective November 19, 2010. 

### The BPA 1997 

### eight-hour ozone maintenance area includes Hardin, Jefferson, and Orange Counties. This SIP revision proposal

was approved by the commission on June 27, 2012, 

### for publication, solicitation of public comments, and a public hearing. The public comment period will begin on June 29, 2012, 

### and end on August 3, 2012, 

### and the public hearing is scheduled for August 1, 2012. 

### The final submission of this SIP revision will document the public review process including a formal
summa:ry of comments received and the TCEQ's responses to those comments.

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.texas.gov

How is our customer service? tceq.texas.govjcustomersurvey

### Mr. Coleman Page Two

This SIP revision is expected to be noncontroversial as it will only update the approved 2008 

### BPA maintenance plan to incorporate the EPA's MOVES model. This SIP revision replaces the existing 2008 

### BPA maintenance plan on-road mobile source emissions inventories for nitrogen oxides (NOx) and volatile organic compounds (VOC) based on the EPA's MOBILE model with those based on the EPA's MOVES model. On-road mobile source emissions inventory updates include those for 2005, 2011, 2014, 2017, 

### and 2021. 

### In addition, this SIP revision replaces the existing 2021 

### NOx and VOC MVEBs with those derived from the MOVES-based emissions inventories.

Attached to this submission is one hardcopy of the required documentation. An 

### electronic version of the submission in PDF format that is identical to the hardcopy has been sent to Guy Donaldson at EPA, Region VI. The TCEQ respectfully requests that the EPA proceed with final review of the enclosed draft BPA Attainment Area On-Road Mobile Source Emissions Inventory and MVEB Update SIP Revision. 

### If you have any questions or need additional information, please contact David Brymer at (512)239-1725.



### Executive Director Texas Commission on Environmental Quality


### ZCjjz Enclosure: Draft Beaumont-Port Arthur Attainment Area On-Road Mobile Source Emissions Inventory and Motor Vehicle Emissions Budget Update State Implementation Plan RevisionREVISIONS TO THE STATE OF TEXAS AIR QUALITY IMPLEMENTATION PLAN FOR THE CONTROL OF OZONE AIR POLLUTION

BEAUMONT

- PORT ARTHUR ATTAINMENT AREA FOR THE 1997 EIGHT

- HOUR OZONE STANDARD

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711

- 3087

BEAUMONT

- PORT ARTHUR ATTAINMENT AREA ON

ROAD MOBILE SOURCE EMISSIONS INVENTORY AND MOTOR VEHICLE EMISSI ONS BUDGET UPDATE STATE IMPLEMENTATION PLAN REVISION

Project Number 2012

- 005

- SIP

- NR

Proposal June 27, 2012This page intentionally left blankES -1 EXECUTIVE SUMMARY

In 2008, the c ommission adopted the Eight

- Hour Ozone Redesignation Request and Maintenance Plan for the Be aumont

- Port Arthur (BPA) Ozone Nonattainment Area (Project No. 2008

- 006

- SIP

- NR), which fulfills all Federal Clean Air Act (FCAA) requirements to redesignate the BPA ozone nonattainment area (Hardin, Jefferson, and Orange Counties) to attainment of the 1997 eight

- hour ozone standard and demonstrates continued attainment of th at standard throu gh 2021

. The plan was approved by the United States Environmental Protection Agency (EPA) effective November 19, 2010, and the BPA area was redesignated to attainment for the 1997 eight

- hour ozone standard. The 2008 BPA maintenance plan contains on

- road mo bile emissions inventories

, a nitrogen oxides ( NO X

) motor vehicle emissions budget (MVEB ) , and a volatile organic compounds (VOC) MVEB developed using the EPA’s MOBILE emissions estimation model. On March 2, 2010, the EPA officially released a new model, the Motor Vehicle Emission Simulator (MOVES) model, to replace the MOB ILE model for SIP applications.
Beginning March 2, 2013, transportation conformity must be conducted using the MOVES model. To demonstrate transportation conformity, a nonattainment or ma intenance area must show that its metropolitan transportation plans, transportation improvement programs, and projects funded by the Federal Highway Administration or the Federal Transit Adm inistration conform to the MVEB s established in the state implemen tation plan (SIP). Conformity must be demonstrated before area transportation plans can be approved or funded by the U nited S tates Department of Transportation or the Metropolitan Planning Organizations. Updating MVEB s using MOVES

- based on

- road mobile emis sions inventories requires a SIP revision. This proposed SIP revision would facilitate future MOVES

- based transportation conformity d eterminations by providing MVEB s based on the latest version of the MOVES model, MOVES2010a

.
This proposed SIP revision would replace the 2008 BPA maintenance plan on

- road mobile source emissions inventories for NO X and VOC based on the EPA’s MOBILE model with those based on the EPA’s MOVES model. On

- road mobile source emissions inventory updates include those for 2005, 201 1, 2014, 2017, and 2021 . In addition, 2021 NO X and VOC MVEB s would be updated based on the MOVES

- based emissions inventories.

This proposed SIP revision include s documentation to satisfy the EPA’s MOVES implementation policy guidance 1 concerning updating maintenance plans with MOVES, which indicates that states must (1) demonstrate that the updated plan continues to meet all maintenance requirements and (2) document that growth and control strategy assumptions for all other source cate gories (area, non

- road mobile , and stationary point ) continue to be valid and any minor updates would not change the conclusions of the approved maintenance plan.

1 EPA, 2009. “ Policy Guidance on the Use of MOVES2010 for State Implementation Plan Development, Transportation Conformity, and Other Purposes.” Transportation and Regional Programs Division

, Office of Transportation and Air Quality

, U.S. Environmental Protection Agenc y, EPA

- 420 -B- 09

- 046 , December 2009.i SECTION V -A : LEGAL AUTHORITY

General Th e Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the quality of the state’s air, including maintaining adequate visibility.

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477

- 5, Vernon’s Texas Civil Statutes

. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, 2009 , and 2011

. In 1989, the TCAA was codified as Chapter 382 of the Texas Health and Safety Cod e.
Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution control agency and is the principal authority in the state on matters relating to the quality of air

resources

. In 1991, the legislature abolished the TACB effective September 1, 1993, and its powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource Conservation Commission (TNRCC)

. With the creation of the TNRCC, the authority over air quality is found in both the Texas Water Code and the TCAA

. Specifically, the authority of the TNRCC is found in Chapters 5 and 7

. Chapter 5, Subchapters A - F, H - J, and L, include the general provisions, organization, and general powers and duties of the TNRCC, and the responsibilities and authority of the executive director

. C hapter 5 also authorizes the TNRCC to implement action when emergency conditions arise and to conduct hearings

. Chapter 7 gives the TNRCC enforcement authority

. In 2001, the 77th Texas Legislature continued the existence of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the TCEQ

. In 2009, the 81st Texas Legislature, during a special session, amended section 5.014 of the Texas Water Code, changing the expiration date of the TCEQ to September 1, 2011 , unless continued in existence by the Texas Sunset A ct

. In 2011, the 82nd Texas Legislature continued the existenc e of the TCEQ until 2023.
The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in the state’s air and to control the quality of the state’s air by preparing and developing a general, comprehensive plan

. The TCAA, Subchapters A - D, also authorize the TCEQ to collect information to enable the commission to develop an inventory of emissions; to conduct research and investigations; to enter property and examine records; to prescribe monitoring requirements; to institute enforcement proceedings; to enter into contracts and execute instruments; to formulate rules; to issue orders taking into consideratio n factors bearing upon health, welfare, social and economic factors, and practicability and reasonableness; to conduct hearings; to establish air quality control regions; to encourage cooperation with citizens’ groups and other agencies and political subdi visions of the state as well as with industries and the federal government; and to establish and operate a system of permits for construction or modification of facilitie s.
Local government authority is found in Subchapter E of the TCAA

. Local governments have the same power as the TCEQ to enter property and make inspections

. They also may make recommendations to the commission concerning any action of the TCEQ that affects their territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements with the TCEQ or other local governments

. In addition, a city or town may enact and enforce ordinances for the control and abatement of air pollution not inconsistent with the provisions of the TCAA and the rules or orders of the commissi on.ii Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and maintenance programs in certain areas of the state, consistent with the requirements of the Federal Clean Air Act; coordinate with federal, state, and local transpor tation planning agencies to develop and implement transportation programs and measures necessary to attain and maintain the NAAQS; establish gasoline volatility and low emission diesel standards; and fund and authorize participating counties to implement vehicle repair assistance, retrofit, and accelerated vehicle retirement programs.

