SUBJECT: Technical Support Document — District of Columbia, Maryland, and Virginia;

2002 Base Year Emissions Inventory, Reasonable Further Progress Plan,Contingency Measures, Reasonably Available Control Measures, and

Transportation Conformity Budgets for the Metropolitan Washington, DC 1997 8-Hour Ozone Moderate Nonattainment Area

FROM: Maria A.’Pino, Senior Air Quality Planning Specialist

Office of Air Program Planning

TO: File (2J 2sJ//ITHRU: Cristina Fernandez, Associate Directof

Office of Air Program Planning

This document provides a technical review of revisions to the District of Columbia,

Maryland, and Virginia State Implementation Plans (SIPs) for the Washington, DC-MD-VAmoderate 1997 8-hour ozone nonattainment area (the Washington Area). The District of

Columbia Department of the Environment (DDOE), the Maryland Department of the

Environment (MDE), and the Virginia Department of Environmental Quality (VADEQ) worked

together to develop a joint plan for the Washington Area to address emissions inventory,

reasonable further progress (RFP), reasonably available control measures (RACM) analysis, andRFP contingency measure requirements for the 1997 8-hour ozone national ambient air quality

standard (NAAQS). This plan, entitled “Plan to Improve Air Quality in the Washington, DCMD-VA Region, State Implementation Plan (SIP) for 8-Hour Ozone Standard, Moderate AreaSIP,” will be referred to as “the Washington Area 8-hour ozone plan” throughout this document.

The Washington Area 8-hour ozone plan was submitted to the Environmental Protection Agency

(EPA) as a SIP revision by DDOE on June 12, 2007, by MDE on June 4, 2007, and by VADEQ

on June 12, 2007. These SIP revisions also establish a motor vehicle emissions budget (MVEB)

for 2008 for the Washington Area.I. BACKGROUND

A. General Requirements

Section 182 of the Clean Air Act (CAA) and s 1997 8-hour ozone regulations (40

CFR 51.910) require each moderate and above 8-hour ozone nonattainment area to submit an

emissions inventory and RFP SIP revision that describes how the area will achieve actual

emissions reductions of volatile organic compounds (VOC) and nitrogen oxides (NOx) from a
Specifically, section 1 72(c)( 1) states the following: “Such plan provisions shall provide for the

implementation of all reasonably available control measures as expeditiously as practicable

(including such reductions in emissions from existing sources in the area as may be obtained

through the adoption, at a minimum, of reasonably available control technology) and shall

provide for attainment of the national primary ambient air quality standards.” Control measuresthat would advance the attainment date are considered RACM and must be included in the SIP.

RACM are necessary to ensure that the attainment date is achieved “as expeditious as

practicable.”

Phase 1 of the 8-hour ozone implementation rule, published on April 30, 2004 (69 FR

23951), set out criteria for classifying nonattainment areas under the 1997 8-hour ozone standard.The Phase 1 rule also addressed revocation of the 1-hour NAAQS; how anti-backsliding

principles will ensure continued progress toward attainment of the 8-hour ozone NAAQS;attainment dates; and the timing of emissions reductions needed for attainment. On November29, 2005, EPA published the Phase 2 final rule for implementation of the 8-hour standard. ThePhase 2 rule addressed the RFP control and planning obligations as they apply to areasdesignated nonattainment for the 1997 8-hour ozone NAAQS (70 FR 71612). The Phase 2 final

rule was revised on June 8, 2007 (72 FR 31727). Among other things, the Phase 1 and 2 rules

outline the SIP requirements and deadlines for various requirements in areas designated asmoderate nonattainment. The rules set a due date ofJune 15, 2007 for the required base yearemission inventory, RFP plan, modeling and attainment demonstration, RACM, MVEB, and

contingency measures (40 CFR 51.908(a)).

Section 182(b)(1) ofthe CAA and EPA’s 1997 8-hour ozone implementation rule (40

CFR 51.910) require each 8-hour ozone nonattainment area designated moderate and above to

submit for review and approval into its SIP an emissions inventory and RFP plan that describes

how the area will achieve actual emissions reductions of VOC and NOx from a baselineemissions inventory. For a moderate 8-hour ozone nonattainment area with an attainment datemore than 5 years after designation, a 15 percent RFP reduction in ozone precursor emissions is

required within 6 years (2002-2008). For a moderate area with an approved 15 percent rate-ofprogress (ROP) plan under the 1-hour standard, states can use reductions from VOC or NOx or acombination of either. For a moderate area without and approved ROP plan, a 15% reduction inVOC is required. The reductions may come from anywhere within the 8-hour nonattainmentarea. Table 1 outlines these requirements.

