# SIP Revision
for the Spokane County

, Washington
Second 10

- Year Limited Maintenance Plan
for PM 10

Spokane Regional Clean Air Agency Spokane, Washington

In conjunction with

Air Quality Program Washington State Department of Ecology Olympia, Washingto n



## November 2015ii
November 2015 

## Publication and Contact Information
This report is available on Spokane Regional Clean Air Agency’s website, www.SpokaneCleanAir.org

.

Contact: Spokane Regional Clean Air Agency Attn: Margee Chambers 3104 E. Augusta Avenue Spokane, WA 99207 Phone: (509) 477

- 4727 Fax: (509) 477

- 6828 Email: mchambers@spokanecleanair.org

If you need this document in an alternate format for the visually impaired or hearing loss, call Spokane Regional Clean Air Agency at (509) 477

- 4727.iii
November 2015 

## Contents

Publication and Contact Information

................................ ................................ ................................ ............ ii

List of Figures and Tables

................................ ................................ ................................ ............................. iv

Figures

................................ ................................ ................................ ................................ ...................... iv

Tables

................................ ................................ ................................ ................................ ....................... iv

Acronyms and Abbreviations

................................ ................................ ................................ ........................ v
Acknowledgements

................................ ................................ ................................ ................................ ..... vii

Abst ract/Executive Summary

................................ ................................ ................................ ..................... viii

1. Introduction

................................ ................................ ................................ ................................ .............. 1

2. Background

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

3. Li mited Maintenance Plan Option

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

4. Particulate Matter Monitoring

................................ ................................ ................................ .................. 6

5. Emission Inventory

................................ ................................ ................................ ................................ .... 7

6. Control Measures

................................ ................................ ................................ ................................ ...... 9

7. Contingency Measures

................................ ................................ ................................ ............................ 11

8. Commitment to Continued Monitoring

................................ ................................ ................................ .. 12

9. Verification of Continued Attainment

................................ ................................ ................................ .... 12

10. Summary of Maintenance Plan Commitments

................................ ................................ ..................... 13

11. Required Plans Complete

................................ ................................ ................................ ...................... 13

Summary of Control and Contingency Measures

................................ ................................ ....................... 13

Appendix A. Limited Maintenance Plan Qualific ation

................................ ................................ ................ 15
Appendix B. Ecology 2014 Network Report/EPA approval

................................ ................................ ......... 18

Appendix C. Emission Inventory Documentation

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

Appendix D. Changes to Regulation 1

– Article VI

– Emissions Prohibited since adoption into the SIP

..... 30iv
November 2015 

## List of Figures and Tables

**Figures** Figure 1. Spokane County Maintenance Area (SCMA)

................................ ................................ ................. 3 Figure 2. PM 10 Maximum and Second Highest Values

................................ ................................ .................. 4 Figure 3. Smoke Control Zone

................................ ................................ ................................ ..................... 10 Figure 4. Out Year VMT Estimate Plot

................................ ................................ ................................ ........ 16



### Tables Table 1. Comparison of First and Second LMP Emissions Inventory

................................ ............................ 7 Table 2. Annual and Daily PM 10 Emissions 2011

................................ ................................ ........................... 8
Table 3. Second 10

- Year LMP Commitments

................................ ................................ .............................. 13
Table 4. Tabular Estimation of PM 10 Design Values

................................ ................................ .................... 15
Table 5. Tabular Estimation of PM 10 Look

- Up Concentrations Using Table 6

- 1 of PM 10 SIP Guidelines

.... 15
Table 6. Modeled VMT Data

................................ ................................ ................................ ....................... 16 Table 7. Mobile Source Contribution to Design Value

................................ ................................ ................ 17
Table 8. Particulate Matter 10 PM 10 , Parameter code 81102

................................ ................................ .... 19 Table 9. Spokane County Residential Wood Combustion Emissions

................................ .......................... 28 Table 10. Unpaved Road Emissions Calculations

................................ ................................ ........................ 29v November 2015 

## Acronyms a **nd Abbreviations**

μg/m 3 micrograms per cubic meter

ADT Average Daily Traffic

ADVMT Average Daily Vehicle Miles Traveled

AP42 EPA's compilation of Air Pollutant Emission Factors

AQI Air Quality Index

AQS Air Quality System

CAA Clean Air Act

CAAA Clea n Air Act Amendments

CARB California Air Resources Board

DOL Washington State Department of Licensing

DQO Data Quality Objectives

DV Design Value Ecology Washington State Department of Ecology

EI Emission Inventory

EPA U.S. Environmental Protection Agency

FEM Federal Equivalent Method

FRM Federal Reference Method

FTA Federal Transit Administration g/hr grams per hour

HPMS U.S. Department of Transportation Highway Performance Monitoring System I/M Vehicle Inspection and Maintenance IPP/QAP Inve ntory Preparation Plan and Quality Assurance Plan

LMP Limited Maintenance Plan

MOS Margin of Safety

MOVES EPA Motor Vehicle Emission Simulator

NAA Nonattainment Area

NAAQS National Ambient Air Quality Standards

NAMS National Ambient Monitoring Site

NEAP Columbia Plateau Windblown Dust Natural Events Action Plan

NEI National Emission Inventory

O SPI Washington State Office of the Superintendent of Public Instruction

PM 10 Pa rticulate Matter, ten microns o r less

PM 2.5 Particulate Matter, 2.5 microns or less

RACM Reasonably Available Control Measures

RWC Residential Wood Combustion

SCAPCA Spokane County Air Pollution Control Authority 1

SCMA Spokane County Maintenance Area

SIP State Implementation Plan

1 In 2007 the Board of the Spokane County Air Pollution Control Authority (SCAPCA) changed t heir name to the Spokane Regional Clean Air Agency (SRCAA), Resolution #07

- 15vi
November 2015

SLAMS State and Local Ambient Monitoring Site

SRCAA Spokane Regional Clean Air Agency

SRTC Spokane Regional Transportation Council

TEOM Tapered Element Oscillating Microbalance

TSP Total Suspend Particulate

VMT Vehicle Miles Traveled

WRAP Western Regional Air Partnership

WSDOT Washington Stat e Department of Transportation

WSU Washington State Universityvii
November 2015 

## Acknowledgements
The authors of this report would like to thank the following people for their contribution to this study:

Spokane Regional Clean Air Agency Margee Chambers Ron Edgar
Carl Gross
Julie Oliver

Mark Rowe April Westby

Washington State Department of Ecology Ranil Dhammapala

Laurie Hulse

- Moyer
Sean Lundblad Sally Otterson Mike Ragan

Spokane Regional Transportation Council Sylvia Ferrin Anna Ragaza

- Bourassa

Spokane County

John Pedersonviii
November 2015 

## Abstract/Executive Summary

The cities of Spokane, Spokane Valley, Millwood and surrounding unincorporated areas in Spokane County

, Washington meet the federal standard for Particulate Matter 10 microns and smaller (PM 10 ). This State Implementat ion Plan (SIP) explains how this area will continue to meet this standard through

2025.

E nvironmental Protection Agency (EPA) sets standards for particulate pollution because smaller particles such as soot, dust and unburned fuel can penetrate deeply int o the lungs and cause health problems.

The current 24

- hour federal health standard for PM 10 , set in 1987, is 150 micrograms per cubic meter of air (μg/m 3 ). To maintain compliance with the standard, monitored levels should not exceed this level in

the are a more than once a year averaged over a three year period.

The Spokane County Maintenance Area (SCMA or maintenance area) which includes the cities of Spokane, Spokane Valley, Millwood and surrounding unincorporated areas

, violated the 24 hour

standard in the 1980s. Windblown dust, re

- entrained road dirt and sanding material, unpaved road dust and smoke from woodstoves and fireplaces all contributed to the violation s of the standard. The Spokane Regional Clean Air Agency (SRCAA) operates federal referenc e method (FRM) and/or federal equivalent method (FEM) ambient air monitors in the SCMA to track compliance with the federal PM 10 standard. Ambient monitoring has shown the SCMA in attainment since 1994. With completion of an approved attainment SIP and L im ited M aintenance P lan (LMP) the SCMA was re

- designated to
attainment in 2005. SRCAA has enforcement authority for the SCMA.

The Clean Air Act (CAA) requires an area being re

- d e signated to attainment have an EPA

- approved maintenance plan that provides for the area’s continued compliance with the PM 10 standard for 10 years. A second 10

- year plan must follow the first . This SIP Revision is for the Spokane County Washington, Second 10

- year Limited Maintenance Plan for PM 10 . This plan:

• Meets the requiremen t for a second 10

- year plan,

• Covers the period through 2025, and

• Fulfills the final maintenance planning requirements of the CAA for the SCMA.

Since the maintenance area meets EPA criteria and shows little risk of re

- violating the federal standards,
this streamlined maintenance plan called a LM P has been developed

. The LMP relies on the same control measures that brought the area into attainment and supported the initial maintenance plan

. These measures include:

• Control of dust from paved and unpaved r oadways

• Controls to prevent particulate matter from becoming airborne

• Curtailment of wood burning devices during impaired air quality

• Standards for new solid fuel burning devices

• Outdoor burning restrictionsix
November 2015 The underlying control measures and contingency measures from the attainment and maintenance plan are still in place, thus meeting the LMP guidance criteria. Any changes or potential revisions to these control measures will be addressed in separate submittals to the EPA as discussed in this document. SRCAA proposes that Ecology, as the Governor’s designee for the SIP, submit this LMP to EPA and request EPA approve this LMP as a revision under the SIP.

Ecology will lead the public comment period to fulfill federal requirements for public comment and

h earings. SRCAA will continue to monitor air quality in the SCMA and document the area’s continued compliance with the 1987 PM 10 Standard.1
November 2015 

## 1. Introduction

This State Implementation Plan (SIP) revision explains how the Spokane County Maintenance Area (SCMA ) currently meets and will continue to meet the 1987 National Ambient Air Quality Standard (NAAQS) for particulate matter 10 microns or smaller (PM 10 ) through 2025. Spokane Regional Clean Air Agency 2 (SRCAA), the local clean air agency with jurisdiction o ver Spokane County

, prepared this plan

.

Particulate Matter Standards

– The Environmental Protection Agency (EPA) set air quality standards for particulate matter to protect public health. Particulate matter pollution is a public health issue because

smal ler particles can penetrate deep into the lungs and cause health problems. Particulate matter comes from soot, dust and unburned fuel suspended in the air. EPA revised the particulate matter NAAQS from total suspended particulate (TSP) to PM 10 on July 1, 1987, since smaller particles were determined to be more harmful. The primary or health

- based 24

- hour standard for PM 10 was set at 150 μg/m 3 , and cannot be exceeded more than once a year on average over three years. This standard remains in effect today . Ten years later on July 18, 1997, EPA set a 24

- hour for fine particulate matter (particulate matter 2.5 microns or smaller or PM 2.5 ) at 65 μg/m 3 . In 2006, the 24

- hour standard was revised from 65 μg/m 3 to 35 μg/m 3

.