Applicable Law The following statutes and rules provide necessary authority to adopt and implement the state implementation plan (SIP)

. The rules listed below have previously been submitted as part of the SIP.

Statutes All sections of each subchapter are included, unless otherwise noted. TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2011 TEXAS WATER CODE September 1, 2011
Chapter 5: T exas Natural Resource Conservation Commission Subchapter A: General Provisions Subchapter B: Organization of the Texas Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties of the Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§5.225, 5.22 6, 5.227, 5.2275, 5.231, 5.232, and 5.236) Subchapter H: Delegation of Hearings Subchapter I: Judicial Review Subchapter J: Consolidated Permit Processing Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145, and 5.515 only) Subchapter M: Environmental Permitting Procedures (§5.558 only)

Chapter 7: Enforcement Subchapter A: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 only) Subchapter B: Corrective Action and Injunctive Relief (§7.032 only) Subchapter C: Administrative Penalties Subchapter D: Civil Penalties (except §7.109) Subchapter E: Criminal Offen ses and Penalties: §§7.177, 7.179

- 7.183

Rules All of the following rules are found in 30 Texas Administrative Code, as of the following latest effective dates:

Chapter 7: Memoranda of Understanding, §§7.110 and 7.119 December 13, 1996 and May 2, 2002

Cha pter 19: Electronic Reporting March 15, 2007

Chapter 35: Subchapters A

- C, K: Emergency and Temporary Orders and Permits; Temporary Suspension or Amendment of Permit Conditions July 20, 2006iii Chapter 39: Public Notice, §§39.402(a)(1) - (6), (8), and (10) - ( 12), 39.405(f)(3) and (g), (h)(1)(A) - ( 4), (6), (8) - (11), (i) and (j), 39.407, 39.409, 39.411 (a), (e)(1) - (4)(A)(i) and (iii), (4)(B), (5)(A) and (B), and (6) - (10), (11)(A)(i) and (iii) and (iv), (11)(B ) - (F), (13) and (15), and (f)(1) - (8), (g) a nd (h), 39.418(a), (b)(2)(A), (b)(3), and (c), 39.419(e), 39.420 (c)(1)(A) - (D)(i)(I) and (II), (D)(ii), (c)(2), (d) - (e), and (h) , and 39.601 - 39.605 June 24, 2010
Chapter 55: Requests for Reconsideration and Contested Case Hearings; Public Comment, §§ 55.150, 55.152(a)(1), (2), (5)

, and (6) and (b), 55.154(a), (b), (c)(1) - (3)

, and (5), and (d) - (g), and 55.156(a), (b), (c)(1), (e)

, and (g) June 24, 2010
Chapter 101: General Air Quality Rules October 27, 2011
Chapter 106: Permits by Rule, Subchapter A May 1 5 , 20 11
Chapter 111: Control of Air Pollution from Visible Emissions and Particulate Matter February 16, 2012

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for Designated Facilities and Pollutants May 14, 2009
Chapter 114: Control of Air Pollution from Motor Vehicles August 11 , 201 1
Chapter 115: Control of Air Pollution from Volatile Organic Compounds December 29 , 2011
Chapter 116: Permits for New Construction or Modification March 1, 2012
Chapter 117: Control of Air Pollution from Nitrogen Compounds April 19, 2012

Chapter 118: Control of Air Pollution Episodes March 5, 2000

Chapter 122: §122.122: Potential to Emit December 11, 2002

Chapter 122: §12 2.215: Minor Permit Revisions June 3, 2001
Chapter 122: §122.216: Applications for Minor Permit Revisions June 3, 2001
Chapter 122: §122.217: Procedures for Minor Permit Revisions December 11, 2002

Chapter 122: §122.218 : Minor Permit Revision Procedures for Permit Revisions Involving the Use of Economic Incentives, Marketable Permits, and Emissions Trading June 3, 2001iv SECTION VI: CONTROL STRATEGY

A. Introduction (No change)
B. Ozone (Revised)
1. Dallas

- Fort Worth (No change)
2. Houston

- Galveston

- Brazoria (No change)
3. Beaumont

- Port Arthur ( Revised ) Chapter 1: General (Revised) Chapter 2: Redesignation Requirements ( Revised ) Chapter 3: Attainment Emissions Inventory (No change) Chapter 4: Maintenance Demonstration (Revised) Chapter 5: Monitoring Network (No change) Chapter 6: Contingency Plan (No change)
4. El Paso (No change)
5. Regional Strategies (No change)
6. Northeast Texas (No change)
7. Austin Area (No change)
8. San Antonio Area (No change)
9. Victoria Area ( No change )
C. Particulate Matter (No change)
D. Carbon Monoxide (No change)
E. Lead (No change)
F. Oxides of Nitrogen (No change)
G. Sulfur Dioxide (No change)
H. Conformity with the National Ambient Air Quality Standards (No change)
I. Site Specific (No change)
J. Mobile Sources Strategies (No change)
K. Clean Air Interstate Rule (No change)
L. Transport (No change)
M. Regional Haze (No change)v TABLE OF CONTENTS

Executive Summary
Section V

- A: Legal Authority Section VI: Control Strategy
Table of Contents List of Acronyms
List of Tables List of Figures List of Appendices Chapter 1: General (Updated) 1.1 Background and Introduction (Updated)
1.1.1 Purpose of Plan (Updated)
1.1.2 One

- Hour Ozone History in the BPA Area (No Change)
1.1.3 Eight

- Hour Ozone History in the BPA Area (Updated) 1.1.3.1 2008 and 2010 Eight

- Hour Ozone Standards (Added) 1.2 Public Hearing Information (Updated)
1.3 Social and Economic Consideration (No Change) 1.4 Fiscal and Manpower Resources (No Change) Chapter 2: Redesignation Requirements (Updated) 2.1 Attainment of the 1997 Eight

- Hour Ozone National Ambient Air Quality Standard (Updated)
2.1.1 Ozone Data (No Change)
2.1.2 Ozone Trend Analysis (Updated) 2.2 SIP Approvability Under Section 110( k ) of the Federal Cl ean Air Act (No Change)
2.3 Permanent and Enforceable Emission Reductions (Updated)
2.3.1 Control Strategies (No Change)
2.3.2 2002 Periodic Emissions Inventory (No Change)
2.3.3 Trend Analysis (Updated)
2.3.3.1 Nitrogen Oxides Trends (Updated) 2.4 Section 175A Requirements for Maintenance Plans (No Change) Chapter 3: Attainment Emissions Inventory (No Change) Chapter 4: Maintenance Demonstration (Updated)
4.1 General (Updated)
4.2 Future Emissions and Verification of Continued Attainment (Updated)
4.2.1 Area Sources (Updated)
4.2.1.1 Flash Emissions from Upstream Oil and Gas Production (No Change) 4.2.1.2 Updated Verification of Continued Attainment for Area Sources (Added)vi 4.2.2 On

