PLAN TO IMPROVE AIR QUALITY IN THE

WASHINGTON, DC-MD-VA REGION

March 7, 2008

State Implementation Plan (SIP) for Fine Particle (PM25) Standards

And 2002 Base Year Inventory for the

Washington DC-MD-VA Nonattainment Area
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PLAN TO IMPROVE AIR QUALITY IN THE

WASHINGTON, DC-MD-VA REGION

State Implementation Plan (SIP) for Fine Particle (PM2.5)

Standard and 2002 Base Year Inventory

for the

WASHINGTON DC-MD-VA NONATTAINMENT AREA

Prepared by:

Metropolitan Washington Council of Governments

forthe

District of Columbia Department of Environment

Maryland Department of the Environment

and the

Virginia Department of Environmental Quality

on behalf of the Metropolitan Washington Air Quality Committee

March 7, 2008
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Alternative formats ofthis publication can bemade available for persons with disabilities.

Phone: 202.962.3300 or 202-962.3213

(TDD)

Email: accornrnodations(mwcOg.Org.

For details: www.mwcog.org.

For Virginia: Phone: (804) 698-4070Email: abbanksdeq.virgiflia.gov

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TABLE OF CONTENTS

1. EXECUTWE SUMMARY .1-1

1.1 Introduction and Background 1-11.2 SIP Requirements for Nonattainment Areas 1-41.3 The SIP Process 1-41.4 The Metropolitan Washington Air Quality Committee (MWAQC) 1-51.5 Interstate Air Quality Council 1-61.6 State Commitment/Implementation Assurances 1-61.7 Submittal ofthe Plans 1-61.8 Sanctions 1-61.9 Base Year 2002 Emission mv. and FY 2009 Emission Inv 1-71.10 Reductions in PM2.5Precursors from Measures, 2002-2009 1-91.11 Establishment of a Budget for Transportation On-Road Motor Vehicle Emissions 1-111.12 Attainment Demonstration 1-121.13 Analysis ofReasonably Available Control Measures (RACM) 1-131.14 Contingency Measures 1-131.15 Document Contents 1-14

2.0 FINE PARTICLE POLLUTION 2-1

2.1 Definition of Fine Particle Pollution 2-12.2 Health and Environmental Effects 2-12.3 Seasonal Variation ofPM25 Concentrations and Constituents 2-3

2.4 Diurnal Variation of Fine Particles 2-82.5 Trajectories of Fine Particles 2-82.6 Major Constituents of PM2.5in the Washington Region 2-10

2.7 Sources of Fme Particles and Constituents in the Washington Region 2-11

2.8 Determination of Significance for Precursors 2-122.9 Compliance with the Annual PM2.5NAAQS 2-14

3.0 THE 2002 BASE-YEAR INVENTORY 3-1

3.1 Background and requirements 3-13.2 Total Emissions by Source 3-5

3.2.1 Point Sources 3-53.2.2 Area Sources 3-53.2.3 Onroad Mobile Sources 3-53.2.4 Nonroad Mobile Sources 3-63.2.5 Biogenic Sources 3-7

