State Implementation Plan Revision

Oakridge Fine Particulate Matter (PM_2.5) Attainment Plan

Section x.xx of the

State Implementation Plan

June 15, 2012 Draft

1010 Main Street

Springfield, Oregon 97477

EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency (EPA) adopted revisions to the National Ambient Air Quality Standards (NAAQS) for PM_2.5 in September 2006. PM_2.5 is fine particulate matter two and a half microns and less in diameter, or about 1/28^th the diameter of a human hair. Also referred to as respirable particulate matter, these tiny particles are inhaled deep into the lungs where they accumulate and aggravate respiratory conditions, particularly asthma. Fine particulate (PM_2.5 microns and smaller) are associated with heart and lung disease, increased respiratory symptoms and disease, decreased lung function, and premature death. Chronic exposure to fine particulate has also been implicated in increased risk for cardiac events. Populations especially at risk include children, the elderly, and those with existing health problems.

On October 8, 2009, the Environmental Protection Agency (EPA) issued final area non-attainment designations for the 24-hour national air quality standards for fine particulate matter (PM_2.5). Oakridge was designated a non-attainment area in Oregon. Under the Clean Air Act, an area that violates the federal standards is designated as “nonattainment” and must adopt a plan with emission reduction measures to bring the area back into compliance. The area designated as non-attainment for PM_2.5 contains Oakridge, the small town of Westfir and surrounding area.

The Oakridge PM_2.5 Attainment Plan

The City of Oakridge has struggled to meet air quality standards. Oakridge was proposed a PM₁₀ “non-attainment” area in September 1992, and designated on January 20, 1994. The City last exceeded that standard in 1993. Voluntary measures to reduce wood smoke emissions adopted in 1999 have reduced measured particulate levels. Progress in reducing wood smoke emissions in Oakridge made it possible for the City to meet the previous PM_2.5 standard of 65 µg/m^3. Despite progress in improving air quality, the tightening of the PM_2.5 standard in 2006 presented yet another challenge.

Local climate and topography make Oakridge prone to wintertime temperature inversions, low wind speeds and poor atmospheric dispersion. During the winter months, Oakridge air quality is often threatened due to high concentrations of smoke from woodstoves settling on the valley floor of the city. Figure 1 shows the worst case dayⁱ contribution of each of these source categories in the Oakridge nonattainment area.

Figure 1: Oakridge Nonattainment Area 2008 Worst Case Day Emissions ¹

Attainment of Standards

Despite significant progress in reducing particle pollution, the Oakridge area exceeded and consequently violated the federal 24-hour fine particulate (PM_2.5) 2006 standard of 35 µg/m³ but complied with the annual PM_2.5 standard of 15 µg/m³ in the 2001-2011 period. Woodstove related PM_2.5 pollution occurred during this period due to wintertime inversions and high emissions.

The main purpose of the Oakridge PM_2.5 attainment plan is to return the Oakridge area back to compliance with the 2006 24-hour standard by 2014 as required by federal law. Oakridge does not violate the annual PM_2.5 standard. This attainment plan fulfills federal requirements regarding EPA designated nonattainment areas.

The City of Oakridge has taken steps to address pollution from woodstoves. On February 20, 2003, the Oakridge City Council adopted a home wood heating ordinance that:

•  Changed previous voluntary measures to mandatory,

•  Prohibited burning garbage in woodstoves and fireplaces,

•  Incorporated a 40 percent opacity limit on chimneys,

•  Incorporated the PM_2.5 standard into the program, and

•  Required the removal of uncertified woodstoves from property to be sold or rented.

In December 2008, the Oakridge City Council passed an ordinance prohibiting the use of an uncertified solid fuel heating device in a residence. The Lane Regional Air Protection Agency (LRAPA) has also worked closely with the City of Oakridge and other partners to help residents replace old, uncertified wood stove with new, cleaner burning and energy efficient heating systems. LRAPA also issues daily home wood heating advisories November 1 through the last day of February. When air quality is forecast to be in the unhealthy for sensitive groups range, LRAPA activates an automatic callware system to alert residents by telephone about burning restrictions.

The use of these strategies and others identified by an advisory committee should further reduce ambient concentration of PM_2.5 below the national health-based standard by 2014. The estimated ambient concentrations for both the annual and the worst case day are predicted to decrease based on a ratio of the 2008 ambient concentration to the projected emission inventory for the year 2014.

The analysis shown in Table 1 shows Oakridge needs additional strategies to return the community back to attainment.

Table 1: PM_2.5 Attainment Demonstration

Strategies and Contingency Plan

Woodstove Curtailment and other Woodstove Strategies

Oakridge has been proactive in adopting a number of strategies to reduce emissions from home wood heating. These strategies include:

•  City ordinances to curtail burning during stagnant weather periods.

•  City ordinance requiring the removal of an uncertified wood stoves upon sale of a home

•  City ordinance prohibiting the use of a noncertified wood stove in a residence

•  Partnering in additional change-out programs to encourage removal of noncertified stoves

A new stove certification program by EPA and the woodstove replacement programs continue to result in a significant emissions reduction in Oakridge. The continued replacement of older woodstoves coupled with better enforcement of daily advisories are expected to continue to decrease emissions through 2014 even with a moderate growth in households.

Other Strategies

Curtailing open burning has been identified as a way to reduce PM emissions. The Oakridge City Ordinance prohibits burning within the City limits on days with high concentrations of particulate matter in the month of October and March 1 – June 15. All open burning is prohibited between November 1 and February 28 inside the City limits.

Oregon Department of Forestry (ODF) requires federal land managers to follow strict smoke management instructions and avoid smoke impacts to Oakridge. ODF has designated Oakridge as a Special Protection Zone (SPZ). During the November 15 through February 15 period, prescribed burning in the SPZ is allowed only when the ODF smoke management meteorologist believes there will be no measurable smoke impacts within the nonattainment area.

Contingency Plan Elements

The following strategies are recommended as potential contingency strategies to fully meet the air quality standards, if it becomes clear that the strengthened ongoing strategies will not be sufficient to attain the PM_2.5 standards by 2014 and or to maintain compliance with the standards through 2024 and beyond:

•  Stricter opacity limit, revising the current 40% opacity limit to a more restrictive 20% limit, as has been done in some other northwest communities.

•  Stricter green-yellow-red advisory program, with more yellow and red advisory days each winter.

•  Phase-out of city woodstove curtailment exemptions (for sole source, economic hardship).

If Oakridge meets the EPA Clean Air Act deadline for meeting the standard, the contingency plan will not be enacted.

INTRODUCTION

Background

In September 2006, the U.S. Environmental Protection Agency (EPA) strengthened the daily (24-hr) PM_2.5 (fine particulate) standard by lowering the level from 65 mg/m³ to 35 mg/m³ and retained the annual PM_2.5 standard of 15 mg/m³. Fine particulate matter (PM_2.5) is a mixture of extremely small particles and droplets in the air and is known to cause or contribute to respiratory disease, asthma attacks, heart problems, and premature death. Areas in violation of the PM_2.5 standard (based on the most recent three years of federal reference monitoring data) are designated as a “nonattainment area” by the EPA. Oakridge, Oregon has been designated as nonattainment for the daily PM_2.5 standard. The Lane Regional Air Protection Agency (LRAPA) must develop an attainment plan that will bring air quality into compliance with the standard as soon as possible, and submit this plan to EPA.

What is PM_2.5?

This plan addresses the 24-hour and the annual ambient air quality standards for PM_2.5 as defined in the federal Clean Air Act. Particulate matter (PM) is the general term used for a mixture of solid particles or liquid droplets found in the air. Some particles are large or dark enough to be seen as soot or smoke. Others are so small they can be detected only with an electron microscope. These particles come in a wide range of sizes (“fine” particles are less than 2.5 micrometers in diameter and coarser-sized particles are larger than 2.5 micrometers), and originate from many different sources. Fine particles (PM_2.5) generally result from fuel combustion from residential fireplaces and woodstoves, pile and forest burning, industrial facilities, and motor vehicles. Coarse particles (PM₁₀) are generally emitted from sources such as vehicles traveling on paved and unpaved roads, materials handling, and wood products operations, as well as wind-blown dust.

