# f. h!2

John R

. Kasich, Governor

Mary Taylor, Lt. Governor

Craig W. Butler

, Director

Protection Agency



### JUL 0 6 20t6

Robert A. Kaplan Acting Regional Administrator

Attn .: R-19J

U.S

. EPA, Region 5

77 West Jackson Blvd. Chicago, Illinois 60604-3507

Re : Request for Approval of the Redesignation Request and Maintenance Plan for the Cleveland-Akron-Lorain, OH Area for the 2008 Eight-Hour Ozone Standard

Dear Acting Administrator Kaplan:

I am writing to formally request a redesignation to attainment of the Cleveland-Akron-Lorain,

Ohio area (Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage and Summit) with
respect to the 2008 eight-hour ozone standard. The enclosed submittal combines the redesignation request and the required maintenance plan for this area

.

Ohio Environmental Protection Agency (Ohio EPA) requested a one-year extension request

for the Cleveland-Akron-Lorain

, Ohio area to attain the standard on February 20, 2015 and provided U

. S. EPA with supplemental information on March 19, 2015. U

. S

. EPA published proposed rulemaking granting the one-year attainment extension on August 27, 2015 (80 FR 51992). On May 4, 2016 (81 FR 26697) U.S. EPA published a final action approving the oneyear extension request for the Cleveland-Akron-Lorain

, Ohio nonattainment area with an effective date of June 3, 2016

.

Monitoring of existing air quality indicates that the 2008 National Ambient Air Quality

Standard (NAAQS) for ozone has been attained throughout this area based on certified

2013-2015 air quality data. Emissions projections indicate that current controls, existing State
rules, existing federal rules

, and Ohio ' s PSD program will be more than sufficient to maintain

the NAAQS indefinitely into the future

. These programs will, therefore

, constitute the

attainment and maintenance plan for the Cleveland-Akron-Lorain, Ohio area

.

The enclosed information, compiled by the Ohio EPA, Ohio Department of Transportation

, the Akron Metropolitan Area Transportation Study

, and the Northeast Ohio Areawide Coordinating Agency, shows significant emission reductions in point and mobile sources
since ambient violations have occurred

. A significant portion of the improved air quality can be attributed to federal programs for the mobile source sector, and the regional reductions

associated with the transport programs and the implementation of CAIR/CSAPR.

SO We st Town Street • Suite 700 • P.O. Box 1049 • Co lumbu s, OH 43216

- 1049
epa.ohio.gov • (614) 644

- 3020 • (614) 644

- 3184 (fax)The public hearing for this package was held on June 27, 2016

, in Cleveland, Ohio and public comments were accepted through June 27

, 2016 as well. No comments we r e received during the public hearing

.

I am also request i ng that this redesignation request be processed by U

. S

. EPA as expeditiously as possible due to the upcoming nonattainment designations for the 2015 o z one NAAQS

. These designations are scheduled to occur in October 2017 and the ClevelandAkron-Lorain, Ohio area will potentially be designated nonattainment for the 2015 ozone NAAQS

. It is vital to Ohio and the Cleveland-Akron-Lorain area to reach attainment for the

2008 ozone NAAQS before this time to avoid trigging any implications under the Clean Air Act

for areas designated nonattainment for a newer standard but have not been designated back

to attainment for a standard that has been revoked

.

This subm i ttal consists of one (1) hard copy of the required documentation

. An exact dupl i cate

electronic version of the submittal in PDF format is available at http :// www

. epa

. state

. oh

. us / dapc / SIP / 2008

. asp x under the heading " Clean Data Requests, Redesignations and Maintenance Plans ".

If you have any questions, please contact Jennifer Van Vlerah in our Divis i on of Air Pollution

Control at (614) 644-3696

.

Sincerely

,

. Butl e r Director

enclosures

cc : Robert Hodanbosi

, DAPC

Jennifer Van Vlerah

, DAPC

# REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

T HE CLEVELAND

- AKRON

- LORAIN , OH

8

- HOUR OZONE

NONATTAINMENT AREA

Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and Summit Counties, Ohio

Prepared b y: Ohio Environmental Protection Agency

Division of Air Pollution Control

J uly 2016Th is page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One

Introduction

................................ ................................ ................................ ................................ ..... 1 Background

................................ ................................ ................................ ................................ ..... 1 Geographical description

................................ ................................ ................................ ................ 2 Status of air quality

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

Chapter Two Requirements for redesignation

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

Ch apter Three Ozone monitoring

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

Ozone NAAQS

................................ ................................ ................................ .............................. 10 Ambient data quality assured

................................ ................................ ................................ ........ 11 Three complete years of data

................................ ................................ ................................ ....... 12 Commitment to continue monitoring

................................ ................................ ............................. 15

Chapter Four

Emission i nventory

................................ ................................ ................................ ........................ 1 6

Base y ear i nventory

................................ ................................ ................................ ...................... 1 7

Emission p rojections

................................ ................................ ................................ ..................... 1 8

Demonstration of m aintena nce

................................ ................................ ................................ ..... 22

Permanent and e nf orceable e missions r eductions

................................ ................................ ...... 29

Provisions for f uture u pdates

................................ ................................ ................................ ........ 34

Chapter Five

Con trol measures and regulations

................................ ................................ ................................ 3 6

Em ission inventories/statements

................................ ................................ ................................ .. 3 6 Implementation of p ast SIP r evisions

................................ ................................ ........................... 36

New s ource r eview p ro v isions

................................ ................................ ................................ ..... 4 6

As suranc e of continued controls

................................ ................................ ................................ .. 47

Chapter Six

Con tingency measu res

................................ ................................ ................................ ................. 48 Commitment to revise plan

................................ ................................ ................................ ........... 48

Commitm ent for contingency measures

................................ ................................ ....................... 48

P otential contingency measures

................................ ................................ ................................ ... 49

List of VOC and NO

x sources

................................ ................................ ................................ ....... 51

Chapter Seven Modeling Analysis

................................ ................................ ................................ ......................... 52 Summary of Modeling Res ults for National Emission Control Strategies in Final Rulemaking

... 52 U.S. EPA Modeling Analysis for Interstate Transport “Good Neighbor” Provision

...................... 52 LADCO Modeling for Eight

- Hour Ozone Sta ndard

................................ ................................ ....... 55 Summary of Existing Modeling Results

................................ ................................ ........................ 56

Chapter Eight

Pub lic participation

................................ ................................ ................................ ........................ 58ii

Chapter Nine

Conclusions

................................ ................................ ................................ ................................ ... 5 9iii FIGURES

Figure 1 Map of the Cleveland

- Akron

- Lorain, OH N onattainment A rea and M onitor

L ocations

................................ ................................ ................................ ............... 11 Figure 2 Maximum 8

- Hour Concentrations versus Temperate Days

................................ 32 Figure 3 Average Maximum 4 th High ver sus Average Summer Temperatures

................. 33 Figure 4 Average Maximum 4 th High versus Average Summer Relative Humidity

............ 34 Figure 5 NOx Emissions from EGUs 2003

- 20 1 4

................................ ............................... 38

TABLES

Table 1 Monitoring Data for Cleveland

- Akron

- Lorain, OH 2012

- 2014 and 201 3

– 201 5

.. 1 3

Ta ble 2 Emission Estimations for On

- r oad Mobile Sources for Ashtabula Co ., Ohio

....... 1 8

Table 3 Emission Estimations for O n

- road Mobile Sources for Cuyahoga Co ., Ohio

....... 1 9

Table 4 Emission Estimations for On

- road Mobile Sources for Geauga C o ., Ohio

.......... 1 9

Table 5 Emiss ion Estimations for On

- road Mobile Sources for Lake Co. , Ohio

............... 1 9

Table 6 Emission Estimations for On

- road Mobi le Sources for Lorain Co. , Ohio

............. 19

Table 7 Emission Estimations for On

- road Mobile Sources for Medina Co

. , Ohio

.......... 19

Table 8 Emission Estimations f or On

- Road Mobile Sources for Portage Co., Ohio

......... 19

Tab le 9 Emission Estimations for On

- road Mobile Sources for Summit Co., Ohio

.......... 20

Table 10 Emission Estimations for On

- road Mobile Total Cleveland

- Akron

- Lorain, O H

Sources

................................ ................................ ................................ ................. 20

Table 1 1 Mobile Vehicle Emissio n Budge t for the Cleveland

- Akron

- Lorain, O H

................ 20

Table 1 2 NOx Emission Inventory Ashtabula Co , Ohio

. ................................ ...................... 22

Table 1 3 NOx Emission Inventory Cuyahoga Co., Ohio

. ................................ ..................... 23

Table 1 4 NOx Emiss ion Inventory Geauga Co., Ohio

. ................................ ........................ 2 3

Table 1 5 NOx E mission Inventory Lake Co., Ohio

. ................................ ............................. 23

Table 16 NOx Emis sion Inventory Lorain Co., Ohio

. ................................ ........................... 24

Table 17 NOx Emis sion Inventory Medina Co

., Ohio

. ................................ ......................... 24

Table 18 NOx Emission Inventory Portage Co., Ohio

................................ ......................... 24

Table 19 NOx Emission Inve ntory Summit Co., Ohio

. ................................ ......................... 25

Table 2 0 NOx Emission Inventory C levela nd

- Akron

- Lorain , OH

, Total

............................... 25

Table 2 1 VOC Emission Inventory Ashtabula Co, Ohio.

................................ ..................... 25

Table 2 2 VOC Emission Inventory Cuyahoga Co., Ohio.

................................ .................... 26

Table 2 3 VOC Emission Inventory Geauga Co., Ohio.

................................ ....................... 26

Table 2 4 VOC Emission Inventory Lake Co., Ohi o.

................................ ............................. 2 6

Table 25 VOC Emissio n Inventory Lorain Co., Ohio.

................................ .......................... 26

Table 26 VOC Emission Inve ntory Medina Co

., Ohio

. ................................ ......................... 27

Table 27 VOC Emission Inventory Portage Co., Ohio

................................ ......................... 27

Table 28 VOC Emission Inve ntory Summit Co., Ohio

. ................................ ........................ 27

Table 29 VOC Emission Inventory C leveland

- Akron

- Lorain

, OH , Total

.............................. 28

Table 3 0 Projected E mission E stimates 2014

- 20 3 0 C leveland

- Akron

- Lorain , OH

............. 28

Table 3 1 Combined C omparison of 2011 an d 2014 On

- road , Non

- road and EGU Totals

. 30

Table 3 2 U.S. EPA “Good Neighbor” Provision Modeling R esults Average Design Values. 54

Table 3 3 U.S. EPA “Good Neighbor” Current Design Values

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

Table 34 LADCO’s Modeling Results for the C leveland

- Akron

- Lorain , OH Area

. .............. 56iv APPENDICES

A Air Quality System (AQS ) Data and SLAMS Certification

B Mobile Source Emissions I nventory

C Public Participation Documentationv This page left intentionally blank1

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE

CLEVELAND

- AKRON

- LORAIN , OH

OZONE NONATTAINMENT AREA

Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and

Su mmit Counties, Ohio



### CHAPTER ONE

I ntroduction The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standa rd. O n March 12,

2008 , the United States Enviro nmental Protection Agency ( U.S. EPA ) revised the air quality standard for ozone replacing the 19 97 eight

- hour standard of 0.08 parts per million (ppm) with a more stringent standard of 0.075 ppm

.

On March 2 1, 2012 (77 FR 30088)

, U.S. EPA designated nonattainment areas

for the 2008 eight

- hour ozone standard. Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to be redesignated to attainment provid ed certain criteria are met. The fol lowing are the criteria that must be met in order for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the eight

- hour

ozone standard. ii) An approved State Implementation Plan (SIP) for the area

under Se ctio n 110(k ). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements

have been met.

Background

The current C leveland

- Akron

- Lorain

, OH nonattainment area includes the following Counties : Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and Summit.

As part of the 1997 eight

- hour ozone standard designations

, the following

C ounties within the C leveland

- Akron

- Lorain

, OH area were designated as

moderate nonattainment pursuant to Subpart 2 of the CAA and

, therefore

, were subject to nonattainment area rul emakings : Ashtabula, Cuyahoga,2

Geauga, Lake, Lorain, Medina, Portage, and Summit Counties. The

Cleveland

- Akron

- Lorain, OH area was redesignated to attainment on September 15, 2009 ( 74 FR 47414 ) and a revision to the approved motor vehicle emissions budge ts was approved on March 19, 2013 (78 FR 16785)

. A maintenance plan was approved at th at time.

As a result of th e 2012 ozone designations for the 2008 eight

- hour ozone

standard

, U.S. EPA designated the C leveland

- Akron

- Lorain , OH area marginal

nonatt a inment , pursuant to Subpart 2 of the CAA

, and the Ohio Environmental Protection Agency ( Ohio EPA ) was required to submit certain nonattainment plan elements by July 20, 2014

. Ohio EPA submitted those elements on July 18, 2014 and U.S. EPA published a prop osal and direct final action approving that submittal on March 10, 2016 (81 FR12626 and 81 FR 12591). The approval became effective May 9, 2016.