Spokane County Maintenance Area Comp liance History

– Spokane County violated the 24

- hour PM 10 NAAQS multiple times a year from 1985 through 1993. There were three main causes of t hese exceedances of the NAAQ S : w indblown dust, re

- suspended dust from traction sand and tracking of dirt from unp aved roads, and wood burning heating devices. These exceedances were recorded at multiple

locations throughout the maintenance area. The primary location and highest values were at the PM 10 monitor located a t Freya St and Ferry Ave

. (Spokane

- Ferry St site ) in the City of Spokane. When the 1990 Clean Air Act Amendments (CAAA) was passed, EPA designated the Spokane County Maintenance Area (SCMA) a nonattainment area, an area out of compliance with the PM 10 standards.

Ecology and SRCAA prepared plans to fulf ill the Clean A ir Act (CAA) requirements. An a ttainment plan described how the area would comply with the standard; a maintenance plan described how the area would stay in compliance.

The three mai n sources of particulate matter continue to be windblown dust (dust storms), dust from roadways and smoke from wood stoves and fireplaces. Wood stoves and fireplace smoke is a

wintertime issue . C ontrol measures to limit wood burning during period of poor air quality were put into place and included in the atta inment plan. Th ese control measure s and state requirements on new wood fueled burning devices have reduced smoke particulate.

Resuspended road dust is mainly a late winter and early spring problem . A control measure requiring cities, Spokane County and Washington State Department of Transportation to submit and follow plans to reduce use of sanding material , use cleaner sanding material and clean roadways within the maintenance area more frequently and in a more timely manner. There have been no furth er exceedances attributed to road dust since the implementation of road dust control plans.

2 In 2007 the Board of the Spokane County Air Pollution Control Authority (SCAPCA) changed their name to the Spokane Regional Clean Air Agency (SRCAA), Resolution #07

- 152
November 2015 Frequency of windblown dust impacts has been down as soil conservation programs have led to
increased use of no

- till and minimal till farming practices. Additiona l road paving by city and county have controlled critical unpaved roads that were shown to impact PM 10 levels.

The control measures and contingency measures from the attainment and maintenance plan are still in place. The area monitored attainment in the 1995

- 1997 years and EPA redesignated the area to

attainment in 2005 . The area continues to be in compliance with the PM 10 NAAQS.

Plan Structure

– This SIP revision includes the SCMA compliance history and describes the how the area

met and will continu e to meet the standards, as well as what will be done if the standard is exceeded. This plan also includes other EPA required elements, such as an emission s and monitoring review and public process requirements.

This document is organized as follows:

• Se ction 2

– SCMA and PM 10 Standard Background

– describes the area’s compliance history and contains back ground information on the PM 10 standard

• Section 3

– Limited Maintenance Plan (LMP) Option

– describes the criteria an area must meet to qualify for this option and how the SCMA meets these criteria

• Section 4

– PM 10 Monitoring History

– provides a brief history of monitoring in the SCMA

• Section 5

– Emission Inventory

– includes historical information on the most significant PM 10 emission categories from th e original maintenance plan and an updated inventory on these categories

• Section 6

– Control Measures

– lists the measures and rules that were in place in the original maintenance plan, the current rules that maintain and enforce these measures and include s a request that EPA incorporate and include the updated rules in Washington State’s SIP

• Section 7

– Contingency Measures

– describes the provisions that are in place in rules and will be taken, if the PM 10 standard is violated

• Section 8

– Commitment to Co ntinue Monitoring

– states that continued monitoring will be

done

• Section 9

– Verification of Continued Attainment

– describes how continued compliance will be
confirmed

• Section 10

– Summary of Maintenance Plan Commitments

– outlines commitments of this pl an

• Section 11

– Completion of Required Plans

– states that this document fulfills federal planning requirements



## 2. Background

Historical information on the SCMA, its compliance, and federal plan history are below.

Spokane County Maintenance Area

– The SC MA is located in Washington State, east of the Cascade
Mountains, 300 miles east of Seattle just west of the Idaho State boarder. Much of the SCMA is located in the drainage basin of the Spokane River with elevations ranging from around 1700 feet in the r iver valley near downtown Spokane to 2300 feet on the western boundary of the SCMA and 2200 feet on the eastern edge. The primary PM 10 monitor

, Spokane Augusta established in 2009, is located on the east side of the City of Spokane at an elevation of 1945 feet. Prior to 2009 Spokane Ferry St was the primary3
November 2015 and design value monitor located approximately 1⁄2 mile south of the Augusta site along the same traffic

corridor. The topography and location influence the meteorology throughout the SCMA. In general the climate is mild and arid in the summer, cold and moist in the winter. The predomina nt wind direction is from the south to southwest with most high wind speed condition coming out of this direction. High pressure over the region during winter months l eads to strong temperature inversion s in the river basin.

Figure 1 . Spokane County Maintenance Area (SCMA)

Spokane County Compliance History

– The SCMA shown in Figure 1 was designated Group I for vio lating

the 24

- hour PM 10 standard in 1987. The area was designated as a PM 10 Non

- Attainment Area (NAA), which was classified as Moderate, under the 1990 CAA Amendments. The Spokane NAA was determined by EPA to attain the PM 10 24

- hour NAAQS by its extended attainment date of December 31, 1997. A

PM 10 attainment plan was submitted in 1994 and approved by EPA in 1997. The first PM 10 Limited Maintenance Plan (LMP) and request for re

- designation was submitted in 2004 and approved in 2005. 3

Due to a lack of evidence linking health problems to long

- term exposure to coarse particle pollution, the

EPA revoked the annual PM 10 standard in 2006. 4 Figure 2 on next page show s maximum concentration
for each year, 2000 through 2014, and the s econd highest value for that year

. Data for the chart comes from the EPA AirData site and includes data flagged as an exception event.

3 (70 F R 38029) Federal Register/ Vol. 70, No. 126/ Friday, July 1, 2005/ Rules and Regulations Approval and Promulgation of Air Quality Implementation Plans; Spokane PM 10 Limited Maintenance Plan and Redesignation Request. Direct final rule effective August 3 0, 2005

4 (71 FR 61144) Federal Register/ Vol. 71, No. 200/ Tuesday, October 17, 2006/ Rules and Regulations National Ambient Air Quality Standards for Particulate Matter. Effective December 18, 20064
November 2015 Figure 2 . PM 10 Maximum and Second Highest Values

The data for the year 2000 to through the first quarter of 2009 is from Ferry St, the remainder through 2014 is from Augusta Ave. The first maximum values for the years 2001, 2005, 2008 and 2013 were flagged as exceptional events. 5

Plans Submitted

– Ecology and SRCAA prepared attainment and th e first of the two required

maintenance plans to fulfill CAA requirements. An attainment plan describes how the area compl ies with the standard; a maintenance plan describ es how the area stay s in compliance . These plans are:

• Attainment Plan

– A revised PM 10 SIP was submitted November 15, 1991 that used rollback modeling to demonstrate attainment. EPA subsequently requested dispersion modeling to

demonstrate attainment . On December 9, 1994 Ecology submitted the Spokane PM 10 Attainment plan for the Spoka ne PM 10 nonattainment area. EPA approved the plan on January
27, 1997 (62 FR 3800)

.

• Redesignation Request and Maintenance Plan

– Ecology s ubmitted the Limited Maintenance
Plan ( 2005 LMP ) and request for redesignation November 30, 2004 , EPA appr oved the Pl an and request which became effective Aug ust 30, 2005 (70 FR 38029)

.

5 Data have been flagged, but unless there is regulato ry significance, that is, the area is in danger of violating the standard, a demonstration would not be submitted. The values stay in the record until EPA approved a demonstration and places a concurrence flag on the data.5
November 2015 This plan, the SIP Revision for the Spokane County, Washington Second 10

- Year Limited Maintenance
Plan for PM 10 , is the last maintenance plan for this area. This maintenance plan revisi on ensures compliance through 2025 and fulfills the second 10

- year planning requirements of CAA Section 175A (b).



## 3. Limited Maintenance Plan Option

Because the SCMA is a maintenance area, the CAA requires Ecology to adopt and submit a plan that

demonstrat es compliance with the NAAQS through 2025. EPA developed the Limited Maintenance Plan (LMP) option so areas with little risk of reviolating the PM10 standard could be easily redesignated f rom nonattainment to attainment (also called maintenance status). E PA also allows states to use this policy to prepare the required second 10

- year maintenance plans, if the area meets the qualification criteria in

the EPA Limited Maintenance Plan Option Guidance ( LMP Guidance). This section describes the advantages of t he LMP option and how the SCMA meets the qualification criteria.

Maintenance Demonstration

– A maintenance plan normally contains an emissions or modeling demonstration that shows how the area will stay in compliance through the 10

- year maintenance period . This demonstration normally requires a projected emissions inventory. However, an area meeting the LMP qualification criteria is a t little risk of violating the standard because emissions are not expected to grow sufficiently to threaten maintenance of the standard. Therefore, when an area meets the criteria, the maintenance demonstration is presumed to be satisfied and there is no need to project emissions over the maintenance period.

Transportation Conformity

– The transportation conformity rule (4 0 CFR Parts 51 and 93) applies to nonattainment and maintenance areas. It is not reasonable to expect that motor vehicle emissions would grow enough to threaten maintenance if an area expects only limited growth in traffic emissions and qualifies for the LMP option. Therefore, a regional emissions analysis in not required to determine whether the region’s long

- range transportation plan and short

- term transportation improvement program conform to the maintenance plan. Other conformity requirements, such a s consultation between agencies on air quality impacts of transportation projects, still apply.

LMP Qualification Criteria

– To take advantage of the LMP option, an area must be attaining the NAAQS, cannot exceed the average 24

- hour PM 10 design value of 9 8 μg/m 3 based on the most recent 5 years of data and should expect only limited growth in on

- road motor vehicle emissions. The SCMA meets these criteria as described below; supporting information can be found in Appendix A.

How the SCMA qualifies for the LMP option:

1. The area must be attaining the NAAQS: Spokane County attained the standard in 1997, was formally redisignated as in attainment in 2005, and has continued to be in compliance.

2. T he average 24

- hour PM 10 design value for the area based upon the most recent five years of data should not exceed 98 μg/m 3

. A design value is t he statistic based on monitoring data that determines and area’s compliance status. The LMP Guidance directs the design value be based on the most recent five years of data. The SCMA design value on Federal Reference Method (FRM) and Federal Equivalent Methods (FEM) 24

- hour PM 10 monitoring data from 2010 through 2015 is 80 μg/m3 using the “Tabular Estimation of PM 10 Design Concentrations” Table 6

- 1 of the6
November 2015 PM 10 SIP Guidance. Si nce this value is below 98 μg/m 3 , the value stipulated in the LMP Guidance,

the SCMA meets this condition.

3. The area should expect only limited growth in on

- road motor vehicle PM 10 Emissions (including fugitive dust) and should have passed a motor vehicle regional emissio ns analysis test (i.e.,

passes the Motor Vehicle Regional Analysis Methodology found in Attachment B of the LMP Guidance.) SCMA meets both these criteria. First, the Spokane Regional Transportation Council (SRTC) projects only limited gro wth in on

- road motor vehicle PM 10 emissions for the SCMA from 2015 through 2025. Second

, the area passes the motor vehicle regional emissions analysis test.

The SCMA continues to attain the PM 10 NAAQS . T he design values are below the defined margin of
saf ety and the growth in PM 10 emissions from motor vehicles will not threaten compliance with the standard. Thus, the SCMA meets the LMP qualification criteria and qualifies for the LMP option.