3.3 Annual Inventories 3-7
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5.0 CONTROL MEASURES .5-1

5.1 Point Source Measures 5-2

5.2 Area Source Measures 5-7

5.3 Nonroad Source Measures 5-8

5.4 On-road Source Measures 5-16

5.5 Supplemental Control Measures 5-24

6.0 REASONABLY AVAILABLE CONTROL MEASURES (RACM) ANALYSIS 6-1

6.1 Statutory and Regulatory Requirements for RACM Analysis 6-1

6.1.1 Discussion ofReasonable Control Measures 6-1

6.1.2 Evaluation ofRACM for Purposes ofAchieving Attainment 6-2

6.2 Summary 6-2

6.2.1 RACM Determinaton 6-2

6.2.2 RACT Applicability 6-3

7.0 MOTOR VEHICLE EMISSION BUDGETS 7-1

7.1 Motor Vehicle Emissions Budget and the Washington Area

Transportation Conformity Process 7-2

7.2 Budget Level for On-Road Motor Vehicle Source Emissions 7-3

7.2.1 Attainment Year 2009 On-Road Motor Vehicle Emissions Budgets 7-4

7.2.2 Contingency Budget 7-4

7.3 TCMs and TERMs 7-4

7.4 Trends in On-Road Motor Vehicle Emissions 7-4

8.0 1997 PM2.5NONATTAINMENT AREA PLAN COMMITMENTS 8-1

8.1 Schedules of Adopted Control Measures 8-1

8.2 New Source Review Permitting 8-7

8.3 RACT Applicability 8-8

8.4 Revision of New Source Review Regulations 8-8

9.0 ATTAINMENT DEMONSTRATION 9-1

9.1 Modeling Study Overview: Background and Objectives 9-1

9.1.1 Relationship to Regional Modeling Protocols 9-1

9.1.2 Conceptual Model 9-2

9.2 Domain and Database Issues 9-2

9.2.1 Episode Selection 9-2

9.2.2 Size ofthe Modeling Domain 9-3

9.2.3 Horizontal Grid Size 9-3

9.2.4 Vertical Resolution 9-3

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5 Initial and Boundary Conditions 9-3
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9.4 Attainment Demonstration .9-16

9.4.1 Model Attainment Test 9-179.4.2 Unmonitored Area Analysis 9-23

9.4.3 Local Area Analysis 9-24

9.4.4 Emissions Inventories 9-24

9.4.5 Supplemental Analyses and Weight of Evidence Determination 9-259.4.6 Summary and Conclusions of Attainment Demonstration 9-269.4.7 Procedural Requirements 9-27

10.0 CONTINGENCY PLAN 10-1

10.1 Background 10-1

10.2 Enforceability Issues 10-110.3 EvaluationlRequired Reductions 10-1

10.4 Identified Contingency Measures 10-2

Glossary

List of TablesTableA 1-10Table 2-1 EPA SIP Requirements for PM Pollutants 2-13

Table 2-2 Summary of Significance Determinations for SIP Controls and Motor Vehicle EmissionBudgets 2-13

Table 2-3 Summary ofRationale for Insignificance Determinations for VOCs and NH3for SIPControls 2-14Table 3-1 2002 Base Year Annual PM2.5Direct Inventory 3-2

Table 3-2 2002 Base Year Annual NO Inventory 3-2Table 3-3 2002 Base Year Annual SO2Inventory 3-3

Table 3-4 2002 Base Year Annual VOCs Inventory 3-3

Table 3-5 2002 Base Year Annual NH3Inventory 3-4

Table 3-6 2002 Base Year Annual PM10 Direct Inventory 3-4

Table 4-1 2002-2009 Growth Factors 4-2Table 4-2 2009 Projected Uncontrolled PM2.5Direct Emissions 4-6Table 4-3 2009 Projected Uncontrolled NO Emissions 4-6

Table 4-4 2009 Projected Uncontrolled SO2Emissions 4-7

Table 4-5 Fuel Reid Vapor Pressure 4-li

Table 4-6 Other NONROAD Model Inputs 4-liTable 4-7 2009 Projected Controlled PM2.5Direct Emissions 4-13Table 4-8 2009 Projected Controlled NO Emissions 4-13

Table 4-9 2009 Projected Controlled SO2 Emissions 4-14Table A Summary of Control Strategies 5

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Table 9-3 Annual SMAT Results for Washington, D.C. MSA 2009 Beyond-On-The-Way Control

Measures and Virginia CAIR Rule 9-21

Table 9-4 2009 Annual SMAT Results Comparison for Regional Modeling Runs 9-22Table 9-5 24-Hour Modeling Attainment Test Using EPA SMAT Methodology

2009 Beyond-On-The-Way Control Measures and Virginia CAIR Rule 9-22Table 9-6 2009 24-Hour SMAT Results Comparison for Regional Modeling Runs 9-23

