ENCLOSURE
RICHMOND
OZONE
NONATTAINMENT
AREA
PETITION
FOR
RECLASSIFICATION
TECHNICAL
SUPPORT
DOCUMENT
JULY
12,
2004
2
Richmond
Nonattainment
Reclassification
Petition
Ozone
Air
Monitoring
Data
Analysis
INTRODUCTION
The
Department
of
Environmental
Quality
operates
four
continuous
ozone
air
quality
monitors
in
the
Richmond
metropolitan
area.
These
monitors
are
configured
to
provide
a
comprehensive
profile
of
ozone
concentrations
in
the
Richmond
area
and
includes
both
upwind/
downwind
and
urban/
rural
sites.
Specifically,
these
monitors
are
listed
below:

 
Chesterfield
County
Monitor
(
Bensley
Armory)
­
Serves
as
the
upwind
monitor
to
the
Richmond
metro
area
that
is
located
the
center
of
the
County.
 
Henrico
County
Monitor
(
Math
&
Science
Center)
 
Serves
as
the
urban
core
monitor
located
just
North
of
central
Richmond
City.
 
Hanover
County
Monitor
(
McCellan
Road)
 
Serves
as
the
primary
downwind
monitor
for
the
metro
area.
 
Charles
City
Monitor
(
Shirley
Plantation)
 
Serves
as
a
secondary
downwind
monitor
for
the
metro
area.

This
monitoring
network
has
been
in
place
for
since
the
early
1990'
s
with
the
exception
of
the
local
movement
of
the
Hanover
monitor
in
2000.

Provided
below
is
a
map
of
the
location
of
the
Richmond
ozone
monitors
and
their
current
design
values
based
on
2001
to
2003
data,
which
represents
the
average
of
the
4th
highest
values
during
each
of
these
years.

Richmond
Monitoring
Network
&
Current
Ozone
Design
Values
Hanover
Petersburg
Charles
City
Henrico
Chesterfield
Richmond
Colonial
Heights
Hopewell
Prince
George
I­
95
I­
85
I­
64
I­
95
I­
64
HANOVER
94
PPB
CHARLES
CITY
91
PPB
CHESTERFIELD
86
PPB
HENRICO
90
PPB
3
The
current
"
worst
case"
monitor
that
was
used
to
set
the
8­
hour
ozone
standard
nonttainment
classification
is
the
primary
downwind
monitor
located
in
Hanover
County.
This
monitor's
current
design
value
is
94
ppb
which
is
within
the
5%
range
allowed
for
reclassification
to
the
lower
marginal
level.
All
the
other
monitors
in
the
metro
area
have
design
values
within
the
marginal
classification
range.

MONITORING
DATA
TRENDS
To
further
analyze
ozone
trends
in
the
Richmond
area,
individual
and
cumulative
data
evaluations
have
been
performed
on
ozone
monitoring
data
in
the
area
beginning
in
1990.
Provided
below
are
trend
graphs
for
each
of
the
four
Richmond
monitors
showing
the
design
value
trends
from
1990
to
the
current
three­
year
period.

Richmond
Monitor
Design
Value
Trends
from
1990
to
2003
As
can
be
clearly
seen
from
these
graphs,
the
general
trend
lines
for
the
Richmond
monitors
have
increased
only
slightly
over
period
analyzed.
In
addition,
three
monitors
have
remained
solidly
in
the
marginal
range
in
terms
of
design
values
during
the
same
period.
Furthermore,
a
definite
downward
trend
can
be
seen
at
these
three
monitors
since
the
official
promulgation
of
the
8­
hour
ozone
standard
in
1997.
The
anomaly
observed
in
the
Hanover
monitor
is
due
to
its
closure
and
removal
after
the
1999
ozone
season.
Therefore,
the
trend
after
the
1997­
1999
design
value
period
is
not
available
for
this
particular
monitor.
The
relocated
Hanover
monitor
has
just
completed
its
first
threeyear
monitoring
period
recording
a
design
value
of
94
PPB.