These particles can accumulate in the respiratory system and are associated with numerous health effects. Fine particles are most closely associated with such health effects as increased hospital admissions and emergency room visits for heart and lung disease, increased respiratory symptoms and disease, decreased lung function and premature death. Sensitive groups that are at greatest risk include the elderly, individuals with cardiopulmonary disease such as asthma, and children.

National Ambient Air Quality Standards for PM_2.5

EPA has established National Ambient Air Quality Standards (NAAQS) for PM_2.5 at 35 micrograms per cubic meter (µg/m³) for a daily (24-hour) average and 15 µg/m³ as an annual average. Any value monitored above these levels, as defined by federal rules and guidance, is considered an exceedance. EPA uses the 98^th percentile of the 24-hr PM_2.5 within any given year and averages it over three calendar years. An exceedance of the average 98^th percentile over three years greater than 35 µg/m3 is considered a violation. An exceedance of the annual standard averaged over three years becomes a violation of the annual standard. If an area violates either standard, EPA designates it as a nonattainment area. This plan includes a demonstration of continuing attainment with both standards.

Purpose of Attainment Plan

This document provides a pathway for continued improvement to reduce particulate emissions and to return the Oakridge Nonattainment Area (NA) to attainment for PM_2.5 (state classification will be “maintenance”) by achieving the more protective national health standards adopted in 2006. It is a plan to ensure Oakridge meets the 24-hour and annual National Ambient Air Quality Standards for PM_2.5 and maintains the annual standard for PM_2.5. This document complies with the applicable 1990 Federal Clean Air Act (CAA) requirements and Environmental Protection Agency (EPA) guidance and policies. The attainment plan provides strategies to meet the PM_2.5 standards by 2014 and provides contingency measures should Oakridge not meet the deadline. To demonstrate "attainment" requires the collection of representative monitoring data using approved measuring instruments and procedures, with adequate quality assurance. EPA must approve the plan and publish its findings in the Federal Register. Redesignation back to attainment is possible only after Oakridge meets the standards for three consecutive years and a maintenance plan is drafted, adopted by the Environmental Quality Commission (EQC) and approved by EPA. EPA will then formally redesignate Oakridge back into attainment in the Federal Register.

Oakridge Area Description

Oakridge, Oregon lies in an alluvial plain in the foothills at the southern end of the Willamette River valley. The city is in Lane County, Oregon, approximately 45 miles east-southeast of Eugene, and 28 miles west of Willamette Pass, the summit of the Cascade Mountain Range. The city limits of present-day Oakridge includes the historic City of Oakridge and, directly west, the area formerly known as Willamette City. Figure 2 shows the location of Oakridge in Lane County.

The area of applicability for this attainment plan includes an area that contains the City of Oakridge and the small town of Westfir. Figure 3 shows the Oakridge non-attainment area.

The City of Oakridge is situated in a valley oriented east-west, through which flows the middle fork of the Willamette River. Elevation of the area ranges from 1100 feet at the lower (west) end of the UGB to 1600 feet, MSL, with areas of densest population situated between 1100 feet and 1200 feet. Mountains rise on the north and south sides to 1700 feet and 1600 feet, respectively.

Westfir is a very small (population 335) isolated rural mountain community that is located along the north fork of the Willamette River about 1 mile NW of Oakridge. Its elevation is about the same as Oakridge and it is surrounded by the same high mountains. Westfir and Oakridge are in separate steep sided river valleys separated by a 400-foot ridge. The Westfir valley is very narrow, only about 1/4 mile across at its widest point, while the Oakridge valley is about 1 mile across at its widest point.

Figure 2: Oakridge Location

Figure 3: Nonattainment Area

UGA – Urban Growth Area

History of Efforts to Address Particulate Matter in Oakridge

Oakridge has historically struggled with air quality issues during the winter months, especially on cold days during periods of air stagnation. Oakridge was proposed a PM₁₀ “non-attainment” area in September 1992, and designated on January 20, 1994. PM₁₀ is defined as particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers as measured by an approved method listed in 40 CFR 53. A formal attainment plan was developed for the Oakridge (UGB) by 1991, however, at that time the area still had not met the standard. LRAPA subsequently revised the PM₁₀ plan and submitted it to EPA in 1996. EPA approved the attainment plan on May 14, 1999. One of the key strategies in the plan included a mandatory woodstove curtailment program and a woodstove change-out program. On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to allow open backyard burning only during the months of October, March, April, and May. This eliminated burning during wintertime periods of maximum atmospheric stagnation when burning is more likely to contribute to exceedances of the 24-hour standard. An aggressive wood stove change-out project, along with a voluntary residential wood burning advisory program, further reduced winter time PM₁₀ emissions. In a letter of agreement with the Oregon Department of Transportation (ODOT), dated July 29, 1996, ODOT agreed to use a chemical de-icing compound on Highway 58 as an alternative to sanding roads during the winter on. As a result of these strategies, the area was able to meet and continue to meet the PM₁₀ standards from 1994 to present.

LRAPA began monitoring fine particulate matter (PM_2.5) concentrations in 1998. EPA revised the particulate standard in 1997 to include PM_2.5 and established a daily standard of 65 ug/m³. The original PM₁₀ strategies included in the attainment plan were so successful in maintaining clean air that Oakridge met the fine particulate (PM_2.5) standard.

In 2006, EPA modified the PM_2.5 standard, cutting the threshold for the 24-hour exceedance day roughly in half to 35 µg/m³. Oakridge has not yet been able to meet this new daily PM_2.5 standard, so continued progress is need to further reduce particulate emissions. LRAPA has measured PM_2.5 at the same location in the Oakridge (Willamette Activity Center) since 1998 and PM₁₀ since 1989. LRAPA has also operated a nephelometer in Oakridge since 1989 which makes it possible to estimate PM_2.5 during 1989-1998. Many of the same pollutant sources for PM₁₀ are the same for PM_2.5.

Between 2006 and 2011, PM_2.5 concentrations in Oakridge on worst winter days violated the more protective 24-hour national health standard adopted in 2006. There were no exceedances of the annual PM_2.5 standard. The maximum 24-hour exceedance of the PM_2.5 standard occurred in 2001 with a measured high concentrations above the 35 µg/m³ standard (95.7 µg/m³ on 1/7/2001). EPA’s deadline for meeting the standards is December 31, 2014. Emission reduction strategies included in this plan should provide compliance with the Clean Air Act Amendments even with a modest population growth. Should the community fail to meet the standard by 2014, automatic contingency measures will be taken and are clearly identified in this plan.

What is in this Attainment Plan?

Nonattainment Area

The plan provides an analysis of the existing nonattainment area situation. It describes the past and the current state of air quality. It identifies and quantifies the current nature of the air quality problem.

Attainment Demonstration

The key component of the plan is in the attainment demonstration analysis where emissions again are predicted into the future but strategies are identified to reduce emissions. There is also an explanation of the past and current economic situation and past and current meteorological situation. It predicts air quality into the future based on a growth analysis to show how much worse the air quality can become. It tells how the air quality can improve by implementing these various approaches or tactics to reduce emissions enough to meet the standards. Credit is given to each strategy or tactic and emission reductions are estimated into future. It provides for a commitment by the community to return Oakridge to attainment status and explains and quantifies those commitments. The commitment shows how to improve air quality by using these strategies and promises to watch for changes to assure the commitment is met. If the commitment is not met, it identifies what future additional strategies will be necessary to implement immediately, should the initial commitments fail to meet the standard by 2014.