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anywhere within the 8

hour

nonattainment area.

In addition, RFP plans must include contingency measures, which are additional controls

that would be implemented ifthe area fails to make reasonable further progress. $ CAA

section 172(c)(9). Implementation of these measures would provide additional emissions

reductions of up to 3 percent ofthe adjusted base year inventory (or lesser percentage that willmake up the identified shortfall). RFP plans must also include a MVEB, which is the allowableon-road mobile emission an area can produce and continue to demonstrate RFP. 40 CFR 93.

B. The Washington Area

In 1997, EPA revised the health-based NAAQS for ozone, setting it at 0.08 parts per

million (ppm) averaged over an 8-hour time frame. EPA set the 8-hour ozone standard based on

scientific evidence demonstrating that ozone causes adverse health effects at lower ozone

concentrations and over longer periods oftime, than was understood when the pre-existing

1-hour ozone standard was set. EPA determined that the 8-hour standard would be more

protective of human health, especially children and adults who are active outdoors, and

individuals with a pre-existing respiratory disease, such as asthma.

On April 30, 2004 (69 FR 23951), EPA finalized its attainment/nonattainment

designations for areas across the country with respect to the 8-hour ozone standard. These

actions became effective on June 15, 2004. Among those nonattainment areas is the Washington

Area. This Washington Area includes the District of Columbia (the District); Arlington, Fairfax,

Loudoun, and Prince William Counties and the cities of Alexandria, Fairfax, Falls Church,

Manassas, and Manassas Park in Virginia (the Northern Virginia area) and Calvert, Charles,

Frederick, Montgomery, and Prince George’s Counties in Maryland. Pursuant to Phase 1 of the

8-hour ozone implementation rule, an area was classified under Subpart 2 ofthe CAA based on

its 8-hour design value ifthat area had a 1-hour design value at or above 0.121 ppm (the lowest

1-hour design value in Table 1 of Subpart 2). Based on this criterion, the Washington Area was

classified under Subpart 2 as a moderate nonattainment area. See 40 CFR 81.309, 81.321 and

8 1.347.

II. EVALUATION OF STATE SUBMITTAL

A. Base Year Emissions Inventory

An emissions inventory, required by section 172(c)(3) of the CAA, is a comprehensive,

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must cover emissions on an annual basis and also for on a typical ozone season day basis. Theinventories for RFP and attainment demonstration planning are computed based on a “typical”ozone season day.

DDOE, MDE and VADEQ (the States) along with the Metropolitan Washington Council

of Governments (MWCOG) worked together to develop a 2002 base year inventory for theWashington Area. This inventory is found in Chapter 3 and Appendix B ofthe Washington Area

8-hour ozone plan. A summary ofthe Washington Area 2002 base year VOC and NOx

emissions inventory is included in Tables 2a and 2b, below.

Table 2a. Washington Area 2002 Base Year VOC Emissions in Tons per Day (tad)

Source Category District of Maryland Virginia Source Category

Columbia Totals

Point 0.24 4.6 8.07 12.91

Area 16.81 92.49 83.35 192.64

Nonroad Mobile 8.91 63.82 53.06 125.79

On-road Mobile 13.09 56.13 47.71 116.94

Total (excluding biogenics) 39.05 217.04 192.19 448.28

Biogenic Emissions 13.63 166.7 134.41 314.74

Total 52.68 383.74 326.6 763.02

Table 2b. Washington Area 2002 Base Year NOx Emissions in Tons per Day (tpd)

District of . . . Source Category Source Sector . Maryland Virginia Columbia Total

Point 4.89 155.78 59.93 220.6

Area 2.16 6.77 15.32 24.25

Nonroad Mobile 10.54 34.21 40.97 85.72

On-road Mobile 23.7 132.27 110.68 266.65

Total (excluding biogenics) 41.29 329.03 226.9 597.22

Biogenic Emissions 0.1 1.75 1.22 3.07

Total 41.39 330.78 228.12 600.29

EPA Region III’s Air Quality Analysis Branch (AQAB) reviewed the 2002 base year

inventory for the Washington Area using the appropriate EPA policy and guidance. Please see

the attached “Technical Support Document (TSD) for the Emission Inventories for the

Washington DC-MD-VA 8 Hour Ozone State Implementation Plan (SIP) Base Year Inventory,”

prepared by Janet C. Kremer and signed by Walter Wilkie, Air Quality Analysis Branch Chief,

on February 4, 2009 (Washington Area Emission Inventory TSD). As discussed in detail in the

4
(

)(

) 

has been determined to be the 2002 adjusted base year inventory. Sections 182(b)(1)(B) and (D)

require the exclusion from the base year inventory of emissions benefits resulting from the

Federal Motor Vehicle Control Program (FMVCP) regulations promulgated by January 1, 1990and the Reid Vapor Pressure (RVP) regulations promulgated June 11, 1990 (55 FR 23666). The

FMVCP and RVP emissions reductions are determined by the state using EPA’s on-road mobilesource emissions modeling software, MOBILE6. The FMVCP and RVP emission reduétions are

then removed from the base year inventory by the state, resulting in an adjusted base year

inventory. The emission reductions needed to satisfy the RFP requirement are then calculatedfrom the adjusted base year inventory. These reductions are then subtracted from the adjusted

base year inventory to establish the emissions target for the RFP milestone year (2008).