To
further
evaluate
this
data,
the
average
of
the
design
values
for
all
four
monitors
has
been
plotted
and
is
presented
below.
This
graph
serves
as
an
indication
of
the
overall
ozone
concentration
trends
in
Richmond
during
the
1990
to
2003
period.
Chesterf
ield
Co.,
71­
H
0.070
0.080
0.090
0.100
0.110
Henrico
Co.,
72­
M
0.070
0.080
0.090
0.100
0.110
Hanover
Co.,
73­
C
0.070
0.080
0.090
0.100
0.110
Charles
City
Co.,
75­
B
0.070
0.080
0.090
0.100
0.110
4
Overall
Richmond
Monitor
Design
Value
Trend
(
1990
to
2003)

It
can
been
seen
that
the
general
trend
for
the
Richmond
area
is
that
ozone
concentrations
and
corresponding
design
values
are
consistent
with
a
marginal
nonattainment
classification
and
have
remained
mostly
in
the
core
marginal
range
of
85
to
90
PPB.

Finally,
the
number
of
days
when
exceedances
of
the
8­
hour
standard
were
recorded
in
the
Richmond
area
from
1994
to
2003
have
been
plotted
below
to
serve
as
an
indicator
of
the
amount
of
time
that
area
residents
have
been
exposed
to
levels
of
ozone
above
the
standard.

Number
of
Richmond
High
Ozone
Days
(
Three­
Year
Average
Trend)
3­
year
Averages
for
all
Richmond
Monitors
(
1990
to
2003)

0.060
0.070
0.080
0.090
0.100
1
2
3
4
5
6
7
8
9
10
11
12
Units
­
ppm
Central
Richmond
Exeedance
days
0
5
10
15
20
25
30
94'
to
96'
95'
to
97'
96'
to
98'
97'
to
99'
98'
to
00'
99'
to
01'
00'
to
02'
01'
to
03'
5
Again,
this
data
shows
a
mostly
stable
and
consistent
trend
of
average
exceedance
days
in
the
Richmond
area,
other
than
the
exceptional
period
during
the
late
1990'
s.
The
same
clear
downward
trend
can
again
be
seen
from
this
peak
period
(
1997
to
1999)
to
the
present
time.

CONCLUSIONS
The
analysis
of
monitoring
data
provided
above
supports
the
petition
for
the
reclassification
of
the
Richmond
8­
hour
ozone
nonattainment
area
to
a
marginal
nonattainment
area
in
that:

 
Three
of
the
four
monitors
in
the
Richmond
metro
area
have
and
continue
to
record
levels
consistent
with
a
marginal
nonattainment
classification.

 
The
majority
of
the
monitoring
indicators
for
the
Richmond
metro
area
are
indicative
of
a
marginal
nonattainment
area
with
design
values
and
overall
area
averages
well
within
the
range
for
this
lesser
classification
(
85
to
92
PPB).

 
The
one
monitor
of
exception
to
this
general
trend
in
Hanover
County
is
located
in
the
rural
and
sparsely
populated
Northeast
corner
of
the
nonattainment
area.
The
vast
majority
of
the
metro
area's
population
is
located
in
areas
where
the
corresponding
monitors
are
consistently
recording
marginal
levels
of
ozone
nonattainment
(
Chesterfield
&
Henrico).

 
Thus
far,
no
exceedances
of
the
8­
hour
standard
have
been
recorded
in
the
Richmond
area
during
the
2004
ozone
season.
6
Richmond
Nonattainment
Reclassification
Petition
Regional
Ozone
Modeling
Analyses
INTRODUCTION
Given
the
tight
timeframe
for
submitting
this
petition
for
the
reclassification
of
the
Richmond
nonattainment
area,
only
limited
modeling
could
be
performed
specifically
to
support
this
petition.
However,
several
previous
modeling
exercises
performed
by
DEQ
and
EPA
provide
consistent
indications
that
the
Richmond
area
is
likely
to
attain
the
ozone
standard
during
the
2007
to
2010
timeframe.
A
listing
of
these
modeling
analyses
is
provided
below:

 
DEQ
Early
Action
Compact
Regional
Ozone
Modeling
 
EPA
NOX
SIP
Call
Rule
Modeling
 
EPA
Clear
Skies
Act
(
CSA)
Modeling
 
EPA
Clean
Air
Interstate
Rule
(
CAIR)
Modeling
The
remainder
of
this
section
will
summarize
these
modeling
exercises
and
the
results
and
predictions
relating
to
the
Richmond
nonattainment
area.

VDEQ
EARLY
ACTION
COMPACT
MODELING
As
part
of
the
early
action
compact
and
planning
process
for
the
Roanoke
and
Winchester
areas
in
Virginia,
the
DEQ
performed
a
regional
modeling
exercise
to
demonstrate
that
these
areas
would
attain
the
8­
hour
ozone
standard
by
2007.
Although
Richmond
was
not
the
focus
of
this
modeling,
data
is
also
available
for
this
area
that
provides
data
on
predicted
ozone
reductions
and
resulting
levels
in
the
Richmond
area
by
2007.
Provided
below
are
graphic
and
table
summaries
of
the
data
for
Richmond
from
this
modeling:

Regional
Modeling
Results
 
Base
Case
Episode
(
August
1999)
7
Regional
Modeling
Results
 
2007
Future
Control
Case
Predictions
(
full
domain)

Regional
Modeling
Results
 
2007
Future
Control
Case
Predictions
(
Central
VA)

Although
initial
visual
review
of
these
results
appears
to
indicate
a
continuing
issue
with
high
8­
hour
ozone
levels
in
the
Richmond
areas,
it
should
be
noted
that
in
the
base
case
modeling,
ozone
concentrations
are
over­
predicted
in
the
Richmond
area
for
the
selected
1999
episode.
Logically,
this
over­
prediction
is
continued
into
the
2007
control
episode.
While
all
the
factors
leading
to
this
over­
prediction
by
the
model
are
not
yet
known,
much
of
this
may
be
attributable
to
a
major
error
in
Richmond
utility
emissions
and
the
overly
conservative
estimates
of
Richmond
VOC
point
source
emissions
due
to
the
application
of
rule
effectiveness
and
other
factors.
8
After
correcting
the
error
in
area
utility
emissions,
the
control
case
was
run
again
and
produced
the
following
results.

Revised
Modeling
Results
 
2007
Future
Control
Case
(
Corrected
Utility
NOX
Emissions)

Attainment
Test
Results
for
Monitors
in
the
Richmond
Area
(
Exact
Grid
Cell)

County/
City
Modeled
Average
Base­
Year
(
1999)
Daily
8­
hr
Maximum
O3
(
ppb)
Modeled
Average
Future­
Year
(
2007)
Daily
8­
hr
Maximum
O3
(
ppb)
Relative
Reduction
Factor
(
RRF)
Current
Design
Value
(
1997­
1999)
Future
Design
Value
(
1997­
1999)
Current
Design
Value
(
2001­
2003)
Future
Design
Value
(
2001­
2003)

Chesterfield
83.31
69.13
0.83
91
75.5
86
71.4
Henrico
86.43
76.77
0.888
96
85.2
90
79.9
Hanover
83.67
72.31
0.864
99
85.5
94
81.2
Charles
City
80.87
71.37
0.882
96
84.7
91
80.3
Attainment
Test
Results
for
Monitors
in
the
Richmond
Area
(
Max
9
Grid
Cells)

County/
City
Modeled
Average
Base­
Year
(
1999)
Daily
8­
hr
Maximum
O3
(
ppb)
Modeled
Average
Future­
Year
(
2007)
Daily
8­
hr
Maximum
O3
(
ppb)
Relative
Reduction
Factor
(
RRF)
Current
Design
Value
(
1997­
1999)
Future
Design
Value
(
1997­
1999)
Current
Design
Value
(
2001­
2003)
Future
Design
Value
(
2001­
2003)

