Reply to Attn Of: AWT-107

MEMORANDUM

DATE: November 18, 2009

SUBJECT: Technical Support Document fo r the Vancouver Portion of the PortlandVancouver (Pdx/Van) Air Quality Main tenance Area, 8-hour Ozone Section 110(a)(1) Maintenance Plan.

FROM: Krishna Viswanathan, Environmental Scientist

TO: Docket EPA-R10-OAR-2007-0112

TABLE OF CONTENTS

I. Purpose II. Background III. Review of the Maintenance Plan IV. Evaluation V. Conclusion VI. Recommended Agency Action

I. Purpose

This technical support document (TSD) provide s information supporting EPA’s proposed action to approve the State of Washi ngton’s January 17, 2007 request to approve the Section 110(a)(1) Ozone Maintenance Plan and supporting rules. The submittals are specifically for the Vancouver portion of the Portland-Vancouver (Pdx/Van) Ai r Quality Maintenance Area (AQMA). The Section 110(a)(1) Maintenance Plans for this ar ea demonstrates how the State of Washington will maintain compliance with the 1997 8-hour Ozone National Ambient Air Quality Standards (NAAQS).

On May 22, 2007, EPA received a request from the Oregon Department of Environmental Quality (ODEQ), to approve a SIP revision pertai ning to the Maintenance Plan for the Portland Portion of the Pdx/Van AQMA, and the Salem Keizer Area Transpor tation Study Air Quality Area (SKATS AQA), under section 110 of the C AA. That submission by the ODEQ will be acted upon concurrently with this action as they both pertai n to the Pdx/Van Air Quality Maintenance Area.

The 110(a)(1) Maintenance Plan for this area m eets the Clean Air Act (CAA) requirements and demonstrates that the Vancouver portion of the Pdx/Van AQMA will be able to remain in2 attainment for 1997 and 2008 Ozone NAAQS through 2015. Based on my review, I am recommending full approval of the proposed Maintenance Plan and implementing regulations.

II. Background

Ground-level ozone is not emitted directly by so urces. Rather, emissions of volatile organic compounds (VOCs) and nitrogen oxides (NOx) react in the presence of sunlight to form groundlevel ozone. The air pollutants, VOCs and NOx, ar e referred to as precursors of ozone. The Clean Air Act (CAA) establishes a process for air quality management through the attainment and maintenance of the NAAQS.

On March 3, 1978 (43 FR 8961), the Portland-Van couver (Pdx/Van) Interstate Area consisting of the southern portions of Clark County, Wash ington and portions of Multnomah, Clackamas, and Washington Counties in Oregon, was design ated an ozone nonattainment area under the 1977 Clean Air Act. The Interstate designa tion was warranted as the Portland, OregonVancouver, Washington Interstate Urban Area shares a common ai r shed and common air quality problems. 1 On November 15, 1990, the CAA was amended (42 U.S.C 7401-7671(q)) and Section 107(d)(1)(C) provided that designations occurred by operation of law for areas that had been designated nonattainment before enactmen t of the amendments. In the 1990 amendments, the Pdx/Van Interstate nonattainment area was classified as a marginal 1-hour ozone nonattainment area (Section 181(a)(1) of the CAA).

On May 19, 1997, EPA redesignated the Pdx/Van Inte rstate Nonattainment Area to attainment for the 1-hour ozone air quality standard a nd approved a Maintenance Plan (62 FR 27204). On July 18, 1997, EPA revised the ozone NAAQS an d established a new standard of 0.08 ppm averaged over eight hours and temporarily vacate d the 1-hour standard. No violations of the 1997 8-hour ozone standards have been reported in this AQMA. 2

In 2002, EPA began the process to designate areas under the 1997 8-hour ozone standard. On April 30, 2004 (69 FR 23858), EPA designated a nd classified areas for the 8-hour ozone NAAQS. The Carus Site ozone monitor shows th e highest reading in the area with a 2005-2007 design value of 0.065 ppm; the area remains in attainment with the 1997 8-hour ozone NAAQS.