Table 10-1 Contingency Requirement for PM and PM Precursors 10-2

Table 10-2 Contingency Measures for 2009 Attainment 10-3

List of Figures

Figure 1-1 FRM and STN Monitoring Network 1-3Figure 1-2 PM2.5Emissions By Source 1-7

Figure 1-3 NO Emissions By Source 1-8

Figure 1-4 SO2 Emissions By Source 1-8

Figure 1-5 Annual PM2.5Design Value, 200 1-2006 1-12Figure 1-6 24-Hour PM2.5Design Value, 2001-2006 1-13

Figure 2-1 Atmospheric Chemical Reactions that Contribute to PM2.5 2-2

Figure 2-2 Seasonal Variation of PM2.5during 2002-2005 2-3Figure 2-3 Seasonal Variation of Sulfates during 2002-2005 2-4

Figure 2-4 Seasonal Variation ofNitrates during 2002-2005 2-5

Figure 2-5 Seasonal Variation of Organic Carbon during 2002-2005 2-6

Figure 2-6 Seasonal Variation ofAmmonium during 2002-2005 2-7Figure 2-7 PM2.5Diurnal Pattern Based on Daily PM2.5Data from 2003 to 2007 2-8

Figure 2-8 Fine PM Trajectories from 2001 to 2003 2-9Figure 2-9 Annually Averaged 2001-2003 Concentrations ofPM2.5Constituents 2-10

Figure 2-10 PM2.5Composition (% by Mass) Data from McMillan in 2004 2-11Figure 2-11 Annual PM2.5Design Value, Washington Region, 2001-2006 2-15 V

Figure 2-12 24-Hour PM2.5Design Value, Washington Region, 2001-2006 2-15Figure 9-1 Washington, D.C. Metropolitan Statistical Area and Surrounding Region 9-2

Figure 9-1 FRM, STN, and iMPROVE Locations Used for the Model Evaluation 9-8Figure 9-2 Composite FRM Time Series across the OTR+ Region (264 monitors) 9-9

Figure 9-3 MFE and MFB Time Series for FRM PM2.5across the OTR+ Region 9-10 . -

Figure 9-4 Bugle Plot for FRM PM2.5across OTR+ Region 9-11

L Figure 9-5 Bugle Plot for SO4across OTR+ Region 9-12

Figure 9-6 Bugle Plot for NO3across OTR+ Region 9-13Figure 9-7 Bugle Plot for NH4across OTR+ Region 9-13

Figure 9-8 Bugle Plot for EC across OTR+ Region 9-13

Figure 9-9 Bugle Plot for OM across OTR+ Region 9-14

Figure 9-10 Bugle Plot for SoillCrustal across OTR+ Region 9-14Figure 9-11 Bugle Plot for FRM PM2.5in Washington DC MSA 9-15
List of Appendices

Appendix A. MWAQC and AQPAC RostersAppendix B. Base Year 2002 Emissions Inventory and Documentation

Appendix B Attachments

Al. BY 2002 Point Source Emissions SummaryA2. BY 2002 Point Source Emissions Files — NIF3.0 Format (Available on a CD on request)

B 1. Technical Memorandum on Commercial Cooking Emissions

B2. Technical Memorandum on Composting Emissions

B3. BY 2002 Emissions Inventory Document for MarylandB4. Airport Emissions (Metropolitan Washington Airports Authority)B5. Portable Fuel Container Calculation Methodology for VirginiaCl. BY 2002 Area and Nonroad Source Emissions SummaryC2. BY 2002 Area & Non-Nonroad Model Emissions Files — NIF3.0 Format (Available on a

CD on request)

C3. BY 2002 Nonroad Model Emissions Files -NIF3.0 Format (Available on a CD on request)

Dl. BY 2002 Onroad Mobile Source Emissions Inventory and DocumentationD2. BY 2002 Onroad Mobile Model Input_Output Files (Available on a CD on request)