For moderate areas like the Washington Area, the CAA specifies a 15 percent reduction

in ozone precursor emissions over an initial 6-year period. In the Phase 2 Rule (70 FR 71612),

EPA interpreted this requirement for areas that were also designated nonattainment and classified

as moderate or higher for the 1-hour ozone standard. In the Phase 2 Rule, EPA provided that an

area classified as moderate or higher that has the same boundaries as an area, or is entirelycomposed ofseveral areas or portions of areas, for which EPA fully approved a 15 percent plan

for the 1-hour NAAQS, is considered to have met the requirements ofsection 1 82(b)( 1) ofthe

CAA for the 8-hour NAAQS. In this situation, a moderate nonattainment area is subject to RFP

under section 1 72(c)(2) of the CAA and shall submit, no later than 3 years after designation for

the 8-hour NAAQS, a SIP revision that meets the requirements of 40 CFR 51.910(b)(2). The

RFP SIP revision must provide for a 15 percent emission reduction (either NOx andlor VOC)accounting for any growth that occurs during the 6-year period following the baseline emissionsinventory year, that is, 2002-2008.

The Washington nonattainment area under the 1-hour ozone standard was classified as

severe. For the 1-hour ozone NAAQS, EPA fully approved the 15% ROP plans for theWashington, DC 1-hour severe ozone nonattainment area on August 5, 1999 (64 FR 42600), July

19, 2000 (65 FR 44686), and October 6, 2000 (65 FR 59727). Therefore, according to the Phase

2 Rule, the RFP plan for the Washington Area may use either NOx or VOC emissions reductions

(or both) to achieve the 15 percent emission reduction requirement.

According to section 1 82(b)( 1 )(D) of the CAA, emission reductions that resulted from the

FMVCP and RVP rules promulgated prior to 1990 are not creditable for achieving RFP emission

reductions. Therefore, the 2002 base year inventory must be adjusted by subtracting the VOC

and NOx emission reductions that are expected to occur between 2002 and the future milestone

years due to the FMVCP and RVP rules.

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CAA measures turned off. Any other local inputs for vehicle inspection and maintenance(JIM) programs should be set according to the program that was required to be in place in

1990. Fuel RVP should be set at 9.0 or 7.8 depending on the RVP required in the local area

as a result of fuel RVP regulations promulgated in June 1990.

C) Calculate the difference between 2002 and 2008 VOC emissions factors calculated in Step B

and multiply by 2002 vehicle miles traveled (VMT). The result is the VOC emissions

reductions that will occur between 2002 and 2008 without the benefits of any post-1990 CAAmeasures. These are the non-creditable VOC reductions that occur over this period.

Calculate the difference between 2002 and 2008 NOx emissions factors calculated in Step B

and multiply by 2002 VMT. This result is the NOx emissions reductions that will occur

between 2002 and 2008 without the benefits of any post-1990 CAA measures. These are the

non-creditable NOx reductions that occur over this period.

D) Subtract the non-creditable VOC reductions calculated in Step C from the actual

anthropogenic 2002 VOC inventory estimated in Step A. Subtract the non-creditable NOx

reductions calculated in Step C from the actual anthropogenic 2002 NOx inventory estimated

in Step A. These adjusted VOC and NOx inventories are the basis for calculating the target

level of emissions in 2008.

E) The target level of VOC and NOx emissions in 2008 needed to meet the 2008 ROP

requirement is any combination of VOC and NOx reductions from the adjusted inventoriescalculated in Step D that total 18 percent. For example, the target level of VOC emissions in2008 could be a 10 percent reduction from the adjusted.

The States sets out the calculations for the adjusted base year inventory and 2008 RFP targetlevels in Section 5 of the Washington Area 8-hour ozone plan.

A) The Washington Area 2002 anthropogenic base year inventory is found in Table 5-1 ofthe

Washington Area 8-hour ozone plan, and is summarized in Table 3, below.