EPA’s Phase 1 Implementation Rule for the 8-ho ur ozone standard was published on April 30, 2004 (69 FR 23951, 23998). 40 CFR 51.905 sets fort h requirements for anti-backsliding purposes for areas designated attainment for th e 8 hour standard. These provisions require such areas to submit a 10 year Mainte nance Plan under section 110(a)(1 ) of the CAA, if they were also a nonattainment or an attainment/unclassif iable area with a section 175A Maintenance Plan, under the ozone standard. The Maintenance Plan n eeds to demonstrate that the area will maintain the standard for 10 years after designation in accordance with section 110(a)(1) of the CAA. EPA specified that even though the 1-hour ozone standard had been revoked, the 1-hour ozone NAAQS designations and classifica tion statuses were retained as of the effective date of designation for the 8-hour NAAQS, for purposes of anti-backsliding regulations (40 CFR 51.905). Anti-backsliding regulations apply even after revocati on of the 1-hour ozone NAAQS.

1 Letter from Clark L. Gaulding, Chief Air Programs Branch, US EPA Region 10 to Pete r Hildebrandt, Assistant Director, Office of Air Programs, State of Wa shington, dated June 12, 1978.
2 The last exceedance of the 1-hour ozone standard at the Carus Site in Portland oc curred in 1998 when the 1-hour ozone standard was temporarily revoked so the 1-hour ozone contingency plan was not triggered.3 On December 22, 2006, the U.S. Court of Appeals fo r the District of Columbia Circuit vacated EPA’s Phase 1 Implementation Rule for the 8-hour Ozone Standard (69 FR 23951, April 30, 2004). On June 8, 2007, in South Coast Air Quality Management Dist. v. EPA, Docket No. 04- 1201, in response to several petitions for rehearing, the DC Circuit clarified that the Phase 1 Rule was vacated only with regard to those parts of the rule that ha d been successfully challenged – the Phase 1 Rule provisions relate d to classifications for areas cu rrently classified under subpart 2 of Title I, Part D of the CAA. The June 8 decision reaffirmed the December 22, 2006, decision that EPA had improperly failed to retain measur es required for areas that were previously designated nonattainment for the 1-hour standard and the anti -backsliding provisions of the regulations. That decision does not affect EPA’s ability to act on this submission.

On January 17, 2007, the Washington State Depa rtment of Ecology (Ecology) submitted for approval under section 110 of the CAA a revi sed 8-hour ozone Maintenance Plan for the Vancouver Portion of the Portland-Vancouver AQMA. This Plan was developed by the Southwest Clean Air Agency (SWCAA) w ith collaboration from ODEQ and Ecology. Throughout this document the submitting agency is referred to as Ecology, recognizing that air quality management in this area is shared between Ecology and the SWCAA.

The Plan demonstrates how Ecology intends to maintain the 1997 and 2008 8-hour ozone NAAQS. The proposed Maintenance Plan cont ains a base-year inventory for 2002 and demonstrates that emissions will not be grea ter than the base year in 2015. The proposed Maintenance Plan indicates the Plan’s progress will be tracked and identifies measures that would be available to promptly correct any NAAQS violation. Ecology’s SIP submittal meets the CAA requirements for SIP submittals under CAA Section 110(a)(1). Additionally, Ecology’s submittal also meets the requireme nts of CAA 110(l) and CAA 193.

III. Review of the Maintenance Plan

A. What are the components of a section 110(a)(1) 8-hour ozone Maintenance Plan?

CAA Section 110(a)(1) requires states to s ubmit plans to EPA which provide for the implementation, maintenance and enforcement of NAAQS standards in each air quality control region with the state. On May 20, 2005, EPA issued guidance that applie s to areas that are designated as unclassifiable/a ttainment for the 8-hour ozone standard. The purpose of that document is to provide guidance on the maintena nce requirements in section 110(a)(1) of the CAA, and provide guidance to th e states in the development of a SIP. It indentifies five components of an 8-hour ozone Maintenance Plan:

1. Attainment Inventory – The attainment inventory should be based on actual “typical summer day” emissions of volatile organic compounds ( VOCs) and nitrogen oxides (NOx) for a 10-year maintenance period. For purposes of an attainme nt emissions inventory, the state must choose any one of the three years on which the 8-hour ozone attainment designation was based. As many areas are already required to develop an inventory for the 2002 under EPA’s Consolidated Emissions Reporting Rule (67 FR 39602), EPA reco mmends that areas use that year as the attainment emission inventory base year fo r the section 110(a)(1) Maintenance Plan.