- Road Mobile Sources (Updated)
4.2.2.1 Motor Vehicle Emiss ions Budgets (Updated)
4.2.2.2 Safety Margin (Updated)
4.2.3 Non

- Road Mobile Sources (Updated) 4.2.3.1 Airports (No Change)
4.2.3.2 Locomotives and Marine Vessels (No Change) 4.2.3.3 Updated Verification of Continued Attainment for Non

- Road Mobile Sources (Added)
4.2.4 Stationary Point Sources (Updated) 4.2.4.1 Emissions Inventory Compilation (No Change) 4.2.4.2 Updated 2005 Base Year Inventory (No Change)
4.2.4.3 Updated Uncontrolled Milestone Year Inventories (No Change)
4.2.4.4 Updated Verification of Co ntinued Attainment for Stationary Point Sources (Added) 4.3 Control Strategies (No Change)
4.3.1 Point Source NO X Control Strategy (No Change)
4.3.2 National Volatile Organic Compound Emission Standards for Consumer Products (No Change)
4.3.3 National Volatile Organic Compound Emission Standards for Architectural Coatings (No Change)
4.3.4 National Low Emission Vehicle Program / Tier 2 Engine and Fuel Standards (No Change)
4.3.5 Stage I Vapor Recovery (No Change)
4.3.6 Stage II Vapor Recovery (No Change)
4.3.7 Texas Low Emission Diesel (No Change)
4.3.8 Texas Emission Reduction Plan (No Change)
4.3.9 Locomotives and Marine Compression

- Ignition Engines (No Change) 4.4 Emissions Summary (Updated)
4.5 Continued Maintenance with MOVES

- Based On

- Road Mobile Emissions Inventories (Added) Chapter 5: Monitoring Network (No Change) Chapter 6: Contingency Plan (No Change)vii LIST OF ACRONYMS

AutoGC automated gas chromatograph

BPA Beaumont

- Port Arthur

EDMS Emissions and Dispersion Modeling System

EPA United States Environmental Protection Agency

FCAA Federal Clean Air Act

MOVES Motor Vehicle Emission Simulator model

MVEB m otor v ehicle e missions b udget NAAQS National Ambient Air Quality Standard

NO X

n itrogen o xides

p pb p arts p er b illion

p pm p arts p er m illion

SIP s tate i mplementation p lan

TACB Texas Air Control Board

TCAA Texas Clean Air Act TCEQ Texas Commission on Environmental Quality (commission)

TDM Travel Demand Model

TexAER Texas Air Emissions Repository

TexN Texas

- Specific NONROAD m odel

TNRCC Texas Natural Resource Conservation Commission tpd t ons p er d ay
TTI Texas Transportation Institute

TxDOT Texas Department of Transportation

VOC v olatile o rganic c ompoundsviii LI ST OF TABLES

Table 4

- 1: MOBIL E- Based On

- Road Mobile Source NO X and VOC Emissions in the BPA Area (2005, 2011, 2014, 2017, and 2021)
Table 4

- 2: Updated Summary of NO X Emissions in the BPA Area by Source Type (2005, 2011, 2014, 2017, and 2021)
Table 4

- 3: Updated Summary of VOC Emissions in the BPA Area by Source Type (2005, 2011, 2014, 2017, and 2021)
Table 4 -4: Original Summary of Total NO X and VOC Emissions in the BPA Area
Table 4

- 5: Updated Summary of Total NO X and VOC Emissions in the BPA Area (2005, 2011, 2014, 2017, and 2021)
Table 4- 6: BPA Area Ozone Season Weekday On

- Road Mobile Emissions Inventories
Table 4

- 7: 2021 Horizon Year MVEBs for the BPA area using MOVES2010a
Table 4

- 8: Updated Percentages of NO X Emissions in BPA by Source Category
Table 4

- 9: Updated Percentages of VOC Emissions in BPA by Source Categoryix LIST OF FIGURES

Figure 2

- 1: Ozone Design Value Trends in the BPA Area Figure 2

- 2: Ozone Design Values and Population Trends in the BPA Area Figure 2

- 3: Ozone Exceedance Days a nd Number of Monitors in the BPA Area Figure 2 -4: Eight

- Hour Ozone Exceedance Days by Monitor in the BPA Area Figure 2

- 5: Average NO X Trends in the BPA Area Figure 2

- 6: Median Ethylene at AutoGCs in the BPA Area Figure 2

- 7: Median Propylene at AutoGCs in the BPA Area Figure 2

- 8: Median Ethylene Trends from Canister Data in the BPA Area Figure 2

- 9: Median Propylene Trends from Canister Data in the BPA Areax LIST OF APPENDICES
Appendix Appendix Name Appendix D BPA Area On

- Road Emissions Inventories for SIP Submission - 2005, 2011, 2014, 2017, and 2021, TTI Report, February 20121-1 CHAPTER 1: GENERAL (UPDATED)

1.1 BACKGROUND AND INTRO DUCTION (UPDATED)
1.1.1 Purpose of Plan (Updated) In 2008, the commission adopted the Eight

- Hour Ozone Redesignation Request and Maintenance Plan for the Beaumont

- Port Arthur (BPA) Ozone Nonattainment Area (Project No. 2008

- 006

- SIP

- NR), which fulfills all Federal Clean Air Act (FCAA) requirements to redesignate the BPA ozone nonattainment area (Hardin, Jefferson, and Orange Counties) to attainment of the 1997 eight

- hour ozone standard and demonstrates continued attainment of th at standard through 2021 . The plan was approved by the United States Environmental Protection Agency (EPA), effective November 19, 20 10, and the BPA area was redesignated to attainment for the 1997 eight

- hour ozone standard. The maintenance plan contains on

- road mobile emissions inventories , a nitrogen oxides ( NO X

) motor vehicle emissions budget (MVEB ) , and a volatile organic compounds (VOC) MVEB developed using the EPA’s MOBILE emissions estimation model. On March 2, 2010, the EPA officially released a new model, the Motor Vehicle Emission Simulator (MOVES) model, to replace the MOB ILE model for SIP applications.
Beginning March 2, 2013 , transportation conformity must be conducted using the MOVES model. To demonstrate transportation conformity, a nonattainment or maintenance area must show that its metropolitan transportation plans, transportation improvement programs, and projects funde d by the Federal Highway Administration or the Federal Transit Adm inistration conform to the MVEB s established in the state implementation plan (SIP). Conformity must be demonstrated before area transportation plans can be approved or funded by the U nited States Department of Transportation or the Metropolitan Planning Organizations. Updating MVEB s using MOVES

- based on

- road mobile emissions inventories requires a SIP revision. This proposed SIP revision would facilitate future MOVES

- based transportation conformity determinations by providing MVEB s based on the latest version of the MOVES model, MOVES2010a

. This proposed SIP revision would replace the 2008 BPA maintenance plan on

- road mobile source emissions inventories for NO X and VOC based on the EPA’s MOBI LE model with those based on the EPA’s MOVES model. On

- road mobile source emissions inventory updates include those for 2005, 2011, 2014, 2017, and 2021. In addition, 2021 NO X and VO C MVEB s would be updated according to the MOVES

- based emissions inventorie s.
This proposed SIP revision includes documentation to satisfy the EPA’s MOVES implementation policy guidance 2 concerning updating maintenance plans with MOVES, which indicates that states must (1) demonstrate that the updated plan continues to meet all maintenance requirements and (2) document that growth and control strategy assumptions for all other source cate gories (area, non

- road mobile , and stationary point ) continue to be valid and any minor updates would not change the conclusions of the approved maintenance plan.