The analysis has been provided to Ecology a nd EPA Region 10 off ice. EPA and Ecology mutually agreed to the LMP approach. SRCAA will calculate the 5

- year design value estimate and provide it to Ecology annually by April 30 th of each year

. If the design value estimate is below 98 μg/ m 3

, Ecology will include a

stateme nt that the area continues to qualify for the LMP option in the annual monitoring network
report.



## 4. **Particulate Matter Monitoring**

This section discussed the history of PM 10 and to some extent PM 2.5 monitoring in the SCMA.

Particulate Matter Monitoring History

– SRCAA conducts ambient monitoring in Spokane County. Starting in 1985 and in the early 90s there were as many as 9 PM 10 FRM monitoring sites in Spokane County , one of them

, the Crown Zellerbach site (3530 E. Ferry Ave., Spokane, WA), consistentl y showed the highest concentration of PM 10 . That site was later renamed Spokane

- F erry St. Ferry St was used to determine the design value for the attainment SIP and the fir st 10

- year maintenance plan. The Spokane

- Augusta site (3104 E. Augusta Ave., Spoka ne, WA) replaced Ferry St. as the primary site for

PM 10 monitoring when the equipment was moved in 2009

.

Today there are two locations where PM 10 is monitored, Spokane

- Augusta and Turnbull Slough , located on the Turnbull Wildlife Refuge southwest of the City of Spokane

. The Augusta Ave. FEM is used for determining compliance with the NAAQS

. Turnbull is a Special Purpose Monitor (SPM) operated by SRCAA to measure background PM 10 levels and evaluate windblown dust events.

Types of Particulate Monitors

– Spokane

- Augusta monitors both PM 10 and PM 2.5 using both Federal Reference Method (FRM) and Federal Equivalent Method (FEM). The manual FRM data is no longer reported to Ecology. SRCAA continues to operate

, maintain and collect the FRM data for its own us e. Data from the PM 10 FEM is reported by Ecology to AQS . The following monitors have been used to measure particulate matter at the Ferry St

. and Augusta Ave. sites;

• FRM

o PM 10 SA/GMW 1200 High Volume (HI

- Vol) monitor

o PM 2.5 R&P Partisol 2025 sequential m onitor

• FEM7
November 2015 o PM 10 R&P 1400AB TEOM

o PM 2.5 R&P 1400AB TEOM with 8500 FDMS unit and Very Sharp Cut Cyclone

o Met One BAM 1020 (The BAM is being evaluated as a replacement for the PM 2.5 TEOM)

SRCAA commit s to maintaining a PM 10 NAAQS compliance monitor through th e LMP period. The

monitor will be maintained and operated in accordance with federal siting and design criteria set forth

in 40 CFR Part 58. Any changes to the monitor will be proposed under Ecology’s annual network plan and subject to EPA approval.



## 5. **Emission Inventory**

This section presents the emissions inventory for this second 10

- year LMP and briefly describes its development. The LMP Guidance requires the maintenance plan include an attainment inventory

– that is, an inventory with emission levels consistent with attainment of the PM 10 standard.

In the original maintenance plan and LMP SRCAA contracted with E.H. Pechan and Associates, Inc. to develop a very detailed emission inventory. For this 2 nd LMP EPA agreed that SRCAA should develop the

main tenance plan inventory from readily available information. Emission estimates are from Ecology’s
2011 and EPA’s triennial emission inventories. The Na tional Emissions Inventory (NEI) is based on EPA and state inputs. Appendix C. Emission Inventory Docum entation provides details.

Maintenance Plan Inventory

– Washington State’s 2011 Emissions Inventory (EI) is the most recent, complete, readily available emission inventory for Spokane County. Since neither Ecology nor SRCAA
have local information on emi ssions for a number of categories, Ecology accepted the EPA estimates for the missing categories. (See Appendix C.)

Significant source categories

– The most significant sources of PM 10 listed from the original maintenance plan for the SCMA are Paved Roads , Unpaved Roads and Residential Wood Combustion.
Three “Worst

- Case” scenarios were looked at in the first 10

- year maintenance plan ; Levels for Unpaved Roads, Paved Roads and Residential Wood Combustion. Windblown dust was not included in the analysis. Wi ndblown dust during high wind events is addressed under the Columbia Plateau Windblown

Dust Natural Events Action Plan (NEAP) 6 and the Exceptional Events Rule Guidance 7 . There are no new major point sources in the SCMA and other activities and emissions e stimates remain about the same as during the first 10

- year plan.

Table 1 . Comparison of First and Second LMP Emissions Inventory

Year Spokane County SCMA Annual (tons) Daily (tons) Annual (tons) Daily (tons)

2002 18,612 55.1 1 0, 059 30.0

2011 18,933 66.82 6,884 28.10

The detailed emission inventory for Spokane County and the SCMA is shown in Table 2

.

6 A link to Ecology’s NEAP is at https://fortress.wa.gov/ecy/publications/SummaryPages/0302014.html

7 Friday, May 10, 2013, EPA issued interim guidance to help state, local and tribal governments manage air quality

data recor ded during “exceptional events”.8
November 2015 Table 2 . Annual and Daily PM 10 Emissions 2011

Sources Sector Spokane Count y SCMA Annual (tons) Daily (tons) Annual (tons) Daily (tons)

Air Craft 14 0.03 14 0.03

Recreational boats 16 0.08 1 0.01

Construction 4,810 18.6 3,561 13.8

Commercial fuel use 36 0.12 32 0.11

Residential fuel use 7 0.03 5 0.03

Wildfires 14 0.03 0 0

Food and Kindred Products 173 2.59 158 2.37

Structure and Motor vehicle fires, cremation etc. 6 0.02 5 0.02

Nonroad Mobile 164 1.07 71 0.46 Agricultural and silvicultural burning 99 0.88 3 0.03

Residential outdoor burning 101 0.35 0 0

On road mobile 469 1.28 346 0.94

Point sources 8 200 0. 72 160 0. 57

Paved roads 1051 2.64 780 1.96 Unpaved roads 9 5624 15.42 567 1.56

Locomotives 42 0.12 15 0.04

Woodstoves 1,353 7.51 1,062 5.89 Agricultural tiling & harvesting 4,156 13.7 15 0.05

Totals 18, 933 66 .82 6,884 28.10

Sources considered negligible

– Ecology and SRCAA have no local information on emissions for construction dust, cigarette smoke, or commercial charbroiling, but these are assumed to be minimal.
Some of these values are included in the 201 1 NEI, however the emission estimates have large

uncertainties because it was not developed specifically for local areas, or for sub

- county regions like the Spokane County Maintenance Area

. Other sources are deemed insignificant, including outdoor burning

, aircraft emissions, and wildfires.

Smoke from wildfires is considered negligible as no PM 10 data has recently been flagged as being impacted by wild fires. Wildfires also would have a much more significant impact on PM 2.5 and the Spokane area continues to meet the PM 2.5 NAAQS. Outdoor burning is prohibited in the maintenance area, so emissions would be minimal.

Construction Dust in the inventory is data from EPA’s 2011 NEI as accepted by Ecology into their 2011 EI. This data is not estimated by Ecolo gy or SRCAA and is included as found in the NEI. The 2011 data

includes construction dust in four categories: Industrial/Commercial/Institutional, Residential
Construction, Mining/Quarrying

, and Road Construction. Top

- down inventories such as the NEI hav e inherent uncertainties because data is collected nationally and aggregated. The previous attainment plan and 2005 LMP SRCAA’s consultant gathered local information to calculate construction dust that resulted in a much lower contribution than reported i n the NEI. Construction dust was not identif ied as significant in either the attainment plan or the first LMP

. SRCAA local regulation in place to control

8 Air Operating Permit Billin g Data 2012 (reports 2011 emissions), Spokane Regional Clean Air Agency, April Westby, March 2, 2015

9 Spokane Regional Transportation Council updated unpaved road data, email from Anna Ragaza

- Bourassa, March
11, 20159
November 2015 c onstruction dust

, S ection 6.05 10

, is listed under control measure s for unpaved roads but also applie s to
construction activities.

Windblown dust from high wind event s is not included as part of the Washington State EI.



## 6. Control Measures

There were three “Worst

- case” scenarios discussed in the first 10

- year LMP for Unpaved Roads, Paved

Roads and Resi dential Wood Combustion. SRCAA and Ecology relied on Reasonably Available Control Measures (RACM) to return the area to compliance with the PM 10 standard. Ecology and SRCAA have continued to implement the control measures established in the attainment pl an and in the f irst 10

- year
LMP.

Control Measures for Unpaved Roads

– The following resolutions and regulations were adopted to

address dust from unpaved roads. SRCAA’s regulation remains in effect and enforced. City and County paving projects identif ied in the attainment plan were completed prior to the approval of the first LMP.

• SRCAA Regulation Section 6.15 Standards for Control of Particulate Matter o n Unpaved Roads 11

• City of Spokane Resolution 90

- 93, October 8, 1990, Street Paving

• City of Spokan e Resolution 91

- 42, June 17, 1991, Six Year Comprehensive Street Program

• Spokane County Resolution 90

- 1219, October 9, 1990, Street Paving

• Spokane County Resolution 04

- 0461, 2004, County Zoning Code, Chapter 14.802 Off

- street Parking and Loading Standards (replaces Spokane County Resolution 90

- 0812 and Spokane County Zoning Code Ordinances 4.17.059 and 14.802.080

, May 24, 1990, Paving of New Parking Lots) 12

Control Measures for Paved Roads

– The following regulations and resolutions were adopted to address the dust from paved roads.

• SRCAA Regulation Section 6.05 Particulate Matter & Preventing Particulate Matter from becoming Airborne

• SRCAA Regulation Section 6.14 Standards for Control of Particulate Matter on Paved Surfaces 13

• City of Spokane Resolution 93

- 43 , May 10 1993, Street Sweeping & Reduced Use of Sanding

Materials

SRCAA Regulation Section 6.14 which was adopted in 1993 was amended October 7, 2004 Resolution

04

- 21 ; this is a change from the 1993 version listed by EPA

. The changes are shown in Appendi x D.

10 SRCAA Regulation Section 6.05 Partic ulate Matter & Preventing Particulate Matter from becoming Airborne. SRCAA notes that Section 6.05(A) is a nuisance provision outside the scope of regulating criteria pollutants under Clean Air Action section 110 and requests that the EPA correct the SIP to remove this provision.

11 SCAPCA Resolution 07

- 15 Agency name change from SCAPCA to SRCAA

12 E

- mail from John Pederson, Planning Director, Spokane County 2/21/2015. This control measure was labeled as a contingency on Region 10 web page and called SCAPCA Zoning Code Ordinance 4.17.059 and 4.802.080, May 24, 1990, Paving of New Parking Lots. It is in the attainment plan as a control measure and was not included in the

first LMP.

13 SCAPCA Resolution 07

- 15 Agency name change from SCAPCA to SRCAA10
November 2015 After 10 years of trying to track multiple private companies, most were small and tended not to stay in business from year to year, and finding that the larger private companies did not use 250 tons of sanding material in a season R egulation 6.14 w as amended to remove private sanding and sweeping companies from the requirements

. It was decided that is was m ore effective to control particulate emissions from paved surfaces on private property using R egulation 6.05

, Particulate Matter & Preventing Par ticulate Matter from becoming Airborne. As long as the sanding or sweeping is on private property, not a public roadway, SRCAA can require that the m aterial be cleaned up if it beco me s a problem or material is tracked onto a public roadway. T raffic speed s in parking lots and driveways do

not cause much particulate matter to become airborne and are not considered a significant contributor to particulate levels . Tracking on to critical street s during the winter months is mitigated by the cities doing freque nt sweeping of these roadways as required by Section 6.14

.