2. Maintenance Demonstration – The submission should demonstrate how the area will remain in compliance with the 8-hour oz one standard for a period of 10 years following the effective4 date of designation as unclassifiable/attainment. If the effective date of the area’s designation for the 8-hour NAAQS was June 15, 2004, the Maintena nce Plan must project attainment for 2014 or beyond.

A typical method that areas have used to dem onstrate that an area will maintain the 1-hour standard has been to use the attainment inventor y and to show that future emissions of ozone precursors will not exceed those levels. Howeve r, in areas where transport of precursor emissions from an area outside a jurisdiction is a factor to ozone levels, more sophisticated analysis using dispersion models may be require d to demonstrate maintenance of the standard.

3. Ambient Air Quality Monitoring - The state should continue to operate air quality monitors in accordance with 40 CFR Part 58 to verify maintenance of the 8-hour ozone standard.

4. Contingency Plan – The state should develop measures so that in the event of a violation of the 8-hour ozone NAAQS, the measures can be imple mented as expeditiously as practicable after the violation.

5. Verification of Continued Attainment – The state should indicate how it intends on tracking the progress of the Maintenance Plan. This is necessary because emissions projections for the maintenance demonstration depend on assumptions of point, area, and mobile source growth.

B. How has the state addressed the componen ts of a section 110(a)(1) 8-hour ozone Maintenance Plan?

1. Attainment Inventory – Ecology has provided a comprehensive and current emissions inventory for VOCs, NOx, and CO, using 2002 as a base year. The effective year of the 8-hour ozone initial designation was 2004; Ecology projected emissions for 10 years or beyond from the effective date of the initial designation. C onsequently, Ecology developed an emissions inventory for ozone precursors for the year 2002 and 2015. In the Maintenance Plan, Ecology included information on anthropogenic and biogen ic sources of ozone precursors, VOCs and NOx (e.g., “Point sources,” “On-road sources,” “Nonroad sources”, “b iogenic sources”, and “area sources”). The tables below show the VOCs, NOx, and CO attainment emissions inventory for 2002.5 Table 1: Vancouver Area 2002 Atta inment Inventories (lb/day)

Vancouver-Area 2002 Attainment Inventory Typical Summer Day, lb/day (Clark County)

2002 2002 2002 Source Type VOC NO x CO AREA 18,014 665 3,912 BIOGENIC 79,417 965 NONROAD 15,374 23,222 228,078 ON-ROAD 38,315 50,495 397,983 POINT 3,572 6,089 3,803 Total 154,692 81,436 633,776

Figure 1

Vancouver Area 2002 VOC Attainment Inventory

AREA 12%

BIOGENIC

51% ON-ROAD

25% POINT
2%

NONROAD

10% AREA BIOGENIC NONROAD ON-ROAD POINT Vancouver Area
2002 NO x Attainment Inventory

ON-ROAD

62% BIOGENIC
1%
NONROAD

29% AREA 1% POINT
7%

AREA BIOGENIC NONROAD ON-ROAD POINT Vancouver Area 2002 CO Attainment Inventory

ON-ROAD

62% BIOGENIC
0% POINT
1% AREA 1% NONROAD
36%

AREA BIOGENIC NONROAD ON-ROAD POINT

The 2002 Consolidated Emissions Reporting Rule (CERR) emissions data submitted by Ecology and SWCAA to EPA’s National Emission Inventor y (NEI) were used as the basis for the 2002 attainment year inventory. The Technical Appe ndices submitted with Ecology’s Maintenance Plan contain more detailed information for each sector of the emission inventories.