2 EPA, 2009. “ Policy Guidance on the Use of MOV ES2010 for State Implementation Plan Development, Transportation Conformity, and Other Purposes.” Transportation and Regional Programs Division

, Office of Transportation and Air Quality

, U.S. Environmental Protection Agenc y, EPA

- 420 -B- 09

- 046 , December 2009

.1-2 1.1.2 One

- Hour Ozone History in the BPA Area (No Change)
1.1.3 Eight

- Hour Ozone History in the BPA Area (Updated)
1.1.3.1 2008 and 2010 Eight

- Hour Ozone Standards (Added) On March 12, 2008, the EPA lowered the primary and secondary eight

- hour ozone standards to 0.075 parts per million ( ppm ) . The governor recommended to the EPA in March 2009 that Hardin, Jefferson, and Orange Counties be designated as a nonattainment area for the 2008 eight

- hour ozone standard. In September 2009, the EPA announced that it intended to reconsider the 2008 ozone standard. On January 19, 2010, the EPA proposed revision s in the Federal Register ( 75 FR 2938 ) to strengthen the primary eight

- hour ozone standard in the range of 0.060 to 0.070 ppm. On September 2, 2011, the President announced a request that the EPA withdraw the proposed

, reconsidered ozone standard.

In a Sep tember 201 1 memo , the EPA announced that it would proceed with initial area designations under the 2008 (0.075 ppm) eight

- hour ozone standard, starting with the recommendations states made in 2009 and updating those recommendations with the most current, c ertified air quality data (2008 through 2010). The governor submitted a revised designation recommendation in October 2011 that excluded Hardin, Jefferson, and Orange Counties from being designated as nonattainment under the reinstated 2008 eight

- hour ozone standard.

The EPA published final designations for the 2008 ozone standard along with a final rulemaking to revoke transportation conformity under the 1997 eight

- hour ozone standard on May 21, 2012

. Since the BPA area is designated attainment/unclass ifiable for the 2008 eight

- hour ozone standard and is a maintenance area for the 1997 eight

- hour ozone standard , transportation conformity w ill no longer be required upon the effective date of revocation of transportation conformity for the 1997 eight

- hour ozone standard

, July 20, 2013

.

1.2 PUBLIC HEARING INFOR MATION (UPDATED) The commission will offer a public hearing in Beaumont on August 1, 2012, at six o’clock in the evening. The public hearing will be held in the Ho mer E. Nagel Conference Room of the South East Texas Regional Planning Commission at 2210 Eastex Freeway, Beaumont, Texas 77703.

The public comment period will open on Ju ne 29 , 2012 , and will close on August 3 , 20 12

. Notice of public hearing for this SIP revision will be published in the Texas Register and the “Beaumont Enterprise” newspaper

. Written comments will be accepted via mail, fax, or through the eComments system. All comments should reference the “ Beaumont

- Port Arthur Attainment Area On

- Road Mobile Source Emissions Inventory and Motor Vehicle Emissions Budget Update State Implementation Plan Revision ” and Project Number 201 2- 005

- SIP

- NR. Comments may be submitted to Jamie Zech, MC 206, State Implementation Plan Team, Chief Engineer’s Office, Texas Commission on Environmental Quality, P.O . Box 13087, Austin, Texas 78711

- 3087 or faxed to (512) 239

- 6188

. If you choose to submit e lectronic comments , they m ust be submitted through the eComments ( http://www5.tceq.state.tx.us/rules/ecomm ents ) system. File size restrictions may apply to comments being submitted via the eComments system. Comments must be received by August 3 , 2012

.

1.3 SOCIAL AND ECONOMIC CONSIDERATION ( NO CHANGE )
1.4 FISCAL AND MANPOWER RESOURCES ( NO CHANGE )2-1 CHAPTER 2: REDESIGNATION REQUIR EMENTS ( UPDATED)

2.1 ATTAINMENT OF THE 19 97 EIGHT -HO UR OZONE N ATIONAL AMBIENT AIR QUALITY STANDARD (UPDATED)
2.1.1 Ozone Data ( No Change )
2.1.2 Ozone Trend Analysis (Updated) Ozone trends in the Beaumon t- Port Arthur ( BPA ) area have been decreasing over the past 20 years

. Figure 2 -1 : Ozone Design Value Trends in the BPA Area shows decreases in both the eight

- hour and one

- hour ozone design values

. Although both the eight

- hour and the one

- hour design values increased from 2010 to 2011, the overall design value trend has been decreasing

. The eight

- hour ozone design value has decreased by 2 2% over the past 20 years and the one

hour ozone design value had decreased by 27 % over the past 20 years

. The 20 11 eight

- hour ozone design value for the BPA area was 7 9 parts per billion (ppb) , which is below the 1997 eight

- hour ozone standard of 84 ppb ( 0.0 8 p arts per m illion (ppm) )

. The BPA area has not exceeded the eight

- hour ozone standard since 2006

. The 20 11 one

- hour o zone design value for the BPA area was 1 10 pp b , which is also below the revoked one

- hour ozone standard of 125 ppb ( 0. 12 pp m)

. The decreases in ozone have occurred despite increases in population in the BPA

area , as shown in Figure 2

- 2: Ozone Design Values and Population Trends in the BPA Area

. Figure 2 -3 : Ozone Exceedance Days and Number of Monitors in the BPA Area shows that the number of eight

- hour ozone exceedance days has decreased in the BPA area despite an increase in the number of monitors . Although there were more eight

- hour ozone exceedance days in 2011 compared to 2010, the overall trend in exceedance days is decreasing

. There were only four eight

- hour ozone exceedance days in the BPA area in 20 11 , an unusual year with record

breaking temperatures and an unusual number of days that favored the development of ozone.
Because the exceedance day count is dependent on the number of monitors in the area, the number of eight

- hour ozone exceedance days by monitor is shown in Figure 2-4: Eight

- Hour Ozone Exceedance Days by Monitor in the BPA Area

. Exceedances by monitor tend to vary from year to year; however, t he overall trend in the number of eight

- hour ozone exceedance days has been decreasing over the past 20 years.2-2 101 100 97 93 94 91 93 91 88 87 85 90 91 92 88 85 83 81 77 74 79 150

140

130 124 139 139 139 133 133 152

127 144

129 130 128 127

107 107 101 102 110

0 20 40 60 80 100 120 140 160 180199119921993199419951996199719981999200020012002200320042005200620072008200920102011 ppb Ozone Design Values in the BPA Area

1997 Eight

- Hour Ozone NAAQS: 84 ppb 2008 Eight

- Hour Ozone NAAQS: 75 ppb *Design Values are from EPA's AQS. One

- Hour Ozone Design Values

Eight

- Hour Ozone Design Values

Figure 2-1: Ozone Design Value Trends in the BPA Area

0 75 150 225 300 375 450

0 30 60 90 120 150 180199119921993199419951996199719981999200020012002200320042005200620072008200920102011 Thousands ppb Ozone Design Values and Population in the BPA Area

Population Eight

- Hour Ozone Design Values

One

- Hour Ozone Design Values 1997 Eight

- Hour Ozone NAAQS: 84 ppb 2008 Eight

- Hour Ozone NAAQS: 75 ppb *Design Values are from EPA's AQS. **Population from US Census Bureau.

Figure 2-2: Ozone Design Values and Population Trends in the BPA Area2-3 22

12 18

6 31

7 14

11

2 17

7 11
9 13

7 8

3 2 2 2 4

0 3 6 9 12

0 10 20 30 40199119921993199419951996199719981999200020012002200320042005200620072008200920102011 Monitors Days 

### Ozone Exceedance Days and the Number of Monitors in the BPA Area

*Data from EPA's AQS.