The City of Spokane, Spokane County and the Washington Department of Transportation have submitted Sanding and Sweeping Plan s as required by SRCAA Regulation Section 6.14. With its incorporatio n on March 31, 2003 the City of Spokane Valley submitted their plan in 2005 taking over the portion of the Spokane County Plan that is now within the City of Spokane Valley boundaries. Annual
report s are on file with SRCAA.

Control Measures for Residen tial Wood
Combustion

– The following regulations were adopted to address PM 10 and PM 2.5 from Residential Wood Combustion, use of woodstoves and fireplaces.

• SRCAA Article VIII Solid Fuel Burning Device
Standards 14

• WAC 173

- 433 Solid Fuel Burning Device

Stan dards

SRCAA has implemented a solid fuel burning device curtailment program for Spokane County

, when PM pollution impairs air quality SRCAA restricts wood burning. When SRCAA calls burn bans for the area, woodstove use is restricted and
outdoor burn ing i s prohibited. The SRCAA outdoor burning rule is not included as a control

measures as it has never been considered a significant contributor to “worst

- case” residential

wood combustion and no credit was taken in the

attainment SIP.

Burn bans can be call ed in two stages and for
either the “Smoke Control Zone” as shown in Figure 3 or the whole of Spokane County. The

14 This rul e has been amended to conform to the state WAC 173

- 433, SRCAA Resolution 14

- 08 July 10, 2014 and will be submitted to EPA as a SIP revision. Should there be any problem with its adoption into the SIP the previously approved rule is sufficient to assure co mpliance with the PM 10 NAAQS. Figure 3 . Smoke Control Zone11
November 2015 Smoke Control Zone encompasses the entire SCMA and includes additional areas that extend farther into the drainage b asins of the Spokane River, Little Spokane River and Latah Creek, all of which can impact the SCMA during stagnant weather conditions.

• A Stage 1 ban prohibits the use of all uncertified wood heating devices when pollution levels approach unhealthful leve ls. As defined in the WAC and SRCAA Artic le VIII a Stage 1 burn ban (first stage of impaired air quality) is declared if meteorological conditions are predicted to

cause PM 2.5 levels to exceed 35 μg/m 3 in the next 48 hours, based on a 24 hour average.

• A Stage 2 burn ban (second stage of impaired air quality) is declared if meteorological conditions are not expected to change in the next 24 hours, PM 2.5 levels have reached 25 μg/m 3
and a Stage 1 ban has not been sufficient to reduce the increasing PM 2.5 t rend . A Stage 2 ban may be declared without first declaring a Stage 1 ban if PM 2.5 levels are at or above 25 μg/m 3

, meteorological conditions have cause a rapid rise in PM 2.5 levels and 35 μg/m 3 may be exceeded
in the next 24 hours.

The Stage 1 and 2 bur n bans are designed to maintain the PM 2.5 standard and are protective of the PM 10 standard. PM 2.5 is monitored at our primary site at Augusta in addition to multiple locations throughout Spokane County and the SCMA.

Wind Blown Dust

– The SCMA is covered b y the Washington State Department of Ecology Columbia Plateau Windblown Dust Natural Events Action Plan (NEAP) . Windblown dust events will be evaluated for qualification under the Exceptional Events Rule (EER). If appropriate, exceedances will be flagged for
exclusion of data from EPA’s AQS database to hold for future demonstration submittal. If values qualify for EER treatment, and they have regulatory significance, documentation will be submitted per EER requirements

.

SRCAA Orders

– In addition to R egulations and Resolutions the following agency O rders were issued and remain in place from the first 10

- year LMP

.

• SCAPCA 15 Order No. 91

- 01, December 12, 1991 , Alternate Opacity Limit for Kaiser Aluminum

• SCAPCA Order No. 96

- 03, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

• SCAPCA Order No. 96

- 04, April 24, 1996, Revised May 8, 1996, Limiting Potential to Emit, Kaiser

Aluminum

• SCAPCA Order No. 96

- 05, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

• SCAPCA Order No. 96

- 06, October 19, 2000, Limiting Potential to Emit, Kaiser Aluminum

T hese O rders have been included in the Kaiser Aluminum Title V Air Operating Permit as federally
enforceable.



## 7. Contingency Measures

CAA Section 175(A) requires a maintenance plan to include continge ncy measures necessary to ensure prompt correction of any violation of the standard that may occur after redesignation.

15 In 2007 the Board of the Spokane County Air Pollution Control Authority (SCAPCA) changed the Authority’s name to the Spokane Regional Clean Air Agency (SRCAA), Resolution #07

- 15, May 3, 200712
November 2015 Contingency Measure for Paved Roads

– SRCAA’s Regulation 1, Section 6.14 C. 4 require review and
modification of emission reduction a nd control plans for paved roads to provide sufficient reduction in

PM 10 . SRCAA will consider additional control measures for paved roads, including reinstating requirements on businesses and private sweeping and sanding contractors removed in 2004.

Cont ingency Measure for Unpaved Roads

– S RCAA Regulation 1, Section 6.15 G., provides a procedure in the event that emissions from unpaved roads cause a violation of the PM 10 standard

. T he applicable governmental entities shall modify their emission reduction plan s to e nsure compliance with the

standard.

Contingency Measure for Residential Wood Combustion

– S RCAA’s Regulation 1, Article VIII , Section 8.09 p rovides a procedure for prohibition of the use of uncertified woodstoves in the Smoke Control
Zone for t he sole purpose of meeting CAA requirements for contingency measures.

Contingency Measure Trigger

– The c ontingency measures will be triggered if a violation of the PM 10 standard occurs in the SCMA based on FRM and/or FEM monitoring. A violation of the P M 10 standard will be determined by the procedures outlined in 40 CFR Part 50, Appendix K

– Interpretation of th e NAAQS for Particulate Matter.



## 8. Commitment to Continued Monitoring

EPA considers continued monitoring especially important in a LMP area beca u se there is no cap on
emissions; LMPs do not require an emissions budget

. Emissions in the SCMA are not expected to grow enough to threaten compliance with the standards as discussed in Section 3.

SRCAA commits to maintaining a PM 10 NAAQS compliance mon itor through the LMP period. The monitor will be maintained and operated in accordance with federal siting and design criteria set forth

in 40 CFR Part 58 and Ecology’s PM 10 Standard Operating Procedures . Any changes to the monitor will be proposed under Ecology’s annual network plan and subject to EPA approval.



## 9. Verification of Continued Attainment

SRCAA will calculate the SCMA PM 10 3 and 5 year design value s annually and submit them t o Ecology for inclusion in the annual monitoring network report by April 30 th each year through 2025 to confirm the

area continue s to meet the PM 10 NAAQS. A 3

- year PM 10 design value below 150 μg/m 3 or a 3

- year

average of 1 or fewer exceedances demonstrates continued compliance with the PM 10 NAAQS 16

. A 5

- year design value s calculated in accordance with the LMP guidance of less than 98 μg/m 3 shows the area’s continued qualification for the LMP option. Ecology will include a statement in the annual network report to inform EPA of continued attainment and LMP qualification f or the SCMA.

16 Using the method in 40 CFR Part 50 Appendix K

– Interpretation of the National Ambient Air Quality Standards
for Particulate Matter 2.0 Attainment Determinations13
November 2015 

## 10. Summary of Maintenance Plan Commitments
Commitments made in this maintenance plan are summarized in Table 3

.

Table 3 . Second 10

- Year LMP Commitments

Section Commitment Responsible Agenc y
3 Annual calculation of the SCMA PM 10 5

- year design value through 2025 to show continued qualification for the LMP option. Report to Ecology. SRCAA

3 Reporting to EPA on c ontinued qualification of the SCMA for the LMP option in the annual monitoring ne twork report

. Ecology

7 Implementation of the contingency measures if the SCMA violates the PM10 standards based on monitoring. SRCAA

8 Continued Monitoring of PM 10 in the SCMA through 2025. SRCAA

9 Annual calculation of the SCMA PM 10 3

- year design val ue through 2025 to assess compliance with the PM 10 standard. Report to Ecology. SRCAA

9 Reporting to EPA on continued PM 10 Attainment of the SCMA in the annual monitoring network report. Ecology



## 11. Required Plans Complete

The SCMA was redesignated to at tainment for the 1987 24

- hour PM 10 standard in 2005. EPA approved
the first 10

- year maintenance plan in August of 2005. This second LMP ensures compliance through 2025 and fulfills the final requirement for maintenance plans specified by the CAA.



## Summary **of Control and Contingency Measures**

Rules

SRCAA Section 6.05 Particulate Matter & Preventing Particulate Matter from becoming Airborne

SRCAA Section 6.14 Standards for Control of Particulate Matter on Paved Surfaces

SRCAA Section 6.15 Standards for Cont rol of Particulate Matter on Unpaved Roads

SRCAA Article VIII Solid Fuel Burning Device Standards 17

WAC 173

- 433 Solid Fuel Burning Device Standards

Resolutions & Orders City of Spokane Resolution 90

- 93, October 8, 1990, Street Paving City of Spokane Res olution 91

- 42, June 17, 1991, Six Year Comprehensive Street Program City of Spokane Resolution 93

- 43, May 10, 1993, Street Sweeping & Reduced Use of Sanding Materials Spokane County Resolution 90

- 1219, October 9, 1990, Street Paving Spokane County Resoluti on 04

- 0461, 2004, County Zoning Code, Chapter 14.802 Off

- street Parking and Loading Standards
SCAPCA Order No. 91

- 01, December 12, 1991, Alternate Opacity Limit for Kaiser Aluminum

17 As amended 1/6/94 Resolution 94

- 02 . The 2014 amendments , 7/10/2014 Resolution 14

- 08, is proposed as a separate SIP amendmen t

.14
November 2015 SCAPCA Order No. 96

- 03, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

SCAPCA Order No. 96

- 04, April 24, 1996, Limiting Potential to Emit, Kaiser Aluminum

SCAPCA Order No. 96

- 05, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

SCAPCA Order No. 96

- 06, October 19, 2000, Limiting Potential to Emit, Kaiser Aluminum

Contingency Measures

SRCAA Section 6.14 C.4., Standards for Control of Particulate Matter on Paved Surfaces

SRCAA Section 6.15 G., Standards for Control of Particulate Matter on Unpaved Roads

SRCAA Section 8.07 & Section 8.09, Ban on Uncertified Stoves15
November 2015 

## Appendix A. **Limited Maintenance Plan Qualification**

Design Values The SCMA design value based on FRM and FEM 24

- hour PM10 Monitoring data from the Ferry St

. and Augusta Ave. sites in Spokane, Washington. The LMP Guidance directs the design value b e based on the most recent five years of data. The most recent five years of data is from 2010

- 2014 using a
combination of FRM and FEM data from the Spokane

- Augusta site.