Ohio EPA requested a one

- year extension request for the Cleveland

- Akron

Lorain, OH area to attain the standa rd on February 20, 2015 and provided U.S. EPA with supplemental information on March 19, 2015. U.S. EPA published proposed rulemaking on granting the one

- year attainment extension on August 27, 2015 (80 FR 51992). On May 4, 2016 (81 FR 26697) U.S. EPA publ ished a final action approving the one

- year extension request for the

Cleveland

- Akron

- Lorain, OH nonattainment area with an effective date of June 3, 2016.

T his document is intended to support Ohio’s request that the Cleveland

- Akron

Lorain, OH area be re designated from nona ttainment to attainment for the eight

- hour ozone s ta ndard

. The Cleveland

- Akron

- Lorain, OH area has

recorded three (3) years of complete quality

- assured ambient air quality monitoring data for the years 20 1 3 through 20 1 5 dem onstrating a ttainment of the eight

- hour ozone standard.

Geographical Description

The C leveland

- Akron

- Lorain

, OH eight

- hour ozone nonattainment area is

located in northeast Ohio and includes the following C ounties of : Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Med ina, Portage, and Summit. This area is

shown in Figure 1 under Chapter Three

.

Status of Air Quality Ozone monitoring data for the m ost recent three (3) years, 20 1 3 through 20 1 5

, demonstrate that the air quality has m et the NAAQS for ozone in this margin al nonattainment area. The NAAQS attainment, accompanied by decreases in

emission lev els discussed in Chapter F our, supports a redesignation to

attainment for the C leveland

- Akron

- Lorain

, OH area based on the requirements in Section 107(d)(3)(E) of the CAA

.3



### C HAPTER TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment ( R edesignation

G uidance ), issued September 4, 1992 , to Regional Air Directors . Th e redesignation request and maintenance p lan are based on the R edesignation

G uidance, supplemented with additional guidance re ceived from staff of U.S.

EPA Region V.

Below is a summary of each redesignation criterion as it applies to the

C leveland

- Ak ron

- Lorain

, OH area.

i.) Attainment of the standard

- CAA Section 107 (d)(3)(E)(i) There are two components involved in making this

demonstration . The first component relies on ambient air quality

data. The data that are used to demonstrate attainment s hould be the product of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality

- assured in accordance with 40 CFR 58 and recorded in

the Air Quality System (AQS) in order for it to be availa ble to the public for review. Chapter Three discusses this requirement in

more detail

The second component relies upon supplemental U.S. EPA

approved air quality modeling. The supplemental modeling is not required for ozone nonattainmen t areas seeking

re designation ; h owever, Ohio EPA has incorporated photochemical modeling information in Chapter Seven to further support our request that Ohio ’s portion of the nonattainment area be redesignated to attainment

.

ii.) SIP approval

- CAA Section 107 (d)(3)(E)(ii ) The SIP for the area must be fully approved under Section 110(k) and must satisfy all the requirements that apply to the area. Ohio’s SIP was approved on May 4 , 1994 (59 FR 23799)

, March 23 , 1995 (60 FR 15235 ) and May 7, 1996 (61 FR 20458)

and includes the C leveland

- Akron

- Lorain

, OH area. In addition, on July 18, 2014, Ohio EPA submitted a SIP revision for this

area and U.S. EPA published a proposal and direct final action approving that submittal on March 10, 2016 (81 FR 12626 and 81 FR 12591). The ap proval became effective May 9, 2016. Chapter F ive discusses this requirement in more detail

.4

iii.) Permanent and enforce able improvement in air quality

- CAA

Section 107 (d)(3)(E)(iii) The state must be able to reasonably attribute the improvement

in ai r quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction

achieved from federal measures as well as control measures that have been adopted and implemented by the state.

On March 6, 2015, U.S. E PA finalized the “ Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements; Final Rule” (herein referred to as “Implementation Rule”). (80 FR 12264) In the Implementation Rule, U.S. EPA states “Und er CAA section 182(a), Marginal areas have up to 3 years from the effective date of designation to attain the NAAQS, and are not required to submit an attainment demonstration SIP.” (80 FR 12268) Further, U.S. EPA identifies “ An attainment demonstration consists of: (1) Technical analyses, such as base year and

future year modeling of emissions which identifies sources and quantifies emissions from those sources that are contributing to nonattainment; (2) analyses of future year emissions reductions

and a ir quality improvement resulting from existing ( i.e., already adopted or ‘‘on the books’’) national, regional and local programs, and potential new local measures needed for attainment, including RACM and RACT for the area; (3) a list of adopted measures ( including RACT) with schedules for implementation and other means and techniques necessary and appropriate for demonstrating attainment as expeditiously as practicable but no later than the outside attainment date for the

area’s classification; and (4) a R ACM analysis to determine whether any additional RACM measures could advance attainment by 1 year. ” (80 FR 12268) Therefore, these requirements, and specifically, the requirement to adopt specific state measures beyond federal measures, are not applicable to marginal areas, such as the C leveland

- Akron

- Lorain , OH

nonattainment area.

Regardless, Ohio has adopted and implemented control

measures for these c ounties in th e area beyond the federal

measures in order to comply with the 1997 eight

- hour ozone stand ard and Ohio also adopted the initial 1979/1981 s tatewide

rules. Historically the Cleveland

- Akron

- Lorain, OH area was a moderate nonattainment area for the one

- hour standard and the 1997 eight

- hour standard. These measures and rules remain in

effect and ha ve assisted the C leveland

- Akron

- Lorain

, OH area in

reach ing attainment for the 2008 eight

- hour ozone standard.5

Below is a list of several previously adopted Ohio rules that have

contributed to reducing ozone in this area :

 Portable Fuel Containers requ irements

 Architectural and Industrial Maintenance (AIM) Coatings

rules

 Consumer Products rules

 Clean Air Interstate Rule (CAIR)

 Cross State Air Pollution Rule (CSAPR)

 VOC RACT for all current U.S. EPA Control Technique Guidelines (CTG)

 NOx RACT

 E

- Check

 NO
x Sip Call rules

C hapters F our and F ive discuss this requirement in more detail.

iv.) Section 110 and Part D requirements

- CAA Section 107 ( d)(3)(E)( v) For purposes of redesignation, a state must meet all requirements of Section 110 and P art D that were applicable prior to submittal of the complete redesignation request.

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Section 110(a)(1) generally

directs states to submit a SIP that provides for implementation, maintenance, and enforcement of the air quality standards to the U.S. EPA after reasonable notice and public hearing. Section 110(a)(2) provides that the infrastructure SIP submitted by a state must have been adopted by the state after reasonable public notice and hearing, and that, among other things, it must include

enforceable emission limitations and other control

measures 1

, means or techniques necessary to meet the requirements of the CAA; provide for establishm ent and operation of appropriate devices, methods, systems and procedures necessary to monitor ambient air quality; provide for implementation of a source permit program to regulate the modification and construction of any stationary source within the area s covered by the plan; include provisions for the implementation of P art C,

p revention of s ignificant d eterioration (PSD) and P art D, NSR permit programs; include criteria for stationary

1 Other than nonattainment emissi on limitations and measures which are a part of nonattainment area plans and subject to the timing requirements of Section 172 of the CAA.6 source emission control measures, mon itoring, and reporting; include provisions for air quality modeling; and provides for public and local agency participation in planning and emission control rule development. In

Ohio’s December 27 , 20 12 infrastructure SIP submission,

Ohio verified that the S tate fulfills the requirements of Section 110(a)(2) of the CAA

.

Subpart 1 of Part D, found in Sections 172

- 176 of the CAA, sets forth the basic nonattainment requirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS. Subpart 2 of Part D, which includes Section 182 of the CAA, establishes more specific requirements depending

on the area’s ozone nonattainment classification.

The C leveland

- Akron

- Lorain , OH area was designated under Subpart 2 of Part D as a marginal nonattainment area for ozone as part of U. S. EPA “Air Quality Designations for the 2008
Ozone NAAQS .” (77 FR 30088) Therefore, the C leveland

Akron

- Lorain , OH area must meet the applicable requirements of both Subpart 1 and Subpart 2 of Part D. The applicable Subpart 1 requir ements are contained in Section 172(c)(1)

- (9) and in Section 176. The applicable Subpart 2 requirements are contained in Section 182(a) (marginal nonattainment area requirements).

ii.) Subpart 1 of Part D

- Section 172(c) requirements Section 172(c)( 1) requires the plans for all nonattainment areas to provide for the implementation of all RACM as expeditiously as practicable and to provide for attainment for the national primary ambient air quality sta ndards. As

discussed abo ve, U.S. EPA’ s Implementat ion Rule did not require marginal nonattainment areas to implement RACT/RACM. In addition, because attainment has been

reached in the C leveland

- Akron

- Lorain , OH area , no additional measures are needed to provide for

attainment.

The reasonable further pr ogress ( RFP ) requirement under section 172(c)(2) is defined as progress that must

be made toward attainment. This requirement is not relevant for purposes of redesignation because the

C leveland

- Akron

- Lorain , OH area is monitoring

attainment of the 2008 ei ght

- hour ozone standard

. In addition, because the C leveland

- Akron

- Lorain , OH area

has attained the ozone standard and is no longer subject7 to an RFP requirement, the section 172(c)(9) contingency measures are not applicable for purposes of redesignation.

Section 172(c)(3) requires submission and approval of a comprehensive, accurate and current inventory of actual

emissions. This requirement was superseded by the inventory requirement in S ection 182(a)(1) discussed

below.

Section 172(c)(4) requir es the identification and quantification of allowable emissions for major new and modified stationary sources in an area, and S ection 172(c)(5) requires source permits for the construction and operation of new and modified major stationary sources anywhere in the nonattainment area. Ohio has a fully approved new source review program which is discussed

in more detail under Chapter Five.

Section 172(c)(6) requires the SIP to contain control measures necessary to provide for attainment of the

standard. B ecause attainment has been reached, no additional measures are needed to pro vide for

attainment.

Section 172(c)(7) requires the SIP to meet the applicable provisions of S ection 110(a)(2). The Ohio SIP meets the requirements of S ection 110(a)(2) for purp oses of redesignation, as discussed above.

i i i.) Subpart 1 of Part D

- Section 176(c) requirements Section 176(c) of the CAA requires states to establish criteria and procedures to ensure that Federally

supported or funded activities, including highway p rojects, conform to the air quality planning goals in the applicable

SIPs. The requirement to determine conformity applies to transportation plans, programs and projects developed, funded or approved under T itle 23 of the U.S. Code and

the Federal Transit Act (transportation conformity) as well as to all other Federally

- supported or funded projects (general conformity). State conformity revisions must be consistent with Federal conformity regulations relating to consultation, enforcement, and enforceabili ty, which U.S. EPA promulgated pursuant to CAA requirements.

Ohio EPA established two SIPs for conformity. The rules8 in Ohio Administrative Code (OAC) C hapter 3745

- 101 contained Ohio’s SIP approved rules for transportation conformity, and OAC C hapter 374 5

- 102 contained Ohio’s SIP approved rules for general conformity.

Ohio EPA’s transportation conformity rules in OAC Chapter 3745

- 101 were approved as a part of Ohio’s SIP on July 31, 2000 ( 65 FR 34395 ) and April 27, 2007 (72

FR 20945 ). However, Ohio’s tra nsportation conformity rules in OAC Chapter 3745

- 101 were completely removed from Ohio’s SIP on March 2, 2015 (80 FR 11134) when the rules were replaced by a series of memorandums of understanding (MOUs) between Ohio EPA, U

. S

. E PA, and the various state an d local agencies involved in the transportation conformity process. The currently effective MOUs are available on Ohio EPA’s

website at: http://epa.ohio.gov/dapc/sip/trans_conform.aspx

.

Ohio EPA’s general conformity rules in OAC C hapter

3745

- 102 were approved as part of Ohio’s SIP on March 11, 1996 (61 FR 9644 ). In April, 2010, U

. S

. EPA promulgated changes to 40 CFR 51.851. The language in paragraph (a) of the section was changed from “must” t o “may”, thereby eliminat ing the requirement for states to

maintain a g eneral c onformity SIP. For this reason, Ohio EPA requested, and U

. S

. EPA granted rescission of Ohio’s general conformity SIP. The rules in OAC Ch apter

3745

- 102 were removed from the st ate SIP on May 26, 2015 (80 FR 29968)

. The state SIP was replaced by the federal rules in 40 CFR Part 93, subpart B.

iv.) Subpart 2 of Part D

- Section 182(a) requirements Section 182(a)(1) requires the submission of a comprehensive emissions inventory. This requirement is addressed under Chapter Four

.

Section 182(a)(2) requires the submission of certain

corrections to VOC RACT rules, inspection and

maintenance programs and permitting programs. These

corrections were addressed for the C leveland , OH are a under the one

- hour ozone standard and do not need to be addressed again under the 2008 eight

- hour standard.