Eight

- Hour Ozone Exceedance Days (1997 NAAQS) Number of Monitors

Figure 2-3: Ozone Exceedance Days and Number of Monitors in the BPA Area

0 4 8 12 16 20199119921993199419951996199719981999200020012002200320042005200620072008200920102011 Days 

### Eight

- Hour Ozone Exceedance Days by Monitor in the BPA Area

Kountze C85 Beaumont C2/C112/C2002 Port Arthur West C28/C128/C228 Jefferson Co. Airport C1019/C2001 Jefferson Co. Airport C1019/C2001

- POC 2 Hamshire C64/C654 SETRPC 40 Sabine Pass C640/C1654 SETRPC43 Jefferson Co. Airport C643 SETRPC Port Arthur C628 Nederland High School C1035 West Orange C9/C141 SETRPC 42 Mauriceville C311/C642/C665

*Data from EPA's AQS.

Figure 2-4: Eight

- Hour Ozone Exceedance Days by Monitor in the BPA Area2-4 2.2 SIP APPROVABILITY UN DER SECTION 110( k ) OF THE FEDERAL CLEAN AIR ACT (NO CHANGE)
2.3 P ERMANENT AND EN FORCEABLE E M ISSION REDUCTIONS ( UPDATED )
2.3.1 Control Strategies (No Change)
2.3.2 2002 Periodic Emissions Inventory (No Change)
2.3.3 Trend Analysis ( Updated )
2.3.3.1 N itrogen O xides Trends (Updated) Overall, nitrogen oxides ( NO X

) trends in the BPA area are decreasing

. Figure 2 -5: Average NO X Trends in the BPA Area shows the NO X trends at five monitors in the BPA area: Beaumont Downtown (CAMS 2/CAMS 112/ CAMS 2002) , Jefferson County Airport (CAMS 1019/CAMS2001) , Hamshire (CAMS 64/CAMS 654) , Nederland High School (CAMS 1035) , and West Orange (CAMS 9/CAMS141)

. Data for 2011 cover only the first two quarters of the year, and NO X averages during 2011 are subject to change

. The average NO X concentration has remained relatively flat at most monitors until sometime from 2003 to 2006

. After 2006, the last year the BPA area had an ozone design value exceed 84 ppb, most monitors showed a large decrease in NO X concentrations

. West Orange (CAMS 9/ CAMS141) did show a slight increase in average NO X concentrations from 2010 to 2011, but the overall trend from 1991 to 2011 shows a decrease of 54 %

. NO X decreased 26 % from 1991 to 2011 at the Beaumont Downtown (CAMS 2/CAMS 112/ CAMS 2002) site, 40 % from 2 000 to 2011 at the Hamshire (CAMS 64/CAMS 654) site, and 50 % from 2006 to 2011 at the Nederland High School (CAMS 1035) site

.

0 2 4 6 8 10 12 14 16 18199119921993199419951996199719981999200020012002200320042005200620072008200920102011 ppb 

### Average NO X 

### in the BPA Area

Beaumont Downtown C2/C112/C2002 Jefferson County Airport C1019/C2001 Hamshire C64/C654 Nederland High School C1035 West Orange C9/C141

*Data from EPA's AQS. Only the first two quarters of 2011 data are available. Data is subject to change.

Figure 2-5: Average NO X Trends in the BPA Area2-5 V olatile O rganic C ompounds Trends (Updated)
Continuous volatile organic compounds ( VOC ) data are collected at two automated gas chromatograph (AutoGC) monitors in the BPA area

. Those two monitors are Beaumont Downtown (CAMS 2/CAMS 112/ CAMS 2002) and Nederland High School (CAMS 103 5) , which have valid data beginning August 28, 2006, and August 29, 2006, respectively, and ending on December 1, 2011

. Note that the last month of data from 2011 is not yet available

. Figures 2 -6 : Median Ethylene at AutoGCs in the BPA Area and 2- 7: Median Propylene at AutoGCs in the BPA Area show the median ethylene and propylene concentrations at the two AutoGC monitors in the BPA area, respectively

. Both ethylene and propylene have decreased at all monitors over the last five years

. Ethylene decreased 55 % at Beaumont Downtown (CAMS 2/CAMS 112/ CAMS 2002) and 41 % at Nederland High School (CAMS 1035)

. Propylene decreased 54 % at Beaumont Downtown (CAMS 2/CAMS 112/ CAMS 2002) and 35 % at Nederland High School (CAMS 1035)

.

1.82

1.25 1.40

1.09

0.98

0.81 1.40

1.00 1.19

0.82 0.75 0.82

0 0.2 0.4 0.6 0.8

1 1.2 1.4 1.6 1.8

2

2006 2007 2008 2009 2010 2011

ppb 

### Median Ethylene at AutoGCs in the BPA Area

*2011 Data incomplete and subject to change. Beaumont Downtown C2/C112/C2005

Nederland High School C1038

Figure 2-6: Median Ethylene at AutoGCs in the BPA Area2-6 1.31

1.08

0.95

0.80
0.74

0.60 0.78

0.60 0.63 0.58 0.64

0.51

0 0.2 0.4 0.6 0.8

1 1.2 1.4

2006 2007 2008 2009 2010 2011 ppb 

### Median Propylene at AutoGCs in the BPA Area

*2011 Data incomplete and subject to change. Beaumont Downtown C2/C112/C2005

Nederland High School C1038

Figure 2-7: Median Propylene at AutoGCs in the BPA Area

VOC canister data have also been available in the BPA area since 1994

. The VOC canisters samples are 24

- hour averages and are sampled every 6 days

. Figures 2 -8 : Median Ethylene Trends from Canister Data in the BPA Area and 2- 9: Median Propylene Trends from Canister Data in the BPA Area both show that ethylene and propylene, t wo of the most reactive VOC, have been decreasing at nine canister sites in the BPA area over the past 14 and 17 years , respectively

. Only one quarter of data are available for 2011, so concentrations are subject to change

. While the ethylene concentrations are generally higher than the propylene concentrations, the median ethylene concentration s ha ve decreased at the nine canister sites (one of the eight sites has three monitors), with an average decrease of 41 %

. West Orange (CAMS 9/CAMS141) and Beaumont Mary (CAMS 1050) both showed increases in ethylene; however, the West Orange (CAMS 9/CAMS141) canister site stopped operation in 2006

, and the Beaumont Mary (CAMS 1050) site has only been in operation for two years

. Similarly, median propylen e concentrations have decreased at the nine canister sites, with an average decrease of 42%

. Again, the Beaumont Mary (CAMS 1050) site showed a slight increase in propylene concentrations, but it has only been in operation for two years. F or both propylene and ethylene, the increase at Beaumont Mary (CAMS 1050) was less than 0.5 ppb.2-7 0 1 2 3 4 5 6 7 8 9

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

ppb Median Ethylene from Canister Data in the BPA Area

Beaumont Downtown Port Arthur West Port Arthur West POC 00 Port Arthur West POC 01
Groves Port Neches Jefferson County Airport City Service Center / PA
CARROLL STREET PARK Beaumont Mary West Orange

*Only first quarter of 2011 data available. 2011 concentrations subject to chage.

Figure 2-8: Median Ethylene Trends from Canister Data in the BPA Area

0 0.5

1 1.5

2 2.5

3 3.5

4

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

ppb Median Propylene from Canister Data in the BPA Area

Beaumont Downtown Port Arthur West Port Arthur West POC 00 Port Arthur West POC 01
Groves Port Neches Jefferson County Airport City Service Center / PA
CARROLL STREET PARK Beaumont Mary West Orange

*Only first quarter of 2011 data available. 2011 concentrations subject to chage.

