Buddy Garcia, Chairman 

Larry R. Soward, Commissioner 

Bryan W. Shaw, Ph.D., Commissioner 

Glenn Shankle, Executive Director 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by Reducing and Preventing Pollution 

December 12,2007 

Richard E. Greene, Regional Administrator 

U.S. Environmental Protection Agency - Region 6 

1445 Ross Avenue 

Dallas, Texas 75202-2733 

Dear Mayor Greene: 

In response to the guidance issued by the United States Environmental Protection Agency 

(EPA) on October 2, 2007, "Guidance on State Implementation Plan (SIP) Elements 

Required Under 110(a)(l) and (2) for the 1997 Eight-Hour Ozone and PM2.5 National 

Ambient Air Quality Standard," the EPA has requested that states certify that existing 

SIPS contain provisions that address the requirements of the eight-hour and PM2.5 

National Ambient Air Quality Standards. At the request of EPA Region 6 staff, the Texas 

Commission on Environmental Quality (TCEQ) is submitting the following letter 

regarding eight-hour ozone SIP revision submissions for Texas. 

The TCEQ has submitted to the EPA the following eight-hour ozone SIP revisions: the 

Dallas-Fort Worth area on May 30, 2007; Houston-Galveston area on June 15, 2007; the 

Victoria area on March 22, 2007; the El Paso area on January 20, 2006; and two for the 

Beaumont-Port Arthur area on November 16,2004, and October 15,2005. All of the SIP 

revisions have been adopted by the TCEQ pursuant to 40 Code of Federal Regulations 5 

5 1.104. Enclosed is a brief synopsis of each of these SIP revisions. 

TCEQ staff will continue to review the remaining commitments required by the guidance 

and Section 110(a)(l) and (2), and provide the information as appropriate. If you have 

any additional comments, please contact Susana M. Hildebrand, P.E. at 5 12-239-4696. 

Sincerely, - 

- 

David C. Schanb'acher, P.E. 

Chief Engineer 

Enclosure 

P.O. Box 13087 Austin, Texas 78711-3087 512-239-1000 Internet address: www.tceq.state.tx.us 

printed on recycled paper using soy-based ink 
I Eight-Hour Ozone State Implementation Plan (SIP) Revisions in Texas 

I 

I 

I 

Dallas-Fort Worth (DFW) Area - 

The nine-county DFW metropolitan area was designated a moderate ozone nonattainment area ~ulder 

the eight-hour ozone National Ambient Air Quality Standard (NAAQS) on April 15, 2004. The nine 

counties include: Collin, Dallas, Denton, Ellis, Jol-~llson, ICaufnlan, Parker, Rockwall, and Tarrant. 

The DFW Eight-Hour Ozone Attainment Demonstration SIP revision was adopted by the conxnission 

on May 23,2007, and submitted to the EPA on May 30,2007. 

The DFW SIP revision demonstrates attainment of the elght-hour ozone standard using 

photochemical modeling, including reductions fi-om associated 30 Texas Administrative Code (TAC) 

117 rules and voluntary mobile elnlssion reductions, and using weight-of-evidence (WOE), including 

corroborative analysis and additional control measures not explicitly accounted for in the 

photochemical modeling. The 30 TAC 117 rules will reduce nitrogen oxides (NOx) emissions fi-om 

the following sources: 

Major Industrial, Commercial, and Institutional Sources; 

Minor Sources; 

Electric Generating Facilities (EGFs); 

Cement Kilns; and 

East Texas Combustion Sources 

All of the rules apply to the nine-county DFW area except for the East Texas Combustion Rule, 

which applies to 33 counties located in northeast Texas. Through the Voluntary Mobile Einissions , Reduction Program (VMEP) in the nine nonattainlnent co~ulties, the North Central Texas Council of 

_ Governments (NCTCOG) committed to reducing NOx emissions by Mar-h-2009, The-NCTCOG 

also committed to implementing transportation control measures (TCMs) in the nine nonattainlnent 

counties that will further reduce NOx emissions in 2009. Additional information regarding the 

- specifics of these control strategies in the DFW Eight-Hour Ozone Attainment Demonstration SIP - 

revision can be found at: h~://www.tceq.state.tx.us/i~~~plel~~entatiodair/si~/d~.h~nl#EDl . 

Pursuant to 40 Code of Federal Regulations $ 51.102 and after proper notice, the commission 

conducted public hearings to consider the revisions to the SIP. Proper notice included prominent 

advertisement in the areas affected at least 30 days prior to the dates of the hearings. Public 

hearings were held in Houston on January 29, 2007; Dallas on January 31, 2007; Arlington on -- 

February 1, 2007; Midlothian on February 1, 2007; Longview on February 6, 2007; and Austin on 

February 8, 2007. 