SCMA Design Value The PM10 SIP Development Guideline (SIP Guideline) allows determi ning the design value based on

Table 4

. Tabular Estimation of PM 10 Design Values of observation ranges that designates the highest value to be used for the design concentration. The relevant values are shown in Table 5 below.

Table 4 . Tabular Estimation of PM 10 Design Values 18

Number of Values Data Point to be Used

1

- 347 Highest Value

348

- 695 Second Highest Value

696

- 1042 Third Highest Value

1043

- 1390 Fo urth Highest Value

Table 5 . Tabular Estimation of PM 10 Look

- Up Concentrations Using Table 6

- 1 of PM 10 SIP Guidelines

Spokan e Ferry St FRM and FEM data 2006

- 2009 Spokane Aug usta Ave. FRM and FEM 2009

- 2014

5

- year Period Number of

O bservations Look

- Up Concentration μg/m 3 Data Point Used for

Concentration

2007

- 2011 901 89 Third Highest Value

2008

- 2012 779 94 Third Highest Value

2009

- 2113 819 84 Third Highest Value

2010

- 2014 1047 80 Fourth Highest Value

Since the value for 2010

- 2 014 is below 98 μg/m 3 , the value stipulated in the LMP guidance, the SCMA

meets this condition.

Motor Vehicle Regional Analysis To qualify for the PM 10 LMP option, an area should expect only limited growth in on

- road motor vehicle

PM 10 emissions. This me ans the area must pass the Motor Vehicle Regional Analysis, found in

Attachment B of the LMP Guidance. The result of the analysis must be less than 98 μg/m 3 , the margin of Safety (MOS) value for the 24

- hour PM 10 standard.

The following methodology was us ed to determine whether increased emissions from on

- road mobile sources could, in the next 10 years, increase concentrations in the SCMA and threaten the assumption
of maintenance that underlies the LMP Guidance.

DV + (VMT pi x DV
mv ) < MOS

18 PM

- 10 SIP Development Guidelines, publication EPA 450/2 86

- 001, Table 6

- 1, pp.6

- 516
November 2015 5,000,000 5,500,000 6,000,000 6,500,000 7,000,000 7,500,000

2010 2015 2020 2025 2030 

# VMT

VMT

Linear (VMT) Where:

DV = Th e area’s design value based on the most recent 5 years of data, μg/m3

VMT pi = The projected percent increase in vehicle miles traveled (VMT) on paved roads over the next 10 years

VMT upi = The projected percent increase in vehicle miles traveled (VMT) on unpaved roads over the next 10 years

DV
mv = Motor vehicle design value based on on

- road mobile portion of the attainment year inventory, μg/m3

MOS = Margin of safety for 24

- hour PM 10 standard is 98 μg/m3

Step 1. Determine the 5

- year design value (DV) The design value for the 5

- year s of data (2010

- 2014) as shown above is 80 μg/m 3

.

Step 2. Determine the percent increase in maintenance area average VMT over the next ten years (VMT pi

)

The VMT data for the SCMA for 2011 and 2025 was supplied by the Spokane Regional Transportation Council (SRTC). The percent increase in VMT was calculated by taking the difference between 201 5 and 2025 VMT per day and determining the % change. VMT on unpaved roads within the SCMA are not expected to increase and are given a value of 0 percent

. This is the same assumption made and included
in the first 10

- year LMP , so the first calculation is done with the same assumptions

. In addition the s ame calculations are done with the estimated increase on all roadways paved and unpaved

. VMT values are:

Table 6 . Modeled VMT Data 19

Area Year

2010 2020 2030

PM 10 Boundary 5,694,290 6,383,360 7,277,925 Spokane County 8,408,329 9,491,705 10,832,029

Interpolating between the 2010, 2020 and 2030 gives the 2015 and 2025 results as:

2025 = 6,830,643

201 5 = 6,038,825

This is a 1 0 year increase of 791,817.5 VMT

Percent Increase (VMT pi ) = 13%

VMT upi = 0%

Step 3. Determine the motor vehicle design
value based on on

- road mobile portion of the attainment inventory (DV
mv

).

19 Modeled VMT data from SRTC’s current model set used for “Horizon 2040”, their long range transportation plan that was approved in December of 2013. Figure 4 . Out Year VMT Estimate Plot17
November 2015 The third paragraph of Attac hment B of the LMP Guidance offers: “Please note that DV
mv is derived by multiplying DV by the percentage of the attainment year inventory represented by on

- road mobile sources. This variable should be based on both pri mary and secondary PM 10 emissions of the on

- road mobile portion of the attainment year inventory, including road dust. ” Again to be conservative in our
calculations the emissions from construction are not used in the total of all sources. This has the eff ect of increasing the contribution of onroad emissions to t he design value. This further e nsures that the
NAAQS will mos t likely not be exceeded based o n expected VMT growth.

T he SCMA is further split into paved and unpaved road dust

.

• DV mvp = DV * (Tota l paved mobile / Total all sources)

• DV mvup = DV * (Total unpaved mobile/ Total all Sources)

• DV
mv et = DV * (Total on

- road mobile / Total all Sources)

Table 7 . Mobile Source Contribution to Design Value
Category Annual, tons/year Ton s/Day Contribution to Design Value μg/m 3

Vehicle Exhaust and Tire Wear 346 .94 DV
mv et 5.2587 Road Dust, Paved 780 196 DV mvp 10.9650 Road Dust, Unpaved 567 2.45 20 DV mvup 13.7063

Total , all sources (less construction) 3323 14.3 DV
mv 29.93

As calculated in the First 10

- year Maintenance Plan

Step 4. Calculate the Regional Emissions Analysis DV + (VMT pi * DV mvp ) + (VMT upi * DV mvup ) + (VMT pi * DV

mv et ) = 80 + (. 13 * 10.9650 ) + (0 * 13.7063 ) + (. 13 * 5.2587 ) = 8 2 μg/m 3

Step 5. Compare with MO S ≤ 98

8 2 μg/m 3 < 98 μg/m 3

U s ing a 13% increase in all onroad mobile emission the calculation is as follows : Step 4. Calculate the Regional Emissions Analysis DV + (VMT p i * DV

mv ) = 80 + (.13 * 29.93 ) = 8 4 μg/m 3

Step 5. Compare with MOS ≤ 98

8 4 μg/m 3 < 9 8 μg/m 3

The SCMA qualifies for the LMP option with either calcu lation

.

20 Maximum Daily V alue18
November 2015 

## Appendix B. Ecology 2014 Network Report/EPA approval

Purpose of the report The Department of Ecology (Ecology) reviews its ambient air quality monitoring network each year to

ensure that it collects adequate, representative, and useful air quality data on which to base policy decisions. This report summarizes the results of the 201 4 review. These results include:

• Identifying modifications to Ecology’s ambient air monitoring networ k since the 2013 annual network report

• Identifying proposed modifications to the network for the upcoming year

• Documenting Ecology’s ambient air quality monitoring needs, goals, and priorities

2014 Network Report, PM Section The following is the PM monit oring section of the Ecology 2014 Network report for all monitors in Washington State, reference s to other monitoring ha s been removed.

Particulate Matter 10 (PM 10 , 81102)

Recommendations/Proposed Modifications: None

Additional Monitors: None. Continue all identified sites Thurston County Maintenance Area (Lacey PM 2.5 ) The Lacey College Street PM 2.5 nephelometer site (530670013) is being used to assure continued compliance with the PM 10 NAAQS as well as to confirm the Thurston County Maintenance Area (T CMA) continues to meet the qualification criteria of EPA’s Limited Maintenance Plan (LMP) approach.

A 5

- year NPM 10 design value below 98μg/m3 demonstrates the TCMA continues to qualify for the LMP approach. The Lacey

- College Street nephelometer site (53 670013) 5

- year PM 10 design value estimate
for 2009

- 2013 was 45 μg/m3. The PM 10 design value estimate for 2011

- 2013 was 45 μg/m3. This current design value estimates demonstrate the TCMA complies with the PM 10 standard and continues to meet EPA’s LMP qualif ication criteria.

Kent, Seattle, & Tacoma PM 10 Maintenance Areas Three and five year design values for the Kent, Seattle, and Tacoma PM 10 Maintenance Areas were calculated using the table look up method and the statistical fit method outlined in the LMP guidance

document.

A 3

- year PM 10 design value of 150 μg/m3 or below demonstrates continued compliance with the PM 10 NAAQS. A 5

- year design value below 98 μg/m3 is required to qualify for the LMP approach. Design values calculated using the table look u p method fall within the range of uncertainty of the statistical fit method. Because they are the most conservative values, only the statistical fit values are presented

here.

The PM 2.5 FEM TEOM at James St

. and Central Ave

. (530332004) is used to assure continued compliance

with the PM 10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The five year design value is 47±4 μg/m3 and the three year design value is 47±3 μg/m3.19
November 2015 The PM 2.5 FEM TEOM at Seattle

- Duwamish (530330 057) is used to assure continued compliance with the

PM 10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The five year design value is 58±6 μg/m3 and the three year design value is 59±8 μg/m3.

The PM 2.5 Nephelometer at Tacoma

– Alexander Ave

. (530530031) is used to assure continued compliance with the PM 10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The five year design value is 64±12 μg/m3 and the three year design value is 6 5±13 μg/m3.

Table 8

. Particulate Matter 10 PM 10 , Parameter code 81102

AQS# Site Name Est. Type Scale Sampling Type Action for 2014

530650004 Colville, S Oak 11/96 3/07 SLAMS Neighborhood Continuous Continue

530050002 Kennewi ck, Metaline
Ave

. 10/94 SLAMS Neighborhood Continuous Continue

530630021 Spokane, Augusta Ave. 3/09 SLAMS Middle 1/6 Continue

530630021 Spokane, Augusta Ave. 3/09 Collocated Middle 1/12 Continue

530770009 Yakima, S 4th 4/00 SLAMS Neighborhood 1/6 Con tinue

Additional Monitors: None.

Recommendations/Proposed Modifications: None

Note:

Thurston County Maintenance Area (Lacey PM 2.5 ) The Lacey College Street PM 2.5 nephelometer site (530670013) is being used to assure continued compliance with the P M 10 NAAQS as well as to confirm the Thurston County Maintenance Area (TCMA) continues to meet the qualification criteria of EPA’s Limited Maintenance Plan (LMP) approach.

A 5

- year NPM 10 design value below 98μg/m3 demonstrates the TCMA continues to qualif y for the LMP approach. The Lacey

- College Street nephelometer site (53670013) 5

- year PM 10 design value
estimate for 2009

- 2013 was 45 μg/m3. The PM 10 design value estimate for 2011

- 2013 was 45 μg/m3. This current design value estimates demonstrate the TCM A complies with the PM 10 standard and continues to meet EPA’s LMP qualification criteria.

Kent, Seattle, & Tacoma PM 10 Maintenance Areas Three and five year design values for the Kent, Seattle, and Tacoma PM 10 Maintenance Areas were calculated using the table look up method and the statistical fit method outlined in the LMP guidance
document.”

A 3

- year PM 10 design value of 150 μg/m3 or below demonstrates continued compliance with the PM 10 NAAQS. A 5

- year design value below 98 μg/m3 is required to qual ify for the LMP approach. Design values calculated using the table look up method fall within the range of uncertainty of the statistical fit20
November 2015 method. Because they are the most conservative values, only the statistical fit values are presented

here.