Table 3. Washington Area 2002 Anthronoenic Base Year Inventory (Ozone Season tnd)

Source Category VOC NOx

Point 12.91 220.6Area 192.64 24.25

Nonroad 125.79 85.72

On-Road 116.94 266.65

Total 448.28 597.22

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(i) 2002 On

Road 166.55 308.24

(ii) 2008 On-Road 154.10 276.63

Non-creditable Reductions (i) — (ii) 12.45 31.61

D & E) The State’s calculations ofthe Washington Area 2002 VOC inventory adjusted to 2008

and the VOC target level for 2008 are found in Table 5-5 ofthe Washington Area 8-hour

ozone plan, and are summarized in Table 5, below.

Table 5. Washington Area 2008 RFP Target Level Calculations (Ozone Season tpd)

Description Formula VOC

A 2002 Rate-Of Progress Base Year Inventory 448.28

B FMVCP/RVP Reductions Between 2002 And 2008 12.45

C 2002 Adjusted Base Year Inventory Relative To 2008 A -B 435.83

D FP Ratio 15%

E missions Reductions Required Between 2002 & 2008 C * D 65.37

F rarget Level for 2008 C -E 370.45

Please note that the States elected to RFP in the Washington Area using only VOC reductions.

As explained in Section A.I ofthis document, this is allowable. A moderate 8-hour ozonenonattainment area with and approved 15 percent ROP plan under the 1-hour standard can usereductions from VOC or NOx or a combination of either.C. Projected Inventories and Determination of RFP

The States describes their methods used for developing its 2008 projected VOC and NOx

inventories in Section 4.0 of the Washington Area 8-hour ozone plan. Projected uncontrolledand controlled 2008 VOC and NOx emissions are found Tables 4-5 and 4-6 ofthe Washington

Area 8-hour ozone plan. EPA Region III’s AQAB reviewed the procedures used to develop itsprojected inventories and found them to be reasonable. Please see the attached Washington Area

Emission Inventory TSD.

Projected controlled 2008 emissions for the Washington Area are summarized in Table 4-

9 and 4-10 ofthe Washington Area 8-hour ozone plan. The data from Tables 4-9 and 4-10 is

presented in Table 6, below.

7
Mobile 70.98 160.30

Total 358.84 493.22

To determine if 2008 RFP is met in the Washington Area, the total projected controlled

emissions must be compared to the target levels calculated in the previous section ofthisdocument. As shown below in Table 7, the total VOC emission projections meet the 2008 RFP

emission target. Therefore, the 2008 RFP in the Washington Area is demonstrated.Table 7. Determination of whether RFP is met in 2008 in the Washington Area

.

. VOC Emissions Description (tpd)

A Total 2008 Projected Controlled Emissions 358.84B Target Level for 2008 370.45

R1?PmetifA<B Yes

D. Control Measures and Emission Reductions for RFP

The control measures the States took credit for in order to meet the RFP requirement in the

Washington Area are described in Section 6.0 of the Washington Area 8-hour ozone plan. To

meet the RFP requirement for the Washington Area, the States used a combination of area sourcecontrol, nonroad mobile, and on-road mobile measures.

1. Area Source Measures

. Mobile Repair and Refinishing

This rule establishes VOC limits for paints using in mobile repair and refinishing. The VOClimits are consistent with federal limits for mobile equipment refinishing materials. The rulealso requires improved transfer efficiency application equipment, enclosed spray gun cleaning,

and minimal training. This rule applies to all manufacturers of paints used in mobile repairand refinishing and operators of mobile repair and refinishing facilities.

• Portable Fuel Containers Rule, Phase I

This measure introduces performance standards for portable fuel containers and spouts, and is

intended to reduce emissions from storage, transport and refueling activities. The rule alsoincluded administrative and labeling requirements.

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Consumer and commercial products are items sold to retail customers for household, personal

or automotive use, along with the products marketed by wholesale distributors for use in

institutional or commercial settings such as beauty shops, schools, and hospitals. VOC

emissions result from the evaporation ofsolvent contents in the products or solvents used as

propellants. This measure requires the reformulation of certain consumer products to reducetheir VOC content.

• Solvent Cleaning Operations Rule

This rule establishes hardware and operating requirements and alternative compliance optionsfor vapor cleaning machines used to clean metal parts. These machines are used in

manufacturing operations to clean grease, wax, oil and other contaminants from parts when a

high level or cleanliness is necessary. The rule also affects cold cleaners, which are used in

automobile and maintenance facilities and industrial maintenance shops. The rule applies toall counties in the nonattainment area.