Section 182(a)(3)(B) requires the submission of an9 emission statement SIP. This requirement is addressed under Chapter Five

.

v.) Maintenance pla ns

- CAA Section 107 (d)(3)(E)( i v) Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan

that meets the requirements of Section 175(A). The maintenance plan must constitute a SIP revision and m ust provide for maintenance of the relevant NAAQS in the area for

at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.

In addit ion, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state will impleme nt all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) a ttainment inventory ; b.) m aintenance demonstration ; c.) m onitoring network ; d.) v erification of continued attainment ; and e.) c ontingency plan

.
Chapter S ix discusses this requirement in more detail.10



### CHAPTER THREE

OZONE MONITORING CAA Section107 (d)(3)(E)(i)

Requirement 1 of 4 A demonstration that the NAAQS for ozone, as p ublished in 40 CFR 50. 15,

has been attained.

Background

There are twelve monitor s measuri ng ozone concentrations in

this no nattainm ent area. The monitors are o perated by Ohio EPA Division of Air Pollution Control, Northeast District Office

, Department of Public Health Division of Air Quality, Lake County General Health District Air Pollution Control and Akron Regional Air Quality Management

. A listing of the design values based on

the three

- year average of the annual fourth highest daily maximum eight

- h our average ozone concentration s from 20 1 3 through 2015 certified air quality data is shown in Table 1

. The locations of the monitoring sites for this nonattainment area are shown on Figure 1

.11

D emonstration

Figure 1

- Map of the C leveland

- Akron

- Lorai n , OH nonattainment area

and monitor locations

Requirement 2 of 4 Ambient monitoring data quality assured in accordance with 40 CFR 58.10,

recorded in the U.S. EPA AQS data base, and available for public view.

Demonstration

The Ohio EPA has qualit y assured all 201 3 through 201 5 data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio Quality Assurance Manual. Ohio EPA has recorded the data12

in the AQS database and

, therefore , the data are available to the public.

R equirement 3 of 4 A showing that the three

- year average of the fourth highest values, based on data from all monitoring sites in the area or its affected downwind environs, are

below 75 parts per billion (ppb). ( This showing must rely on three complete,

consecutive calend ar years of quality assured data. )

Background The following information is taken from Appendix P

,

“ Interpretation of the Primary and Secondary NAAQS for O 3 ” of

40 CFR Part 58.

Three complete years of ozone monitoring data are required to

demonstrate att ainment at a monitoring site. The eight

- hour primary and secondary ozone ambient air quality standards are met at an ambient air quality monitoring site when the three

- year average of the annual fourth

- highest daily maximum eight

- hour

average ozone concen tration s is less than or equal to 0.075 ppm. When this occurs, the site is said to be in attainment. Three significant digits must be carried in the computations. Because the third decimal digit, in ppm, is truncated, 0.075666* ppm is the largest concen tration that is less than or equal to 0.075 ppm. Therefore, for the purposes of this request, values

below 0.0757 ppm meet the standard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in complian ce with the eight

- hour ozone NAAQS if, and only if, every monitoring site in the area meets
the NAAQS. An individual site's three

- year average of the annual fourth highest daily maximum eight

- hour average ozone concentration s is also c alled the site's des ign value.

Table 1 shows the monitoring data for 20 12

– 20 14 and 2013

- 2015 that were retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design value among all sites in the area. Please note that the standard is

meas ured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.13

D emonstration

Table 1

- Certified Monitoring Data for the C leveland

- Akron

Lorain

, OH a rea for 20 12

– 20 14 and 2013

– 2015

Data source: U. S. EPA Ai r Quality System (AQS)

http://www.epa.gov/aqs

SITE ID COUNTY YEAR %OBS 1 st 2 nd 3 rd 4 th 2012

- 2014 2013

-

2015

8

- HR 8

- HR 8

- HR 8

- HR AVE R. AVER

. 39

- 007

- 1001 Ashtabula 2012 98 97 93 81 79

72 69 39

- 007

- 1001 Asht abula 2013 100 73 73 70 70

39

- 007

- 1001 Ashtabula 2014 100 76 73 70 69

39

- 009

- 1001 Ashtabula 2015 98 83 73 71 70

39

- 0 35

- 00 34 C uyahoga 2012 98 102 88 8 6 8 5

75 69 39

- 0 35

- 00 34 Cuyahoga 2013 98 86 7 3 70 6 9

39

- 0 35

- 00 34 Cuyahoga 2014 99 75 7 4 7 2 7 1

39

- 0 35

- 00 34 Cuyahoga 2015 9 6 7 0 7 0 68 67

39

- 0 35

- 00 60 Cuyahoga 2012 9 8 8 4 8 1 74 73

65 62 39

- 0 35

- 00 60 Cuyahoga 2013 95 6 6 6 0 5 8 57

39

- 0 35

- 00 60 Cuyahoga 2014 9 7 69 68 67 6 6

39

- 0 35

- 00 60 Cuyahoga 2015 94 67 63 63 63

39

- 0 35

- 0064 Cuyahoga 2012 9 8 9 4 90 87 8 3

68 63 39

- 0 35

- 0064 Cuyahoga 2013 9 7 68 66 66 6 4

39

- 0 35

- 0064 Cuyahoga 2014 9 7 66 6 2 6 1 5 9

39

- 0 35

- 0064 Cuyahoga 2015 99 68 67 6 6 6 6

39

- 0 3 5

- 5002 Cuyahoga 2012 99 98 9 4 89 87

71 66 39

- 0 3 5

- 5002 Cuyahoga 2013 99 80 70 6 5 6 5

39

- 0 3 5

- 5002 Cu yahoga 2014 9 9 7 5 6 4 6 3 6 1

39

- 0 3 5

- 5002 Cuyahoga 2015 99 74 7 3 7 2 7 2

39

- 0 55

- 0004 Geauga 2012 100 103 9 9 8 3 8 2 70 6714

SITE ID COUNTY YEAR %OBS 1 st 2 nd 3 rd 4 th 2012

- 2014 2013

-

2015

8

- HR 8

- HR 8

- HR 8

- HR AVE R. AVER

. 39

- 0 55

- 0004 Geauga 2013 100 74 70 66 65

39

- 0 55

- 0004 Geauga 2014 100 77 68 67 65

39

- 0 55

- 0004 Geauga 2015 100 80 7 9 7 3 7 3

39

- 0 8 5

- 000 3 Lake 2012 100 108 9 3 92 8 9

78 73 39

- 85 1

- 000 3 Lake 2013 100 85 7 4 72 70

39

- 0 85

- 000 3 Lake 2014 100 79 7 8 7 6 7 5

39

- 0 85

- 000 3 Lake 2015 9 8 77 7 5 74 7 4

39

- 085

- 0007 Lake 2012 99 97 87 84 83

71 66 39

- 085

- 0007 Lake 2013 100 78 70 69 68

39

- 085

- 0 007 Lake 2014 100 73 66 64 62

39

- 085

- 0007 Lake 2015 100 78 72 72 70

39

- 0 93

- 00 18 Lorain 2012 9 7 89 8 7 85 8 1

69 63 39

- 0 93

- 001 8 Lorain 2013 100 66 63 6 3 6 0

39

- 0 93

- 001 8 Lorain 2014 99 68 68 67 67

39

- 0 93

- 001 8 Lorain 2015 99 68 65 64 62

39

- 103

- 00 04 Medina 2012 98 9 0 75 74 74

67 64 39

- 103

- 00 04 Medina 2013 100 69 66 66 6 5

39

- 103

- 00 04 Medina 2014 100 7 2 65 6 5 6 4

39

- 103

- 00 04 Medina 2015 100 69 65 65 63

39

- 1 33

- 1001 Portage 2012 95 9 1 75 75 74

64 61 39

- 1 33

- 1001 Portage 2013 9 8 67 61 59 58

39

- 1 33

- 1001 Portage 2014 99 66 65 63 6 1

39

- 1 33

- 1001 Portage 2015 100 68 65 65 6415

SITE ID COUNTY YEAR %OBS 1 st 2 nd 3 rd 4 th 2012

- 2014 2013

-

2015

8

- HR 8

- HR 8

- HR 8

- HR AVE R. AVER

. 39

- 153

- 0020 Summit 2012 100 8 6 71 7 0 7 0

62 61 39

- 153

- 0020 Summit 2013 100 7 0 6 4 6 1 60

39

- 153

- 0020 Summit 2014 100 6 6 6 2 59 58

39

- 153

- 0020 Summit 2 015 100 68 6 8 6 5 6 5

The area's design value s ha ve tr ended downward as emissions have

declined due to such factors as cleaner automobiles and fuels

, along

with controls for electric generating units ( EGUs )

, both regionally and locally.

Requirement 4 of 4

A commitmen t that once redesignated, the s tate will continue to operate an appropriate monitoring network to verify the maintenance of the attainment

status.

Demonstration

Ohio EPA commit s to continue moni toring ozone levels at the

Ohio site s indic ated in Figure 1 . Ohio EPA will consult with U.S.

EPA Region V prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirement s of 40 CF R 58 and all other federal requirements. Connection to a central station and updates to the Ohio EPA w eb site 2 will provide real time availability of the data and knowledge of any exceedances. Ohio

EPA will enter all data into AQS on a timely ba sis in accordance with federal guidelines.

2 http://www.epa.gov/ttn/chief/emch/index.html16



### CHAPTER FOUR

EMISSION INVENTORY

CAA Section 107 (d)(3)(E)(iii) , & 1 07 (d)(3)(E)( v )

U.S. EPA ’s R edesignation G uidance requires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO
x ) representative of the year when the area achieves attainment of the ozone air quality standard. Ohio also must demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment

was achieved is based on permanent and enforceable emission reductions

. Other emission inventory related requirements include a projection of the

emission invent ory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is suf ficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emis sion levels during the 10

- year maintenance period.

The emissions inventory development and emissions projection discussion

below

, with the exception of the mobile (on

- road) emissions inventory and projections, identifies procedures used by Ohio EPA regarding emissions from

the counties in the C leveland

- Akron

- Lorain

, OH area.

Area, non

- road, on

- road and point source emissions were compiled as follows:

 Area, non

- road, and point source emissions (EGUs, non

- EGUs and airport related emissions (AIR)) were collected from the data available on U.S. EPA’s Emissions Modeling Clearinghouse website 3 . Using Ozone NAAQS Emissions Modeling pla tform (2011v6.1) data were collected together for the 2011 National Emissions Inventory (NEI) year

and the 2018 and 2025 U.S. EPA

- projected inventories. Therefore, 2011 point emissions are actual reported emissions from the 2011 NEI.

 Because the 2014 NEI is not available at this time, Ohio EPA derived 2014 actual point emissions (for EGUs and non

- EGUs) from state inventory databases (e.g., Ohio’s EIS database which serves as the basis for the 2014 NEI).

 Because all emissions from the state inventory data base, the NEI and

the Ozone NAAQS Emissions Modeling platform (2011v6.1) are annual totals, tons per summer day were derived according to the U.S. EPA guidance document Temporal Allocation of Annual Emissions Using EMCH Temporal Profiles , dated April 29, 2 002 4

, using the temporal allocation references accompanying the 2011v6.1 modeling inventory

files. These files provide SCC specific profiles that allow annual

3 http://www.epa.gov/ttn/chief/emch/index.html

4 https://www3.epa.gov/ttn/chief/emch/temporal/index.html17

emission totals to be distributed across various temporal periods, as described in the guidance document referenced here.

 Using the above datasets:

o 2014 emissions for area, non

- road and AIR point were derived by interpolat ing between 2011 and 2018 . Note that Ohio EPA does not require airport related emissions to be reported and

therefore actual 201 4 airport emissions will not be available until the 2014 NEI is available. If those emissions differ appreciably from the emissions projected using this methodology, Ohio EPA will commit to submitting a revised redesignation request and maintenance plan.

o 2 020 emissions for area, non

- road and point (EGU, non

- EGU and AIR) were derived by interpolating between 2018 and 2025

.

o 2030 emissions for area, non

- road and point (EGU, non

- EGU and AIR) were derived using the TREND function in Microsoft

Excel. If the TREN D function resulted in a negative value, the emissions were assumed to not change.

o Mobile source emissions for all years were developed in conjunction with the Ohio EPA, Ohio Department of

T ransportation (Ohio DOT), the Akron Metropolitan Area Transporta tion Study (AMATS) and the Northeast Ohio Areawide Coordinating Agency (NOACA) and were calculated from emission factors produced by U.S. EPA’s 201 0 Motor Vehicle Emission Simulator (MOVES) software program and data extracted from the region’s travel

- deman d model. Appendix B contains detailed methodology and data for mobile source emissions for all years.

o Biogenic emissions are not included in these summaries.

Requirement 1 of 5 A comprehensive emission inventory of the precursors of ozone completed

fo r the base year.

Background The point source data are taken from Ohio's annua l emissions reporting program.