The following strategies are in place and critical for meeting the PM_2.5 air quality health standards by 2014:

•  Complete woodstove change-out program (with financial assistance to replace non-certified woodstoves with heat pumps, pellet stoves, or high-efficiency certified woodstoves); the current funding has been committed, and this program was completed during December 2011.

•  Continue woodstove-fireplace curtailment program (green-yellow-red advisories, with curtailment required during air stagnation pollution episodes); the city ordinance requires curtailment on red days; LRAPA provides the daily air quality and meteorological forecasts during November-February.

•  Continue backyard open burning program: Burning of garbage is prohibited at all times; city ordinance prohibits open burning of yard debris during November-February; LRAPA provides daily open burning advisory during March-May and October; and open burning is prohibited in June-September during the fire season established by fire departments.

•  Continue outdoor recreational fire (chimineas and other patio heaters) program; LRAPA rules prohibit outdoor recreational fires on yellow-red advisory days during November-February.

•  Continue Oregon Heat Smart program; requires removal of non-certified woodstoves upon home sale, and prohibits burning of garbage in woodstoves and fireplaces.

The plan proposes strengthening existing strategies and introduces new strategies to be implemented in the community. The plan demonstrates that new and continued permanent and voluntary strategies are sufficient to meet the PM_2.5 standards by 2014 and the community will continue to meet the standard into the future. The primary source of PM_2.5 in Oakridge is residential wood heating. The most serious PM_2.5 problems occur during the winter in the urban area of Oakridge, when cooler temperatures trap particles near the ground by atmospheric inversions. Monitoring data clearly shows the high particulate levels occurring during the nighttime periods with light winds and strong temperature inversion. The levels drop significantly after sunrise. These diurnal high and low concentration periods also correspond to the general use of woodstoves as home heating devices. The emissions are greatest during the evening and nighttime periods.

Implementation

The plan describes final commitments by Oregon and the Oakridge community to make the plan work. It outlines the commitment for LRAPA to work with the local community to find solutions to the air quality problem.

Attainment Plan Development Process

LRAPA used the 2008 PM_2.5 emission inventory and the feedback of the Oakridge Advisory Committee, the Lane Council of Governments, and the Oregon Department of Transportation (ODOT) to develop the PM_2.5 attainment plan. The Advisory Committee prepared a list of strategies that was submitted to LRAPA for inclusion in the plan.

Additional strategies recommended by the committee are included in Section X, Attainment Demonstration. The LRAPA Advisory Committee and the Oregon Department of Transportation also reviewed and made recommendations on the plan.

Other factors that were considered in the development of the plan include the projections of future emissions are based on growth rates that are consistent with Oregon Department of Economic Analysis data and requiring the most stringent emission control requirements for any new industrial sources. As required by the federal Clean Air Act the “Lowest Achievable Emission Rate” (LAER) requires owners of a new or expanding industrial facility to install the most restrictive controls regardless of cost in selecting controls, while other controls allow a cost consideration.

NONATTAINMENT AREA

Since the 1990s, Oakridge has undertaken many efforts to manage or control particulate emissions. For example, the community has rallied on several occasions to improve air quality and implemented very stringent controls on its citizens such as implementing a clean air ordinance to regulate both burning in woodstoves and open burning. Due to the success of these programs to address PM₁₀ emissions, when EPA revised the PM standard in 1997 to include PM_2.5, Oakridge was in compliance. Despite the great work of the community, in 2006 when the PM_2.5 standard was revised Oakridge found itself in violation of the 24-hour PM_2.5 standard.

Ambient Air Quality Monitoring in Oakridge

The Oakridge area has one particulate (PM_2.5) monitoring site (see Appendix X) with the sampler located at 47674 School Street, also known as the Willamette Activity Center. LRAPA has monitored at the Willamette Activity Center site since 1987 for PM₁₀ and since 1998 for PM_2.5. After rigorous quality assurance, the data from the Willamette Activity Center site is transferred to ODEQ and on to EPA’s database. The data from the Willamette Activity Center monitor was used as the basis for the nonattainment determination and for determining compliance with the standard.

Image 1: Smoke inversion over Oakridge, where the Willamette Activity Center is located. The particulate matter trapped near the surface by a temperature inversion is clearly visible.

National Ambient Air Quality Standards (NAAQS)

As mentioned previously, in 2006 the EPA revised the PM_2.5 standard to more accurately reflect the latest health information. EPA revised the 24-hour standard from 65 µg/m³ to 35 µg/m³, and kept the annual standard at 15.0 µg/m³. EPA determines compliance with the PM_2.5 standards based on averaging air quality measurements both annually and on a 24-hour basis.

Annual PM_2.5 standard

The annual standard for PM_2.5 is met whenever the three year average of the annual mean PM_2.5 concentrations for a designated monitor is less than or equal to 15.0 µg/m³. Oakridge has met this standard since monitoring started at Willamette Activity Center (Figure 4).

Figure 4: PM_2.5 Annual Standard comparison concentrations from the Oakridge monitor.

24-hour PM_2.5 standard

The 24-hour standard for PM_2.5 is met whenever the three year average of the annual 98^th percentile of values at a monitoring site is less than or equal to 35 µg/m³. The 98^th percentile is a concentration below which 98% of observations fall. This value is used for the 24-hour standard instead of the maximum observation for any given year. By doing so, EPA ensures infrequent peaks are ignored and a more robust value is used for comparison.

From 2001 through 2005, Oakridge was in compliance with the PM_2.5 standard of 65 µg/m³. However in 2006, when EPA revised the standard to 35 µg/m³, Oakridge violated the 24-hour standard. The three year average 98^th percentile for the Oakridge monitoring site has continued to violate the 24-hour standard each year since the standard tightened in 2006, but has decreased significantly over the period 2006 - 2011.

Figure 5: PM_2.5 24-hour Standard comparison concentrations from the Oakridge monitor.

Additional Monitoring

In addition to the Oakridge Federal Reference Method (FRM) monitor, between October 2009 and March 2010, investigative monitoring was done in the Westfir area to determine PM_2.5 concentrations there, and relative difference from the Willamette Activity Center monitor. Several saturation samplers and a Nephelometer were used for this purpose. Figure 6 shows the relative PM_2.5 concentrations, as a function of Nephelometer light scattering, of Westfir and Oakridge. More information regarding the methods and results of this monitoring is available in Appendix X.

Figure 6: Nephelometer estimated PM_2.5 for Oakridge and Westfir during winter 2009-2010.

Verification of Monitoring Location

LRAPA has conducted a field study to verify that the Willamette Activity Center PM_2.5 monitoring site generally represents peak level PM_2.5 concentrations within Oakridge, and is the most appropriate location for a PM_2.5 monitor. The one year, six site monitoring survey was conducted in 2002-2003, and is attached in Appendix X. Results are summarized in Figures 7 and 8.

Figure 7: 2002-2003 Oakridge Monitoring Survey Site Map

Figure 8: 2002-2003 Oakridge Monitoring Survey Results

Findings of this survey agreed with those of PM₁₀ saturation studies from 1991 and 1994. Within Oakridge the highest levels were found in the southwestern portion of the city. Therefore, it was confirmed that this site represents peak levels of PM_2.5 concentrations in Oakridge. In addition, the Willamette Activity Center monitor also represents an area where people live, work, and play, reconfirming the monitor location is the most appropriate for Oakridge.

ATTAINMENT PLAN AND DEMONSTRATION

Emission Inventory

An emission inventory consists of emission estimates from sources that emit PM_2.5 within the Oakridge nonattainment area boundary. The emissions inventory data is essential in developing the attainment demonstration, as it helps identify the sources contributing to the air quality problem and the emission reduction strategies, once implemented, that reduce pollution levels below the standard. Sources of PM_2.5 in Oakridge include minor industry, on-road mobile sources (e.g. car and truck exhaust, road dust), railroads, and area sources (e.g., outdoor burning, woodstoves, and fireplaces).