The PM 2.5 FEM TEOM at James St

. and Central Ave

. (530332004 ) is used to assure continued compliance

with the PM 10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The five year design value is 47±4 μg/m3 and the three year de sign value is 47±3 μg/m3.

The PM 2.5 FEM TEOM at Seattle

- Duwamish (530330057) is used to assure continued compliance with the

PM 10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The five year design value is 58±6 μg/m 3 and the three year design value is 59±8 μg/m3.

The PM 2.5 Nephelometer at Tacoma

– Alexander Ave

. (530530031) is used to assure continued compliance with the PM 10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The f ive year design value is 64±12 μg/m3 and the three year design value is 65±13 μg/m3.

Colville, S Oak

Site Name Colville, S Oak
AQS ID 530650004
GPS coordinates LAT/LONG: 048 32' 41" / 117 54' 13"

Location On the roof of the Courthouse

Address 215 South Oak, Colville County Stevens Distance to road from gaseous probe (meters) 20 Traffic count (AADT, year) N/A21
November 2015

Groundcover Asphalt, cement, grass

Statistical Area Not in an urban area

Monitor Information Pollutant, POC

Parameter code 81102 Basic monitoring objectives(s) NAQQS Compliance Site type(s) Population Exposure Monitor type(s) SLAMS
Instrument manufacturer and model Thermo TEOM

Method code 079 FRM/FEM/ARM/other FEM Collecting Agency Ecology Analytical Lab N/A Reporting Agency Ecology Spatial scale Neighborhood Monitoring start date 11/96 Current sampling frequency Continuous Calculated sampling frequency N/A Sampling season Year

- round Probe height (meters) 2 Distance from supporting structure (m eters) N/A Distance from obstructions on roof (meters) N/A Distance from obstructions not on roof (meters) N/A Distance from trees (meters) 50+ Distance to furnace or incinerator flue (meters) N/A Distance between collocated monitors (meters) N/ A Unrestricted airflow (degrees) 360 Spacing from minor sources No minor sources Probe material for reactive gases Teflon Residence time for reactive gases (seconds) N/A Changes within the next 18 months? None anticipated Is it suitable for compa rison against the PM 10 NAAQS? Yes

Design value 0.34

Purpose: Colville S. Oak is a neighborhood scale site for PM 10 established in 1996, located in the commercial/residential area of Colville on the roof of the Courthouse.

Exceedences: This site has ex ceeded the standard for PM 10 in the past 3 years (2011).

Kennewick, Metaline Avenue

– (BCAA)

Site Name Kennewick, Metaline Avenue
AQS ID 530050002
GPS coordinates LAT/LONG: 046 13' 06" / 119 12' 03"

Location On the roof of the Kennewick Skills Ce nter
Address 5929 West Metaline, Kennewick County Benton22
November 2015 Distance to road from gaseous probe (meters) 84 Traffic count (AADT, year) N/A

Groundcover Rooftop

- asphalt, ground

- grass & asphalt

Statistical Area Richland

- Kennewick

- Pasco, WA

Kennewi ck, Metaline Avenue Monitor Information Pollutant, POC

Parameter code 81102 Basic monitoring objectives(s) NAQQS Compliance Site type(s) Population Exposure Monitor type(s) SLAMS
Instrument manufacturer and model Thermo TEOM

Method code 079 FRM/FEM/ARM/other FEM Collecting Agency Benton County Clean Air Agency Analytical Lab N/A Reporting Agency Ecology Spatial scale Neighborhood Monitoring start date 10/94 Current sampling frequency Continuous Calculated sampling frequency N/A Sampling season Year

- round Probe height (meters) 7 Distance from supporting structure (meters) N/A Distance from obstructions on roof (meters) 18 Distance from obstructions not on roof (meters) N/A Distance from trees (meters) 66

Distance to furnace or incinerator flue (meters) N/A Distance between collocated monitors (meters) 6 Unrestricted airflow (degrees) 360 Probe material for reactive gases Teflon Residence time for reactive gases (seconds) N/A Changes within the next 18 months ? None anticipated Is it suitable for comparison against the PM 10 NAAQS? Yes Design value 1.6 (0.4 1 )

Purpose: Kennewick is a neighborhood scale site for PM 10 established in 1994 and located in the downtown Kennewick area. It is representative of Kenn ewick and the surrounding area which is subject

to windblown dust.

Exceedences: Kennewick had 3 exceedances of 24

- hr PM 10 standard in 2013 and Washington plans to pursue exceptional event status for them.

1 Pending exceptional events demonstration for h igh winds on 9/15/2013, 10/28/2013 and 11/02/2013.

Spokane, Augusta Ave.

– (SRCAA)

Site Name Spokane, Augusta Avenue.
AQS ID 53063002123
November 2015 GPS coordinates LAT/LONG: 047 39' 39" / 117 21' 26"

Location On the roof of the Spokane Region Clean Air Agency

Address 3104 E. Augusta Ave., Spokane County Spokane Distance to road from gaseous probe (meters) 27 Traffic count (AADT, year) N/A

Groundcover Membrane roof, asphalt

Statistical Area Spokane, WA

Monitor Information Pollutant, POC

Paramete r code 81102 Basic monitoring objectives(s) NAQQS Compliance Site type(s) Population Exposure Monitor type(s) SLAMS

- Collocated
Instrument manufacturer and model Thermo TEOM
Method code 079 FRM/FEM/ARM/other FEM/FRM Collecting Agency Spoka ne Region Clean Air Agency Analytical Lab Ecology Reporting Agency Ecology Spatial scale Middle Monitoring start date 3/09 Current sampling frequency Continuous & 1/6 Calculated sampling frequency N/A Sampling season Year

- round Probe height (meters) 3 Distance from supporting structure (meters) 0.5 Distance from obstructions on roof (meters) N/A Distance from obstructions not on roof (meters) N/A Distance from trees (meters) N/A Distance to furnace or incinerator flue (meters) N/A Distance between collocated monitors (meters) N/A Unrestricted airflow (degrees) 360 Spacing from minor sources No minor sources Probe material for reactive gases Teflon Residence time for reactive gases (seconds) N/A Changes within the next 18 m onths? None anticipated Is it suitable for comparison against the PM10 NAAQS? Yes Design value 0.35

Purpose: Augusta Ave. is a middle scale site for PM 10 located in a commercial area of Spokane. The site is representative of the Spokane area which i s a past PM 10 nonattainment area.

Exceedences: We had one exceedance of the 24

- hour PM 10 standard at Spokane. We have flagged this value, leaving open the possibility that we could submit an exceptional event demonstration to EPA in
the future.

Yakima, S 4th

– (YRCAA)24
November 2015

Site Name Yakima, S 4th
AQS ID 530770009
GPS coordinates LAT/LONG: 046 35' 42" / 120 30' 44"

Location On the roof of Yakima Comprehensive Mental Health
Address 402 South 4 th Avenue, Yakima County Yakima
Distance to road from gaseous probe (meters) N/A Traffic count (AADT, year) N/A

Groundcover Membrane roof, cement

Statistical Area Yakima, WA

Monitor Information Pollutant, POC

Parameter code 81102 Basic monitoring objectives(s) NAQQS Compliance Site type(s) Po pulation Exposure Monitor type(s) SLAMS
Instrument manufacturer and model Grasby Anderson

Method code 063 FRM/FEM/ARM/other FRM Collecting Agency Yakima Region Clean Air Agency Analytical Lab Ecology Reporting Agency Ecology Spatial scale N eighborhood Monitoring start date 4/00 Current sampling frequency 1/6 Calculated sampling frequency N/A Sampling season Year

- round Probe height (meters) 2 rooftop, 12 ground Distance from supporting structure (meters) N/A

Distance from obstruc tions on roof (meters) 7 Distance from obstructions not on roof (meters) N/A Distance from trees (meters) 34 Distance to furnace or incinerator flue (meters) N/A Distance between collocated monitors (meters) N/A Unrestricted airflow (degrees) 36 0 Spacing from minor sources No minor sources Probe material for reactive gases Teflon Residence time for reactive gases (seconds) N/A Changes within the next 18 months? None anticipated Is it suitable for comparison against the PM 10 NAAQS? Yes

D esign value 0

Purpose: S 4th is a neighborhood scale site for PM 10 located in a commercial/residential area near downtown Yakima. The site is representative of the Yakima area, a past PM 10 nonattainment area.

Exceedences: This site has not exceeded sta ndard for PM 10 in the past 3 years

.25
November 201526
November 201527
November 2015 

## Appendix C. Emission Inventory Documentation

Ecology’s 2011 triennial emissions inventory (2011 EI ) was use d for the 2 nd 10

- year LMP . The 2011 estimates were available as annual emissions for Spokane County. In th e original maintenance plan and LMP (2005) SRCAA contracted with E.H. Pechan and Associates, Inc. to develop a very detailed emission inventory. For this LMP we concentrated on the significant emissions involved in the three worst

- case scenarios from the a ttainment plan and first LMP ; unpaved roads, paved roads and residential wood

combustion

. Temporal and spatial allocations to the maintenance area of most of the source categories

were the same as develop ed by Pechan 21 for the first LMP

. For any emissions not modified from the 2011 Emissions Inventory, refer to the discussion found in that document. For categories where local data was not available Ecology accepted the EPA estimates in the NEI for the missing categories.

Point Sources

Point source emis sions were based on 2011 data 22 submitted directly to SRCAA by the Air Operating Permit sources and spatially allocated based on facility location.

Nonpoint Sources Residential Wood Combustion, Paved Road Dust and Unpaved Road Dust are nonpoint sources. These emissions are typically estimated by multiplying an activity level, such as wood combusted or Vehicle Miles Traveled (VMT), by an emission factor in mass per activity.

Emissions = Activity level x Emission Factor

Estimation methods and data source s for these nonpoint sources are described below.

Residential Wood Combustion Residential wood combustion (RWC) emissions are based on the 2011 Emission Inventory. RWC consists of home heating and recreational use of woodstoves , fireplaces, and fireplace inserts . Activity parameters for the 2011 EI include the type of wood burning devices [certified (catalytic and noncatalytic) woodstoves, uncertifie d woodstoves and fireplaces], the amount and species of wood burned from each device and seasonal, daily a nd hourly usage rates. A survey was conducted in 2007 by the National Research Center (NRC2007). It covered the central Puget Sound region. The NRC2007 survey was used in the 2011 EI to characterize all counties except those classified as eastern WA

range land. Spokane County was characterized using the household weighted average of all the Puget Sound survey areas from the NRC2007 except King County . Emission factors in pounds of PM 10 per ton
of wood burned were taken from version 1 of EPA’s 2011 Residen tial Wood Combustion tool.

Temporal and spatial allocations to the maintenance area of the RWC emissions were the same as developed by Pechan 23 for the first LMP.

21 E.H. Pechan and Associates, Inc. , 2002 PM 10 Emission Inventory for the Spokane Nonattainment Area, September
2004, Pecha n Report No. 04.08.002/9443.003

22 2011 emission data was obtained from the SRCAA 2012 AOP billing information.