Houston-Galveston-Brazoria (HGB) Area - 

The eight-county HGB metropolitan area was classified as a mode&e ozone nonattainlnent area by 

the EPA under the eight-hour ozone NAAQS on April 15, 2004. The eight couniies include: 

Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller. The govelnor 

of Texas requested a reclassification to severe in June 2007. The United States Environlnental 

Protection Agency (EPA) notified the Texas Colnlnission on Environinental Quality (TCEQ) in July 

2007 that they will begin the process of reclassification from moderate to severe in response to 

Governor Perry's request. The challenges to attain the eight-ho~~r ozone standard are great because 

the HGB area is one of the most comprehensively controlled industrial complexes in the world; the 

area has unique and complex ozone formation chemisby and meteorology; the magnitude of 
I reductions needed is significant; and the TCEQ lacks regulatoiy authority to set eillission standards 

for on-road and non-road mobile sources. 

. . . . On May 23, 2007, the conllnission adopted of a revision to the.SIP for t11e HGB eight-hour ozone . - . ' nonattai-ent area. The-HGB- SIP revision was submitted to tl~e EPA. on June 15,-2007. The HGB 

SIP revision documents the substantial progress toward. attainment made under the one-hour ozone 

NAAQS despite rapid economic and population growth in the area. This SIP revision also documents 

steps toward attainment of the eight-hour ozone standard and is the first step in addressing the eighthour ozone standard in the HGB area. This SIP revision includes revisions to rules in 30 TAC 

Chapter 114, related to the Texas Low Emission Diesel Rule (TxLED) for Certain Marine Fuels, 30 

TAC Chapter 115, Division I, related to the Control of Volatile Organic Compounds (VOC) 

Emissions fro111 Storage and Degassing Operations in the HGB area, and 30 TAC Chapter 117, 

... -. .. related to the Water Heater Rule. The revision also includes local Voluntary Mobile Emission 

. Rkducti'on (VMEP) ~om~itinents. The TCEQ is coinmitted to'continuing progress towai-d attaining 

the standard and will work with the EPA to set submission dates for new obligations and interim 

progress in reducing emissions. The HGB SIP revision attainnleilt deillonstration will include an 

expeditiously as practicable attainment date (no later than June 15, 20 19). Additional infoilnation 

regarding the specifics of these control strategies in the HGB Eight-Hour Ozone SIP revision can be 

foi~nd at: l~~://www.tceq.state.tx.~1~/iinpleinentatioair/si/hb.t11#8ho~r . 

Pursuant to 40 Code of Federal Regulations 5 51.102 and after proper notice, the comlnission 

conducted public hearings to consider tile revision to the SIP. Proper notice included prominent 

advertisement in the areas affected at least 30 days prior to the dates of the hearings. Public 

hearings were held in Houston, January 29, 2007; Dallas, January 31, 2007; Arlington, February 

1, 2007; Midlothian, February 1, 2007; Longview, February 6, 2007; and in Austin, February 8, 

2007. - 

- - - - 

Victoria County - 

On March 7,2007, the commission adopted the Victoria Co~wty Eight-Hour Ozone Maintenance Plan 

and submitted it to the EPA on March 22, 2007. Th~s SIP revrsioil contained an eight-hour ozone 

maintenance plan that will to incoi-porate a plan for illainteilance of the eight-ho~~r ozone NMQS in 

Victoria County as required by 40 CFR §51.905(a)(3) and (4). The revrsion incorporated the ozone 

maintenance plan that contains results of ail updated attainment emissions inventory and technical 

analyses m s~~pport of the project~oils demonstrating illa~ntenance of the eight-hour ozone NAAQS 

through 2014; a discussion of i~loi-~itoring data deilloizstsat~ng attainnlent of the eight-hour ozone 

NAAQS; and a discussion of the contingency plan and trigger levels. Additional info1n1at1on 

regarding the Victorla Eight-HOLIS Ozone Maintenance Plan can be found at: 

httu://www.tceq.state.tx.us/assets/p~iblic/i1~~plen1ei~tation/a~~-/siu/vic/OG023SP ado.pdf. 

Pursuant to 40 CFR 8 51.102 and after proper notice, the coillillission conducted a public hearing to 

consider the revision to the SIP. Proper notice included proi11inent advertiselllent in the ai-eas affected 

- - at least 30 days prior to the date of the hearing. A public hearing was held in Victoria, Texas on 

October 17,2006. 