Figure 2-9: Median Propylene Trends from Canister Data in the BPA Area2-8 2.4 SECTION 175A REQUIREMENTS FOR MAI NTENANCE PL ANS (NO CHANGE)3-1 CHAPTER 3: ATTAINMENT EMISSIONS INVENTORY (NO CHANGE)4-1 CHAPTER 4: MAINTENANCE DEMONSTR ATION (UPDATED)

4.1 GENERAL (UPDATED) This proposed state implementation plan (SIP) revision is an update to the 2008 Beaumont

Port Arthur (BPA) maintenance plan that revises the original on

- road mobile source emissions inventories , nitrogen oxides ( NO X

) motor vehicle emissions budget (MVEB ) , and volatile organic compounds (VOC) MVEB to be based on the United States Environmental Protection Agency’s (EPA) Motor Vehicle Emissio n Simulator (MOVES) model

. The on

- road mobile source emissions inventories and MVEB s adopted with the 2008 BPA maintenance plan

, which was approved by the EPA effective November 19, 2010

, were developed using the MOBILE emissions estimation model. On March 2, 2010, the EPA o fficially released the MOVES model to replace the MOB ILE model for SIP applications. Beginning March 2, 2013, transportation conformity must be conducted using the MOVES model. This proposed update to the 2008 BPA maintenance plan would facilitate future, required, MOVES

- based transportation conformity determinations.

The EPA provided a guidance document 3 to assist states in incorporating MOVES

- based on

road mobile source emissions inventories and MVEB s into existing area maintenance plan s. Th e guidance allows states, under stipulated conditions, to update only the on

- road mobile source portion s of their maintenance plans. S tates must (1) demonstrate that the updated plan continues to meet all maintenance requirements and (2) document that growth and control strategy assumptions for all other source categories (area, non

- road mobile , and stationary point ) continue to be valid and any minor updates would not change the conclusions of the approved maintenance plan.

This proposed SIP revision satisf ies both conditions of the MOVES guidance document ; therefore, only Section 4.4.2: On

- Road Mobile Sources has been revised. For each of the other source categories (area, non

- road mobile

, and stationary point)

, sections have been added describing tha t any minor updates have not changed the conclusions of the 2008 BPA maintenance plan: Section 4.2.1.2: Updated Verification of Continued Attainment for Area Sources ; Section 4

. 2.3.3: Updated Verification of Continued Attainment for Non

- Road Mobile Sources ; and Section 4.2.4.4: Updated Verification of Continued Attainment for Stationary Point Sources

.

4.2 FUTURE EMISSIONS AND VERIFICATION OF CONT INUED ATTAINMENT (UPDATED)
MOVES

- based on

- road mobile source NO X and VOC emissions estimates would change slightly from the MOBILE

- based estimates adopted with the 2008 BPA maintenance plan. Table 4

- 1: MOBILE

- Based On

- Road Mobile Source NO X and VOC Emissions in the BPA Area (2005, 2011, 2014, 2017, and 2021) summarizes, in tons per day (tpd), the on

- road mobile source emissions estimates (MOBILE

- based) that were included in the original maintenance plan. Emissions estimates for area, non

- road mobile, and stationary point sources were not included in Table 4

- 1 because they were n ot updated from the 2008 BPA maintenance plan. MOVES

- based NO X and VOC on

- road mobile source emission estimates are summarized in Tables 4 -2 : Updated Summary of NO X Emissions in BPA by Source Type (2005, 2011, 2014, 2017, and 2021) and 4

-

3 EPA, 2009. “ Policy Guidance on the Use of MOVES2010 for State Implementation Plan Development, Transportation Conformity, and Other Purposes.” Transportation and Regional Programs Division

, Office of Transportation and Air Quality

, U.S. Environmental Protection Agenc y, EPA

- 420 -B- 09

- 046 , December 2009.4-2 3 : Updated Summary of VOC Emissions in BPA by Source Type (2005, 2011, 2014, 2017, and 2021) along with the original estimates for the other source categories (area, non

- road mobile, and stationary point)

. Tables 4

- 2 and 4

- 3 show how this proposed update to the MOVES model would affect the projected overall emissions trends included in the 2008 BPA maintenance plan.

Table 4-1: MOBILE

- Based On

- Road Mobile Source NO X and VOC Emissions in the BPA Area (2005, 2011, 2014, 2017, and 2021)

Source Category 2005 2011 2014 2017 2021 Net Change
NO X 45.60 tpd 17.91 tpd 12.38 tpd 8.66 tpd 6.24 tpd

- 39.36 tpd
VOC 11.63 tpd 7.92 tpd 6.51 tpd 5.58 tpd 4.77 tpd

- 6.86 tpd
Note: The estimate d emissions included in this table were extracted from Tables 4

- 1: Summary of VOC Emissions in BPA by Source Type (2005, 2011, 2014, 2017, and 2021) and 4

- 2: Summary of NO X Emissions in BPA by Source Type (2005, 2011, 2014, 2017, and 2021) of the 2008 BPA m aintenance plan.

Table 4-2: Updated Summary of NO X Emissions in the BPA Area by Source Type (2005, 2011, 2014, 2017, and 2021)

Source Category 2005 2011 2014 2017 2021 Net Change
Area Source 9.06 tpd 9.95 tpd 10.40 tpd 10.86 tpd 11.47 tpd 2.41 tpd
MOVES

- Based On

Road Mobile Source 44.50 tpd 26.60 tpd 18.60 tpd 13.50 tpd 9.70 tpd

- 34.80 tpd

Non

- Road Mobile Source 25.99 tpd 27.08 tpd 27.88 tpd 28.87 tpd 30.63 tpd 4.64 tpd

Stationary Point Source 68.49 tpd 79.17 tpd 81.14 tpd 83.04 tpd 85.44 tpd 16.95 tpd

Total 148.04 tpd 142.80 tpd 138.02 tpd 136.27 tpd 137.24 tpd

- 10.80 tpd

Table 4-3: Updated Summary of VOC Emissions in the BPA Area by Source Type (2005, 2011, 2014, 2017, and 2021)

Source Category 2005 2011 2014 2017 2021 Net Change
Area Source 151.57 tpd 155.68 tpd 156.84 tpd 158.40 tpd 160.54 tpd 8.97 tpd
MOVES

- Based On

Road Mobile Source 11.30 tpd 8.30 tpd 6.30 tpd 5.00 tpd 3.90 tpd

- 7.40 tpd

Non

- Road Mobile Source 4.96 tpd 4.36 tpd 4.23 tpd 4.20 tpd 4.30 tpd

- 0.66 tpd

Stationary Point Source 42.68 tpd 48.26 tpd 49.83 tpd 51.54 tpd 53.95 tpd 11.27 tpd

Total 210.51 tpd 216.60 tpd 217.20 tpd 219.14 tpd 222.69 tpd 12.18 tpd4-3 The MOBILE

- based on

- road mobile source emissions estimates adopted with the 2008 BPA maintenance plan trend downward for both NO X and VOC, with a net decrease from 2005 through 2021 of 39.36 tpd and 6.86 tpd, respectively. The MOVES

- based on

- road estimates also trend downward for both NO X and VOC , with a net decrease of 34.80 tpd and 7.40 tpd, respectively.

Tables 4 -4: Original Summary of Total NO X and VOC Emissions in the BPA Area and 4- 5: Updated Summary of Total NO X and VOC Emissions in BPA (2005, 2011, 2014, 2017, and 2021) depict combined total NO X and VOC base and projection values. Table 4

- 4 is from the 2008 maintenance plan, containing MOBILE

- based on

- road mobile source emissions estimates. Table 4

- 5 shows how this proposed MOVES update would affect total NO X and VOC emissions projections in the BPA area.