Base Year Emission Inventory (2008)

The base year emission inventory is used as the starting point for the attainment demonstration. This inventory includes sources in the nonattainment area during the 2008 baseline year.

The 2008 emission inventory is summarized in Table 1 and Figure 1. The calculation procedures are included in Appendix X.

Table 2: 2008 Estimated Typical Season Day and Worst-Case Day PM_2.5 Emissions.

The emissions inventory on worst winter days is of most interest since the PM_2.5 concentrations measured in Oakridge do not meet the current 24-hour PM_2.5 standard and the peak PM_2.5 concentrations occur on cold, stagnant days during the November-February wood-heating season. Residential wood-heating emissions (from certified and non-certified woodstoves, fireplaces, and pellet stoves) account for about 86% of the emissions on worst winter days, as illustrated in Figure 9.

Figure 9: Oakridge PM_2.5 Emission Inventory for 2008 Worst Winter Days

Residential Wood Combustion

Residential wood combustion is a common way to heat homes in Oregon. To estimate emissions from wood burning, LRAPA conducted a survey for the 2009-2010 heating season in Oakridge-Westfir. The survey provided LRAPA with information on how many homes use various types of wood-heating devices, the amount of wood burned, and other information on wood-heating practices.

Mobile and Nonroad Sources

Road dust and tailpipe emissions of PM_2.5 from motor vehicles were calculated by Lane Council of Governments (LCOG) transportation staff by applying emission factors from the EPA MOVES computer program to total vehicle miles traveled in the nonattainment area. Estimated vehicle miles traveled are from previous transportation modeling by LCOG for the Oregon Department of Transportation. Emissions from railroads were provided by Union Pacific Railroad staff using the EPA NONROAD2008a emissions protocol.

Industrial Point Sources

LRAPA maintains data on industrial point source emissions in Lane County. The only operating industrial point sources within Oakridge-Westfir area are two minor aggregate industry sources operated by Oakridge Sand & Gravel.

Attainment Year Emission Inventory (2014)

The attainment year inventory is an estimation of emissions for the year that the area is expected to attain the PM_2.5 standard. It includes projected emissions for the attainment year based on a number of different factors. Growth rates for population, employment, and VMT through 2014 were used to estimate 2014 emissions. LRAPA took credit for emissions reductions as a result of the woodstove replacement project implemented during 2009-2012 that reduced the number of non-certified woodstoves accounted for in the 2008 emission inventory.

The attainment year emission inventory is based on 2008 emissions inventory, estimated growth rates and the emission reduction strategies that have recently been put into effect. The emission reduction strategies primarily include the continued implementation (with specific strengthening revisions in some cases) of the existing control measures that have been effective in achieving the PM₁₀ standards and the initial (1997) PM_2.5 standards on schedule. The key ongoing control strategies include:

•  City ordinance to curtail burning during stagnant weather periods;

•  City ordinance requiring the removal of a non-certified wood stoves upon sale of a home;

•  City ordinance prohibiting the use of a non-certified wood stove in a residence; and

•  Partnering in additional change-out programs to encourage removal of non-certified woodstoves.

Details of the ongoing control strategies, strengthened control strategies, and contingency measures are described in the subsequent section on the Oakridge Advisory Committee recommendations.

Economic Factors

The economy in Oakridge has shifted from logging-based industries to a more recreation- oriented model. The decline in the harvesting and processing of timber has left Oakridge with no industrial employer or businesses that support the lumber industry. In the 1990’s, the population in Oakridge declined sharply as jobs disappeared. Current census figures show only modest growth of 1.8% between 2000 and 2010, with the current population at 3,205. Within the civilian labor force, 16% were unemployed in 2010 and 21.7% of all families had incomes below the poverty level. The low cost of living has attracted low-income and unemployed people to Oakridge.

The recreation industry has picked up in Oakridge, with mountain biking being very popular. A hostel, brew pub, and other small businesses have opened to support the visitors attracted to the area. Despite the recent business growth, few jobs have been created. Population and employment in Oakridge are expected to increase only modestly over the next 20 years. The population estimate for the year 2025 is 4,000. Any new employment has been assigned to the potential development of the Oakridge Industrial Park.

Growth Rates

Growth is expected to be low to moderate in the Oakridge-Westfir area through 2014. Population, housing, and employment forecasts are expected to increase gradually. VMT growth is based on the previous transportation modeling by LCOG in the Highway 58 corridor.

The 2014 emission inventory is summarized in Table 3. The calculation procedures are included in Appendix X.

Table 3: 2014 Estimated Typical Season Day and Worst-Case Day PM_2.5 Emissions.

Comparison of 2008 to 2014 Emissions

The emission inventory shows an overall decrease in emissions for the attainment year (2014) based on the effectiveness of the emission control strategies.

The differences in the 2008 and 2014 emission inventories are the combination of increases due growth factors and decreases due to emission control strategies. For example, motor vehicle emissions decreased overall due to progressively cleaner gasoline and diesel fuels and motor vehicles, but part of the emissions decrease was offset by gradual growth in traffic volumes. Industry emissions were conservatively increased to reflect operation at maximum capacity in 2014, but both industrial sources are minor so this did not have a major effect on the 2014 inventory. The most significant category is residential wood-heating; emissions were increased to reflect population growth during 2008-2014, decreased due to non-certified woodstove replacements with cleaner burning units during 2009-2012, and decreased due to improvements in the programs for curtailment during stagnant air episodes.

Attainment Strategies – Emission Reduction Analysis

This section describes strategies currently in place or those to be implemented to achieve compliance with the 24 hour PM_2.5 standard. These strategies are expected to improve air quality and meet the PM_2.5 standard by the required 2014 attainment date. These strategies are also known as Reasonably Available Control Measures (RACM). For large industrial emission sources they are called Reasonably Available Control Technologies (RACT) but currently there are not any large industrial facilities located in the Oakridge-Westfir area. For the Oakridge nonattainment area, the main source of emissions is wood smoke from residential wood combustion, and RACM is applicable to this emission category. The current and proposed emission control strategies are consistent with the RACM requirements for residential wood combustion (EPA-450/2-89-015).

Wood Smoke Reduction Strategies (1989 -2011)

The Oakridge Air Pollution Control Ordinance #889

The City of Oakridge adopted a voluntary home wood heating advisory program in 1989 after air quality data showed Oakridge exceeded the federal PM₁₀ standard on numerous occasions. Five years later, on January 20, 1994, EPA officially declared Oakridge a PM₁₀ non-attainment area. A plan to get the area back into attainment with the standards was adopted by EPA in March 1999, and became effective on May 14^th of that year. The Oakridge plan included voluntary measures.

On February 20, 2003, the Oakridge City Council adopted a home wood heating ordinance that:

•  Changed their voluntary measures to mandatory,

•  Prohibited burning garbage in woodstoves and fireplaces,

•  Incorporated a 40 percent opacity limit on chimneys,

•  Incorporated the PM_2.5 standard into the program, and

•  Required the removal of uncertified woodstoves from property to be sold or rented.

In fall 2007, the City of Oakridge revised its home wood heating ordinance to reflect the tightened PM _2.5 standard of 35 µg/m³. A revision to the ordinance in December 2008 included a provision that stated a person or persons may not install or use any solid fuel heating device in any structure within the City except for certified wood stoves or certified pellet stoves with emissions that do not exceed 1.0 grams/hour weighted average tested in conformance with the EPA method, or a fireplace that is not a sole source of heat. Use of these devices is regulated by a daily advisory issued by LRAPA.

LRAPA Advisory Programs

Since adopted in 1989, the LRAPA advisory program has provided a daily wood burning advisory for Oakridge. The program is operated by LRAPA in cooperation with the City of Oakridge and local news media. The advisory, issued daily by LRAPA staff during the months of November through February, is determined by comparing current pollution levels to meteorological conditions and weather forecasts. The advisories are displayed daily on the LRAPA website and can be obtained via telephone at a dedicated hotline number. Advisories are broadcast on radio and television and daily in the regional newspaper. An automatic phone “callware” system is activated when air quality is deteriorating and long periods of stagnant conditions are forecast. The phone system calls all numbers with the 782 prefix in the Oakridge/Westfir area and leaves a recorded message.