• Reformulated Consumer Products Rule (Consumer and Commercial Products), Phase II

Phase II ofthe Consumer and Commercial Products Rule contains more stringent VOCcontent limits than the existing federal consumer products nile. The rule also contains

requirements for labeling and reporting. Manufacturers of various specialty chemicals named

in the rule, such as aerosol adhesives, floor wax strippers, dry cleaning fluids and general

purpose cleaners are affected by this rule.

Area Source 2008 Emission Reductions: 30.98 tpd VOC and 0 tpd NOx.

2. Nonroad Measures — NONROAD Model

The States calculated the emission reductions for 2008 RFP using the EPA NONROAD

model for the following measures:

• Non-Road Gasoline Engines Rule -Phase I and II Emissions Standards for Gasoline-Powered

Nonroad Utility Engines

This federal measure established emissions for small nonroad, spark-ignition (i.e., gasolinepowered) utility engines. The measure affects gasoline-powered (or other spark-ignition) lawn

and garden equipment, construction equipment, and other utility equipment rated at or below

19 kilowatts (an equivalent of 25 or fewer horsepower). Phase 2 ofthe rule applied further

controls on handheld and non-handheld outdoor equipment. (See 60 FR 34581, 65 FR 24267,and 64 FR 15207.)

9
• Emissions Standards for Spark Ignition Marine Engines

This federal measure controls exhaust emissions from new spark-ignition gasoline marine

engines, including outboard engines, personal watercraft engines, and jet boat engines. Once

the program is fully implemented, manufacturers ofthese engines must demonstrate to EPAthat hydrocarbon emissions are reduced, by 75% from present levels, by testing enginesrepresentative of the product line before sale and after use. (See 61 FR 52087.)

• Emissions Standards for Large Spark Ignition Engines

This federal measure controls VOC and NOx emissions from several groups of previouslyunregulated nonroad engines, including large industrial spark-ignition engines, recreational

vehicles, and diesel marine engines. The emission standards apply to all new engines sold inthe United States and any imported engines manufactured after these standards begin.

Controls on the category oflarge industrial spark-ignition engines are first required in 2004.

Controls on the other engine categories are required beginning in years after 2005. (See 67

FR 68241.)

• Reformulated Gasoline Use in Nonroad Motor Vehicles and Equipment

This federally mandated measure requires the use of lower polluting “reformulated” gasolinein the Washington Area. See “Reformulated Gasoline in On-road Vehicles,” above. This

measure affects the various nonroad mobile sources that bum gasoline, such as lawn mowers,

trimmers, generators, and compressors. The program has been in place in the Washington

Area since 1995.

Nonroad Mobile 2008 Emission Reductions (NONROAD Model): 36.91 tpd VOC and

11.68 tpd NOx.

As discussed in the Washington Area Emission Inventory TSD, EPA Region III’s AQAB

reviewed the procedures that the State’s used to develop its projected inventories, including theuse of the NONROAD model, and found them to be reasonable.

3. Other Nonroad Measures

• Standards for Locomotives

This national measure establishes emission standards for newly manufactured and

remanufactured diesel-powered locomotives and locomotive engines. This regulation took

effect in 2000. (See 63 FR 18998.)

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High-Tech Vehicle Inspection and Maintenance (Enhanced I/M)

The CAA requires enhanced J/M programs in serious, severe, and extreme ozone

nonattainment areas, metropolitan statistical areas (MSA), and consolidated MSA (CMSA)portions ofthe Ozone Transport Region (OTR) with urbanized populations over 200,000.Enhanced JIM was required in the Washington 1-hour ozone nonattainment area. That

requirement is still in place due to the anti-backsliding provisions of CAA section 110(1). InMaryland and the District of Columbia, emissions tests are performed at test-only stations.

Virginia tests vehicles in stations that may also perform repairs using a decentralized program.

• Federal Tier I Vehicle Emission Standards and New Federal Evaporative Test Procedures

The CAA required cleaner federal motor vehicle emissions standards (Tier I standards)

beginning with model year 1994. The CAA also requires a uniform level of evaporativeemission controls, which are more stringent than most evaporative controls used in older

vehicles. These federally implemented programs affect light duty vehicles and trucks. See 40

CFR Part 86.

• National Low Emission Vehicle (NLEV) Program

The NLEV program is a vehicle technology program that provides light duty vehicles and

trucks that are significantly cleaner than pre-1998 models. The National LEV program was

developed through an unprecedented, cooperative effort by the northeastern states, auto

manufacturers, environmentalists, fuel providers, EPA, and other interested parties. NationalLEV vehicles are 70% cleaner than 1998 models. The National LEV program will result in

substantial reductions in VOCs and NOx. The States have adopted the NLEV program and

EPA approved the States’ programs into their SIPs. (See 64 FR 72564 and 65 FR 44981.)