Chesterfield
86.94
76.35
0.878
91
79.9
86
75.5
Henrico
91.74
80.22
0.874
96
83.9
90
78.7
Hanover
88.72
79.45
0.895
99
88.6
94
84.1
Charles
City
86.8
78.69
0.907
96
87.1
91
82.5
Nonattainment
Attainment
Two
attainment
tests
were
applied
to
the
modeling
results,
an
exact
monitor
grid
cell
analysis
(
first
table),
and
a
9
grid
cell
maximum
analysis
(
second
table).
As
can
be
seen
by
these
results,
strict
application
of
the
attainment
test
by
developing
relative
reduction
factors
(
RRF)
and
applying
them
to
the
three­
year
design
value
during
the
time
of
the
modeled
episode
(
1997
to
1999)
produces
mixed
results
in
terms
of
predicted
future
9
design
values.
The
exact
cell
test
predicts
attainment
at
all
area
monitors.
The
9
cell
maximum
test
predicts
attainment
at
2
monitors
and
marginal
nonattainment
at
the
other
2
monitors
based
on
the
1997
to
1999
design
values.

However,
since
the
design
values
used
to
officially
designate
these
areas
were
from
a
different
time
period
(
2001
to
2003),
an
additional
analysis
was
performed
by
applying
the
RRFs
developed
by
the
model
to
the
current
area
monitor
design
values.
This
additional
analysis
predicts
attainment
in
2007
at
all
area
monitors
for
both
attainment
tests.

VDEQ
REFINED
EAC
MODELING
(
UPDATED
POINT
SOURCES)

In
an
effort
to
refine
the
EAC
modeling
specific
to
the
Richmond
area
and
to
utilize
more
current
and
representative
estimates
for
point
source
emissions,
revised
2007
point
source
emissions
projections
were
developed
using
the
recently
developed
point
source
emissions
estimates
for
2002.
The
results
of
this
refined
modeling
are
presented
below:

Revised
Modeling
Results
 
2007
Future
Control
Case
(
Revised
Point
Source
Emissions)
10
Attainment
Test
Results
for
Monitors
in
the
Richmond
Area
(
Exact
Grid
Cell)

County/
City
Modeled
Average
Base­
Year
(
1999)
Daily
8­
hr
Maximum
O3
(
ppb)
Modeled
Average
Future­
Year
(
2007)
Daily
8­
hr
Maximum
O3
(
ppb)
Relative
Reduction
Factor
(
RRF)
Current
Design
Value
(
1997­
1999)
Future
Design
Value
(
1997­
1999)
Current
Design
Value
(
2001­
2003)
Future
Design
Value
(
2001­
2003)

Chesterfield
83.31
65.96
0.792
91
72.1
86
68.1
Henrico
86.43
71.34
0.825
96
79.2
90
74.3
Hanover
83.67
67.06
0.801
99
79.3
94
75.3
Charles
City
80.87
68.43
0.846
96
81.2
91
77.0
Attainment
Test
Results
for
Monitors
in
the
Richmond
Area
(
Max
9
Grid
Cells)

County/
City
Modeled
Average
Base­
Year
(
1999)
Daily
8­
hr
Maximum
O3
(
ppb)
Modeled
Average
Future­
Year
(
2007)
Daily
8­
hr
Maximum
O3
(
ppb)
Relative
Reduction
Factor
(
RRF)
Current
Design
Value
(
1997­
1999)
Future
Design
Value
(
1997­
1999)
Current
Design
Value
(
2001­
2003)
Future
Design
Value
(
2001­
2003)

Chesterfield
86.94
71.36
0.821
91
74.7
86
70.6
Henrico
91.74
74.71
0.814
96
78.1
90
73.3
Hanover
88.72
74.03
0.834
99
82.6
94
78.4
Charles
City
86.8
73.65
0.849
96
81.5
91
77.3
Nonattainment
Attainment
Again,
the
same
two
attainment
tests
were
applied
to
the
refined
Richmond
modeling
results.
Under
this
scenario,
in
all
cases
attainment
is
predicted
for
the
area
monitors
and
surrounding
grid
cells.