D3. BY 2002 Onroad Mobile Source Emissions -NIF3.0 Format (Available on a CD on

request)

Appendix C. 2009 Point Source Emissions Summary

Appendix D. Round 7.Oa Cooperative Forecast Projections_2009 Area and Nonroad Source

Emissions Summary

Appendix El. 2009 Onroad Mobile Source Emissions Inventories and DocumentationAppendix E2. 2009 Onroad Mobile Model Input_Output Files (Available on a CD on request)

Appendix F. Transportation Control Measures and Vehicle, Maintenance, or Fuel-Based MeasuresAppendix G. Supplemental Measures Support DocumentationAppendix H. RACM Summary Table

Appendix I. Modeling Documentation

Attachment A. Marama_PM25Forecasting_ReportAttachment A. NESCAUM_PM25_Conceptual_Model

Attachment B. OTC&ASIP_Modeling DomainsAttachment C. Horizontal Grid Definitions for MM5 and CMAQAttachment D. Vertical Layer Definitions for MM5 and CMAQAttachment E. MM5 Meteorological Model ConfigurationsAttachment F. Hao2005_METDataAnalysis-Hao

Attachment F. HeEtAl2005 2002AnnualEvalofl 2kmMM5 SurfParams4OTCModeling-HeAttachment F. ZhangandZhang2005_MM5report-2002data

Attachment F. ZhangandZhengJApplMet2004_PBLschemes

Attachment G. SIP SMOKE Emissions Modeling Configuration

Attachment G. OTC SMOKE Emissions Modeling Configuration
3.0 2002 Base Year Inventory

3.1 Background and Requirements

The 2002 Base Year Inventory is documented in detail in Appendix B (2002 Base YearEmissions Inventory Document for Washington, DC-MD-VA PM2.5Nonattainment Area) of the

PM2.5 SIP document. This inventory document was prepared for the District of Columbia,Maryland, and Virginia by the Metropolitan Washington Council of Governments (MWCOG)

under the auspices of MWAQC. It is available for inspection along with rest ofthe PM2.5 SiP

documents at the offices ofthe MWCOG and the District of Columbia, Maryland, and Virginiaair management agencies in addition to the MWCOG Web site(http://sharepoint.mwcog.org/afrquality).

The emissions inventory covers the Washington, DC-MD-VA PM2.5nonattainment area, Figure

1-1, which is classified as a nonattainment area for the annual PM2.5standard by the

Environmental Protection Agency (EPA). The 2002 emissions inventory is the baseline fortracking the progress for emissions in future years, such as the attainment year 2009. It also

serves as the starting point for calculating the emissions reduction requirement (for man-madesources of emissions) needed to meet the contingency requirements in case the PM2.5standards

are not met in the attainment year 2009. Emissions reductions for attainment contingency are

required for nonattainment areas by the Clean Air Act Amendments (CAAA) and EPA.

Appendix B (2002 Base Year Emissions Inventory Document for Washington, DC-MD-VA

PM2.5Nonattainment Area) ofthe PM2.5 SIP document addresses emissions ofPM25Direct,oxides of nitrogen (NO), sulfur dioxide (SO 2), volatile organic compounds (VOC5), ammonia

(NH 3),andPM10.Direct on an annual basis. Included in the inventory are anthropogenic (man

made) sources, such as point, area, nonroad, and on-road mobile sources and biogenic (naturally

occurring) sources of PM2.5precursors.

The 2002 base year annual inventories for PM2.5Direct, NOR, SO2,VOCs, NH3and PM10 Directcan be seen in Tables 3-1 through 3-6.
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Table 3-1

2002 Base Year AnnualPM25-Direct Inventory I

(tons/year) I.

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District of Maryland Virginia Totala Columbia

Point 126.53 3,497.31 545.71 4,169.55

Area 495.07 7,479.48 5,692.32 13,666.87

Nonroad 298.71 1,007.45 1,312.15 2,618.31

On-Road 156.27 841.18 727.25 1,724.70

Biogenics 0.00 0.00 0.00 0.00

Totala 1,076.58 12,825.42 8,277.43 22,179.44

a Small discrepancies may result due to rounding.