The Technical Appendices submitted with Ecology’s Maintenance Plan contain more detailed information for each sector on the emissions i nventories. Emissions for all source categories were calculated following EPA guidance and are properly documented in the Appendix 3 of the proposed Maintenance Plan. This component of the Maintenance Plan m eets the requirements for attainment inventories under Section 110(a)(1) of the CAA.

2. Maintenance Demonstration – The proposed Maintenance Plan must demonstrate maintenance to 2014 or beyond, as the effective date of designations for this area for the 8 hour ozone NAAQS is 2004. This proposed Maintenan ce Plan meets this criterion by projecting emissions to 2015.

Ecology developed two different gr owth scenarios for major industr ial (point) sources. The first growth scenario (called “2015 Projection”) reflects the 2002 estimate of actual industrial emissions, increased by regional employment proj ections for that sector. The second growth scenario (called “2015 Maintenance Demonstration” ) represents a very conservative estimate of possible future year emissions and is used in maintenance demonstration for the Maintenance Plan. The 2015 Maintenance Demonstration refl ects maximum “legally allowable” emission levels currently permitted for existing indus try, plus the emissions growth allowance reestablished for new industry growth. It is to be noted that the approve d Maintenance Plan for this area (62 FR 27204) included an industrial em issions growth allowance. The current plan continues to use this approach to manage industrial emissions growth and these growth6 allowances were included in the 2015 ozone ma intenance demonstrations. The growth allowance for point sources amounts to 411 tons VOC and 1,313 tons of NOx in the Vancouver, Washington portion of the Portland-Vancouver AQMA. Section 4.2.2.1 of this Maintenance Plan, Requirements for New Sources in a Maintenance Plan Area, explains how the growth allowance will be allocated to industrial facilities.

Although Table 3 indicates that the total future emissions are projected to decrease during the 10-year maintenance period, it is important to note that the formation of ozone is dependent on a number of variables which cannot be estimated by emissions growth and reduction calculations alone. Other variables include w eather and the transport of ozone precursors from areas outside of the State of Washington. As the Pdx/Van Inte rstate Urban Area shar es a common airshed and common air quality problems 3 , examining the effects of transport of Ozone precursors from the Portland side of the AQMA is necessary. In orde r to demonstrate continued maintenance, a state may utilize more sophisticated tools such as di spersion modeling; the State of Washington did use modeling to assess the comprehensive im pacts of growth through 2015 on air quality.

Figure 2

Vancouver 2002 and 2015 Emission projections used for Maintenance Demonstration in lbs/day

Vancouver Area VOC Emissions

0 100,000 200,000Lbs per day

POINT 3,572 3,780 9,682

ON-ROAD 38,315 16,026 16,026

NONROAD 15,374 9,339 9,339

BIOGENIC 79,417 79,417 79,417

AREA 18,014 21,860 21,860 2002 Actual 2015 Growth Projection 2015 Maintenance Demonstration Vancouver Area NOx Emissions

0 40,000 80,000 120,000Lbs per day

POINT 6,089 6,197 22,965

ON-ROAD 50,495 19,482 19,482

NONROAD 23,222 15,183 15,183

BIOGENIC 965 965 965

AREA 665 786 786 2002 Actual 2015 Growth Projection 2015 Maintenance Demonstration

3 Letter from Clark L. Gaulding, Chief Air Programs Branch, US EPA Region 10 to Peter Hildebrandt, Assistant Director, Office of Air Programs, State of Washington, dated June 12, 1978.7 Table 2

Vancouver Area 2015 Maintenance Demonstr ation, Typical Summer Day, lb/day Clark County

Vancouver Area 2015 Maintenance Demonstration Typical Summer Day, lb/day Clark County

2015 2015 2015 Source Type VOC NO x CO AREA 21,860 786 5,337 BIOGENIC 79,417 965 0 NONROAD 9,339 15,183 271,651 ON-ROAD 16,026 19,482 159,167 POINT 9,682 22,965 3,780 Total 136,323 59,381 439,935

Figure 3

Vancouver Area 2015 VOC Maintenance Demonstration

BIOGENIC

58% ON-ROAD

12% POINT 7% AREA 16%

NONROAD

7%

AREA BIOGENIC NONROAD ON-ROAD POINT Vancouver Area 2015 NO x Maintenance Demonstration