The advisory operates using a "green-yellow-red" system as described in the Oakridge City ordinance. A "green" advisory is issued when PM_2.5 levels are forecast by LRAPA to be less than 25 mg/m³, and good smoke dispersion conditions are forecast. "Yellow" advisories are posted when PM_2.5 levels are forecast by LRAPA to be equal to or greater than 25 mg/m³, but less than 30 mg/m³, and the forecast is for marginal smoke dispersion conditions. Under this advisory, residents are advised to burn wood sparingly, and only if alternatives are unavailable. Stage I "Red" advisories are posted when PM_2.5 levels are forecast to be equal to or greater than 30 mg/m³, and the forecast is for marginal or poor smoke dispersion conditions. A Stage II Red Advisory is issued when PM_2.5 levels are forecast to be equal to or greater than 35 mg/m³ . A Stage II Red Advisory requires that no person in charge of a property shall operate or allow to be operated a solid fuel heating device which emits visible emissions unless the person has been granted an exemption by the Oakridge City Administrator. During a Stage II Red advisory, only pellet stoves that emit no visible emissions are allowed to be operated. Residents with exemptions may use any solid fuel heating device. Exemptions are based on sole source of heat or economic need.

Additional strategies have been in place since the early 90’s. LRAPA has provided plastic tarps to residents for covering wood piles to keep wood dry. The agency also hires a seasonal worker to conduct drive-by compliance surveys on green, yellow, and red days using pre-established survey routes.

Open Burning Ordinance

On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to allow open backyard burning only during the months of October, March, April, and May. This eliminates burning during wintertime periods of maximum atmospheric stagnation when burning is more likely to contribute to exceedances of the 24-hour PM_2.5 standard. The open burning restrictions provide a more protective measure to avoid additional contributions to the particulate levels.

Woodstove Change-out Programs

Since 1993, LRAPA has administered woodstove change-out programs to help residents replace old, uncertified wood stoves with cleaner burning, more efficient heating systems. This control measure is central to achieving attainment, and will enhance both long- and short-term compliance. The first program conducted in 1993 provided economic incentives for residents to replace old, high polluting woodstoves with alternative heating systems with lower emission rates. These include electric furnaces and heat pumps, oil, gas, pellet stoves, or EPA certified low-emission woodstoves.

The initial program was funded by the U.S. EPA, together with support from the Oregon Department of Environmental Quality and LRAPA. The program provided up to $2,500.00 per low- or moderate- income household for installation of approved alternative heat sources, either as no-interest loans or outright grants. Participants were required to certify, in writing, that they disposed of their old stoves, and would not utilize non-approved alternatives in the future. A total of 130 stoves were replaced.

In 2005, LRAPA developed the Warm Homes, Clean Air Program for Oakridge. The program is ongoing as funding becomes available. Warm Homes matches Oakridge and Westfir residents with funding from nine partner agencies to help with heating upgrades, weatherization, and home repairs. As part of the program, LRAPA has provided funding for woodstove replacements. During a change-out conducted between July of 2006 and December of 2009, 70 uncertified woodstoves were replaced.

In October 2010, LRAPA continued the Warm Homes program to replace uncertified stoves using funds from the American Recovery and Reinvestment Act. The program offered two-tier funding for qualified residents within the non-attainment boundary designated by U.S. EPA. Residents who qualified as low income based on Housing and Urban Development’s (HUD) income guidelines received a full rebate of up to $5,000 to pay for a ductless heat pump, certified wood stove or pellet stove. All other qualified applicants received a rebate of up to $2,000 based on emission reductions. The program ended in December 2011. LRAPA provided rebates to replace 79 stoves. Wood heat was most popular; 56 new wood stoves were installed, 10 pellet stoves, and 13 electric ductless systems.

Statewide Certification of Woodstoves

In 1986, the Oregon Legislature required the certification of any woodstove sold in Oregon. This requirement was subsequently adopted by EPA on a national basis in 1990. Additionally, the State Building Code Agency prohibits the installation of uncertified woodstoves. The dual effect of this certification and installation requirement resulted in reducing the amount of wood smoke pollution that used to be emitted from the uncertified stoves.

Highway Road Sanding

In an effort to reduce PM₁₀ emissions from road sanding during winter months, the Oregon Department of Transportation (ODOT) signed a letter of agreement regarding using anti-icing agents as an alternative to sand on Highway 58 running through Oakridge. The use of the chemical de-icing compound, calcium magnesium acetate, inhibits ice formation. The practice has resulted in a significant reduction of particulate, however it is not likely to contribute to PM_2.5 reductions.

Smoke Management

By statute, the Oregon Department of Forestry (ODF) is responsible for administering a smoke management program. Smoke from prescribed burning has not significantly impacted the nonattainment area in the past however, there have been safeguards implemented to prevent unintended smoke impacts to the Oakridge nonattainment area. Oakridge is protected under the Oregon Smoke Management Plan as a smoke sensitive area. This means that all prescribed burning during the year is managed in such a way as to avoid any smoke intrusions into the community.

In addition, a Special Protective Zone (SPZ) surrounds Oakridge (see Appendix X) where additional restrictions apply to prescribed burning within the zone during the winter months (November 15 through February 15). During this time, prescribed burning is allowed only when the ODF smoke management meteorologist determines there would be no measurable smoke within the nonattainment area. Between December 1 and February 15, no prescribed burning is allowed in the SPZ on “red” woodstove days. Between November 15 and February 15, no pile burning is allowed if ODF believes that the piles will produce significant smoke after the third day.

Industrial Requirements

Within the designated Oakridge PM_2.5 nonattainment area, new major sources and major modifications of a nonattainment pollutant, including PM_2.5 precursors SO₂ or NO_X, are required to meet the Lowest Achievable Emission Rate (LAER) control technology. Industrial sources must also obtain emission offsets and demonstrate that a net air quality benefit will be achieved. These are the most stringent requirements for industry. In addition, existing sources will be required to have Reasonably Available Control Technology (RACT) and will be required to meet performance standards for certain industry.

Current Strategies

The strategies and regulations implemented between 1989 and 2011 will reduce PM_2.5 emissions and as described in Section XX, “Attainment Demonstration.” Projections show implementing and strengthening ongoing strategies will make it possible for Oakridge area to reach attainment with the standard by 2014. Future strategies are a continuum of past strategies developed over the years that have been adjusted and updated to address the current PM_2.5 standard. Local efforts include revisions to the existing Oakridge clean air ordinance, public education, and woodstove change-outs. State and federal regulations recently implemented affect woodstoves and transportation emissions.

These strategies are permanent and enforceable; they are currently implemented and enacted by county ordinance, state, or federal rules. There are penalties for violating these ordinances or rules.

Heat Smart: Stove Removal upon Sale of Home

In 2010, a statewide requirement mandating the removal of an uncertified stove at the time of home sale went into effect. This statewide rule closely mirrored the existing requirement in the Oakridge ordinance. Under the rule, all uncertified devices that are on the property being sold (including residences, shops, garages, and outbuildings) must be removed at the time of home sale.

Transportation and Fuel-Related Emissions

Federal, state and local transportation regulations and programs recently implemented will reduce mobile and non-road emissions. These include:

•  Federal regulations requiring:

•  Reduced sulfur content of gasoline and diesel

•  Increased fuel economy

•  Oregon regulations requiring:

•  Low emissions vehicles beginning with model year 2009 and newer

•  Renewable fuel standard for biodiesel – 5%.

•  Local programs implementing diesel retrofits of school buses.

Road Paving

According to the emissions inventory done prior to 1991, there were about 2.4 miles of unpaved streets in Oakridge. Since then, based on city records, virtually all unpaved roads have been paved, along with numerous unpaved commercial driveways and parking lots.