Table 4-4: Original Summary of Total NO X and VOC Emissions in the BPA Area

Pollutant (tons per

average ozone

season day) 2005 2011 2014 2017 2021 Net Change

Total NO X 149.14 tpd 134.11 tpd 131.80 tpd 131.43 tpd 133.78 tpd

- 15.36 tpd
Total VOC 210.84 tpd 216.22 tpd 217.41 tpd 219.72 tpd 223.56 tpd 12.72 tpd
Total Combined 359.98 tpd 350.33 tpd 349.21 tpd 351.15 tpd 357.34 tpd

- 2.64 tpd This table is a copy of Table 4

- 3: Summary of Total VOC and NO X Emissions in BPA (2005, 2011, 2014, 2017, and 2021) of the 2008 BPA maintenance plan.

Table 4-5: Updated Summary of Total NO X and VOC Emissions i n the BPA Area (2005, 2011, 2014, 2017, and 2021)

Pollutant (tons per

average ozone

season day) 2005 2011 2014 2017 2021 Net Change

Total NO X 148.04 tpd 142.80 tpd 138.02 tpd 136.27 tpd 137.24 tpd

- 10.80 tpd
Total VOC 210.51 tpd 216.60 tpd 217.20 tpd 219.14 tpd 222.69 tpd 12.18 tpd
Total Combined 358.55 tpd 359.40 tpd 355.22 tpd 355.41 tpd 359.93 tpd 1.38 tpd

The 2008 BPA maintenance plan demonstrate s that o verall NO X emissions are projected to decline by 15.36 tpd from 2005 through 2021 using MOBILE

- based on

- road e missions estimates. U pdating the BPA maintenance plan to incorporate the MOVES model would still result in a decline in projected NO X emissions; however, the decline would be slightly smaller, 10.80 tpd. The original maintenance plan (MOBILE

- based) demonstrated an increase in overall VOC emissions projections from 2005 through 2021 , 12.72 tpd

. While MOVES

- based projections also show an increase in overall VOC emissions

, th at increase is smaller , 12.18 tpd.
Although there is a slight e stimated increase in VOC over the 16 years projected for the BPA maintenance plan , it has been established that NO X emissions reductions are more effective than VOC reductions at reducing ozone design values in the BPA area. In fact, photochemical modeling analysis adopted with t he 2008 BPA maintenance plan showed that reductions in NO X emissions are 3.76 times as effective as VOC reductions at reducing the BPA

- area ozone design value. In its proposed approval of the 2008 plan in the F ederal Register (75 FR 27514), t he EPA supported th e 2008 demonstration by stating that “based on photochemical modeling analyses showing that the formation of ozone in the BPA area is more sensitive to NO X than to VOC emissions, the increase in VOC emissi ons is expected to be fully offset by the decrease in NO X .”4-4 Based on the photochemical modeling analysis included in the original 2008 BPA maintenance plan and supported by the EPA, emissions in the BPA area are expected to remain at levels consistent with attainment for the 199 7 eight

- hour ozone standard t hrough 2021. Please see Section 4.2: Future Emissions and Verification of Continued Attainment of the original 2008 BPA maintenance plan for further details on the photochemical modeling analysis demonstr ating the effectiveness of NO X in reducing ozone design values in the BPA area.

4.2.1 Area Sources (Updated)
4.2.1.1 Flash Emissions from Upstream Oil and Gas Production (No Change)
4.2.1.2 Updated Verification of Continued Attainment for Area Sources (Added) In reviewing the 2008 BPA maintenance plan and applying updates, staff determined that emissions would be further decreased for both NO X and VOC. There are two factors attributed to these reductions: updated growth factors provided by the Eastern Research Group through a

c

ontract in 2010 ; 4 and speciation updates performed on the oil and gas categories for 2005. Although minor updates have occurred in the area source category since the 2008 submission, those updates do not change the overall conclusions of the BPA maintenanc e plan SIP revision.

4.2.2 On

- Road Mobile Sources (Updated) The Texas Commission on Environmental Quality (TCEQ) updated the 2008 BPA maintenance plan’s on

- road mobile source emissions inventory estimates for this proposed SIP revision by contracting with the Texas Transportation Institute (TTI). TTI developed detailed, hourly, link

based ozone season weekday emissions estimates for the three BPA counties, Jefferson, Hardin, and Orange, using the newest version of the E PA’s MOVES model, MOVES2010a. The updated emissions inventory estimates include NO X and VOC emissions for the 2005 base year for the 2011, 2014, and 2017 interim years and for the 2021 horizon year. T TI also used the latest planning assumptions to develop the maintenance i nventories in an effort to ensure that the MVEB s would be consistent with transportation conformity analysis assumptions.

TTI produced emissions estimates using a link

- based methodology that u sed a travel demand model (TDM) and MOVES “rates

- per

- activity .” Emissions were estimated by hourly and 24

- hour periods by MOVES source use type and fuel type, pollutant process, and TDM roadway class. The most recently available data were used

, including Texas Department of Transportation (TxDOT) vehicle classification counts and TxDOT / Texas Department of Motor V

ehicles registration data

. MOVES default data were used as needed. Control programs that were modeled in the analysis include :

• Federal Motor Vehicle Control Program Standards ;

• Federal Low Emissions Heavy

- Duty Diesel Engines Rebuild Program ;

• Federal Heavy

- Duty 2004 Pull

- Ahead Program ;

• Conventional Gasoline with F ederal Low Reid Vapor Pressure; and

• Diesel Fuel with Texas Low Emission Diesel as appropriate for applicable years

. For the fuel programs, MOVES defaults, fuel survey data, and federally regulated values were used. D etails of how these were modeled are found in Appendix D : BPA Area On

- Road Emissions Inventories for SIP Submission - 2005, 2011, 2014, 2017, and 2021 , TTI Report,

4 Eastern Research Group, Inc., “Projection Factors for Point and Area Source,” TCEQ Contract No. 582- 07 -84003, Work Order No. 582- 07

- 84003

- FY10

- 27, August 2010.4-5 February 2012. The emissions inventory development methodology is consistent with the MOVES guidance document provided by the EPA . Table 4-6: BPA Area Ozone Season Weekday On

- Road Mobile Emissions Inventories summarizes the updated 2005, 2011, 2014, 2017, and 2021 NO X and VOC emissio ns calculated using the latest planning assumptions for the three

county BPA are a. Detailed documentation is provided in Appendix D concerning MVEB calculations, modeling methods

, and input parameter development and usage

.
Table 4-6: BPA Area Ozone Season Weekday On

- Road Mobile Emissions Inventories

Year VMT Summer Weekday On

Road VOC Emissions Summer Weekday On

Road NO X Emissions

2005 12,766,328 11.3 0 tpd 44.5 0 tpd

2011 13,221,528 8.3 0 tpd 26.6 0 tpd

2014 13,691,363 6.3 0 tpd 18.6 0 tpd

2017 14,178,111 5.0 0 tpd 13.5 0 tpd

2021 14,854,487 3.9 0 tpd 9.7 0 tpd

4.2.2.1 Motor Vehicle Emissions Budget s (Updated) The 2008 BPA maintenance plan established MOBILE

- based MVEB s, setting the allowable on

road mobile emissions that an area can produce while continu ing to demonstrate maintenance

. Local transportation planning organizations demonstrate that projected emissions from transportation plans, programs, and projects are equal to or less than the MVEB s as required by the federal transportation conformity rule. The NO X and VOC on

- road mobile source emissions inventory totals for 2021, the final year of this maintenance plan, establish the MVEB s . The MOVES

- based MVEB s for this proposed SIP revision are summarized in Table 4-7: 2021 Horizon Year MVEB s for the BPA area using MOVES2010a

. D etailed documentation of MVEB calculations

, modeling methods

, and input parameter development and usage is provided in Appendix D

.
Table 4-7: 2021 Horizon Year MVEB s for the BPA area using MOVES2010a

Calendar Year VOC MVEB NO X MVEB
2021 3.9 tpd 9.7 tpd

4.2.2.2 Safety Margin ( Updated ) No safety margin is included in the revised, MOVES

- based MVEB s in cluded in this proposed SIP revision

.