El Paso CountyAs a result of the Federal Clean Air Act (FCM) Amendments of 1990, El Paso County was 

designated as nonattainment for the one-hour ozone standard. On April 15,2004, the EPA designated 

.El Paso County as attainment for the eight-hour-ozone standard. The EPA7s Phase I lillpleinentation 

Rule for the eight-hour ozone standard directed that areas designated as nonattainment for the onehour ozone standard but designated attainment for the eight-hour ozone standard must submit a 
maintenance plan for the eight-hour ozone standard by June 15, 2007. On January 11, 2006, the 

commission adopted revisions to the SIP to incorporate a plan for illaintenance of the eight-hour 

ozone NAAQS in El Paso County as required by 40 CFR 51.905(a)(3). The SIP revision was 

submitted to the EPA on January 20,2006. 

The SIP revision incorporating the ozone maintenance plan contains results of an updated attainment 

emissions inventory and technical ai~alyses in support of the projections demonstrating inaintenance 

of the eight-hour ozone NAAQS through 2014; a discussion of inonitoring data deinonstrating 

attainment of the one-hour and the eight-hour NAAQS; and a discussion of the contingency plan and 

possible control strategies. This SIP revision retains all SIP control measure and enhances the 

established vehicle Inspection and Maintenance progranl in El Paso. Additional infollnation 

regarding the El Paso Eight-Hour Ozone Maintenance Plan can be found at: 

ht~://www.tceq .state.tx.us/assets/~~iblic/i11~pleineiitatioi1/air/si~/si~docs/2OO5-O7- 

EP/ELP 03 adoptionSIP 05 120G.pdf. 

Pursuant to 40 CFR 51 .I02 and after proper notice, the commission conducted public hearings to 

consider the revisions to the SIP. Proper notice included prominent advertisement in the areas 

affected at least 30 days prior to the date of the hearings. Public hearings were held in El Paso on 

September 1,2005. 

Beaumont-Port Arthur @PA) Area - 

The BPA three-county nonattainment area was classified as a marginal nonattaininent area under the 

eight-hour ozone NAAQS on April 15, 2004. The three counties include: Hardin, Jefferson, and 

Orange. On October 27, 2004, the commission adopted an attainment demonstration for both the 

one-hour and the eight-hour ozone standard for the BPA area. The BPA SIP revision was submitted 

to the EPA on November 16, 2004. The attainment demon strati^^ contained results of photochemical 

modeling and technical analyses in support of the deinonstration of attainment of the one-hour and the 

eight-hour ozone standards. The submittal included the post-1996 inotor vehicle emissions budget 

(MVEB). Additional infornlation regarding the specifics of the 2004 BPA SIP revision can be found 

at: 1~~://www.tceq.state.tx.~1s/ii1~plen~ei~tation/air/sip/oc2OO4bpa rop ad.11tinl. 

On September 28, 2005, the coininlssion adopted the BPA Eight-Hour Ozone Standard Attainment 

Demonstration SIP revision and subsequently submitted it to the EPA on October 15, 2005. The SIP 

revision included the adoption of an Eight-Hour Ozone Attainment Deinonstration SIP revision and 

revisions to Chapter 115 rules. The 2005 BPA SIP revisions addressed each of the remaining 

requirements needed for an EPA-approvable SIP revision. These requirements included a Reasonable 

Available Control Technology (RACT) demonstration with associated rulemaking. The rulemalung 

Tor major-source applicability cutoffs for purposes of RACT included rules for batch processing (30 

TAC 1 15.167, relating to exemptions) and ship building and repair (30 TAC 11 5.427 (a)(3)(H), 

.. . relating to exemptions) set an exemption level of 100 tons per year of VOC, based on all stationary 

sources included in an account. These rules were amended to lower the exemption level to 50 tons per 

year with the BPA SIP revision. The SIP submissloll also contains revision regarding thc Clean Fuel 

Vehicle program and the three percent contingency requireinent and an updated MVEB. Additional 

~ infonllation regarding the specifics of these control strategies in the 2005 BPA SIP revisioil can be 

1 found at: h~://www.tceq.state.tx.us/iinplementation/air/siu/se~t2005bva.l1~1d. 

Pursuant to 40 Code of Federal Regulations 3 51.102 and after proper notice, the coinmission 

conducted public hearings to consider the revisions to the BPA SIP revision. Proper notice included 

prominent advertisement in the areas affected at least 30 days prior to the date of the hearings. Public 

hearings were held in Beaumont on June 16,2005.