Future Strategies – Potential Control Measures

While the current strategies in place indicate Oakridge will reach attainment with the PM_2.5 standard by 2014, a number of future strategies were identified by a local advisory committee to ensure compliance. The advisory committee evaluated options for how to improve air quality in Oakridge and suggested potential control measures. With the help of the committee, LRAPA developed a list of strategies that could be implemented to ensure Oakridge meets the 2014 attainment date.

Oakridge Air Quality Advisory Committee Strategy Recommendations

In July 2011, LRAPA formed an advisory committee in Oakridge to discuss current air quality strategies and explore the feasibility of a number of new strategies identified that would reduce PM_2.5 emissions. They also discussed contingency strategies should Oakridge fail to meet the standard by 2014. While the current strategies in place (e.g. City ordinance, LRAPA’s advisory programs, federal and state regulations) indicated the area would meet the standard by 2014, the committee suggested strengthening the strategies to provide a cushion to ensure attainment by 2014. The following strategies are included as part of this plan.

Woodstove Change-outs

Due to the effectiveness of this strategy in the past, LRAPA will continue to pursue funds to continue offering woodstove change outs within the nonattainment area. Implementation of this strategy may provide substantial reductions in PM_2.5 in the future. LRAPA is not applying any emission credit for this strategy to the 2014 inventory, as it is dependent upon the acquisition of funding which affects the number of stoves replaced. In the most recent round of wood stove change-outs, 75% of the participants qualified as low-income. The poor economy in Oakridge makes it essential any future change-out incentives include grants to cover all of the cost of replacement for low income individuals and substantial (at least 50%) incentives to residents who are not “low income”.

Heat Smart Enforcement:

By ordinance, the City of Oakridge requires all uncertified solid fuel heating devices be removed from any property to be sold or rented unless an exemption has been granted by the City Administrator. It is not known how successfully this ordinance has been enforced. The Oregon Heat Smart law requires DEQ to confirm residences where owners removed or changed-out uncertified woodstoves upon home sale. DEQ currently administers the Heat Smart program and tracks submittals of all uncertified removals at the time of home sale. These submittals can be used to estimate the level of compliance in Oakridge and identify any need for additional education or follow-up. DEQ has established in rules, penalties for noncompliance and hopes to conduct periodic enforcement sweeps throughout the state.

Enforcement of Oakridge Ordinance:

Oakridge Ordinance #889 allows the City to impose a penalty not greater than $500.00 upon anyone who violates City Code related to the use of a solid fuel heating device. Each day’s violation will incur additional fines. At this time, the City of Oakridge has enforcement authority of the ordinance. LRAPA is working with the Oakridge Police Department to strengthen enforcement on Stage I and II advisory days. LRAPA has provided a series of door hangers that can be left at a residence with an excessively smoky chimney. The door hangers include language from the City Ordinance, including potential fines for a violation.

Strengthening Key Ongoing Strategies

The Oakridge Advisory Committee identified several strategy enhancements that were felt to be key to the success of the ongoing strategies:

•  Expanded education and outreach, including multiple versions of educational door-hangers that can be distributed to all homes in Oakridge.

•  Training and certification of police on smoke reading and opacity limits enforcement.

•  Enforcement with citations as appropriate for violations of curtailment during pollution episodes, excessive opacity (40%) requirements, operation of non-certified woodstoves, and burning of garbage.

•  Ongoing improvements in the air quality forecasting and green-yellow-red advisory programs to ensure that all problem stagnation days are addressed appropriately, which may increase the number of yellow or red days.

•  Alternatives to fines payment as appropriate (e.g., attend workshop on clean burning practices, replacement of non-certified woodstove with cleaner burning unit, etc.).

•  Use of fines to fund ongoing woodstove replacement program or other emission reduction strategies.

Contingency Strategies

The following strategies are recommended as potential contingency strategies to fully meet the air quality standards, if it becomes clear that the strengthened ongoing strategies described above will not be sufficient to attain the PM_2.5 standards by 2014 and or to maintain compliance with the standards through 2024 and beyond:

•  Stricter opacity limit, revising the current 40% opacity limit to a more restrictive 20% limit, as has been done in some other northwest communities.

•  Stricter green-yellow-red advisory program, with more yellow and red advisory days each winter.

•  Phase-out of city woodstove curtailment exemptions (for sole source, economic hardship).

Industrial Emission Reductions

Reasonably Available Control Technology

The two existing industrial sources in the Oakridge-Westfir area are minor industrial sources of PM_2.5 emissions. The facilities are a portable rock crusher and a ready-mix concrete plant owned and operated by Oakridge Sand & Gravel.

Estimated Reductions and Credits for Future Strategies

The emission changes between 2008 and 2014 are due to the combination of increases due growth factors and decreases due to emission control strategies.

The most significant category is residential wood-heating; emissions were increased in the 2014 inventory to reflect population growth during 2008-2014, decreased due to non-certified woodstove replacements with cleaner burning units during 2010-2012, and decreased due to improvements in the programs for curtailment during stagnant air episodes. The emission decrease due to woodstove replacements was based on the actual number of woodstove replacements documented after the 2008 baseline year. The emission decrease for the more effective woodstove curtailment program is conservatively estimated at a 30% emission reduction on worst winter days as a result of enforcement of the existing city ordinances during stagnant air episodes subsequent to the 2006-2010 baseline period; mandatory curtailment programs in Oregon have historically documented reductions of 50% or more.

Traffic volumes are projected to gradually increase in future years but motor vehicle emissions are calculated to decrease overall due to progressively cleaner gasoline and diesel fuels and motor vehicles. Industry emissions were conservatively increased in the inventory to reflect operation at maximum capacity in 2014, but both industrial sources are minor so this did not have a major effect on the 2014 emission inventory.

Attainment Demonstration

The attainment demonstration shows how Oakridge will meet the PM_2.5 standard by 2014 through the implementation of control measures listed above. LRAPA used a “proportional rollback/rollforward analysis” or rollback model to conduct the analysis. The goal of this section is to demonstrate that future concentrations are less than the NAAQS at the Willamette Activity Center monitor and other unmonitored parts of the designated nonattainment area.

Baseline Design Value

The demonstration starts with estimating the baseline design value, or baseline concentration, for PM_2.5. The baseline design value is a statistic, expressed as a concentration that describes the PM_2.5 levels at the Willamette Activity Center monitor relative to the NAAQS. The procedure for its calculation is presented in “EPA Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for O3, PM_2.5, and Regional Haze”. PM_2.5 measurements from 2006 to 2010 are used to calculate the design value of 39.5 µg/m³ (see Table 4). Detailed methods on the baseline design value calculation are in Appendix X.

Table 4: Annual PM_2.5 values used to calculate baseline design value.

Background on Precursors

Speciated PM_2.5 samples were collected at Willamette Activity Center for the period July 2009-2011.  The samples showed the dominance of organic and elemental carbon, with secondary inorganic aerosol nitrate and sulfate comprising relatively minor concentrations of total PM_2.5.  Concern had been expressed about the role of secondary organic aerosols (SOAs) as components of total organic carbon, and an additional analysis was conducted by a research scientist at Portland State University (PSU) in collaboration with ODEQ to better understand the magnitude of these aerosols in the Klamath Falls, Oregon air shed.  The results of this analysis showed that the contributions from both biogenic and anthropogenic sources to be minor, less than 1% and 3%, respectively, of total design value PM_2.5.  In consultation with EPA, LRAPA chose to adopt these percent contributions as a conservative assumption for the Oakridge NAA demonstration. Because all secondary aerosols were determined to be minor contributors to total PM_2.5, these components and their concentrations are held constant in the rollback model and assigned a relative reduction factor (RRF) of 1.0.  The precursor emissions to secondary aerosols, including NOx, SO₂, ammonia, and biogenic and anthropogenic VOCs, are not used in the attainment demonstration (LRAPA is utilizing a rollback analysis for the attainment demonstration).