Periodic inventories, which include emissions from all sectors

- mobile, area, non

- road, and point sources

- are prepared every three years.18

Demonstration

The 20 11 inventory is used as the nonattainment base year for the purpose of this submittal

. 5 The 2014 inventory is used as the attainment year inventory for the purposes of comparison. These inventories represent a comprehensive, accur ate, and current inventory of actual emissions from all sources of the relevant pollutants in the C leveland

- Akron

- Lorain , OH area.

Emissions of VOC and NOx for 20 11 and 2014 are identified under Requirement Three of this Chapter.

Requirement 2 of 5 A pr ojection of the emission inventory to a year at least 10 years following redesignation.

Background As discussed above, Ohio EPA prepare d a projected emissions inventory for the C leveland

- Akron

- Lorain

, OH area including

area, non

- road, mobile, and point so urces for precursors of ozone ( VOCs and NO
x ) for the nonattainment area.

Demonstration In consultation with U.S. EPA and other stakeholders, Ohio EPA selected the year 2030 as the maintenance year for this redesignation request. The request also conta ins projected

emission inventories for 2020.

On

- Road Mobile Emission Estimations

Table s 2 through 10 contain the results of the emissions anal ysis for the appropriate years. All emissions estimations are expressed in tons per summer day (TSD).

Tabl e 2

- Ashtabula County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 2.88 2.09 1.38 1.06
NOx (TSD) 6.35 4.22 2.28 1.56
VMT (miles/day) 3,154,204 3,232,705 3,399,487 3,608,559

5 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as required under

CAA Section 182(a)(1). Ohio EPA is not requesting that inventory be replaced with the 2011 inventory in this submittal in Ohio’s SIP.19

Table 3

- Cuyahoga County

, Ohio E mission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 27.04 17.84 12.18 9.37 NOx (TSD) 50.73 31.72 17.65 12.01
VMT (miles/day) 28,384,168 28,467,810 28,392,560 28,736,592

Table 4

- Geauga County

, Ohio Emission Estimations fo r

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 4.76 2.03 1.45 1.11 NOx (TSD) 7.46 3.73 2.20 1.60
VMT (miles/day) 2,559,395 2,650,527 2,718,014 2,919,951

Table 5

- Lake County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 2 0 14 20 20 20 30 VOC (TSD) 5.94 4.30 2.85 2.15
NOx (TSD) 11.97 8.05 4.71 3.25
VMT (miles/day) 5,789,656 5,918,927 6,031,050 6,419,270

Table 6

- Lorain County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30
VOC (TSD) 7.80 5 .69 3.79 2.86

NOx (TSD) 14.11 10.29 5.76 3.86

VMT (miles/day) 6,968,846 7,133,870 7,237,077 7,689,523

Table 7

– Medina County

, Ohio Emission Estimations for On

Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 5.41 3.95 2.78 2.22 NOx (TSD) 14.59 10 .33 5.85 4.30

VMT (miles/day) 6,169,676 6,370,242 6,688,963 7,281,548

Table 8

– Portage County, Ohio Emission Estimations f or On

Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 4.48 3.38 2.39 2.00 NOx (TSD) 9.96 6.77 3.93 2.90
VMT (miles/day) 5,1 37,069 5,270,104 5,882,626 6,360,77720

Table 9

– Summit County, Ohio Emission Estimations for On

Road Mobile Sources

20 11 20 14 20 20 20 30
VOC (TSD) 13.61 10.07 6.96 6.01

NOx (TSD) 29.19 19.45 11.15 8.62

VMT (miles/day) 15,901,993 16,368,909 17,696,79 1 18,872,705

Table 1 0

- Emission Estimation Totals for On

- Road Mobile

Sources for the C leveland

- Akron

- Lorain

- OH A rea

20 11 20 14 20 20 20 30 VOC (TSD) 71.92 49.35 33.78 26.78
NOx (TSD) 144.36 94.56 53.53 38.10
VMT (miles/day) 7 4,065,007 75,413,094 78,046,568 81,888,925

Motor Vehicle Emission Budget

Table 1 1 contain s the motor vehicle emissions budget s for the

Cleveland

- Akron

- Lorain

, OH area

.

Table 1 1

- Mobile Vehicle Emission s Budget for the Cleveland

Akron

- Lorain , OH Area

20 20

Estimated

Emissions 20 20

Mobile Safety Margin

Allocation* 20 20

Total

Mobile Budget 20 30

Estimated

Emissions 20 30

Mobile Safety Margin

Allocation* 20 30

Total

Mobile Budget

VOC (TSD) 33.78 5.07 38.85 26.78 4.02 30.80

NOx (TSD) 53.53 8.03 61.56 3 8.10 5.72 43.82

VMT (miles/day) 78,046,568

- - 81,888,925

- -

*The 15 percent margin of safety was calculated by taking 15 percent of the mobile source emission estimates.

Th e above budget s for the Cleveland

- Akron

- Lorain, OH area, agreed upon as part o f the interagency consultation process,

include the emission estimates calculated for 2020 and 20 30

with an additional 15 percent margin of safety allocated to those

estimates

.

In an effort to accommodate future variations in travel demand

models and VM T forecast when no change to the network is planned, Ohio EPA consulted with U

. S

. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15 percent margin of safety allocation was agreed21

upon and has been added to th e emissions estimates for the

Cleveland

- Akron

- Lorain, OH nonattainment area.

The emission estimates are derived from the travel demand

model and MOVES20 10 as described above

. All methodologies, the latest planning assumptions

, and the safety margins allo cations were determined through the interagency consultation process described in the Transportation Conformity

Memorandum o f Understanding (MOU) among NOACA, AMATS, Ohio DOT, and Ohio EPA.

A 15 percent margin of safety is appropriate because : 1) there i s an acknowledged potential variation in VMT forecast and potential estimated mobile source emissions due to expected modifications to TDM and mobile emissions models; and 2) t he

total decrease in emissions from all sources is sufficient to

accommodate thi s 15 percent allocation of safety margin to mobile sources while still continuing to maintain the total

emissions in the C leveland

- Akron

- Lorain

, OH area well below

the 20 14 attainment level of emissions.

The 15 percent margin of safety was calculated b y taking 15 percent of the mobile source emission estimates. Safety margin, as defined by the conformity rule, looks at the total

emissions from all sources in the nonattainment area. The

actual allocation is less than 15 percent of the total emission

re duction from all sources as can be seen from Table 3 0

.

In summary, f or all three s tates combined, t he mobile budget safety margin allocation translates into :

- An a llocation of 5.07 TSD for VOC and 8.03 TSD for NOx

for 20 20 ; and

- A n allocation of 4.02 TSD fo r VOC and 5.72 TSD for NOx

for 20 30

.

When compared to the overall safety margin, as defined in 40

CFR 93.101 6

, discussed under “Requirement 3 of 5” below, it is evident this allocation is significantly below the total safety margin for this area (see Tab le 3 0 )

.

6 "safety margin" means the amount by which the total projected emissions from all sources of a given pollutant are less than the tot al emissions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance.22

The current eight

- hour budgets will no longer be applicable either after the effective date of the approved redesignation or after the effective date of any U.S. EPA action approving a finding that the new eight

- hour conformity budget included in this submittal is adequate for transportation conformity purposes

, whichever date comes first.

Requirement 3 of 5 A demonstration that the projected level of emissions is sufficient to maintain

the ozone standard.

Background

Maintenance is demonstrate d when the future

- year (2030) projected emission totals are below the 2014 attainment year

totals.

Sectors included in the following tables are: Electrical Generating Unit (EGU) ; Non

- Electrical Generating Unit (Non

EGU) ; Non

- road Mobile (Non

- road) ; Air port (AIR); Other

- Area ( Area ) ; and On

- road Mobile (On

- road).

Demonstration

NO x

Table 1 2

- Ashtabula County , Ohio NO x Emission Inventory

Totals ( TSD )

Sector 2011

Base 2014

Attainment 2020

Interim 2030

Maintenance Safety

Margin

EGU 4.21 1.26 0.30 0.7 1

Non

- EGU 0.74 0.74 0.73 0.71

AIR 0.00 0.00 0.00 0.00

Non

- road 2.89 5.95 1.95 1.36

Area 4.02 3.82 3.40 2.67

On

- road 6.35 4.22 2.28 1.56

TOTAL 18.21 15.99 8.66 7.01 8.9823

Table 13

– Cuyahoga County, Ohio NO x Emission Inventory

Total s (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 30

Maintenance Safety

Margin

EGU 2.83 1.10 0.03 0.01

Non

- EGU 7.62 7.40 6.43 6.05

AIR 1.67 1.80 2.10 2.68

Non

- road 18.83 21.03 11.00 7.66

Area 13.78 13.60 13.10 12.03

On

- road 50.73 31. 72 17.65 12.01

TOTAL 95.46 76.65 50.31 40.44 36.21

Table 1 4

- Geauga County, Ohio NOx Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 30

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.02 0.02 0.03 0.03

AIR 0.00 0.00 0.00 0.00

Non

- road 1.66 2.89 0.90 0.61

Area 0.87 0.90 0.94 0.95

On

- road 7.46 3.73 2.20 1.59

TOTAL 10.01 7.54 4.07 3.18 4.36

T able 15

– Lake County, Ohio NO x Emission Inventory Totals

(TSD)

Sector 20 11

Base 20 14

Attainment 2 0 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 27.27 5.48 2.96 2.96

Non

- EGU 1.94 1.81 1.97 1.99

AIR 0.01 0.01 0.01 0.01

Non

- road 4.83 6.66 3.20 2.36

Area 4.25 4.12 3.82 3.24

On

- road 11.97 8.05 4.71 3.25

TOTAL 50.27 26.13 16.67 13.81 12.3 224

Table 16

- Lorain County, Ohio NO x Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 12.73 10.48 0.04 0.04

Non

- EGU 1.84 1.66 1.91 1.92

AIR 0.01 0.01 0.01 0.01

Non

- road 6. 17 7.40 3.70 2.40

Area 5.04 4.83 4.35 3.49

On

- road 14.11 10.29 5.76 3.86

TOTAL 39.90 34.67 15.77 11.72 22.95

Table 17

- Medina County, Ohio NO x Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safe ty

Margin

EGU 0.00 0.00 0.01 0.01

Non

- EGU 0.20 0.21 0.20 0.27

AIR 0.02 0.02 0.02 0.02

Non

- road 2.95 3.07 1.50 0.79

Area 1.98 1.93 1.82 1.58

On

- road 14.59 10.33 5.85 4.30

TOTAL 19.74 15.56 9.40 6.97 8.59

Table 18

- Portage

, Ohio NO x E mission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.28 0.32 0.29 0.29

AIR 0.00 0.00 0.00 0.00

Non

- road 2.66 4.14 1.39 0.79

Area 3.11 2.98 2.69 2.15

O n
- road 9.96 6.77 3.93 2.90

TOTAL 16.01 14.21 8.30 6.13 8.0825

Table 19

- Summit County

, Ohio NO x Emission Inventory Total

( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.00 0.00 0.01 0.01

Non

- EGU 1.59 1.33 0.7 4 0.76

AIR 0.33 0.36 0.44 0.58

Non

- road 6.30 6.25 3.13 1.86

Area 5.34 5.28 5.08 4.66

On

- road 29.19 19.45 11.15 8.62

TOTAL 42.75 32.67 20.55 16.49 16.18

Table 2 0

– C leveland

- Akron

- Lorain

- OH A rea NO x Emission

Inventory Totals ( TSD )

NOx 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

Ashtabula 18.21 15.99 8.66 7.01
Cuyahoga 95.46 76.65 50.31 40.44
Geauga 10.01 7.54 4.07 3.18

Lake 50.27 26.13 16.67 13.81

Lorain 39.90 34.67 15.77 11.72

Medina 19.74 15.56 9.4 0 6.97
Portage 16.01 14.21 8.30 6.13

Summit 42.75 32.67 20.55 16.49

COMBINED

NOx TOTAL 292.35 223.42 133.73 105.75 117.67

VOC

Table 2 1

- Ashtabula County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

In terim 20 3 0

Maintenance Safety

Margin

EGU 0.06 0.01 0.03 0.11

Non

- EGU 7.04 6.68 7.04 7.04

AIR 0.00 0.00 0.00 0.01

Non

- road 7.35 2.51 4.01 2.18

Area 3.81 3.75 3.66 3.58

On

- road 2.88 2.09 1.38 1.06

TOTAL 21.14 15.04 16.12 13.98 1.0626

T able 22

- Cuyahoga County, Ohio VOC Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.04 0.01 0.00 0.00

Non

- EGU 2.77 2.73 2.57 2.49

AIR 0.41 0.43 0.49 0.60

Non

- road 24.86 15.42 16. 66 14.86

Area 33.36 32.55 31.56 30.93

On

- road 27.04 17.84 12.18 9.37

TOTAL 88.48 68.98 63.46 58.25 10.73

Table 23

- Geauga County, Ohio VOC Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Ma rgin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.04 0.08 0.04 0.04