EPA
MODELING
EXERCISES
A
number
of
modeling
exercise
have
be
performed
by
EPA
to
support
various
rulemaking
actions,
beginning
with
the
NOX
SIP
Call
(
SC)
and
most
recently
in
support
of
the
Clear
Skies
Act
(
CSA)
and
Clean
Air
Interstate
Rule
(
CAIR).
Although
these
various
modeling
exercises
were
performed
for
different
reasons,
all
of
them
have
produced
predicted
future
ozone
levels
that
provide
additional
information
on
predicted
ozone
trends
in
the
future.
A
summary
of
these
modeling
exercises
and
the
resulting
ozone
predictions
for
the
Richmond
area
is
provided
in
the
table
below:

MONITOR
2007
2010
2015
2020
Chesterfield
74
PPB
(
SC)
74
PPB
(
CAIR)
71PPB
(
CAIR)
69
PPB
(
CSA)
Henrico
77
PPB
(
SC)
77
PPB
(
CAIR)
74
PPB
(
CAIR)
65
PPB
(
CSA)
Hanover
77
PPB
(
SC)
NA
NA
NA
Charles
City
77
PPB
(
SC)
77
PPB
(
CAIR)
74
PPB
(
CAIR)
65
PPB
(
CSA)

As
can
be
seen
above,
all
of
these
EPA
modeling
exercises
predict
attainment
in
the
Richmond
area
as
early
as
2007
and
continuing
out
to
2020
with
decreasing
ozone
concentrations.
11
CONCLUSIONS
The
referenced
modeling
exercises
support
the
petition
for
the
reclassification
of
the
Richmond
8­
hour
ozone
nonattainment
area
to
a
marginal
nonattainment
area
in
that:

 
There
is
a
preponderance
of
modeling
evidence
that
the
Richmond
area
will
continue
to
experience
lower
ozone
levels
and
is
likely
to
attain
the
8­
hour
standard
by
2007.

 
Specifically,
almost
all
of
these
analyses
predict
that
the
Richmond
area
will
come
into
compliance
with
the
8­
hour
standard
by
2007
or
2010,
depending
on
the
analysis
involved.

 
Continue
attainment
and
decreasing
ozone
levels
are
predicted
for
the
Richmond
area
out
into
the
future
(
2015
&
2020).
12
Richmond
Nonattainment
Reclassification
Petition
Ozone
Precursor
Emissions
Analysis
INTRODUCTION
The
Department
of
Environmental
Quality
periodically
develops
comprehensive
air
pollutant
emissions
inventories
to
support
air
quality
planning
and
tracking
purposes.
A
statewide
base
year
2002
ozone
precursor
inventory,
currently
in
draft
form,
has
been
developed
to
serve
as
a
baseline
for
8­
hour
ozone
planning
purposes.
A
summary
of
this
inventory
and
projected
emissions
to
2007
for
the
Richmond
area
are
provided
in
this
analysis
to
document
the
anticipated
emissions
reductions
expected
from
existing
and
future
state
and
federal
control
programs.
These
controls
can
be
categorized
as
follows:

 
Stationary
&
Area
Source
Controls
­
In
addition
NOX
SIP
Call
program
which
will
produce
significant
utility
NOX
emission
reductions,
the
EPA
has
developed
a
number
of
control
programs
to
address
smaller
"
area"
sources
of
emissions
that
are
significant
contributors
to
ozone
formation.
These
programs
reduce
emissions
from
such
sources
as
industrial/
architectural
paints,
vehicle
paints,
metal
cleaning
products,
and
selected
consumer
products.