23 E.H. Pechan and Associates, Inc. , 2002 PM 10 Emission Inventory for the Spokane Nonattainment Area, September
2004, Pecha n Report No. 04.08.002/9443.00328
November 2015 Table 9 . Spokane County Residential Wood Combustion Emissions

Dev ice Type Emission

rate by
type Tons Burned (Spokane County) Emissions Tons/year

Fireplace 23.6 21459 253.22

Inserts

, certified catalytic 20.4 4319 44.05

W oodstoves

, certified catalytic 20.4 6931 70.70

Inserts

, certified non

- catalytic 19.6 12956 126.96

W oodstoves

, certified non

- catalytic 19.6 2079 203.78

Inserts , uncerti fi ed 30.6 15933 243.77

Woodstoves , uncertified 30.6 25574 391.28

Pellet stoves 3.06 2291 3.51 Firelogs, all devices 29.32 1051 15.41

Total 1352.68

Paved Road Dust

P aved Ro ad Dust emissions are based on the 2011 EI . Average Daily Vehicle Miles Traveled (ADVMT) for Spokane County was estimated by Washington State Department of Transportation (WSDOT ) under the national Department of Transportation’s Highway Performance Monito ring System (HPMS). HPMS is a system of traffic counts collected over several urban and rural sampling areas. WSDOT makes estimates of county VMT by roadway (functional) classification using the HPMS data. PM 10 emission rates in grams per mile were calc ulated using equation 2 in EPA’s AP42. Monthly emissions wer e cal culated using monthly adjustment factors and summing the appropriate months to get seasonal and annual

emissions.

Unpaved Road Dust Similar to paved roads, unpaved road dust emissions are g enerated as vehicles pass alo ng unpaved roadways and disturb the layer of loose material on or near the road surface. The unpaved road

calculation excludes emissions from exhaust and brake and tire wear, which are estimated as part of the

onroad mobile so urce emissions.

ADVMT is used to estimate unpaved road activity and calculate dust emissions. The County Road Administration Board (CRAB) provided roadway mileage and ADVMT estimates on unpaved roads by county. WSDOT provided estimates of city jurisdi ction unpaved roadway mileage for each county. The CRAB data was used to develop average daily traffic (ADT) per mile; this was multiplied by the latest miles of unpaved roads in Spokane County and the SCMA obtained from the Spokane Regional Transportatio n Council to get the ADVMT

.

Ecology used equation 2 of EPA’s AP42 to develop monthly unpaved roads PM 10 Emission Rates in lb/mi,

Table 3

- 8 of the 2011 EI . SRCAA used ADVMT for Spokane Cou nty’s SCMA unpaved roads and the monthly emission rate to get daily and annual unpaved road emissions.29
November 2015 Table 10 . Unpaved Road Emissions Calculations

Spokane County SCMA

Month lb/mi Days ADVMT Tons/month Tons/day ADVMT Tons/month Tons/day

JAN 0.202 31 116708 365 11.79 12929 37 1.19

FEB 0.2 83 28 116708 462 16.51 12929 47 1.67

MAR 0.121 31 116708 219 7.06 12929 22 0.71

APR 0.167 30 116708 292 9.75 12929 29 0.98

MAY 0.202 31 116708 365 11.79 12929 37 1.19

JUN 0.306 30 116708 536 17.86 12929 54 1.80

JUL 0.323 31 116708 584 18.85 12929 59 1 .90

AUG 0.417 31 116708 754 24.33 12929 76 2.45

SEP 0.362 30 116708 634 21.12 12929 64 2.13

OCT 0.229 31 116708 414 13.36 12929 42 1.35

NOV 0.264 30 116708 462 15.41 12929 47 1.55

DEC 0.296 31 116708 535 17.27 12929 54 1.74

Annual Unpaved Road Emis sions 5624 567 Average Daily Unpaved Road Emissions 15.42 1.56

ADVMT ADT/mi le 96.5 Spokane Co

miles 1209.41 116708

SCMA miles 121.97 1177030
November 2015 

## Appendix D. Changes to **Regulation 1**

**– Article VI** 

**– Emissions Prohibited**  **since adoption into th e SIP** 

SRCAA notes that Section 6.05(A) is a nuisance provision outside the scope of regulating criteria pollutants under Clean Air Action section 110 and requests that the EPA correct the SIP to remove this provision.

SECTION 6.05 PARTICULATE MATTER AND PREVENTING PARTICULATE MATTER FROM

BECOMING AIRBORNE

A. It shall be unlawful for any person to cause or allow the discharge of particulates in sufficient numbers to unreasonably cause annoyance to any other person when deposited upon the real property
of others , except as follows:

.

1. Temporarily due to breakdown of equipment provided the breakdown is reported as soon as possible but no later than the next regular working day and repairs are promptly made.

2. The time period allowed by the Control Office r for the owner or operator to meet the compliance order.

B. It shall be unlawful for any person to cause or permit particulate matter to be handled, transported or stored without taking reasonable precautions to prevent the particulate matter from becom ing
airborne.

C. It shall be unlawful for any person to cause or permit a building or its appurtenances or a road to be constructed, altered, repaired, or demolished without taking reasonable precautions to prevent particulate matter from becoming airborn e. Reasonable precautions to prevent particulate matter from becoming airborne must also be used on roads used as detour routes around roads, or section of road that are being constructed, altered, repaired, demolished, or closed for any purpose.

D. It sh all be unlawful for any person, including the owner or person in control of real property to cause or allow particulate matter to be deposited upon a paved roadway open to the public without taking every reasonable precaution to minimize deposition. Reason able precautions shall include, but are not limited to, the removal of particulate matter from equipment prior to movement on paved streets and the prompt removal of any particulate matter deposited on paved streets.

E. It shall be unlawful for any person to cause or allow visible emissions of fugitive dust unless reasonable precautions are employed to minimize the emissions. Reasonable precautions may include, but are not limited to, one or more of the following:

1. The use of control equipment, enclosur es, and wet (or chemical) suppression techniques, and curtailment during high winds;

2. Surfacing roadways and parking areas with asphalt, concrete, or gravel;

3. Treating temporary, low traffic areas (e.g., construction sites) with water or chemical

sta bilizers, reducing vehicle speeds, constructing pavement or rip rap exit aprons, and cleaning31
November 2015 vehicle undercarriages and tires before they exit to prevent the track

- out of mud or dirt onto paved public roadways; or

4. Covering or wetting truck loads or al lowing adequate freeboard to prevent the escape of

dust

- bearing materials.

SECTION 6.14 STANDARDS FOR CONTROL OF PARTICULATE MATTER ON PAVED SURFACES

A. Applicability. The provisions of Section 6.14 shall apply to any government agency of a state, county

, city or local government municipal corporation or private company that applies or contracts for application of sanding materials to or mechanically sweeps or vacuums or contracts for sweeping or vacuuming of paved surfaces within the PM10 Nonattainment a rea , or within the PM10 maintenance area after the nonattainment area is redesignated to attainment. This Section shall also apply to all suppliers of sanding materials to be used by these affected entities.

B. Definitions.

1. Affected Entity is any gove rnmental agency of a state, county, city or local government municipal corporation as or private company that applies sanding material to, or mechanically sweeps or vacuums paved surfaces within the PM10 Nonattaiment area described in Subsection

A

.

2. App roved Laboratory means a certified or approved facility capable of performing the specified tests in a competent, professional, and unbiased manner in accordance with ASTM testing procedures.

3. The Authority is the Spokane County Air Pollution Control Au thority Regional Clean Air Agency

.

4. Base Sanding Amount is the average amount of sanding materials applied per lane mile by each affected entity within the PM10 Nonattainment Area during the 1992

– 1993 season or another base season, as requested by an affected entity and approved by the Authority.

5. Durability Index means the percent loss of weight as determined using ASTM "Standard Test Method for Resistance to Degradation of Small

- Size Coarse Aggregate by Abrasion and Impact in the Los Angeles Machi ne", designated C131

- 89, or other approved ASTM procedure.

6. Full Deployment means that sanding materials have been applied to all priority roadways targeted for treatment during a snow/ice event are sanded

.

7. Percent Fines means the percent material p assing a #100 sieve as determined by the American Society for Testing Materials (ASTM) "Standard Method for Sieve Analysis of Fine and Coarse Aggregates", Designation C136

- 84a (1988) (American Highway and Transportation Officials designation T27

- 88), or ot her approved ASTM procedure.

8. PM10 Maintenance Area means the same as the PM10 Nonattainment area unless otherwise defined in an approved PM10 Maintenance Plan.32
November 2015 8 9

. PM10 Nonattainment Area means the Spokane County PM10 Nonattainment Area, defined

in CF R Title 40, Part 81, as designated on November 15, 1990. This definition will remain in effect, even after the United States Environmental Protection Agency makes a determination that the PM10 standard that existed before September 16, 1997, no longer appl ies to Spokane County. Retaining the definition ensures compliance with the Environmental Protection Agency’s Guidance for Implementing the 1

- Hour Ozone and Pre

- Existing PM10 NQQAS, dat3ed December 29, 1997, by continuing implementation of control measure s in the State Implementation Plan and preserving air quality gains.

9 10

. Priority Roadway means any street, arterial, or highway, within the PM10 Nonattainment Area, with more than 15,000 average daily traffic count, and any connecting entrance or exit

r amp.

1 0 1

. Recycled Sanding Materials means previously used sanding materials which have been collected from roadways or paved areas and are then re

- used as is, after washing, or after blending with new sanding materials.

1 1 2

. Sanding Materials means nat ural geologic materials, excluding salt and other de

- icing chemicals, used to provide increased traction on roadways or paved areas.

1 2 3

. Season means the period beginning, November 1, in one calendar year and concluding on April 30, the next calendar yea r.

C. Emission reduction and control plans. Each affected entity shall submit to the Authority an initial plan, including an implementation schedule describing the programs and methods to be used to reduce PM10 emissions from paved surfaces , within 30 day s after the effective date of this regulation

. If the affected entity incorporated after the effective date of this regulation, that entity shall submit an initial plan within 180 days of incorporation. In reviewing each plan, the Authority shall allow con sideration of mobility and transportation safety factors. Approval of any plan shall require that the Authority

determine In approving any initial plan, or plan revision the Authority must make a finding , in consultation with the Washington State Departmen t of Ecology, that the cumulative effect of the plans submitted by all affected entities will achieve and maintain at least a 70% reduction, from the 1992

- 1993 base season, in the 24 hour PM10 emissions from paved surfaces.

1. Each plan is subject to ap proval by the Authority and shall address but not necessarily be
limited to , at a minimum, all of the following:

a. Base sanding amount;

b. Percent sanding reduction goal;

c. Sanding materials specifications to be employed;

d. Criteria for application of sanding materials. Where and when sanding materials are applied;

d e . Identification of priority roadways;33
November 2015 e f . Locations, application rates, and circumstances for the use of chemical deicers and other sanding alternatives;

f g . Street sweeping frequenc y and technology to be employed;

h. Factors for determining when and where to initiate street sweeping following a sanding event, with the goal of expeditious removal of sanding materials from priority roadways when safety and mobility requirements have b een satisfied;

h i . An implementation schedule giving the estimated dates of start and completion, if applicable, of each part of the plan; and

j. A schedule for removal of sanding materials from all surfaces to which they are applied.

2. Beginning 30 da ys after the effective date of the regulation, t T he plans submitted shall be implemented by each affected entity

. U u pon approval of each plan , the affected entity shall implement the approved plan

.