Table 3-2

2002 Base Year Annual NO Inventory

(tons/year)

District of Maryland Virginia Totala Columbia

Point 1,317.46 45,829.43 14,195.67 61,342.56

Area 1,694.70 5,167.94 7,091.38 13,954.02

Nonroad 3,535.64 9,972.89 13,213.58 26,722.11

On-Road 8,827.37 47,640.16 41,107.78 97,575.31

Biogenics 25.91 430.75 301.22 757.88

Totala 15,401.08 109,041.17 75,909.63 200,351.88

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Small discrepancies may result due to rounding.
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Table 3-3

2002 Base Year Annual SO Inventory

(tons/year)

District of Maryland Virginia Totala Columbia

Point 2,467.55 164,784.06 37,400.23 204,651.84

Area 463.44 2,375.52 9,496.59 12,335.56

Nonroad 376.46 894.19 1,562.46 2,833.10

On-Road 289.88 1,734.88 1,515.22 3,539.98

Biogenics 0.00 0.00 0.00 0.00

Totala 3,597.33 169,788.65 49,974.50 223,360.49

a Small discrepancies may result due to rounding.

Table 3-4

2002 Base Year Annual VOCs Inventory

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(tons/year)

District of Maryland Virginia Totala Columbia

Point 87.76 1,112.16 701.94 1,901.86

Area 6,313.88 31,667.71 34,395.80 72,377.39

Nonroad 2,042.83 14,224.36 14,225.08 30,492.27

On-Road 4,913.24 20,495.11 18,495.56 43,903.91

Biogenics 2,519.63 31,126.70 24,906.38 58,552.71

Totala 15,877.34 98,626.04 92,724.76 207,228.14

a Small discrepancies may result due to rounding.
Table 3-5

2002 Base Year Annual NH3Inventory

(tons/year)

a Small discrepancies may result due to rounding.

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District of Maryland Virginia Totala Columbia

Point 11.13 25.33 0.00 36.46

Area 12.59 3,113.84 543.72 3,670.14

Nonroad 0.00 0.00 0.00 0.00

On-Road 383.37 2,035.19 1,827.06 4,245.62

Biogenics 0.00 0.00 0.00 0.00

Totala 407.08 5,174.36 2,370.78 7,952.22

aSmall discrepancies may result due to rounding.

Table 3-6

2002 Base Year AnnualPM10-Direct Inventory

(tons/year)

District of Maryland Virginia Totala Columbia

Point 181.56 5,208.23 997.63 6,387.42

Area 2,680.45 23,359.83 26,571.31 52,611.59

Nonroad 310.18 1,057.65 1,380.70 2,748.53

On-Road 223.62 1,200.36 1,048.21 2,472.19

Biogenics 0.00 0.00 0.00 0.00

Totala 3,395.81 30,826.06 29,997.85 64,219.72
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3.2 Total Emissions by Source

3.2.1 Point Sources

For emissions inventory purposes, point sources are defined as stationary, commercial, or

industrial operations that emit more than 10 tons/year. The point source inventory consists ofactual emissions for the base year 2002 and includes sources within the geographical area ofthe

Washington, DC-MD-VA PM2.5nonattainment area. The states of Maryland and Virginia and the

District of Columbia are responsible for compiling and submitting point source emission

estimates.

In 2002, the State of Maryland also included all types of Andrews Air Force Base (AFB)

emissions in their point source emissions. These sources are called quasi-point source emissions.

3.2.2 Area Sources

Area sources are sources of emissions that are too small to be inventoried individually and that

collectively contribute significant emissions. Area sources include smaller stationary point

sources not included in the states’ point source inventories such as printing establishments, dry

cleaners, and auto-refinishing companies as well as nonstationary sources such as evaporative

emissions during transport of petroleum tank trucks and portable fuel containers.