NONROAD

26%

ON-ROAD

33% AREA 1% BIOGENIC 2% POINT 38%

AREA BIOGENIC NONROAD ON-ROAD POINT Vancouver Area 2015 CO Maintenance Demonstration

NONROAD

62% BIOGENIC

0% AREA 1% POINT 1%

ON-ROAD

36%

AREA BIOGENIC NONROAD ON-ROAD POINT

Table 3

V ancouver Area VOC and NOx Emissions (lb/day), % Change 2002-2015 (Clark County) --- VOC, lbs per day --- --- NO X , lbs per day ---
2015 2015 Source 2002 Maintenance % Source 2002 Maintenance % Type Actual Demonstration Change Type Actual Demonstration Change
AREA 18,014 21,860 21.3% AREA 665 786 18.2% BIOGENIC 79,417 79,417 BIOGENIC 965 965 NONROAD 15,374 9,339 -39.3% NONROAD 23,222 15,183 -34.6% ON-ROAD 38,315 16,026 -58.2% ON-ROAD 50,495 19,482 -61.4% POINT 3,572 9,682 171.0% POINT 6,089 22,965 277.2%

---------- ---------- ---------- ---------- 154,692 136,323 81,436 59,381

The submissions support the conclusion that Vancouve r’s area on-road emissions are expected to decrease significantly: 58% le ss VOC emissions and 61% less NO x emissions, primarily due to implementation of federal motor vehicle em ission and fuel standards and continuing implementation of the vehicle inspection pr ogram. Non-road emissions also show an approximate 35% decrease in NO x and 39% reduction in VOC emissi ons due to the phase-in of federal emission and fuel standards. The eventu al shift from Stage II vapor recovery at gas stations to on-board canisters in cars is reflected in the 2015 m odeling projections and8 maintenance demonstration of this plan. Point source “actual” emissions are not expected to change significantly. The bar chart above show s the “actual” emissions in the 2002 attainment inventory, the 2015 growth projection and the “all owable” emissions with the growth allowance used in the 2015 Maintenance Demonstration. This demonstrates that the net VOC emissions are lower by about 13% and NOx emissions lower by about 37% in 2015 compared to 2002 levels. Point Sources, with the growth allowance emissi ons included show the greatest increase with onroad mobile sources showing the greatest decrease.

Ecology’s submissions summarize the results of dispersion modeling study performed for the Pdx/Van Maintenance Area in 2004 by the Washi ngton State University (WSU) (see table and chart below). For further details of the st udy see Appendix 4 - Modeling and Attainment Demonstration, of the Ecology SIP submittal. These results are shown in the table below.

Table 4 2015 Maintenance Demonstration for the Pdx/ Van Maintenance Area (ozone values) 8-hour ozone standard = 0.08 ppm Exceedance ≥ 0.085 ppm maximum Violation > 0.085 ppm Predicted Design Value

Monitoring Site 1998 Current Design Value,
ppm Relative Reduction

Factor 2015 Predicted Design Value*,
ppm

Portland/Carus 0.075 0.955 0.072 Portland/Milwaukie 0.059 1.046 0.062 Portland/Sauvie Island 0.059 0.923 0.054 Vancouver/Mountain View 0.063 0.975 0.061

*Predicted Design Value is calculated using the EP A statistical procedure called the Relative Reduction Factor described in Appendix 6 of the Ecology’s su bmittal and in EPA’s 8-hour ozone modeling guidance. Predicted design value is compared to the 8-hour ozone standard to determine compliance.