• Tier 2 Vehicle Standards

This federal measure set emissions standards for all passenger vehicles, including sport utility

vehicles (SUVs), minivans, vans and pick-up trucks. These regulations also require lowerlevels of sulfur in gasoline. The new tailpipe standards are set at an average standard of 0.07grams per mile for NOx for all classes of passenger vehicles beginning in 2004. (See 65 FR6697.)

• Heavy Duty Diesel Engine (HDDE’) Rule

This federal program affects heavy-duty diesel engines in trucks. Under the HDDE rule, truck

manufacturers must comply with more stringent tailpipe standards for NOx and hydrocarbons

starting in 2004. (See 62 FR 54694.)

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5. Transportation Control Measures (TCMs) and Vehicle Technology, Fuel, orMaintenance Measures

Section 108(f) ofthe CAA provides examples of TCMs that can be implemented to reduce

emissions from mobile sources. Most TCMs are designed to reduce vehicle miles traveled or

vehicle trips or improve the flow oftraffic. In conjunction with state departments oftransportation and local transit authorities, the States identified a number of projects designed toreduce vehicle travel and mitigate traffic congestion in the Washington Area. These measures

include purchase of alternative-fueled vehicles, improvements to bicycle and pedestrian facilities,

and improvements to transit services and access to transit facilities. Additional information onTCMs is contained in Appendix F ofthe Washington Area 8-hour ozone plan.

TCM and Vehicle Technology, Fuel and Maintenance Measures 2008 Emission Reductions:

0.19 tpd VOC and 0.49 tpd NOx.

6. Voluntary Bundle

States can take credit for emission reductions from voluntary measures pursuant to EPA’sSeptember 2004 and August 2005 policy memoranda, “Incorporating Emerging and Voluntary

Measures in a State Implementation Plan (SIP)” and “Guidance on Incorporating Bundled

Measures in a State Implementation Plan.” The States developed a set of measures for thevoluntary bundle that includes new measures as well as some voluntary measures from the

Washington Area 1-hour ozone SIP. The States included an estimate of the emission reductions

from the voluntary measures in Appendix H of the Washington Area 8-hour ozone plan.

Voluntary Bundle 2008 Emission Reductions: 0.19 tpd VOC and 0.28 tpd NOx.

7. RFP Emission Reduction Summary

While many ofthe emission control measures used to meet RFP also resulted in NOx emission

reductions, the States elected to meet RFP in the Washington Area using only VOC reductions.

Table 8 summarizes the VOC emission reductions that the States claimed in the Washington

Area 8-hour ozone plan to meet RFP in the Washington Area.

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Onroad Measures (TCMs) 0.19

Voluntary Bundle 0.19Total 74.32

E. Contingency Measures for Failure to Meet RFP

Section 1 72(c)(9) ofthe CAA requires a state with a moderate or above ozone

nonattainment area to include sufficient additional contingency measures in its RFP plan in casethe area fails to meet RFP. The same provision ofthe CAA also requires that the contingencymeasures must be fully adopted control measures or rules. Upon failure to meet an RFPmilestone requirement, the state must be able to implement the contingency measures without

any further rulemaking activities. Upon implementation ofsuch measures, additional emissionreductions of at least 3 percent of the adjusted 2002 baseline emissions must be achieved. For

more information on contingency measures, see the April 16, 1992 General Preamble (57 FR

13512) and the November 29, 2005 Phase 2 8-hour ozone implementation rule (70 FR 71612).

1. Requirements and Target Calculations

To meet the requirements for contingency emission reductions, EPA allows states to use

NOx emission reductions to substitute for VOC emission reductions in their contingency plans.

However, the States chose to use only VOC reductions to meet the contingency measurerequirement in the Washington Area. The States discuss the Washington Area contingency

measures for failure to meet RFP in Section 11 ofthe Washington 8-hour ozone plan. The States

calculated the contingency VOC reduction for the Washington Area as shown in Table 9, below.

The RFP contingency requirement may be met by including in the RFP plan a demonstration of

18 percent VOC & NOx RFP. The additional 3 percent reduction above the 15 percent

requirement must be attributed to specific measures.

13
.FP Emissions Reductions Required Between 2002 & 65 37 E2008 C*D 0

F Contingency Percentage 0.3% 2.7%

1.31 15.27

0 Contingency Emission Reduction Requirements C * F

H Contingency Measure Target Level for 2008 C- E- G 369.15 550.34

2. VOC Contingency Measures

• Portable Fuel Containers Rule, Phase I and Phase II

This measure introduces performance standards for portable fuel containers and spouts, and isintended to reduce emissions from storage, transport and refueling activities. The rule alsoincluded administrative and labeling requirements.

