Buddy Garcia, Chairman Larry R. Soward, Commissioner BryanW. Shaw, Ph.D., Commissioner Glenn Shankle,Executive Director 

# TEXAS COMMISSION ON

# ENVIRONMENTAL QUALITY Protecting TexasbyReducing and Preventing Pollution



### December 12,2007

RichardE. Greene, RegionalAdministrator U.S. EnvironmentalProtectionAgency -

### Region 6 1445RossAvenue Dallas, Texas 75202-2733

DearMayor Greene:



### Inresponse to the guidance issuedby the United States EnvironmentalProtectionAgency (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 PM2.5National 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 therequest ofEPA Region 6 staff,the Texas Commission on Environmental Quality (TCEQ) is submitting the following letter regarding eight-hour ozone 

### SIPrevision 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-PortArthur areaonNovember 16,2004, and October 15,2005. All of the 

### SIP revisions have been adoptedby the TCEQ pursuant to 40 Code ofFederal Regulations 

## 5 5 1.104. Enclosed is a brief synopsis ofeach of these SIP revisions. TCEQ staffwill continueto 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 SusanaM. 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 onrecycled paper using soy-based inkI 

### Eight-Hour Ozone StateImplementation Plan (SIP) Revisions in Texas 

### I

I I 

### Dallas-Fort Worth (DFW) Area 

# - The nine-county DFW metropolitan area was designated a moderate ozonenonattainment 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. TheDFW Eight-Hour Ozone Attainment Demonstration SIPrevision was adoptedby the conxnission on May 23,2007, and submitted to the EPA onMay 30,2007.

The DFW SIP revision demonstrates attainment of the elght-hour ozone standard using photochemical modeling, including reductions fi-omassociated 30 Texas AdministrativeCode (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 117rules will reduce nitrogen oxides 

### (NOx) emissions fi-om the following sources: Major Industrial, Commercial, and Institutional Sources; Minor Sources; Electric GeneratingFacilities (EGFs); CementKilns; 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

, ReductionProgram (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 canbe 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 ProtectionAgency (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 ofI 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 substantialprogress toward. attainment made under the one-hour ozone 

### NAAQS despite rapid economic and population growth in the area. This SIPrevision 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'continuingprogress 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 SIPrevision 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 commissionadoptedthe 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 NMQSin 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 includedproi11inent advertiselllentin the ai-easaffected

- 

### - 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 amaintenance 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 January20,2006.

The SIP revision incorporatingthe ozone maintenance plan containsresults of an updated attainment emissions inventory and technical ai~alyses in support of the projections demonstratinginaintenance of the eight-hour ozone NAAQS through 2014; a discussion of inonitoring data deinonstrating attainment ofthe one-hour and the eight-hourNAAQS; and a discussion ofthe 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 OzoneMaintenancePlan canbe 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-PortArthur @PA) Area 

### - TheBPA 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 onNovember 16, 2004. The attainment

### demon strati^^containedresults of photochemical modeling and technical analyses in supportofthe deinonstration ofattainmentofthe one-hour andthe eight-hour ozone standards. The submittal included the post-1996 inotor vehicle emissions budget (MVEB). Additionalinfornlation regarding the specificsofthe 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 SIPrevision and subsequentlysubmitted 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-approvableSIPrevision. 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 100tons per year of VOC, based on all stationary sources included in an account. These rules were amendedto lower the exemption level to 50tonsper year with the BPA SIPrevision. The SIP submissloll also containsrevision regardingthc Clean Fuel Vehicle program and the three percent contingencyrequireinent 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 SIPrevision. Proper notice included prominent advertisement in the areas affected at least 30 daysprior to the date ofthe hearings. Public hearings were held in Beaumonton June 16,2005.