 
Motor
Vehicle
Controls
­
Significant
progress
continues
in
reducing
motor
vehicle
emissions.
Several
federal
programs
have
established
more
stringent
engine,
vehicle
and
fuel
standards
for
cars,
sport
utility
vehicles,
and
large
trucks.
These
programs
combined
are
expected
to
produce
progressively
larger
emission
reductions
over
the
next
twenty
years
as
new
vehicles
replace
older
ones.

 
Non­
Road
Vehicle
&
Equipment
Standards
­
The
category
of
"
non­
road"
sources
that
covers
everything
from
lawn
&
garden
equipment
to
aircraft,
has
become
a
significant
source
of
air
pollutant
emissions.
In
response,
EPA
has
adopted
a
series
of
strategies
to
address
these
sources.
These
programs
include
engine
emission
standards
for
lawn
&
garden
equipment,
construction
equipment,
boat
engines,
and
locomotives.

2002
BASELINE
EMISSIONS
INVENTORY
FOR
RICHMOND
Provided
below
is
a
summary
of
the
2002
baseline
ozone
season
daily
emissions
inventory
of
VOC
and
NOX
for
the
Richmond
nonattainment
area:

VOC
Emissions:

CATEGORY
DAILY
EMISSIONS
Point
27.94
tons
Area
45.71
tons
Nonroad
19.64
tons
Mobile
46.31
tons
TOTAL:
139.60
tons
Point
Area
Nonroad
Mobile
33%
20%

18%
33%
13
NOX
Emissions:

CATEGORY
DAILY
EMISSIONS
Point
120.80
tons
Area
25.62
tons
Nonroad
19.81
tons
Mobile
72.29
tons
TOTAL:
238.51
tons
2007
PROJECTED
EMISSIONS
INVENTORY
FOR
RICHMOND
Provided
below
is
a
summary
of
the
2007
projected
ozone
season
daily
emissions
inventory
of
VOC
and
NOX
for
the
Richmond
nonattainment
area:

VOC
Emissions:

CATEGORY
DAILY
EMISSIONS
Point
30.18
tons
Area
46.70
tons
Nonroad
14.14
tons
Mobile
32.16
tons
TOTAL:
123.17
tons
NOX
Emissions:

CATEGORY
DAILY
EMISSIONS
Point
81.63
tons
Area
26.60
tons
Nonroad
17.26
tons
Mobile
50.82
tons
TOTAL:
176.31
tons
Point
Area
Nonroad
Mobile
51%
30%

11%
8%

Point
Area
Nonroad
Mobile
26%
25%

11%
38%

Point
Area
Nonroad
Mobile
46%
29%

15%
10%
14
OZONE
PRECURSOR
EMISSION
REDUCTIONS
IN
RICHMOND
BY
2007
Provided
below
is
a
summary
of
the
anticipated
emission
reductions
in
ozone
season
daily
emissions
of
VOC
and
NOX
for
the
Richmond
nonattainment
area
by
2007:

As
can
be
seen
from
the
graph
above,
it
is
predicted
that
a
12%
reduction
in
VOC
emissions
and
26%
reduction
in
NOX
emissions
will
occur
in
the
Richmond
nonattainment
area
by
2007
due
to
the
implementation
of
state
and
federal
control
measures.

CONCLUSIONS
The
emissions
analysis
presented
supports
the
petition
for
the
reclassification
of
the
Richmond
8­
hour
ozone
nonattainment
area
to
a
marginal
nonattainment
area
in
that:

 
Significant
reductions
in
both
VOC
and
NOX
emissions
are
expected
in
the
Richmond
area
between
2002
and
2007.

 
These
local
reductions,
combined
with
ozone
transport
reduction
from
other
areas,
are
likely
to
be
sufficient
to
bring
the
area
into
compliance
with
the
8­
hour
ozone
standard.

 
The
predicted
reductions
from
many
of
these
control
measures
will
continue
to
increase
beyond
the
2007
timeframe.
0
50
100
150
200
250
Tons
Per
Day
2002
2007
Inventory
year
VOCs
NOx
­
12%
­
26%