In addition to the study of secondary aerosols, a positive matrix factorization (PMF) study based on the speciated data from Willamette Activity Center was conducted by EPA Region 10 to identify likely sources of speciated PM_2.5.  The study showed the importance of residential woodsmoke to the high levels of organic carbon, an estimated 70-75% of total PM concentrations. 

The SANDWICH speciation formulation, based on adjusted and corrected Willamette Activity Center speciation data, is used to speciate the FRM measured design value (DV) for use in the rollback model.  The SANDWICH is a convenient profile of the DV with which to describe the components that contribute to PM_2.5 exceedances.  This profile is shown in Figure 10, and shows that over 95% of total PM is from organic and elemental carbon with smaller amounts of secondary inorganic aerosols, such as sulfate (1%) and nitrate (0.4%). The SOA study, the SANDWICH analysis, and the PMF study are described in more detail in Appendix X.  Based on the evidence cited above, the primary sources contributing to nonattainment in Oakridge are considered to be those that emit direct emissions of PM_2.5.  As a result, LRAPA has focused its strategies for the attainment demonstration on these sources.

Figure 10: Speciated Components of PM_2.5 (using SANDWICH analysis)

Speciated Filter Sample Analysis

PM_2.5 is a mixture and can be divided into major components: mass associated with sulfates, nitrates, ammonium, organic carbon, elemental carbon, particle bound water, and other primary inorganic particulate matter. Percent contribution to the total mass by each of these major components is used to estimate relative contribution by different emission sources.

From July 2009 to 2011, LRAPA conducted PM_2.5 speciation monitoring at the Willamette Activity Center location. Total PM_2.5 mass measurements using the FRM are used mainly to determine attainment or nonattainment of the standard. However, to provide information about particular source contribution to that total mass it was necessary to co-locate a speciation sampler that allows the breakdown of the total mass into different chemical species.

The total mass of PM_2.5 using the FRM sampler is not equal the simple sum of the measured components from the speciation filter, therefore it is necessary to make adjustments to represent FRM mass. In order to apply the results of the speciated filter analysis to the aerosol mass measurements, EPA Region 10 conducted Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbonaceous Material Balance Approach (SANDWICH) which is the default method in EPA modeling guidance to define baseline PM_2.5. The SANDWICH approach uses a combination of speciation measurements and modeled estimates to represent FRM PM_2.5 measurements. The goal is to reconstruct the measured speciated components so that they add up to the measured FRM PM_2.5 mass. Table 4 shows the results as percent contribution by a speciated component (sulfates, nitrates, organic carbon (OC), elemental carbon (EC), ammonia (NH3), and other primary particulate (OPP)). Detailed methods of the SANDWICH analysis are included in Appendix X.

Table 5: Contribution by speciated components. Results of SANDWICH analysis for winter (Oct-Mar).

Minor PM_2.5 Components

In addition to the speciated components in Table 5, ODEQ, in partnership with Portland State University, examined contribution by secondary organic aerosols in Klamath Falls, Oregon and found it to be relatively low. Anthropogenic secondary organic aerosols contribute 3% and biogenic 1% to the total measured PM_2.5 mass. LRAPA chose to adopt these percent contributions as a conservative assumption for the Oakridge NAA demonstration. Secondary organic aerosols and the other minor components sulfate, nitrate, and background EC and OC are assumed to be constant in rollback modeling. More details about this analysis are included in Appendix X.

Each source emits a different proportion of OC, EC, and OPP, the three components used to develop a speciated emissions inventory. This proportion, or the speciation profiles, for each source category are taken primarily from EPA SPECIATE 4.2 and 4.3 databases. The following source categories are included in the analysis:

Rollback Model

In Oregon, the rollback model has been used for demonstrating attainment of the PM NAAQS since the 1990s. PM₁₀ attainment plans which utilize this rollback model have been adopted and approved by EPA for the Klamath Falls, Lakeview, LaGrande, Grants Pass, and Oakridge areas. In evaluating the appropriate modeling analysis of PM_2.5 for Oakridge, LRAPA considered many different modeling approaches, including rollback and more sophisticated methods such as dispersion and receptor modeling. However, both dispersion and receptor are more resource intensive and do not offer substantial improvements in demonstrating attainment under conditions that exist in Oakridge. A rollback model can simulate worst case day conditions when stagnant conditions and slow emissions movement within the nonattainment area occur.

Oakridge is particularly well suited for a rollback demonstration because of a) the relatively small area of the NAA, b) the bowl shape of the local airshed and the presence of inversions and low mixing heights during evening hours when measured particulates are highest, c) the very few types of emissions sources in the NAA, with only a single industrial source and home wood heating devices dominating the emissions. Based on these considerations, LRAPA has chosen a rollback model for the area.

The rollback model is based on the assumption that there is a direct correlation between emissions of a pollutant and measured concentrations of that pollutant in the same airshed, and that changes in emissions will result in corresponding changes in concentration. This correlation is used to predict future concentrations based on future emissions. The change in concentrations caused by changes in emissions is represented by the Relative Response Factor (RRF). An RRF less than one indicates a reduction in future concentrations, RRF equal to one indicates no change, and RRF larger than one indicates an increase. RRFs are calculated for each speciated component (EC, OC, and OPP) used in the rollback model. Details of the analysis are presented in Appendix X. The results show a cumulative RRF = 0.696, which indicates a decrease in future concentrations. After the cumulative RRF is applied to the input data for the baseline design value, the results are used to calculate a future design value of 28.0 µg/m³.

Table 6: Baseline and Future projected design values.

The future ambient concentration levels are below the NAAQS (35 µg/m³) for a 24-hour average and the attainment of the standard is demonstrated with the application of the current strategies in place. The current reduction strategies described earlier in this section lower the emissions enough to meet the NAAQS at the Willamette Activity Center monitor.

Unmonitored Area Analysis

The previous section describes the demonstration of attainment at the Willamette Activity Center monitor. In addition, a supplemental analysis was conducted to examine future design values away from the Willamette Activity Center, both within Oakridge and in the neighboring city of Westfir. The unmonitored area analysis is based on a 2002–2003 saturation survey of Oakridge, and the 2009-2010 monitoring of Westfir. These monitoring efforts are described in greater detail in Appendix X.

The ratio of average concentration at each of these monitors to the average concentration at Willamette Activity Center is applied to the baseline design value at Willamette Activity Center to establish a “baseline” design value for each monitor. The same ratio is then applied to the Willamette Activity Center future design value to estimate a future design value for each site. Since there is currently only one point source in the emissions inventory for Oakridge, a dispersion modeling exercise to estimate source impacts was deemed unnecessary.

In both monitoring efforts referenced here, the Willamette Activity Center was the location of the highest observed concentration. Base and future design values for all monitored locations were below the NAAQS, indicating that the Willamette Activity Center concentration is the highest in the area. More detail of the unmonitored area analysis is available in Appendix X.

Application of Future Strategies

Including current strategies, and strengthening of these strategies, the rollback model shows that the Oakridge non-attainment area will achieve the standard of 35 µg/m³ by 2014. At 28.0 µg/m³, the future design value includes a buffer for potential variation while still meeting the standard. The Oakridge Advisory Committee developed contingency strategies to include in the attainment plan, if necessary, in order to assure continued compliance and include a protective buffer. Using these contingency strategies would result in additional emission reductions and consequently could also be used to show further reduction in the attainment demonstration roll back model. At this time, these additional measures do not appear necessary. The results of the rollback at Willamette Activity Center show a cumulative relative reduction factor (RRF) of 0.694 with current strategies and future strengthening of these strategies recommended by the committee.   Table 6 shows the baseline and future design values based on all current attainment strategies:

Table 7: Baseline and Future design values.