3. Within 45 days of submittal of the reports required in Subsection G F . of this Section, the Authority shall determine if the plan commitments have been met and shall notify any each
affected entity that has failed to meet plan commitments fully implement its plan

.

4. If the authority determines that any g overnmental entity has failed to meet the plan commitments, the Authority, shall require that any affected governmental entity submit a revised plan within 30 days of notification by the Authority. The revised plan shall establish methods for meeting the plan commitments. Any revised plan must be implemented upon approval by the Authority.

5 4 . If the Authority , after consultation with the affected entities, the Washington Department of Ecology, and the United States Environmental Protection Agency, deter mines that the emission reduction and control plans do not provide for sufficient reduction in PM10 emissions to achieve the emission reduction credit for paved road surfaces as contained in the State Implementation Plan, the Authority may require the any or all affected governmental entities to modify their plans in order to achieve additional reductions.

5. Each affected entity shall review their approved plan within 90 days of the effective date of the amendment to this regulation and every five (5) yea rs thereafter and within 90 days of the Authority’s determination made pursuant to Subsection C. 4. and revise the plan as appropriate to ensure that identified priority roadways reflect changes in traffic counts and driving patterns and that all aspects o f the plan reflect current sanding and sweeping technologies, programs, and schedules of the affected entity and requirements of the Authority. All amended plans are subject to approval by the Authority.

D. Sweeping requirements. Beginning the effective date of this regulation, the City of Spokane, Spokane County, and the Washington State Department of Transportation, or their contractors, shall clean all priority roadways in an expeditious manner following each event when road conditions are34
November 2015 appropriate and safety and mobility requirements have been satisfied. Cleaning shall be accomplished with broom sweepers or a more effective technique approved by the Authority.

E D . Sanding Materials Specifications

1. Material Standards. No affected entity shall us e sanding materials, whether new or recycled, which equal or exceed 3% fines and 25% durability index.

2. Contractual Requirements. After the effective date of this regulation, no affected entity shall execute a contract for the purchase of sanding materi als unless the contract includes standards at least as stringent as those set forth in Subsection E.1. of this Section.

F E . Testing

1. Supplier Testing Requirements

a. Suppliers of sanding materials shall have tests performed by an approved laboratory

t o determine the percent fines and durability index on representative samples of their sanding materials which are supplied to affected entities.

b. The sampling and test frequency and methodology used shall ensure that the samples are representative and e nable the supplier to certify to the affected entity that the actual sanding materials supplied for use will meet the requirements of Subsection E D

. of this Section.

2. User Requirements. Affected entities or their contractors shall have at least one test performed by an approved laboratory to determine the percent fines and durability index on all recycled materials at least once for the first 250 tons of recycled materials used each season and at least once for every 500 tons of recycled materials used t hereafter during the same season.

3. Authority Audits. The Authority may enter the site of any affected entity or supplier of sanding materials subject to this Section for the purpose of obtaining a sample of sanding
materials to determine if the material s meet the requirements of Subsection E D . of this Section.

G F . Reporting

1. Supplier Reporting Requirements. Prior to, or upon, delivery of sanding materials, suppliers shall provide affected entities that use their sanding materials a report demonstrati ng that the supplier has met all testing requirements of this Section applicable to the time period in which deliveries are made. The supplier shall certify in writing to the affected entity that the sanding materials meet the requirements of Subsection E D . of this Section.

2. Affected Entity Reporting Requirements

a. Affected entities that use recycled sanding materials shall submit to the Authority copies of the results of testing conducted according to Subsection F E .2. of this Section

no later than 30 days after the tests are conducted.35
November 2015 b. No later than June 30, of each year, affected governmental entities shall submit a report to the Authority containing information for the preceding season on:

1) the total amount of sanding materials (both new and r ecycled) and salt and other deicing chemicals used;

2) the number of lane miles sanded, salted and deiced; and

3) the number of full deployment episodes; and

4) the same information specified in b.(1), b.(2) and b.(3), for all private companies performi ng sanding, salting, or deicing services under contract with the affected governmental intity.

c. No later than June 30, of each year, private companies that use 250 tons of sanding material or more per season for non

- governmental applications within the PM10 nonattainment area shall submit a report to the Authority containing information for the preceding season on the total amount of sanding materials (both new and recycled) and salt and other deicing chemicals used;

d c . Within 7 calendar days of award ing a contract for the purchase of sanding materials to a supplier, an affected entity shall notify the Authority of the supplier's name and location of the aggregate sources from which the materials will be supplied.

e d . Affected entities shall maintain on file reports received under the provisions of
Subsection G F .1. of this Section for a period of three (3) years.

3. Sweeper Reporting Requirements

a. Affected entities shall maintain monthly records to document the information

described below. No later than June 30, of each year, each affected entity shall submit a report to the Authority which that shall contain the information described below for each priority roadway

.

1) Date of each sweeping operation;

2) Priority L l ane miles swept;

3) All other lane miles swept;

3 4 ) Type of equipment used; and

4 5 ) Number of passes on priority roadways

.

5) The same information specified in a.(1), a(2), a(3) and a.(4), for all private companies performing sweeping under a contract with the affected governmental entity.36
November 2015 4. Authority Audits. All records generated under the provisions of this Section shall be made available for inspection upon request by the Authority.

H G . Alternate Test Methods and Standards. Alternate percent fines and durability index test proc edures may be approved by the Authority should they be determined to provide a measure that is equivalent to the test procedures of this Section.

I H . Alternate Sanding Materials. Experimentation with new sanding materials may be approved by the Authority provided the Authority finds that the impact of such experiments will not cause or contribute to a violation of the National Ambient Air Quality Standard (NAAQS) for PM10 a failure to maintain the
70% reduction in PM10 emissions from the 1992

- 93 base seaso n, as described in Subsection C

.

J. Failure to comply with this Section will subject affected entities and/or suppliers to penalties as provided in Article II of this Regulation.

SECTION 6.15 STANDARDS FOR CONTROL OF PARTICULATE MATTER ON UNPAVED ROADS

A. Applicability. The provisions of Section 6.15 shall apply to:

1. The City of Spokane, the Town of Millwood, Spokane County, and other governmental entities responsible for the maintenance of unpaved public roads within the PM10 Nonattainment Area;

and

2. Those specific unpaved public roads which have been identified by Ecology or the Authority for inclusion in an implementation plan or a maintenance plan for control of PM10 emissions.

B. Definitions.

1. Authority means the Spokane County Air Pollutio n Control Authority Regional Clean Air Agency

.

2. Ecology means the Washington Department of Ecology.

3. EPA means the United States Environmental Protection Agency or the Administrator of the United States Environmental Protection Agency or his/her desi gnated representative.

4. Implementation Plan has the same meaning as in Section 110 of the Federal Clean Air Act (42 USC 7410).

5. Maintenance Plan has the same meaning as in Section 175A of the Federal Clean Air Act (42 USC 7505).

6. Palliative means salts and other hygroscopic materials, petroleum resins, asphalt emulsions, adhesives, chemical soil stabilizers or other surface treatment materials acting as a method of dust control, and not prohibited for use by any local, state, or federal law, rule, or regulation.

7. Paved means application of concrete, asphaltic concrete, asphalt, or combination thereof as a means of forming a permanent surface for a road.37
November 2015 8. PM10 Nonattainment Area means the Spokane County PM10 Nonattainment Area, defined in

CFR T itle 40, Part 81, as designated on November 15, 1990. This definition will remain in effect, even after EPA makes the determination that the PM10 standard that existed before September 16, 1997, no longer applies to Spokane County. Retaining the definition ensures compliance with the EPA’s Guidance for Implementing the 1

- Hour Ozone and Pre

- Existing PM10 NAAQS, dated December 29, 1997, by continuing implementation of control measures in the Implementation Plan and preserving air quality gains.

9. Reasonable Further Progress has the same meaning as in Section 171(1) of the Federal Clean Air Act (42 USC 7501).

C. Emission Reduction and Control Plan. Each applicable governmental entity shall submit an Emission Reduction and Control Plan for approval by the Aut hority, which includes the following for each applicable unpaved road:

1. A schedule for paving, periodic application of palliative, or implementation of other control

measures.

2. Specification of the type of palliative to be applied and its application rate, paving specifications, or specifications of other control measures with sufficient detail for the Authority

to determine emission reductions.

D. Emission Reduction Contingency Plan. Each applicable governmental entity shall submit an Emission

Reduc tion Contingency Plan for approval by the Authority, which includes the following for each applicable unpaved road:

1. A schedule for paving, periodic application of palliative, or implementation of other control

measures.

2. Specification of the type of palliative to be applied and its application rate, paving specifications, or specifications of other control measures with sufficient detail for the Authority

to determine emission reductions.

E. Effective dates. The applicable governmental entities shal l comply with the following effective dates whenever an unpaved road is identified by Ecology or the Authority for control of PM10 emissions as part of an implementation plan:

1. For any unpaved road so identified prior to the effective date of Section 6. 15 of this regulation, the entity shall submit the Emission Reduction and Control Plan or Emission Reduction Contingency Plan, whichever applies, within 60 days after the effective date.

2. For any unpaved road so identified after the effective date of Se ction 6.15 of this regulation, the entity shall submit the Emission Reduction and Control Plan or Emission Reduction Contingency Plan, whichever applies, within 60 days after such identification.

F. Approval and Implementation.38
November 2015 1. The Authority shall rev iew the Emission Reduction and Control Plan submitted pursuant to Section 6.15.C. of this Regulation and within 60 days after approval by the Authority, the applicable governmental entity shall implement the plan.

2. The Authority shall review the Emissio n Reduction Contingency Plan submitted pursuant to Section 6.15.D of this Regulation and upon approval by the Authority and within 60 days after the EPA makes the findings in Section 6.15.G of this Regulation, the applicable governmental entity shall imple ment the plan.

3. The Authority will not approve an Emission Reduction and Control Plan or an Emission Reduction Contingency Plan unless the Authority finds that the plans will achieve the total emission reductions required by the implementation plan. If the Authority finds that a plan will not achieve the required reductions, then the applicable governmental entity shall revise the plan to achieve the required reductions and resubmit the plan for review by the Authority.

G. Findings by EPA. In the event the EPA determines that the Spokane PM10 Nonattainment Area has failed to make Reasonable Further Progress or has failed to timely attain a National Ambient Air Quality Standard for PM10 or has violated a National Ambient Air Quality Standard for PM10 afte r redesignation as an attainment area, and emissions from unpaved roads are determined by the EPA, in consultation with Ecology and the Authority, to be a contributing factor to such failure or violation, the applicable governmental entities shall comply w ith the requirements of Section 6.15.F.2 of this Regulation.

H. Reporting. Within 6 months after the effective date of Section 6.15 of this Regulation, and annually thereafter as determined by the Authority, each applicable governmental entity shall submi t a written report to the Authority which demonstrates compliance with the Emission Reduction and Control Plans and the Emission Reduction Contingency Plans.

I. Failure to comply. Failure to comply with Section 6.15 of this Regulation will subject affecte d entities to penalties as provided in Article II of this Regulation.

SECTION 6.16 MOTOR FUEL SPECIFICATIONS FOR OXYGENATED GASOLINE (Repealed 9/1/05,

Res. 05

- 19)