Figure 4

Portland-Vancouver 8-hour Ozone Trend (1997-2005) and 2015 projection 3 year averages of the 4th highest daily ozone value

0.030 0.040 0.050 0.060 0.070 0.080 0.090 0.100

1997 1998 1999 2000 2001 2002 2003 2004 2005 2015

Year8 hr Ozone (ppm) 3 year rolling average of 4th highest

Portland/Carus

Portland/Milwaukie

Portland/Sauvie Island

Vancouver/Mtn.View Ozone AQ Standard 0.085 ppm

Ozone Monitoring Sites9 These results in Table 4 and Figure 4 clearly i llustrate that the Pdx/Van AQMA will maintain compliance with the 8-hour ozone standard through 2015. The Carus mo nitoring site, downwind of Portland, has historically been the site with the highest ozon e readings in the region. The model predicted that the Milwa ukie site would produce a sligh tly higher maximum value under worst case meteorological conditions, and the ma ximum values at both Milwaukie and Carus would exceed but not violate the st andard. However, the Carus site is expected to remain the highest and most important site for determin ing compliance with the ozone standard. The 4 th high design values at Carus and all other sites demons trate continued complia nce with the ozone NAAQS.

Supplemental Review for CAA Compliance

Does Ecology’s proposed 8-hour ozone Maintenan ce Plan meet other CAA pre-requisites for approval?

A review of whether this Plan revision meet s all CAA requirements wa s done per Section 110(l) of the CAA which states “....The Administrator sh all not approve a revision of a plan if the revision would interfere with any applicable re quirement concerning attainment and reasonable further progress (as defined in section 171), or an y other applicable requirement of this Act.”

The Ozone NAAQS was revised in 2008. The 2008 8-hour Ozone NAAQS we re promulgated in March 2008 with primary and secondary standa rds at 0.075 ppm or 75 ppb. All monitoring data in the area shows that the ar ea is not in violation of th e 2008 ozone NAAQS. These are the currently applicable NAAQS and the attainment de monstration has to clearly show that the 2008 NAAQS is also not being violated into the futu re due to the changes pr oposed by the State of Washington. As seen from the Table 4 and Fi gure 4 above, the 2015 predicted design values are below the 2008 NAAQS. Therefore, this plan de monstrates compliance with all applicable Ozone NAAQS.

We applied the same standard of review for a ll criteria pollutant NAAQS. Historical monitoring shows this area is in compliance wi th other criteria air pollutants NAAQS 4 . Additionally, EPA’s evaluation of the impacts of the changes proposed in this Plan has determined that these changes will not cause an increase in direct or precursor emissions that will interfere with the attainment or maintenance of any other NAAQS.

Therefore, an approval of this plan revision will not interfere with any applicable requirement concerning attainment or mainte nance of any applicable NAAQS.

Control Strategies for the Vancouver, WA area, applicable rules and changes

The control strategies in th e Portland-Vancouver Ozone Main tenance Plans are supported by current effective rules that are de scribed below. Both the strategies in the current effective rules and the proposed revised rules were relie d upon in the maintenance demonstration. The following strategies are supported by the rules th at are in the currently approved SIP and will continue to remain in the Vancouver Ozone Mainte nance Plan as they currently apply to sources in the Clark County, Washington area.

4 EPA’s AirData database at http://www.epa.gov/oar/data/reports.html10 Control Strategies (Included in current Federally Approved SIP)

 General Regulations for Air Pollution Sources (SWCAA 400)

o Air Discharge Permit Applications (Noti ce of Construction) (400-109) – submittal and processing of Air Discharge Permit (ADP) applications.

o New Source Review (400-110) – General requirements for ADP issuance, Best Available Control Technology (BACT) is required of all sources

o Requirements for New Sources in Nona ttainment Areas (400-112) New source review for nonattainment areas

o Requirements for Replacement of Substa ntial Alteration of Emission Control Technology at an Existing Stationary S ource (400-114) Reasonably Available Control Technology (RACT) for control equipment required

o Maintenance of Equipment (400-116) – minimum maintenance requirements

o Requirements for Nonattainment Areas ( 400-190) - procedural requirements for developing nonattainment provisions

 Emission Standards and Controls for Sour ces Emitting VOCs (SWCAA 490) – category specific requirements for gasoline loading a nd dispensing facilities, drycleaners, surface coater, graphic arts systems, flatwood pane l manufacturers and surf ace finishing facilities

 Emission Standards and Controls for Sources Emitting Gasoline Vapors (SWCAA 491) – requirements for gasoline stations (includes Stage I and Stage II gasoline vapor recovery) and specific requirements for fixed roof gasoline storage tanks, gasoline loading terminals, bulk gasoline tanks and gasoline transport tanks.