2008 VOC Emission Reductions: 1.31 tpd

3. NOx Contingency Measures

• Clean Air Interstate Rule (CAIR)

CAIR requires NOx and S02 emission reductions from large fossil fuel-fired electricgenerating units. The rule is set up in several phases with the first phase ofNOx reductions to

come by 2009. EPA approved Virginia CAIR program into the Virginia SIP in 2007 (72 FR73602). EPA put a Federal Implementation Plan (FTP) in place for the District in 2006 (71

FR 25328). On July 11, 2008, the DC Circuit Court issued its decision to vacate and remand

both CAIR and the associated CAIR FIPs (North Carolina v. EPA, 531 F.3d 836 (DC Cir.,2008). However, in response to EPA’s petition for rehearing, the court issued an order

remanding CAIR to EPA without vacating either CAIR or the CAIR FIPs (North Carolina v.

EPA, 550 F.3d 1176 (DC Cir., 2008)). The court, thereby, left CAIR in place in order to“temporarily preserve the environmental values covered by CAIR” until EPA replaces it with

a rule consistent with the court’s opinion (id. at 1178). Because CAIR has been remanded to

EPA without vacatur, CAIR and CAIR FIPs are currently in effect in Virginia and the District.

• Maryland’s Healthy Air Act (HAA)

The HAA requires reductions in NOx, SO2, and mercury emissions from Maryland’s largestand oldest coal fired power plants. EPA approved the HAA into Maryland’s SIP in 2008.(See 73 FR 51599.)

2008 NOx Emission Reductions: 15.3 tpd (total)

(DC: 0.66 tpd; MD: 12.19 tpd; VA: 2.45 tpd)

14
g

, 

g

y 

q

g

Area.

Table 10. Evaluation of the Washington Area 2008 RFP Contingency MeasureRequirement

Description VOC NOx

(tpd) (tpd)

A Total 2008 Projected Controlled Emissions 358.84 493.22B Contingency Measure Target Level for 2008 369.15 550.34Contingency measure requirement met if A < B Yes Yes

F. RACM Analysis and Determination

1. RACM Requirement

Pursuant to section 172(c)(1) ofthe CAA, states are required to implement all RACM as

expeditiously as practicable for each nonattainment area. Specifically, section 1 72(c)( 1) states

the following: “In general—Such plan provisions shall provide for the implementation of allreasonably available control measures as expeditiously as practicable (including such reductionsin emissions from existing sources in the area as may be obtained through the adoption, at a

minimum, of reasonably available control technology) and shall provide for attainment ofthenational primary ambient air quality standards.” Furthermore, in EPA’s Phase 2 Rule, EPAdescribes how states must include a RACM analysis with their attainment demonstration (70 FR71659). The purpose ofthe RACM analysis is to determine whether or not reasonably availablecontrol measures exist that would advance the attainment date for nonattainment areas. Control

measures that would advance the attainment date are considered RACM and must be included inthe SIP. RACM are necessary to ensure that the attainment date is achieved “as expeditious as

practicable.” RACM is defined by the EPA as any potential control measure for application topoint, area, on-road and nonroad emission source categories that meets the following criteria:

• The control measure is technologically feasible;• The control measure is economically feasible;

• The control measure does not cause “substantial widespread and long-term adverse

impacts;’’

• The control measure is not “absurd, unenforceable, or impracticable;” and

• The control measure can advance the attainment date by at least one year.

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• be enforceable;• be technically feasible;• be economically feasible (proposed as a cost of $3,500-$5,000 per ton or less);

• not create substantial or widespread adverse impacts within the region; and• reduce emissions from the source being controlled more than the de minimis threshold,

proposed as 0.1 tons per day.As stated in section 7.1.8 ofthe Washington Area 8-hour ozone plan, preliminary

modeling results indicate that any RACM would need to collectively reduce NOx and/or VOC

emission by more than 20 to 40 tpd by the 2008 ozone season in order to advance the attainmentdate by one year.

The States evaluated 322 potential stationary, area, nonroad, and mobile source control

measures against the RACM criteria. Several measures would have provided some emissionreductions. However, the States determined that none ofthe mandatory measures would achievereductions in the 2008 ozone season. In addition, the States determined that the total reductionsfrom these measures would be less than 20 to 40 tpd. Therefore, the States concluded that thereare no RACM appropriate to advance the Washington Area’s attainment date.

3. EPA Evaluation

EPA has reviewed the States’ analysis. To meet the RACM requirement, the States must

demonstrate that it has adopted all RACM necessary to move the Washington Area towardattainment as expeditiously as practicable and to meet all RFP requirements. As demonstratedabove in section IV ofthis document, the States have met the RFP requirements for theWashington Area.