AIR 0.00 0.00 0.00 0.00

Non

- road 3.34 1.32 2.37 2.13

Area 4.14 4.05 3.94 3.87

On

- road 4.76 2.03 1.45 1.11

TOTAL 12.28 7.48 7.80 7.15 0.33

T able 24

– Lake County, Ohio VOC Emissi on Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.32 0.26 0.02 0.02

Non

- EGU 0.73 0.80 0.64 0.63

AIR 0.01 0.01 0.01 0.01

Non

- road 8.22 4.14 4.56 2.77

Area 6.41 6.30 6.15 6.06

On

- ro ad 5.94 4.30 2.85 2.15

TOTAL 21.63 15.81 14.23 11.64 4.17

Table 25

- Lorain County, Ohio VOC Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.09 0.08 0.00 0.00

Non

- EGU 2.51 1.97 2 .50 2.50

AIR 0.02 0.02 0.02 0.03

Non

- road 8.96 5.13 5.36 3.78

Area 7.54 7.37 7.14 6.95

On

- road 7.80 5.69 3.79 2.86

TOTAL 26.92 20.26 18.81 16.12 4.1427

Table 26

- Medina, Ohio VOC Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attain ment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.64 0.52 0.62 0.63

AIR 0.04 0.04 0.04 0.04

Non

- road 3.60 2.33 2.45 2.11

Area 5.23 5.14 5.03 4.97

On

- road 5.41 3.95 2.78 2.22

TOTAL 14.92 11.98 10.92 9.97 2.01

Table 27

- Portage County, Ohio VOC Emission Inventory Totals

(TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.91 1.12 0.91 0.89

AIR 0.00 0.00 0.00 0.00

Non

- road 4.90 2. 12 3.18 2.52

Area 5.92 5.82 5.69 5.61

On

- road 4.48 3.38 2.39 2.00

TOTAL 16.21 12.44 12.17 11.02 1.42

T able 28

- Summit County

, Ohio VOC Emission Inventory Totals

( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 1.22 1.04 1.14 1.12

AIR 0.09 0.10 0.11 0.13

Non

- road 7.33 4.90 5.09 4.80

Area 14.44 14.19 13.87 13.62

On

- road 13.61 10.07 6.96 6.01

TOTAL 36.69 30.30 27.17 25.68 4.6228

Table 29

– C leveland

- Akron

- Lorain

- OH Area VOC Emission

Inventory Totals ( TSD )

VOC 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

Ashtabula 21.14 15.04 16.12 13.98

Cuyahoga 88.48 68.98 63.46 58.25

Geauga 12.28 7.48 7.80 7.15

Lake 21.63 15.81 14.23 1 1.64

Lorain 26.92 20.26 18.81 16.12

Medina 14.92 11.98 10.92 9.97

Portage 16.21 12.44 12.17 11.02

Summit 13.61 10.07 6.96 6.01

COMBINED

VOC TOTAL 215.19 162.06 150.47 134.14 27.92

VOC and NOx

Table 3 0

- Cleveland

- Akron

- Lorain, OH A rea Comparison of 2014

attainment year and projected emission estimates ( TSD )

20 14 20 20 20 20

Projected

Decrease 20 3 0 20 3 0

Projected

Decrease

VOC 162.06 150.47 11.59 134.14 27.92

NO
x 223.42 133.73 89.69 105.75 117.67

As shown in the table above, V OC emissions in the

nonattainment ar ea a r e projected to decrease by 11.59 TSD in

20 20 and 27.92 TSD in 20 3 0

. In general, emissions for all sectors are projected to decline or remain stable . EGU sources in Ashtabula County ) show a slight increase , but this is fractional compared to the overall reductions expected. Furthermore, Ashtabula, Cuyahoga, Lorain, and Summit Counties show a minor increase in regards to a ir emissions

. A gain this increase

does not affect the overall reduction in VOC emissions for the

area and are likely contributed to slight changes in population projections

. C leaner vehicles and fuels are expected to be in place in 2018 and will cause an overall drop in VOC emissions.

NO
x emissions in the nonattainment area are projected to

d ecr ease by 89.69 TSD in 20 20 and 117.67 TSD in 20 3 0

. N on

road and on

- road emissions are all projected to decline . A rea emissions are projected to decline in all counties expect Geauga, where a slight increase in emissions is projected

. Air29

emissions are proj ected to remain steady or slightly increase in Cuyahoga, and Summit Counties. EGU emissions are projected

to decrease overall for the Cleveland

- Akron

- Lorain, OH area. Geauga, Lake, Lorain, Medina, and Portage are projected to

have minor increases with non

- EGU emissions. However

, overall

non

- EGU NOx emissions are decreasing for the Cleveland

Akron

- Lorain, OH area as a whole. Decreases from U.S. EPA rules covering EGUs (NOx SIP Call, CAIR and CSAPR), Tier 2

Motor Vehicle Emissions Standards and Gasoline Su lfur Control Requirements 7 , Highway Heavy

- Duty Engine Rule 8

, and the

Non

- Road Diesel Engine Rule 9 are factored into the changes.

As identified in Table 1 1 above, an additional mobile budget margin of safety allocation is being requested for mobile

emiss ions. The mobile budget margin of safety allocation

translates into an additional 5.07 TSD for VOC and 8.03 TSD for NOx in the year 20 20 and 4.02 TSD for VOC and 5.72 TSD for

NOx in the year 20 3 0. U.S. EPA’s conformity regulations allow

for allocation, throug h a revision to the SIP, of all or some portion of the overall area’s safety margin (emission reductions

from 2014 to 20 3 0 ) to the mobile emissions budgets for future conformity.

- In 20 20 : 5.07 TSD of the 11.59 TSD safety margin for

VOC and 8.03 TSD of the 89.69 TSD safety margin for NOx as a mobile emissions budget safety margin.

- In 20 3 0: 4.02 TSD of the 27.92 TSD safety margin for

VOC and 5.72 TSD of the 117.67 TSD safety margin for NOx as a mobile emissions budget safety margin.

Requirement 4 of 5

A dem onstration that improvement in air quality between the year violations

occurred and the year attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic

conditions or unusually favorable meteorolo gy.

Background Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for ozone in 20 1 3 through 20 1 5

. U.S.

EPA ’s R edesignation G uidance (p 9) states : “A state may generally demonstrate maintenance of the NAAQS by eithe r

7 http://www.epa.gov/fedrgstr/EPA

- AIR/2000/February/Day

- 10/a19a.htm

8 http://www.epa.gov/fedrgstr/EPA

- AIR/1997/October/Day

- 21/a27494.htm

9 http:// www.epa.gov/fedrgstr/EPA

- AIR/1998/October/Day

- 23/a24836.htm30

showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling

to show that the future mix of sources and emissions rates will
not cause a violation of the NAAQS.”

Demonstration

Perm anent and enforceable reductions of VOC and NOx

emissions have contributed to the attainment of the eight

- hour

ozone stan dard. Some of these reductions were due to the application of tighter federal standards on new vehicles and non

road diesel engines wh ile reductions in EGU emissions were due to implementation of CAIR/CSAPR

.

With respect to EGUs, changes at several facilities have resulted

in reductions in NOx emissions. Cleveland E lectric I lluminating

C o ., E astlake P lant in Lake County ( OH ) permanent ly shutdown

in April of 2015. Prior to the shutdown, EGU NOx emissions had dropped from 27 .27 TSD to 5.48 TSD (2011 to 2014). The First Energy Generation, LLC Lake Shore facility in C uyahoga County (OH) permanently shutdown in April of 201 5 . Prior to th e shutdown, EGU NOx emissions had dropped in Cuyahoga County from 2.83 TSD to 1.10 TSD (2011 to 2014). The First Energy Generation, LLC Ashtabula Plant in Ashtabula County (OH) shutdown coal fired boilers in April of 2015 and December

of 2015. Prior to t he shutdown, EGU NOx emissions in Ashtabula County had dropped from 4.21 TSD to 1.26 TSD (2011 to 2014). Even greater reductions than predicted will be

achieved in these areas due to the shutdown of these facilities.

Reductions achieved are discus sed in greater detail under Chapter Five.

Table 3 1

– C leveland

- Akron

- Lorain

, OH A rea Combined

Comparison of 20 11 base y ear and 20 14 attainment

year EGU, non

- road, and on
- road reductions

20 11 20 14

EGU NOx 47.04 18.32

Non

- road NOx 46.29 57.39

Non

- road VOC 68.56 37.87

On

- road VOC 71.92 49.35

On

- road NO x 144.36 94.5631

To further support Ohio’s demonstration that the improvement in air quality between the year violations occurred and the year attainment was achieved is based on permanent and

enforce able emission reductions and not on temporary adverse

economic conditions or unusually favorable meteorology

, a n analysis was performed by Ohio EPA in order to demonstrate the improvement in air quality is not based on unusually favorable meteorology.

Oh io EPA analyzed the maximum fourth

- high eight

- hour ozone

value for May, June, July, August and September, years 2000 to 2015. The values were analyzed against average monthly temperatures, the number of days with a temperature exceeding 80° F, and the ave rage relative humidity. While the formation of tropospheric ozone is dependent on a large number of atmospheric variables, ozone formation is strongly and positively correlated with elevated temperatures and humidity. The utilization of an extended perio d of record (2000

- 2015) should

eliminate or dampen the influence of other meteorological variables affecting ozone formation, such as wind direction and wind speed

.

Meteorological data for the Cleveland

- Akron

- Lorain, OH area was compiled from monthly loca l climatological data obtained from the National Oceanic and Atmospheric Administration’s National Climatic Data Center (NCDC). The data was recorded at the meteorological station located at the Cleveland

- Hopkins International Airport, WBAN 14820. Ohio E PA has previously determined that data from this meteorological station is representative of meteorological conditions across the

nonattainment area

, and utilizes this same data for New Source Review and Prevention of Significant Deterioration air quality permit modeling applications. Monitor data was compiled from

the U.S. EPA’s AQS database for the same period.

The first analysis compared the maximum eight

- hour ozone

concentration at each monitor in the Cleveland

- Akron

- Lorain, OH

area to the number of d ays where the maximum temperature was greater than or equal to 80° F. The results of this analysis are shown in Figure 2.32

Figure 2

– Maximum eight

- hour ozone concentrations versus number

of days greater than or equal to 80° F for Cleveland

Monito rs

The data shown in Figure 2 indicates that while there is some correlation between the number of days in which temperatures were at or exceeded 80° F, this correlation is not 1 to 1. While there is clearly some degree of correlation when comparing one year to the next, the same is not observed when examining the monitor values and temperature data over the period of study. Secondly, a clear trend in decreasing ozone concentrations at all monitors is apparent, while no suc h trend is observed in the temperature data. Lastly, there is a clear similarity in the recorded ozone values, which is consistent with the regional nature of ground

- level ozone formation.

To further examine the relationship between meteorological

factor s and ozone concentrations, Ohio EPA examined the relationship between average summer temperatures for each year of the 2000 to 2015 period and the 4 th maximum eight

- hour ozone concentration. Given the similarity of ozone

concentrations observed at each m onitor (see Figure 2) and the regional nature of ozone formation, Ohio EPA conducted this analysis using the average 4 th maximum eight

- hour ozone

concentration from all monitors in the Cleveland

- Akron

- Lorain,

OH area. The results of this analysis are show n in Figure 3.33

Figure 3

– Average m aximum 4 th h igh eight

- hour ozone concentrations

versus average summer temperatures

The data shown in Figure 3 indicates that while there is some correlation between average summer tempera tures and ozone concentrations, this correlation does not exist over the study period. The linear regression lines for each data set demonstrate that average summer temperatures have increased over the 2000 to 2015 period, while average ozone

concentratio ns have decreased. The correlation between temperature and ozone formation is well establish ed; these data serve as strong evidence to suggest that reductions in precursors are responsible for the significant reductions in

elevated ozone concentrations in the Cleveland

- Akron

- Lorain,

OH area and not due to unusual or favorable summer temperatures

.

Lastly, Ohio EPA analyzed the relationship between average summertime relative humidity and average 4 th maximum eight

hour ozone concentrations in the Clevelan d

- Akron

- Lorain, OH

area. As with the data shown in Figure 3, Ohio EPA considered the overall trend in ozone monitors by analyzing the average of

4 th maximum 8

- hour concentrations across all monitors in the area. These data are shown in Figure 4.34

Figure 4

– Average maximum 4 th high eight

- hour ozone concentrations

versus average summer relative humidity

The data presented in Figure 4 do not indicate a correlation between relative humidity and ozone concentrations, and the

pe riod of study represents a significant spread of average summertime relative humidity.

The analys e s of meteorological variables associated with ozone

formation above further support Ohio’s demonstration that the improvement in air quality between the year violations occurred

and the year attainment was achieved is based on permanent

and enforceable emission reductions and not on unusually favorable meteorology

. The extended study period should dampen the effects of minor variations in wind directions and wind speeds, and provides a sufficient basis to examine long

term trends in both the meteorological variables and the regional

ozone concentrations in the Cleveland

- Akron

- Lorain, OH area.

Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the

emission levels

, including an annual emission statement from major sources.

Demonstration In Ohio, major point sources in all counties are required to

submit air emissions information annually, in accordance with

U. S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor emission sectors every three years. These ozone precursor inventories will be prepared for future years as necessary to comply with the inventory reporting req uirements35

established in the CFR

. Emissions information will be compared

to the 20 11 base year and the 20 3 0 projected maintenance year inventories to assess emission trends, as necessary, and to assure continued compliance with the ozone standard.36



### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

CAA Section 107 ( d)(3)(E)(ii), 107(d)(3)(iv) & 107(d)(3)(E)(v)

Requirement 1 of 4 Section 182(a)(3)(B) requires states to submit emissions statements.

Background Section 182(a)(3)(B) req uires states to submit emissions statements within two years of the enactment of the Clean Air Act Amendments and then every three years thereafter.

Demonstration Ohio EPA submitted its emissions statement SIP on March 18, 1994 which was approved by U.S . EPA on October 13, 1995 (59 FR 51863). In addition, on July 18, 2014, Ohio EPA submitted a

SIP revision for this area and U.S. EPA published a proposal and direct final action approving that submittal on March 10, 2016 (81 FR 12626 and 81 FR 12591). The approval was effective May 9, 2016

. As discussed in Chapter Four ( Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (statements) every three years.

Requirement 2 of 4 Evidence that control measures required in pas t ozone SIP revisions have been fully implemented.

Background

O n October 27, 1998, U.S. EPA promulgated the NO
x S IP Call requiring 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and

cement kilns in th e eastern United States. Ohio promulgated this

rule in 2001. NOx SIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement progr am to address violations discovered by field office staff. Compliance is tracked through the Clean Air Markets data monitoring program. Be ginning in 2004, this

rule account s for a reduction of approx imately 31 percent of all

NO
x emissions state wide compa red to previous uncontrolled

years. The other 21 states also have adopted these rules.

As discussed in detail below, U.S. EPA subsequently replaced

the NOx SIP Call with CAIR and CSAPR. CSAPR continue s to37

be implemented and amounts to even further reduct ions than

that realized under the NOx SIP Call.

Section 182(b) contains additional provisions applicable to moderate nonattainment areas, for which the Cleveland

- Akron

Lorain

, OH area was under the one

- hour standard and the 1997 eight

- hour standard . Sec tion 182(b)(3) requires gasoline vapor recovery systems for gasoline dispensing stations in the area

, and Section 182(b)(4) requires motor vehicle inspection and maintenance programs , and Section 182(b)(2) requires RACT under Section 172(c)(1)

.

D emonstrat ion

NOx SIP Call

Controls for EGUs under the NOx SIP Call formally commenced May 31, 2004. E missions covered by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. D ata taken from the U.S. EPA

Clean Air Markets w eb site, quantif y the gradual NO
x reductions

that have occurred in Ohio as a result of Title IV of the 1990

CAA Amendments and the beginning of the NO
x SIP Call Rule. Ohio developed the NO
x Budget Trading Program rules in OAC Chapter 37 45

- 14 10 in response to the SIP Call. OAC Chapter

3745

- 14 regulates EGUs and certain non

- EGUs under a cap and trade program based on an 85 percent reduction of NOx emissions from EGUs and a 60 percent reduction of NO
x emissions from non

- EGUs, compared to his torical levels. This

cap stayed in place through 2008, at which time the CAIR program supersede d it as discussed above

.

On April 21, 2004, U.S. EPA published Phase II of the NO x SIP Call that establishes a budget for large (greater than 1 ton per day e missions) stationary internal combustion engines. Ohio

EPA’s OAC rule 3745

- 14

- 12 addresses stationary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the compliance plan occurred by May 1, 2006

, and the compliance demonstration began May 1, 2007.

The 2007 controlled NO x emissions are 599 tons statewide for

the ozone season

.

10 http://www.epa.state.oh.us/dapc/regs/3745

- 14/3745_14.html38

As discussed further below, s tarting January 1, 2009, CAIR

commenced and emissions covered by this program have

continued trending downward. D ata taken from the U.S. EPA

Clean Air Markets w eb site, quantif y the gradual NO
x reductions

that have occurred in Ohio as a result of implementation of CAIR. CAIR’s cap and trade program stayed in place through 2014, at which time the CSAPR program superseded it.

The following graph depicts the trend in NOx emissions from

EGUs for the entire nonattainment area:

Figure 5

- NO x Emissio ns from EGUs

– Entire Nonattainment Area

Electric Generating Units,

2003

- 2014

VOC RACT

The Cleveland

- Akron

- Lorain, OH area was required to adopt RACT for the following source categories under Section 182(b)(2) for the one

- hour standard and the 1 997 eight

- hour

ozone standard : (a) all VOC sources covered by Control Technique Guidelines ( C TGs) issued between November 15,

1990 and the date the C leveland area attained the one

- hour ozone standard; (b) all VOC sources covered by a CTG issued prior to No vember 15, 1990; and (c) all other major non

- CTG stationary sources in the C leveland area.39

U.S. EPA approved Ohio EPA’s V OC RACT rules on September 7, 1994 (59 FR 46182 ) , October 23, 1995 (60 FR 54308), April 25, 1996 (61 FR 18255 ), and July 28, 2009 (7 4 FR 37171)

.

RACT rules have been applied to all new sources locating in

Ohio since that time. RACT requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also ha s an active enforcement program to address violations discovered by field office staff. The Ohio RACT rules are found in OAC Chapter 3745

- 21 11

.

Gasoline Vapor Recovery Systems Section 182(b)(3) requires states to submit Stage II vapor recovery rules no la ter than November 15, 1992. The U.S. EPA partially approved and partially disapproved Ohio's SIP revision for implementation of Stage II on October, 20, 1994 (59 FR 52911). As stated in that rulemaking action, with the exception of paragraph 3745

- 21

- 09 (DD D)(5), U.S. EPA considers Ohio's Stage II program to fully satisfy the criteria set forth in the September 17, 1993, U.S. EPA guidance document for such programs entitled "Enforcement Guidance for Stage II Vehicle Refueling Control Programs." Furthermore, the September 17, 1993, guidance memorandum states that once onboard vapor recovery regulations are promulgated, the Stage II regulations are no longer applicable for moderate ozone nonattainment areas. The U.S. EPA promulgated onboard vapor recovery rules in February 1994. Therefore, pursuant to Section 202(a)(6) of the CAA, Stage II would no longer be required. However, some areas, including Ohio, retained Stage II requirements to provide a control method to comply with rate

- of

- progress emission

reducti on targets. Congress recognized that onboard refueling vapor recovery and Stage II would eventually become

redundant , and actually increase emissions, and provided the U.S. EPA authority to allow states to remove Stage II from their

SIPs after U.S. EPA fin ds that onboard refueling vapor recovery is in widespread use. On May 16, 2012, the U.S. EPA determined that onboard refueling vapor recovery technology is in widespread use throughout the motor vehicle fleet for purposes of controlling motor vehicle refue ling emissions. This action (77 FR 28772) also provided notice of an upcoming guidance document for states to use to prepare a SIP revision to remove or phase

- out Stage II controls. U.S. EPA published this

11 http://www.epa.state.oh.us/dapc/regs/3745

- 21/3745_21.html40

guidance on August 7, 2012 (EPA

- 457/B

- 12

- 001). The guidance noted that since Section 182(b)(3) requirements no longer applied, the only requirements for Stage II controls are

state SIPs (which includes Ohio, as noted above ) , Section 184(b)(2) for areas in the ozone transport region (does not apply

to O hio)

, and section 193 for any area that adopted Stage II controls prior to November 15, 1990 (does not apply to Ohio). In order to remove Stage II control requirements from the SIP, CAA Section 110(l) is required to be addressed. Ohio EPA

conducted this demonstration a nd submitted the SIP revision request to U.S. EPA on July 15, 2015

. This demonstration included a new requirement for the use of low permeation hoses which will provide even greater VOC emissions reductions in the

future.

Motor Vehicle I nspection and Maintenance Program U.S. EPA's final I/M regulations in 40 CFR Part 85 require the states to submit a fully adopted I/M program by November 15,

1993 under Section 182(b)(4) . U.S. EPA approved Ohio's enhanced I/M program (E

- Check), on April 4, 1995 (60 FR 16989) and January 6, 1997 (62 FR 646). The E

- C heck

program continues to be being implemented in this area.

In addition to the above, there are several measures beyond the CAA requirements that have been implemented in this area.

Tier II Emission Standards for Vehicles and Gasoline Sulfur

Standards

In February 2000

, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal,

automakers will b e required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules w ere phase d in

between 2004 and 2009. U.S. EPA has estimated that NO
x emission reductions were a pproxima tely 77 percent for

passenge r cars, 86 percent for smaller SUVs, light truc ks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans,

and heavier trucks. VOC emission reductions were

ap proximately 12 percent for passen ger cars, 18 pe rcent for smaller SUVs, light trucks, and min ivans, and 15 percent for larger SUVs, vans, and heavier trucks.41

Tier III Emission Standards for Vehicles and Gasoline Sulfur

Standards In March 2014, U.S. EPA finalized a federal rule to further strengthen Tier II vehicle emission and fuel standards. This rule will require automakers to produce cleaner vehicles and

refineries to make cleaner, lower sulfur gasoline. This rule will be phased in between 2017 and 2025. Tier III requires all passenger vehicles to meet an average standard of 0.03 gram/mile of NOx. Compared to Tier II, the Tier III tailpipe standards for light

- duty vehicles are expected to reduce NOx and VOC emissions by approximately 80%. Tier III vehicle

standards also include evaporative standar ds using onboard diagnostics that will result in a 50% reduction in VOC emissions compared to Tier II reductions. The rule reduces the sulfur content of gasoline to 10 ppm, beginning in January 2017.

Heavy

- Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low

- sulfur diesel fuel standards, which was phased in from 2004 through 2007. This rule applies to heavy

- duty gasoline and diesel trucks and buses.

This rule resulted in a 40 percent r eduction in NO
x from diesel trucks and buses, a large sector of the mobile sources NO
x inventory.

Clean Air Non

- road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non

- road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The

new standards cut emissions from non

- road diesel engi nes by more than 90 percent . Non

- road diesel equipment, as described

in th is rule, accounted for 47 percent of diesel particulate matter (PM) and 25 percent of NO
x from mobile sources nationwide.

Sulfur levels were reduced in non

- road diesel fuel by 99 percent

from previous levels, from appr oximately 3,000 parts per million (pp m ) to 15 ppm in 2009. New engine standards took effect, based on engine horsepower, starting in 2008.

Non

- road Spark

- Ignition Engines and Recreational Engine

Standards Effective in January 2003, this standard regulates NOx, VOCs, and carbon monoxide (CO) for groups of previously unregulated

non

- road engines. This standard applies to all new engines sold in the United States and imported after the standards went into effect. The standard applies to large spark

- ignition engines42

(forklifts and airport ground service equipment), recreational vehicles (off

- highway motorcycles and all

- terrain vehicles), and recreational marine diesel engines. When all of the non

- road spark

- ignition engines and recreational engine standards are fully implemented, an overall 80% r eduction in NOx, 72% reduction in VOC, and 56% reduction in CO emissions are expected by 2020.

Reciprocating Internal Combustion Engine Standards This new standard, effective in May 2010, regulates emissions of air toxics from existing diesel powered stat ionary reciprocating internal combustion engines that meet specific site rating, age, and size criteria. These engines are typically used at industrial facilities (e.g. power, chemical, and manufacturing plants) to generate electricity for compressors and pumps and to produce electricity to pump water for flood and fire control during emergencies.

The standard applies to stationary diesel engines: (1) that are located at a major source of air toxics emissions and that were installed prior to June 12, 2006; (2) used at major sources of air toxics, having a site rating of less than or equal to 500 horsepower and were constructed or reconstructed before June 12, 2006; and (3) used at major sources of air toxics for nonemergency purposes, having a site rating o f greater than 500 horsepower and were constructed or reconstructed before December 19, 2002.

Operators of existing engines were required to: (1) install emission control equipment that would limit air toxics up to 70% for stationary non

- emergency engines with a site rating greater than 300 horsepower; (2) perform emission tests to demonstrate engine performance and compliance with rule requirements; and (3) burn ultra

- low sulfur fuel in stationary non

- emergency engines with a site rating greater than 300 horsepower.

The engine standards took effect in 2013. According to U.S. EPA estimates, this rule has resulted in emission reductions from existing diesel

- powered stationary reciprocating internal combustion engines of approximately 1,000, 2,800, and 27,0 00 tpy of air toxics, fine particles (PM2.5), and CO, respectively.