 VOC Area Source Rules for reducing emissions from Consumer Products, Spray Paints, Motor Vehicle Refinishing and Area Source Common Provisions (SWCAA 493-100 through 500)

Control Strategies with Proposed Rule Revisions:

The following rules were submitted by Ecology for in corporation into the federally enforceable SIP in order to implement th e proposed Maintenance Plan.

Revised Emission Check Rules for the Washington SIP

Ecology submitted changes to the Emission Check Program (ECP) WAC 173-422 for EPA approval and adoption into Wash ington’s federally approved Stat e Implementation Plan (SIP). EPA had previously approved Washington’s EC P and modifications. The most important changes in this submission allow late model vehicl es to be tested with their on-board diagnostic systems instead of with a tail-pipe test and ma ke related changes to th e section of the rules related to vehicle repair. Ecology is also requesting that fee-provi sions that are in the current Washington SIP be removed.

Rules submitted for approval and inclusion in the federally approved SIP:

WAC 173-422-020 Definitions. WAC 173-422-030 Vehicle emission inspection requirement. WAC 173-422-031 Vehicle emission inspection schedules. WAC 173-422-060 Gasoline vehicle emission standards.11 WAC 173-422-065 Diesel vehicle ex haust emission standards. WAC 173-422-070 Gasoline vehicle exhaus t emission testing procedures. WAC 173-422-075 Diesel vehicl e inspection procedure. WAC 173-422-190 Emission specialist authorization. WAC 173-422-195 Listing of author ized emission specialists.

These rules submitted by Ecology are in the docket for this proposed action. EPA reviewed these rule changes and is satisfied that the substantive changes allow la te-model vehicles to be tested with on-board diagnostic (OBD) sy stems as opposed to the tailpipe test, and related changes to the sections of the rule on ve hicle repair. Other changes includ e updates to the rules to reflect changing technology in automobiles, and to enhan ce clarity of the rules. Significant changes to the Diesel Vehicle Inspection Procedures include the adoption of the snap -acceleration procedure for testing and related changes.

Additionally, Ecology has requested removal of WAC 173-422-130 Inspection fees provision, and the words “twelve or less dollars” from WAC 173-422-160 Fleet and diesel owner vehicle testing requirements.

Ecology’s January 8, 2007 Maintenance Plan submitta l noted that revisions were also made to Southwest Clean Air Agency rules that support the maintenance determ ination. Specifically, Ecology noted that revisions were made to SWCAA 400-111, Requirements for New Sources in Maintenance Plan Areas; and SWCAA 400-113, Requi rements for New Sources in Attainment or Unclassifiable Areas. The re vised rules were included in the January 8, 2007 submittal.

However, as Ecology has indicated to EPA that these rule revisions were included with the submission for informational purposes only and not for incorporation into the federally enforceable SIP, EPA is not taking any action on these rule revisions. Instead EPA is relying on and maintaining the federally enforc eable SWCAA 400-030, 400-101, 400-111 and 400-113 SIP approved rules (62 FR 27204) for supporting the Ma intenance Plan demonstration. However, as Ecology has demonstrated that th e NAAQS is not violated usi ng the new established growth allowances, EPA is approving thos e new growth allowances along w ith this submittal to be used instead of the 1996 growth allowances.

Ecology and SWCAA submitted information that s upports that the various control strategies summarized above work together with other elem ents in the Maintenance Plan, including the tracking of emissions growth, ambient ozone monitoring and the early warning and action elements in the contingency plan, to meet air quality management goals and protect compliance with standards.

In summary, EPA proposes to approve change s to the Inspection & Maintenance Emissions Check Program and incorporate them into the federally enforceable SIP for the State of Washington. EPA is also proposing to approve the new industrial growth allowances used for the maintenance demonstration to be used with th e existing federally approved versions of SWCAA 400-111 and 400-113 (62 FR 27204) as the applicable rules. These changes were included in the technical attainment demonstration which esta blishes compliance with all applicable ozone NAAQS for this area.12 Voluntary Measures not re lied upon for SIP approval

Washington implements other programs such Co mmute Trip Reduction and the Public Education programs that can also contribute to ozone precursor emission reductions. However these reductions have not been quantified or relied upon for the maintenance demonstration of this SIP approval action.