The States evaluated all source categories that could contribute meaningful emission

reductions, and compiled an extensive list of potential control measures. Furthermore, the States

considered the time needed to develop and adopt regulations and the time it would take to see the

benefit from these measures. While the States found that the measures could not be used to

advance the Washington Area’s attainment date, the State’s determined that many ofthe

measures were useful and would be considered for future SIPs for the Washington Area.Therefore, EPA concurs with the States’ conclusion that there are no RACM that would haveadvanced the 2010 attainment date for the Washington Area.

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for conformity purposes are outlined in 40 CFR 93.11 8(e)(4). The process for determining the

adequacy ofsubmitted SIP budgets is described in 40 CFR 93.118(f).

States must establish VOC and NOx MVEBs for each ofthe milestone years up to the

attainment year and submit the mobile budgets to EPA for approval. Upon adequacydetermination or approval by EPA, states must conduct transportation conformity analysis for

their Transportation Improvement Programs (TIPs) and long range transportation plans to ensure

highway vehicle emissions will not exceed relevant MVEBs. Failure of demonstrating such

transportation conformity lapses resulting in freezing offederal highway funds and all federal

highway projects in the lapsed area.

The States discuss transportation conformity in Section 8.0 of the Washington Area 8-

hour ozone plan. The States describe their methods and provide detailed input parameters used inmodeling the inventories in Appendices El and E2 ofthe Washington Area 8-hour ozone plan. In

the Washington Area, the Metropolitan Washington Air Quality Committee (MWAQC) consultswith the Transportation Planning Board (TPB) to establish mobile source emissions budgets.

The MWCOG Transportation Planning Department calculated the 2008 mobile emissions

inventory using EPA’s MOBILE6.2 and the Travel Demand Model Version 2.ld#50 with 2005

vehicle registration data. The Washington Area MVEB for the 2008 RFP is based on the

projected 2008 mobile source emissions accounting for all mobile control measures. (See Table6, “Washington Area 2008 Projected Controlled VOC & NOx Emissions (tpd).”) The budgetsare equal to the projected 2008 on-road mobile source emission inventories minus reductions

from transportation control measures. The States also established MVEBs for 2009, but EPA is

not evaluating that budget in this document.

The MVEBs for the 2008 RFP are shown in Table 11, below.

Table 11. Washington Area 2008 RFP MVEBs

VOC (tpd) NOx (tpd)

(A) Projected Controlled Mobile Emissions 70.98 160.30(B) Transportation Control Measures 0.19 0.49(A)-(B) 70.79 159.81

MVEB (rounded to nearest 0.1 tpd) 70.8 159.8

For budgets to be approvable, they must meet, at a minimum, s adequacy criteria (40

CFR 93.11 8(e)(4)). In a September 4, 2009 Federal Register notice, EPA notified the public that

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MVEBs to be reasonable. Because the 2008 RFP MVEBs are adequate for transportation

conformity purposes and the methods the States used to develop them are correct, the 2008 RFP

budgets are approvable.

III. SUMMARY AND RECOMMENDATIONS:

The EPA Region III Air Protection Division (APD) has reviewed the States’ 2008 RFP

plan, contingency measures for failure to meet RFP, and RACM analysis for the Washington Area

and found them to be approvable. In addition, EPA Region III’s AQAB determined that the

States used acceptable techniques and methodologies to develop the Washington Area 2002 base

year emission and 2008 milestone year projected inventories. Furthermore, APD has found the

Washington Area’s 2008 REP MVEBs adequate for transportation conformity purposes.

Therefore, APD recommends approval of the following SIP elements in the Washington Area 8-

hour ozone plan: the 2002 base year emissions inventory, the RFP plan and associated 2008

projected emission inventories, the RACM analysis, the contingency measures for failure to meet

2008 RFP, and the 2008 MVEBs for the Washington, DC-MD-VA moderate nonattainment area.

Attachments: - “Technical Support Document (TSD) for the Washington, DC-MD-VA Nonattainment Area:

8 Hour Ozone State Implementation Plan (SIP) Attainment Demonstration and Base Year

Inventory,” prepared by Janet C. Kremer and signed by Walter Wilkie, Air Quality Analysis

Branch Chief, on February 4, 2009 (Washington Area Emission Inventory TSD).

- “Adequacy Status of the Metropolitan Washington DC Area (DC—MD—VA) Area 8-Hour

Ozone Non-Attainment Area’s Reasonable Further Progress Plan Vehicle Emission Budgets

for Transportation Conformity Purposes” (74 FR 45853). -_ .____.

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