4.2.3 Non

- Road Mobile Sources ( Updated )
4.2.3.1 Airports (No Change)
4.2.3.2 Locomotives and Marine Vessels (No Change)
4.2.3.3 Updated Verification of Continued Attainment for Non

- Road Mobile Sources (Added) NONROAD Model For all Texas non

- road mobile source categories except aircraft, airport equipment, locomotives, and commercial marine vessels, emissions are calculated using the Texas

- Specific NONROAD4-6 (TexN) model that utilizes the EPA’s latest NONROAD model. While the TexN model utilizes input files and post

- processing routines to estimate Texas specific emissions estimates, it retains the EPA ’s NONROAD model as the core model to conduct the basic emissions calculations.

Th e EPA’s NONROAD2005 model, which was used as the core model for the 2008 BPA maintenance plan, was upda ted to the NONROAD2008a version in April 2009

. T he NONROAD2008a model accounted for the addition of two new federal rules that affect the equipment categories in the non

- road mobile source sector ; therefore

, the TexN model was updated accordingly. In addit ion , equipment survey studies have been conducted and emissions updated for the diesel construction equipment sector, the agricultural equipment sector, and drilling rig diesel engines since 2009

. Using current methodology and the TexN/EPA NONROAD2008a mod el, emissions calculated for each county in the BPA area are , overall, lower and demonstrate a downward trend for both NO X and VOC compared to the emissions reported in the 2008 BPA maintenance plan

. A lthough minor updates have occurred in the non

- road mobile source category since the 2008 submission

, those updates do not change the overall conclusions of the BPA maintenance plan

. Airports The Federal Aviation Administration’s Emissions and Dispersion Modeling System (EDMS) version 5.1 was used to estima te NO X and VOC emissions for commercial aircraft, general aviation, and ground support equipment emissions in the 2008 BPA maintenance plan. The model has not changed since the 2008 submission, and the repopulated EDMS files, which reflect 2011 operations, indicate that both NO X and VOC emissions declined between 2005 and 2011.

The 201 1 emissions calculated for the airports source category in the BPA area demonstrate a downward trend for both NO X and VOC compared to the emissions reported in the 2008 BPA

ma intenance plan. Although minor updates have occurred in the airports source category since the 2008 submission, those updates do not change the overall conclusions of the BPA maintenance plan.

Locomotives and Commercial Marine Vessels Texas Air Emissions R epository ( TexAER ) data from 2005, which was developed from the 2005 Consolidated Emissions Reporting Rule data, were used to estimate NO X and VOC emissions from l ocomotive and commercial marine vessel activities in the 2008 BPA maintenance plan

. Th e metho dology has not changed since the 2008 submission.

Actual 2011 emissions calculated for locomotive and commercial marine vessel activities in the BPA area, when compared to the projected 2011 emissions reported in the 2008 BPA maintenance pl an, are lower and demonstrate a downward trend for both NO X and VOC. Since the original inventories conservatively estimated future year locomotive and commercial marine vessel activities emissions, recalculation of the milestone year inventories would not cha nge the overall conclusions of the 2008 BPA maintenance plan.4-7 4.2.4 Stationary Point Sources ( Updated )
4.2.4.1 Emissions Inventory Compilation (No Change)
4.2.4.2 Updated 2005 Base Year Inventory (No Change)
4.2.4.3 Updated Uncontrolled Milestone Year Inventories (No Change)
4.2.4.4 Updated Ve rification of Continued Attainment for Stationary Point Sources (Added) There have been no changes to the point source emissions inventories included in the 2008 BPA maintenance plan. Those inventories projected positive point source emissions growth for a ll future milestone years. Actual point source emissions for 2008 through 2010 are below the 2005 base year emissions, below emissions trends projected in the maintenance plan, and are anticipated to remain below projected emissions. Since the original inv entories conservatively estimated future year point source emissions, recalculation of the milestone year inventories would not change the overall conclusions of the 2008 BPA maintenance plan.

4.3 CONTROL STRATEGIES (NO CHANGE)
4.4 EMISSIONS SUMMARY (UPDATED)
U pda ted percentages of emissions by source category for 200 5 , 20 11 , 20 14

, 2017, and 20 21 are reflected in Table s 4-8 : Updated Percentages of NO X Emissions in BPA by Source Category and 4-9 : Updated Percentages of VOC Emissions in BPA by Source Category . T he percentages of contribution from source categories have changed slightly with the MOVES

- based on

- road mobile source emissions inventory updates . Table 4 -8 shows that on

- road mobile source emissions determined using the MOVES model account for a slightly larger percentage of NO X emissions, overall, than those determined using the MOBILE model. Table 4

- 9 shows that on

road mobile source emissions determined using the MOVES model account for a slightly smaller percentage of VOC emissions, overall, than thos e determined using the MOBILE model. As in the 2008 BPA maintenance plan , t he se tables show that the largest man

- made contribution of NO X is from stationary point sources and the largest man

- made contribution of VOC is from

area sources

. C ontributions from biogenic emissions are not included in the summary

, because the maintenance measures are limited to the reduction of man

- made emissions.

Table 4-8: Updated Percentages of NO X Emissions in BPA by Source Catego ry

Source Category 2005 2011 2014 2017 2021
Area Source 6.12% 6.97% 7.54% 7.97% 8.36%
MOVES

- Based On

- Road Mobile Source 30.06% 18.63% 13.48% 9.91% 7.07%

Non

- Road Mobile Source 17.56% 18.96% 20.20% 21.19% 22.32%

Stationary Point Source 46.26% 55.44% 58.79% 60.94% 62.26%

Table 4-9: Updated Percentages of VOC Emissions in BPA by Source Category

Source Category 2005 2011 2014 2017 2021
Area Source 72.00% 71.87% 72.21% 72.28% 72.09%
MOVES

- Based On

- Road Mobile Source 5.37% 3.83% 2.90% 2.28% 1.75%4-8 Source Category 2005 2011 2014 2017 2021
Non

- Road Mobile Source 2.36% 2.01% 1.95% 1.92% 1.93%

Stationary Point Source 20.27% 22.28% 22.94% 23.52% 24.23%

4.5 CONTINUED MAINTENANC E WITH MOVES

- BASED ON

- ROAD MOBILE EM ISSIONS INVENTORIES (ADDED) Revising the on

- road mobile source emissions inventories and MVEB s for this proposed SIP revision would minimally affect projected NO X and VOC emissions trends from the 2005 base year across the 2011, 2014, and 2017 milestone years and the 2021 horizon year ; however, NO X emissions are still projected to decrease and VOC emissions are still projected to increase (see Tables 4

- 2 and 4

- 3). On

- road mobile source emissions inventories were the only inventories updated; however, in determining whether to update inventories for the other source categories, TCEQ staff found that area, non

- road mobile, and stationary point sour ce emissions all trend ed below the projections included in the 2008 BPA maintenance plan. In addition, photochemical modeling analyses adopted with the 20 08 BPA maintenance plan and supported by the EPA demonstrate that the formation of ozone in the BPA area is more sensitive to NO X than to VOC emissions . The slight increase in VOC emissions , which was shown in the original BPA maintenance plan as well as t his proposed update, would be offset by the decrease in NO X emissions. Th ose factors, along with the overall downward trend in ozone design values for the BPA area, show that this proposed SIP revision would continue to meet all requirements for maintenanc e of the 1997 eight

- hour ozone standard.5-1 CHAPTER 5: MONITORING NETWORK ( NO CHANGE )6-1 CHAPTER 6: CONTINGENCY PLAN (NO CHANGE)Appendix Available Upon Request

Jamie Zech jamie.zech@tceq.texas.gov 512.239.3935