Category 3 Marine Diesel Engine Standards This new standard, effective in June 2010, promulgated more stringent exhaust emission standards for new large marine diesel engines with per

- cyl inder displacement at or above 3043

liters (commonly referred to as Category 3 compression

- ignition marine engines) as part of a coordinated strategy to address emissions from all ships that affect U.S. air quality. These emission standards are equivalent to those adopted in the

amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). The emission standards apply in two stages: near

- term standards, for newly built engines, which took effect in 2011 a nd long

- term standards requiring an 80% reduction in NOx emissions that will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of diesel fuel with up to 1,000 ppm sulfur for use in Category 3 marin e vessels. The regulations generally forbid production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters unless operators achieve equivalent emission reductions in other ways.

U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreign flagged and in

- use vessels that are covered by MARPOL Annex VI. When this strategy is fully implemented in 2030, U.S. EPA estimates that NOx and PM2.5 emissions in the U.S. will be reduced by approximately 1.2

million tpy and 143,000 tpy, respectively.

Clean Air Interstate Rule (CAIR)/Cross State Air Pollution Rule (CSAPR) On May 12, 2005, U.S. EPA published the following regulation:

“Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (CAIR); Rev isions to Acid Rain Program; Revisions to the NOx SIP Call; Final Rule.” This rule established the requirement for states to adopt rules limiting the emissions of NOx and SO2 and provided a model rule for the states to use in developing their rules in orde r to meet federal requirements. The purpose of CAIR was to reduce interstate transport of PM2.5, SO2, and ozone precursors (NOx).

CAIR applied to any stationary, fossil fuel

- fired boiler or stationary, fossil fuel

- fired combustion turbine, or a generator with a nameplate capacity of more than 25 megawatt electrical (MWe) producing electricity for sale. This rule provided annual state caps for NOx and SO2 in two phases, with Phase I caps for NOx and SO2 taking effect in 2009 and 2010, respectively.

Phase II caps were to become effective in 2015. U.S. EPA allowed limits to be met through a cap and trade program if a state chose to participate in the program. SO2 emissions from44

power plants in the 28 eastern states, as well as Washington D.C subject to CAIR we re to be cut by 4.3 million tons from 2003 levels by 2010 and 5.4 million tons from 2003 levels by 2015.

NOx emissions were to be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 million tons by 2015. In response to U.S. EPA’s rulemaking, O hio submitted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009. The revised CAIR SIP was approved as a direct final action on September 25, 2009 (74 FR 48857). Ohio’ s rule incl uded annual and seasonal NOx trading programs, and an annual SO2 trading program. This rule required compliance effective January 1,

2009.

In July 2008, the D.C. Circuit court vacated CAIR and issued a subsequent remand without vacatur of CAIR in December 2008. The court then directed U.S. EPA to revise or replace CAIR in order to address the deficiencies identified by the court. On July 6, 2011, U.S. EPA finalized CSAPR as a replacement for CAIR. On August 21, 2012, the U.S. Court of Appeals for the D.C.

Circuit vacated CSAPR and directed U.S. EPA to continue administering CAIR “pending the promulgation of a valid replacement.” In a subsequent decision on the merits, the Court vacated CSAPR based on a subset of petitioners’ claims, but on April 29, 2014, t he U.S. Supreme Court reversed that decision

and remanded the case to the D.C. Circuit court for further proceedings. Throughout the initial round of D.C. Circuit proceedings and the ensuing U.S. Supreme Court proceedings, the stay remained in place and U. S. EPA has continued to implement CAIR. In order to allow CSAPR to replace CAIR in an equitable and orderly manner while further D.C. Circuit Court proceedings were held to resolve petitioner’s remaining claims, U.S. EPA filed a motion asking the D.C. Circ uit Court to lift the stay. U.S EPA also asked the court to toll all CSAPR compliance deadlines that had not passed as of the date of the stay order by three years. On October 23, 2014, the Court granted the U.S.

EPA’s motion. CSAPR became effective on Jan uary 1, 2015, for SO2 and annual NOx, and May 1, 2015 for ozone season NOx. Combined with other final state and U.S. EPA actions, CSAPR will reduce power plant SO2 emissions by 73% and NOx emissions by 54% from 2005 levels in the CSAPR region, which

includ es the states of Indiana, Kentucky, and Ohio.45

Oil and Natural Gas Industry Standards This new standard, issued on April 17, 2012, regulates VOC and

air toxic emissions from hydraulically fractured natural gas wells and also includes requirements for seve ral other sources of pollution in the oil and natural gas industry that were previously unregulated in the United States. U.S. EPA estimates that these standards will apply to approximately 11,400 new natural gas wells hydraulically fractured each year and an additional 1,400 existing natural gas wells refractured annually. When these standards are fully implemented in 2015, U.S. EPA estimates that VOC and air toxic emissions in the U.S. will be reduced by approximately 190,000 to 290,000 tpy and 12,000 to 20,000 tpy, respectively.

Mercury and Air Toxic Standards This new standard, effective in April 2012, regulates emissions of mercury, acid gases, and non

- mercury metallic toxic pollutants from new and existing coal and oil

- fired EGUs. U.S.

EPA estimates t hat this rule will apply to approximately 1,100

coal

- fired and 300 oil

- fired EGUs at 600 power plants in the U.S. According to U.S. EPA, most facilities will comply with these standards through a range of strategies, including the use of existing emission controls, upgrades to existing emission controls, installation of new pollution controls, and fuel switching.

Following promulgation of the rule, U.S. EPA received petitions

for reconsideration of various provisions of the rule, including requests to reco nsider the work practice standards applicable during startup periods and shutdown periods. U.S. EPA granted reconsideration of the startup and shutdown provisions as no opportunity to comment was provided to the public regarding the work practice requireme nts contained in the final rule. On November 30, 2012, U.S. EPA published a proposed rule reconsidering certain new source standards and startup and shutdown provisions in MATS. U.S. EPA proposed certain minor changes to the startup and shutdown provisions contained in the

2012 final rule based on information obtained in the petitions for reconsideration. On April 24, 2013, U.S. EPA took final action on

the new source standards that were reconsidered and also the

technical corrections contained in the Novem ber 30, 2012, proposed action. U.S. EPA did not take final action on the startup and shutdown provisions and, on June 25, 2013, added new information and analysis to the docket and reopened the public comment period for the proposed revisions. U.S. EPA

too k final action on the remaining topics open for reconsideration on November 19, 2014. The compliance date for existing46

sources was April 16, 2015, while the compliance date for new

sources was April 16, 2012.

On November 25, 2014, the U.S. Supreme Court a ccepted several challenges to the rules brought by the utility industry and a coalition of nearly two dozen states. On June 29, 2015, the

U.S. Supreme Court ruled that U.S. EPA did not properly account for compliance costs when crafting the MATS rule and

r emanded the decision to the D.C. Circuit Court for

reconsideration.

EGUs As discussed above, several federally enforceable changes at

EGUs have resulted in reductions in NOx emissions and will result in further reductions than projected

. Cleveland E lectr ic

I lluminating C o ., E astlake P lant in Lake County (OH) permanently shutdown in April of 2015 ; First Energy Generation, LLC Lake Shore facility in Cuyahoga County (OH) permanently shutdown in April of 2015 ; and First Energy Generation, LLC

Ashtabula Plant in Ashtabula County (OH) shutdown coal fired boilers in April of 2015 and December of 2015.

Together, these rules will substantially reduce local and regiona l sources of

ozone precursors.

Requirement 3 of 4 Acceptable provisions to provide for new sou rce review.

Background Ohio has a longstanding and fully implemented New Source Review (NSR) program. Thi s is addressed in OAC Chapter

3745

- 31 12 . The C hapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting program in OAC

rules 3745

- 31

- 01 to 3745

- 31

- 20. Ohio's PSD program was

conditi onally approved on October 10, 2001 (66 FR 51570 ) and

received final approval on January 22, 2003 (68FR 2909 ) by

U.S. EPA as part of the SIP

.

Demonstration Any facility that is not listed in the 20 08 13 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or

12 http://www.epa.state.oh.us/dapc/regs/3745

- 31/3745_31.html

13 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as required under CAA Section 182(a)(1).47

reconstruct without meeting all applicable NSR requirement s

. On ce the area is redesignated, Oh io EPA will implement NSR through the PSD program

.

Requirement 4 of 4

Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates through photochemical modeling

that the standard can be maintained wi thout one (1) or more control measure s.

Demonstration Ohio commits to maintaining the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to VOC and/or

NO
x sources, as requi red for maintenance of the ozone standard

in the Cleveland

- Akron

- Lorain, OH area , will be submitted to

U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal section and the Ohio Attorney

General’s Office , has the legal authority and nec essary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in the

Cleveland

- Akron

- Lorain, OH area.48



### CHAPTER SIX

CO NTINGENCY MEASURES

CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4 A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration

Ohio hereby commits to review its maintenance p lan eight (8) years after redesignation, as required by Section 175(A) of the

CAA

.

Requirement 2 of 4 A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the event that future vio lations of the am bient standard occur.

Demonstration Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response:

A warning level r esponse shall be prompted whenever an annual (1

- year) fou rth high monitored value of 79 ppb occurs in a single

ozone season within the maintenance area. A warning level

r esponse will consist of a study to determine whether the ozone value indicates a trend toward higher ozone values or whether emissions appear t o be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing for implementation as well as

economic and social considera tions. Implementation of

neces sary controls in response to a warning level r esponse trigger will take place as expeditiously as possible, but in no

event later than 12 months from the conclusion of the most recent ozone season ( October 3 1 ).

Shoul d it b e determined through the warning l evel study that action is necessary to reverse the noted trend, the procedures

for control selection and implementation outlined under “ action

l evel response ” shall be followed.49

Action Level Response :

An a ction l evel r e sponse shall be prompted whenever a two

- year average fourth high monitored value of 76 ppb or greater occurs within the maintenance area. A violation of the standard (three

year average fourth high value of 85 ppb or greater) shall also prompt an action l evel response. In the event that the a ction

l evel is triggered and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropolitan planning organizati on or regional council of governments, will

determine additional control measures needed to assure future

attainment of the NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the close of the ozone season that prompted the a ction l evel. Ohio EPA will also consider the timing of an a ction l evel t rigger and determine if additional, significant new regulations not currently included as part of the maintenance provisio ns will be implemented in a timely manner and will constitute our response

.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will

include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or S tate level, and that

measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to

return the area to attainment.

Requirement 3 of 4 A list of potential contingency measures that would be implemented in such an

event.

Demonstration Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and

effective at the t ime the selection is made. The select ion of

measures will be based on cost

- effectiveness, emission reduction potential, economic and social considerations or other50

factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested a nd affected persons in the maintenance area prior to selecting app ropriate contingency

measures. Because it is not possible at this time to determine

what control measure s will be appropriate at an unspecified time in the future, the list of contingency m easures outlined below is

not exhaustive

.

1) Tighten VOC RACT on existing sources covered by U.S.

EPA Control Technique Guidelines issued after the 1990

CAA

.

2) Apply VOC RA CT to smaller existing sources.

3) One or more transportation control measures sufficie nt to

achieve at le ast half a percent reduction in actual area wide VOC emissions. Transportation measures will be selected from the following, based upon the factors listed above after consultation with affected local governments:

a) t rip reduction program s, including, but not limited to, employer

- based transportation management plans, area wide rideshare programs, work

sche dule changes, and telecommuting ;

b) t raffic flow and t ransit improvements ; and

c) o ther new or innovative transportation measures not yet i n widespread use that affect ed local governments deem appropriate.

4) Alternative fuel and diesel retrofit programs for fleet vehicle operations.

5) Require VOC or NO
x emission offsets for new and modified major sources.

6) Increase the ratio of emission offsets required for new

sources.

7) Require VOC or NO
x controls on new minor sources (less than 100 tons).

8) Adopt additional NOx RACT for existing combustion

sources.51

No contingency measure shall be implemented without providing the opportunity for full public pa rticipation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.

Requirement 4 of 4

A list of VOC and NO
x sources potentially subject to future additional control requiremen t s.

Demonstration The following is a list of VOC and NO
x sources potentially subject to

future controls.

NO
x RACT

 EGUs

 other sources less than 100 tons per year

VOC RACT

 architectural and industrial maintenance coatings

 automobile refinishing shops

 cold cleaner degreasers

 synthetic organic compound manufacturing

 organic compound batch processes

 wood manufacturing

 industrial wastewater

 aerospace in dustry

 plastic parts coating

 volatile organic liquid storage

 industrial solvent cleaning

 offset lithography

 i ndustrial surface coating

 other sources greater than 50 tons per year52



### CHAPTER SEVEN

MODELING ANALYSIS

Summary of Modeling Results for National Emission Control Strategies in

Final Rulemakings

Although U.S. EPA’s Redesignation Guidance does not require modeling for

ozone nonattainment areas seeking redesignation, extensive modeling has been performed covering the Cleveland

- Akron

- Lorain, OH area to determine the effect of national emission control strategies on ozone levels. This area

includes Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and

Summit Counties in Ohio. These modeling analyses determined that this area was significantly impacted by ozone and ozone precursor transport and regional NOx reductions will help the area attain the 2008 eight

- hour ozone

standard of 75 ppb in this area.

