h!2 

Protection Agency 

FEB 2 9 2016 

Mr. George Czerniak 

John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Craig W. Butler, Director 

Director, Air and Radiation Division 

U.S. EPA Region V 

77 W. Jackson Blvd. 

Chicago, IL 60604 

Re: Supplemental Information for the Request for Approval of Amendments to 

Paragraph (ODD) of Ohio Administrative Code (OAC) Rule 3745-21-09 into Ohio's State 

Implementation Plan (SIP) Dated July 15, 2015. 

Dear Mr. Czerniak: 

To aid you in your review of Ohio's July 15, 2015 submittal to revise its State Implementation 

Plan (SIP) submittal to remove the requirements for Stage II vapor recovery (Stage II) in the 

Cleveland, Cincinnati, and Dayton areas, please accept the following additional information. 

The Ohio Stage II program was originally implemented to address the ozone National Ambient 

Air Quality Standards (NAAQS) through the reductions of volatile organic compound (VOC) 

emissions from controls at gasoline dispensing facilities (GDFs). VOCs mainly contribute to 

the formation of ground-level ozone but to a lesser extent, VOCs also contribute to the 

formation of particulate matter (PM) although the extent of the contribution varies significantly 

by location or region within the United States. 

While VOC is one of the precursors for PM (NAAQS) formation, a study (Journal of 

Environmental Engineering - Quantifying the sources of ozone, fine particulate matter, and 

regional haze in the Southeastern United States, June 24, 2009) indicates that in portions of 

the Midwest (including portions of Ohio) where Stage II has been implemented, emissions of 

direct fine particulate matter (PM2.5) and the precursor sulfur dioxide (S02) are more significant 

to ambient PM2.s concentrations than nitrogen oxides (NOx) and VOC. Specifically, PM2.s 

sensitivities to anthropogenic VOC emissions are near zero for the entire region, including the 

Cincinnati region. This study also indicated that the impact of S02 emissions, especially from 

electric generating units, was most significant in the Cincinnati area due to S02 emissions in 

the entire mid-west region (Wisconsin, Illinois, Indiana, Michigan and Ohio). In fact, emissions 

from the mid-west had the largest effect on PM2.5 sensitivities in the Cincinnati region. For this 

reason, a similar impact is expected in the Cleveland and Dayton areas. The technical 

analysis provided has met U.S. EPA's guidance and demonstrates anthropogenic VOCs are 

insignificant to the formation of PM2.5 in these areas. 

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax) 
The Ohio Environmental Protection Agency (Ohio EPA) has evaluated the impact of the Stage 

II SIP revision on air emissions as part of a Clean Air Act (CAA) section 11 O(i) analysis, and 

has determined that the removal of Ohio's Stage II program will not interfere with the 

attainment or maintenance of the 8-hour ozone or PM2.5 NAAQS, or any other applicable 

requirement of the CAA in either the Cleveland, Cincinnati, or Dayton areas. 

Any temporary VOC emissions increases resulting from the removal of the Stage II systems at 

GDFs before the January 1, 2017 widespread use date are being offset through the installation 

of low permeation hoses on all gasoline dispensing facilities during the decommissioning 

process. 

In addition, based on our evaluation the revisions to the Ohio Stage II program do not affect 

attainment or maintenance of the carbon monoxide, nitrogen dioxide, lead, PM or sulfur 

dioxide NAAQS. 

Please contact Bob Hodanbosi if you have any questions about this submittal. 

Sincerely, 

/Ut �/Zkt_. 

Robert Hodanbosi 

Chief Division of Air Pollution Control, Ohio Environmental Protection Agency