Contingency Plan

The attainment plan must contain contingency measures that would be implemented in the event that the Oakridge nonatttainment area fails to meet the standard on or after December 2014. These contingency measures are designed to correct the violation of the PM_2.5 standards and be implemented immediately. EPA requires that any contingency measures must equal one year equivalent of reasonable further progress (RFP). In Oakridge, RFP would equal about one microgram per cubic meter (µg/m3) of further required reduction.

Contingency Strategies

The following contingency strategies will be implemented to fully meet the air quality standards, if it becomes clear that the strengthened ongoing strategies described earlier will not be sufficient to attain the PM_2.5 standards by 2014:

a.  Stricter opacity limit, revising the current 40% opacity limit to a more restrictive 20% limit, as has been done in some other northwest communities;

b.  Stricter green-yellow-red advisory program, with more yellow and red advisory days each winter; and

c.  Phase-out of city woodstove curtailment exemptions (for sole source, economic hardship).

Using these contingency strategies is expected to result in additional emission reductions of three µg/m3 or more and show further reduction for reasonable further progress. This would more than achieve the one µg/m3 target needed to meet the EPA reasonable further progress test.

If Oakridge meets the PM_2.5 standard by the EPA Clean Air Act 2014 deadline, the contingency plan will not be enacted. If Oakridge does not meet the PM_2.5 standard by the EPA Clean Air Act 2014 deadline, the contingency plan will be enacted by the beginning of the immediate next wood-heating season, November 15, 2015.

If the high PM_2.5 concentration was determined to be an Exceptional Event based on EPA's Exceptional Events Rule, as flagged by ODEQ and concurred by EPA, no further action may be needed.

PCAdmin, 2012-06-25T13:50:00Z
See DEQ comments and redline/strikeout edits below. FYI – there is a lot of redundancy in the document. Have highlighted part of it, but not all. Assume you had different writers here. It shows.

PCAdmin, 2012-06-25T11:38:00Z
Should describe the size of the zone, and maybe include a map.

PCAdmin, 2012-06-25T11:23:00Z
And the SPZ prohibits any PB on red woodstove days.

PCAdmin, 2012-06-25T11:24:00Z
For what? Need to explain

PCAdmin, 2012-06-25T11:25:00Z
How much stricter? May be too vague for EPA

PCAdmin, 2012-06-25T11:31:00Z
Really? Sounds pretty extreme. I would not do this, may cause major compliance problems

PCAdmin, 2012-06-25T11:29:00Z
Besides those above – any others?

PCAdmin, 2012-06-25T11:22:00Z
I think this should come first, after Introduction. Also, you repeat some of the same info on PM2.5 health effects in both Background and What is PM2.5.

PCAdmin, 2012-06-25T11:33:00Z
and LRAPA Board too, yes?

PCAdmin, 2012-06-25T11:39:00Z
Could include the SPZ on this map

PCAdmin, 2012-06-25T11:44:00Z
Can remove quotes – you already use nonattainment above without them

Rachel Sakata, 2012-06-26T14:11:00Z
Actually, I thought it was December 14, 2014, since that’s the official date in the FR.

PCAdmin, 2012-06-25T11:48:00Z
I’m confused. Why does this bullet start by saying “complete” if it’s already completed?

Rachel Sakata, 2012-06-26T14:12:00Z
I agree, the “complete” word confused me too.

PCAdmin, 2012-06-25T11:51:00Z
Don’t you want to add prescribed burning/SPZ here too?

PCAdmin, 2012-06-25T11:54:00Z
This sentence does not make sense – maybe remove this word, but still not sure what you’re trying to say here.

PCAdmin, 2012-06-25T12:44:00Z
Isn’t LAER one of the attainment strategies? Why mentioned here? Shouldn’t it be on page 11 bullet list?

Rachel Sakata, 2012-06-26T14:14:00Z
This paragraph seems to be a mishmash of thoughts.

PCAdmin, 2012-06-25T11:57:00Z
Odd choice of word

PCAdmin, 2012-06-25T11:59:00Z
I would delete this

PCAdmin, 2012-06-25T12:00:00Z
Despite these aggressive efforts….

PCAdmin, 2012-06-25T12:01:00Z
Don’t really need to give the address of the monitor

PCAdmin, 2012-06-25T12:01:00Z
You’ve already covered this above

PCAdmin, 2012-06-25T12:06:00Z
You should say this on page 12 where you talk about the official PM2.5 monitor.

PCAdmin, 2012-06-25T12:08:00Z
And what does Figure 6 show? That Westfir does not have the same high PM2.5 levels as Oakridge…

Rachel Sakata, 2012-06-26T14:22:00Z
So, when were these ongoing strategies put into effect? That’s not quite clear. I’m assuming they were not calculated as part of the 2008 inventory, but you don’t explicitly state that.

PCAdmin, 2012-06-25T13:29:00Z
What about LAER for new sources?

Rachel Sakata, 2012-06-26T14:29:00Z
So, I’m a little confused now, because you list this as a main heading but then also include road sanding, smoke management, and industrial sources. Also, are these considered existing strategies? How are they different from current strategies (below) that covers the same time period (1989 – 2011)?

PCAdmin, 2012-06-25T12:46:00Z
Font inconsistency

PCAdmin, 2012-06-25T13:08:00Z
Font inconsistency

PCAdmin, 2012-06-25T13:11:00Z
same thing

PCAdmin, 2012-06-25T13:21:00Z
And the SPZ prohibits any PB on red woodstove days.

PCAdmin, 2012-06-25T13:30:00Z
You are repeating LAER and RACT here. If you keep it, then don’t need to spell out these acronyms again.

PCAdmin, 2012-06-25T13:27:00Z
Will be? Are?

Rachel Sakata, 2012-06-26T14:32:00Z
Seems like this section and the section above are all talking about current/existing strategies. May want to merge the two. Or is it that the existing strategies were accounted for in the 2008 EI, the current strategies were not (but were in the 2014 EI)? I’m a bit confused.

PCAdmin, 2012-06-25T13:44:00Z
to achieve the standard

Rachel Sakata, 2012-06-26T14:33:00Z
so you are or are not implementing these strategies? I think EPA will comment that you can’t really include/take credit for these unless you’re going to be implementing them. We got dinged by EPA for that in the KFalls plan.

Rachel Sakata, 2012-06-26T14:36:00Z
So, I’m sure EPA has commented on this to you, but they wanted to see what the reduction was from these strategies. In other words, what strategy/ies give you the biggest bang for the buck?

Rachel Sakata, 2012-06-26T14:37:00Z
How are these enforced? Are you adopting rules to ensure the contingency strategies kick in by the required deadline?

PCAdmin, 2012-06-25T13:36:00Z
strongly recommend against this

PCAdmin, 2012-06-25T13:38:00Z
This does not belong under Industrial heading above

Rachel Sakata, 2012-06-26T14:38:00Z
I agree, this probably belongs somewhere else. Maybe under the 2014 EI discussion?

Rachel Sakata, 2012-06-26T14:39:00Z
EPA wanted us to cite the FR, not guidance.

Rachel Sakata, 2012-06-26T14:40:00Z
So are you saying that the Oakridge airshed is similar to KFAlls? Probably just need a sentence saying that to make it clear.

Rachel Sakata, 2012-06-26T14:41:00Z
Same comment as above.

Rachel Sakata, 2012-06-26T14:42:00Z
w

Rachel Sakata, 2012-06-26T14:42:00Z
We took this out after getting feedback from EPA that it could go in an Appendix.

Rachel Sakata, 2012-06-26T14:44:00Z
You might want to look at the latest draft of the KFalls plan. We’ve edited this section significantly since the last time you saw it.

Rachel Sakata, 2012-06-26T14:46:00Z
When I see contingency, it makes me think that Oakridge didn’t meet the standard. You might want to use a different word here.

PCAdmin, 2012-06-25T13:46:00Z
FYI, this is the 3^rd time in the document you mention this.