U.S. EPA Modeling Analysis for Interstate Transport “Good Neighbor”

Provision

U.S. EPA conducted modeling for the Interstate Transport “Good Neighbor”

Provision. This analysis was performed in 2014 and included in the “Air Quality Modeling Technical Support Document for the 2008 Ozone NAAQS Transport Assessment” to assist states in developing “Good Neighbor SIPs,” as required by the CAA to address interstate transport of air pollution that affects

downwi nd states' ability to attain and maintain the 2008 eight

- hour ozone

standard

. Some of the major federal emission strategies included in the modeling are: National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Reciprocating Internal Combust ion Engines (RICE) and cement manufacturing plants, the Boiler Maximum Achievable Control Technology (MACT) rule, the Energy Independence and Security Act (EISA)

renewable fuel standard mandate, New Source Performance Standards (NSPS) for VOC controls, the Mobile Source Air Toxics rule, Tier III Emission Standards for Vehicles and Gasoline Sulfur Standards, Emission Standards for Locomotives and Marine Compression

- Ignition Engines, and the Nonroad Spark

- Ignition Engines and Recreational Engine Standards.

T his modeling was conducted to identify monitoring sites that may have difficulty attaining the 2008 eight

- hour o zone standard in 2018 and identify states that were contributing to attainment issues at a given monitoring site. The air quality model used for this rulemaking was the Comprehensive Air Quality Model with Extensions (CAMx) version 6.10. The modeling domain consisted of a 12 kilometer (km) x 12 km coarse grid covering the continental

United States and portions of Canada and Mexico and 25 vertical layers from the surface up through the troposphere to a height of 50 millibars of pressure.53

Base year 2011 emissions were modeled. Meteorology from 2011 was created using the Weather Research Forecasting (WRF) Model version 3.4 and was

used for the base ca se and projected year modeling runs. More detailed information on the CAMx input file and additional data used for the photochemical modeling can be found in U.S. EPA’s “Air Quality Modeling Technical Support Document for the 2008 Ozone NAAQS Transport

Ass essment,” dated January 2015.

Table 3 2 shows the results of U.S. EPA’s “Good Neighbor” Provision modeling

for ozone impacts at the ozone monitors in the Cleveland

- Akron

- Lorain, OH area. The monitor identification number, county, and the 2009

– 2013 eight

hour ozone base period average design values that were used to calculate 2018 projected average design values. Note that the 2009

– 2013 average design values were calculated by averaging the three 3

- year design values

from 2009

– 2011, 2010

– 2012, and 201 1

– 2013.

Model results are used in a relative rather than absolute sense. Relative use of

the model results calculates the fractional change in maximum concentrations

based on two different emission scenarios, 2011 NEI emissions and 2018 projected emissi ons for this exercise. This fractional change, also known as a relative response factor (RRF), can be applied to each monitor’s average base period design value to determine ozone impacts. This approach differs from using the absolute or actual modeled res ult, which may show under

- or over

predictions with the actual monitored values. The 2009

– 2013 average design values were multiplied by the corresponding RRF to determine all 2018 projected average design values.54

T able 3 2

- Comparison of Cleveland

- Akron

- Lorain , OH Area Average

Design Values with U.S. EPA “Good Neighbor” Provision Modeling Results ( ppm )

Monitor ID County Monitored

Average Design

Value 2009

- 2013 U.S. EPA

Projected

Average
Design Value

2018

39

- 007

- 1001 Ashtabula 0.0773 0.0668

39

- 035

- 003 4 Cuyahoga 0.0777 0.0639

39

- 035

- 0060 Cuyahoga 0.0685 0.0560

39

- 035

- 0064 Cuyahoga 0.0700 0.0602

39

- 035

- 5002 Cuyahoga 0.0767 0.0630

39

- 055

- 0004 Geauga 0.0747 0.0653

39

- 085

- 0003 Lake 0.0800 0.0649

39

- 085

- 0007 Lake 0.0717 0.0584

39

- 093

- 0018 Lorain 0.071 7 0.0586

39

- 103

- 0004 Medina 0.0690 0.0607

39

- 133

- 1001 Portage 0.0683 0.0604

39

- 153

- 0020 Summit 0.0720 0.0642

Due to the differences in the base period 2009

– 2013 average design values

and more current average design values for all of the Cleveland

- Ak ron

- Lorain,

OH area ozone monitors, a comparison of these values, as well as the 2018 projected average design values taken from the “Good Neighbor” Provision was made, and are presented in Table 3 3

. The current average design values

were calculated by ave raging the three 3

- year design values from 2010

– 2012, 2011

– 2013, and 2012

– 2014 , and 2013

- 2015

.

Comparison of the 2009

– 2013 average design values wi th current 3

- year

average design value s for all ozone monitors in the Cleveland

- Akron

- Lorain,

OH a rea show th at current average design values are below the average eight

hour ozone design values for 2009

– 2013

.

Based on the 2009

– 2013 average design values, the 2018 projected average design values modeled well below the 2008 eight

- hour ozone standa rd of 75 ppb . With the exception of the Cuyahoga monitor (39

- 035

- 0064) and Lake County monitor s (39

- 085

- 0003 and 39

- 085

- 0007) , if the modeling was

conducted with the 2010

– 2014 average design values, the 2018 projected average design values would be lower than the current results, further re

enforcing maintenance of the standard. Modeling conducted using the 2011

- 2015 average design values would result in 2018 projected design values at all monitors well below the current results, again further reinforcin g maintenance

of the standard. For the highest monitor in the area ( Lake County monitor 39

-55

085

- 0003 ) , the 2018 projected average design value is 0.0 649 ppm, well below

the level of the 2008 eight

- hour ozone standard that demonstrates attainment (0.0757 ppm )

.

T able 3 3

- Comparison of C leveland

- Akron

- Lorain , OH Area Current

Design Values with U.S. EPA “Good Neighbor” Design Values ( ppm )

Monitor ID County Monitored

Average
Design Value

2009

- 2013 Monitored

Average
Design Value

2010

- 2014 Monitored

Average
Desig n Value

2011

- 2015 U.S. EPA

Projected

Average
Design Value

2018

39

- 007

- 1001 Ashtabula 0.0773 0.0753 0.0720 0.0668

39

- 035

- 0034 Cuyahoga 0.0777 0.0777 0.0740 0.0639

39

- 035

- 0060 Cuyahoga 0.0685 0.0673 0.0647 0.0560

39

- 035

- 0064 Cuyahoga 0.0700 0.0707 0.0673 0.0602

39

- 035

- 5002 Cuyahoga 0.0767 0.0757 0.0710 0.0630

39

- 055

- 0004 Geauga 0.0747 0.0737 0.0700 0.0653

39

- 085

- 0003 Lake 0.0800 0.0803 0.0770 0.0649

39

- 085

- 0007 Lake 0.0717 0.0723 0.0700 0.0584

39

- 093

- 0018 Lorain 0.0717 0.0717 0.0677 0.0586

39

- 103

- 00 04 Medina 0.0690 0.0690 0.0667 0.0607

39

- 133

- 1001 Portage 0.0683 0.0673 0.0640 0.0604

39

- 153

- 0020 Summit 0.0720 0.0680 0.0637 0.0642

LADCO Modeling for Eight

- Hour Ozone Standard

The LADCO performed photochemical modeling for ozone, which used the

most recent emissions inventories and model updates. This modeling was performed to support attainment demonstrations for the five

- state LADCO region. The photochemical model used by LADCO and Indiana for the eight

hour ozone standard analysis is CAMx version 6.11, developed by Environ. This model has been accepted by U.S. EPA as an approved air quality model for regulatory analysis and attainment demonstrations. Requirements of 40 CFR 51.112, as well as the “Guidance on the Use of Models and Other Analyses in Attainment Demonstrations for the 8

- hour Ozone NAAQS” (EPA

454/R

- 05

- 002, Oct. 2005), are satisfied with the use of CAMx for attainment demonstrations. Meteorology from 2011, as well as 2011 base year emissions (based on legally enforceable emission control s required by consent decrees, state rules, or permit), was used to conduct this modeling. The base period

average design values for attainment purposes were calculated from the periods 2009

– 2011, 2010

– 2012, and 2011

– 2013. The projected year

modeled was 2018.56

Table 34 shows that modeled ozone concentrations in the Cleveland

- Akron

Lorain, OH area for 2018 will be below the eight

- hour ozone standard of 75 ppb . As shown in Table 3 2 above, the current 201 1

– 201 5 average design

values decreased from the 2009

– 2013 average design values , thus the projected average design values would be lower than the LADCO modeling results using the latest average design values. For Lake County monitor 39

- 085

- 0003 , the projected average design value was well below the 20 08 eight

hour ozone standard at 0.0 644 ppm. I f the LADCO modeling was performed using the lower 201 1

– 201 5 average design value, it is expected that the 2018 projected average design value would be further below the standard for the Lake County monitor , a s well as all other monitors in the area

.

Table 34

- LADCO’s Modeling Results for the C leveland

- Akron

- Lorain

, OH Area ( ppm )

Monitor ID County Monitored

Average
Design Value

2009

- 2013 Monitored

Average
Design Value

2010

- 2014 Monitored

Average
Design Value

2011

- 2015 LADCO

Projected
Average Design

Value 2018

39

- 007

- 1001 Ashtabula 0.0773 0.0753 0.0720 0.0663

39

- 035

- 0034 Cuyahoga 0.0777 0.0777 0.0740 0.0625

39

- 035

- 0060 Cuyahoga 0.0685 0.0673 0.0647 0.0547

39

- 035

- 0064 Cuyahoga 0.0700 0.0707 0.0673 0.0612

39

- 035

- 5002 Cuyahoga 0.0767 0.0757 0.0710 0.0659

39

- 055

- 0004 Geauga 0.0747 0.0737 0.0700 0.0672

39

- 085

- 0003 Lake 0.0800 0.0803 0.0770 0.0644

39

- 085

- 0007 Lake 0.0717 0.0723 0.0700 0.0586

39

- 093

- 0018 Lorain 0.0717 0.0717 0.0677 0.0579

39

- 103

- 0004 Medina 0 .0690 0.0690 0.0667 0.0632

39

- 133

- 1001 Portage 0.0683 0.0673 0.0640 0.0623

39

- 153

- 0020 Summit 0.0720 0.0680 0.0637 0.0660

Summary of Existing Modeling Result s

U.S. EPA and LADCO modeling shows that national emission control measures will bring the Cl eveland

- Akron

- Lorain, OH ar ea into attainment of the 2008 eight

- hour ozone NAAQS by 2018, if not earlier. Rulemakings to be implemented in the next several years will provide assurance that air quality

will continue to meet the standard into the future. U. S. EPA’s modeling support

for the Interstate Transport “Good Neighbor” Provision show future year design

values for the Cleveland

- Akron

- Lorain, OH area will attain the ozone standard with 2018 projected average design values below the 2008 eight

- hour ozone standard of 75 ppb . In addition, LADCO’s modeling results continue to show 2018 projected average design values below the eight

- hour ozone standard

.57

U.S. EPA and LADCO modeling demonstrates that the Cleveland

- Akron

Lorain, OH ozone nonattainment area will attain the 2008 eight

- hour ozone standard. Future national and local emission control strategies will ensure that the area’s attainment will be maintained with an increasing margin of safety

over time.58



### CHAPTER EIGHT

PUBLIC PARTICIPATION

Ohio published n otification for a public hearing and solicitation for publi c comment concerning the draft redesignation petition and maintenance p lan in

the widely distributed county pub lications

.

The p ublic hearing to receive comments on the redesignation re quest was he ld

on June 27 , 201 6 at 2110 East Aurora Road, Twinsburg, Ohio 44087

. T he public comment peri od close d on June 27 , 201 6

. No testimony was provided at the public hearing and no c omments were received during the public comment period. Appendix C includes a copy of the public notice and transcript from the public hearing and comment period.59



### CHAPTER NINE

CONCLUSIONS

The C leveland

- Akron

- Lorain

, OH ozone nonattainment area has attained the

2008 NAAQS for ozone and complied with the applicable provisions of the

1990 Amendments to the CAA regarding redesignations of ozone

nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepa red a redesignation request and maintenance p lan that meet the requirement s of Section 110 (a)(1) of the 1990 CAA

.

Based on this presentation, the C leveland

- Akron

- Lorain

, OH ozone nonattainment area meets the requirements for redesignation under the CAA

and U.S. EPA guidance. Ohio has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures. Furthermore, because this area is subject to significant transport of pollutants, significant regional NO
x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of O hio hereby requests that the C leveland

- Akron

- Lorain

, OH ozone nonattainment area be redesignated to attainment simultaneously with U.S.

EPA approval of the maintenance p lan provisions contained herein. In addition, the State of Ohio requests that this maintenance plan satisfy the requirements of CAA Section 175A (b), for subsequent plan revisions required for areas redesignated for the eight

- hour ozone standard

.This page left intentionally blank