3. Ambient Air Quality Monitoring – Ecology and the South West Clean Air Agency (SWCAA) commit to operate an ozone air quality monitoring network in accordance with 40 CFR 58 to verify maintenance of the 8-hour oz one standard in Vancouve r, WA (see Appendix 1 of Ecology’s submittal). The agencies further co mmit that any modification to the ambient air monitoring network, such as removal of duplicative or unnecessary monitors, will be accomplished through close consultation with th e EPA Regional office. Proposed network modifications would be accompanied by technical and statistical analysis sufficient to document a given monitor may be removed because it is u nnecessary or duplicative in the case of network reductions, or to justify the value of investing in monito ring network enhancements. In accordance with 40 CFR 58, the final network design will be subject to the approval of the EPA Regional Administrator.

4. Contingency Plan – Section 110(a)(1) of the CAA requires that the state develop a contingency plan which will ensure that any vi olation of a NAAQS is promptly corrected. The purpose of the contingency plan is to adopt meas ures, outlined in the Main tenance Plan, in order to assure continued attainment in the event of a violation of the 8-hour ozone NAAQS. The Maintenance Plan should identify the even ts that would “trigger” the adoption and implementation of a contingency measure(s), the contingency measure(s) that would be adopted and implemented, and the schedul e indicating the time frame by wh ich the state would adopt and implement the measure(s).

The provisions specified under Part A of the Contingency Plan for the Portland-Vancouver AQMA are linked to ambient concentrations of oz one and would be triggered if measured ozone levels at any of the ozone monitoring sites (Mou ntain View, Sauvie Island, Milwaukie, or Carus) exceed the early-warning thresholds below, or if a violation of the 8-hour ozone standard occurs. EPA is satisfied that the measures specified in Part A of the Contingency Plan in the proposed Maintenance Plan for the Vancouver portion of the Pdx/Van AQMA will promptly correct any violation of the NAAQS.

5. Verification of Continued Attainment – Ecology and SWCAA will continue to monitor ambient air quality ozone le vels in the Vancouver portion of the Portland-Vancouver AQMA during the ozone season (May through Septem ber) using the ozone monitoring network as described in Appendix 1 of Ecology’s submitta l. Ecology and SWCAA will update countywide emission inventories every three years as requ ired by the Consolidated Emission and Reporting Rule (CERR) to update the National Emissions Inventory. If ambient ozone levels increase, Ecology and SWCAA will compare CERR updates with the 2002 and 2015 emissions inventories and evaluate the assumptions used in the 2015 emissions projections to determine whether emissions are increasing at a rate not anticipated in the Maintenance Plan.13 III. Evaluation

The State of Washington has met the requireme nts to submit a Section 110(a)(1) Maintenance Plan that presents satisfactory information regard ing the five elements of the Maintenance Plan and has satisfied Sections 110(l) and 193 of the CAA. Therefore, approval of the State of Washington’s 8-hour Ozone Main tenance Plan is recommended.

IV. Conclusion

This SIP revision request satisfies all re quirements for an acceptable SIP revision.

V. Recommended Agency Action

The SIP revision request should be approved.

Rules Approved with the Action

WAC 173-422-020 Definitions. WAC 173-422-030 Vehicle emission inspection requirement. WAC 173-422-031 Vehicle emission inspection schedules. WAC 173-422-060 Gasoline vehicle emission standards. WAC 173-422-065 Diesel vehicle ex haust emission standards. WAC 173-422-070 Gasoline vehicle exhaus t emission testing procedures. WAC 173-422-075 Diesel vehicl e inspection procedure. WAC 173-422-190 Emission specialist authorization. WAC 173-422-195 Listing of author ized emission specialists.

Removal of WAC 173-422-130 Inspection fees, a nd deletion of the words “of twelve or less dollars” from WAC 173- 422-160 Fleet and diesel owner vehicle testing requirements.