Area source emissions typically are estimated by multiplying an emission factor by some known

indicator of collective activity for each source category at the county level. An activity level is

any parameter associated with the activity of a source, such as production rate or fuel

consumption that may be correlated with the air pollutant emissions from that source. For

example, the total amount of VOC emissions emitted by commercial aircraft can be calculated

by multiplying the number of landing and takeoff cycles (LTOs) by an EPA-approved emission

factor per LTO cycle for each specific aircraft type.

Several approaches are available for estimating area source activity levels and emissions. These

include apportioning statewide activity totals to the local inventory area and using emissions per

employee (or other unit) factors. For example, solvent evaporation from consumer and

commercial products such as waxes, aerosol products, and window cleaners cannot be routinely

determined for many local sources. The per capita emission factor assumes that emissions in a

given area can be reasonably associated with population. This assumption is valid over broad

areas for certain activities such as dry cleaning and small degreasing operations. For some other

sources an employment-based factor is more appropriate as an activity surrogate.

3.2.3 Onroad Mobile Sources
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evaporation characteristics of motor fuel, and temperature data. The general equation for the

estimation of mobile sources is

Emissions = (Travel Component) x (Emission Factor).

Emissions accounted for in the mobile source inventory include [

Origin: Emissions include “cold start” and “hot start” emissions

occurring during the first few minutes of vehicle operation.

Running: Emissions occurring on local streets and on the region’s

network of arterial streets, freeways, and nonramp freeways.

Running Loss: Emissions due to the heating of fuel and fuel lines.Crankcase: Emissions due to blow-by.

Destination: Evaporative or “hot soak” emissions occurring at the

conclusion of a vehicle trip after the engine is turned off.

Diurnal: Evaporative emissions occurring when the vehicle is at rest due

to temperature fluctuations.

Resting Loss: Emissions due to the permeation of fuel through hoses and

fittings.

Auto Access: Emissions attributable to auto trips to Metrorail stations or to

park-and-ride lots.

Bus: Bus emissions, i.e., Metrobus, Ride-on, etc.

3.2.4 Nonroad Mobile Sources

Emissions for all nonroad vehicles and engines except airport [aircraft, ground support

equipment (GSE), and auxiliary power units (APUs)], locomotives, and diesel marine vessels

were calculated using EPA’s NONROAD2005 model version 2005 a (February 8, 2006). Thismodel was run with its associated graphic user interface NONROAD2005.1.0 (June 12, 2006),

reporting utility version 2005c (March 21, 2006), and all geographical allocation data filesupdated until February 1, 2006.

Emissions from the “nonroad vehicles and engines” category result from the use of fuel in a I ‘

diverse collection of vehicles and equipment, including vehicles and equipment in the following L

categories:

• Recreational vehicles, such as all-terrain vehicles and off-road motorcycles;

• Logging equipment, such as chain saws;• Agricultural equipment, such as tractors;• Construction equipment, such as graders and back hoes;

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• Average load factor expressed as average fraction of available power;

• Available power in horsepower;• Activity in hours of use per year; and• Emission factor with deterioration and/or new standards.

The emissions are then temporally and geographically allocated using appropriate allocation

factors.

Aircraft (military, commercial, general aviation, and air taxi) and auxiliary power umts (APU)

operated at airports along with locomotives and diesel marine vessels are also considered

nonroad

sources and are included in the nonroad category

Metropolitan Washington Airports Authority (MWAA) provided all types of airport emissions

for Dulles (Fairfax and Loudoun) and Reagan National (Arlington) airports, which aredocumented in Air Pollution Emission Inventoriesfor Washington Dulles InternationalAirport

andRonaldReagan Washington NationalAirportfor Calendar Years 2002 2008 20091 (see

Attachment B4 of the 2002 Base Year Inventory document) Nonroad model-generated ground

support equipment emissions for Loudoun and Arlington counties were replaced by emissions

provided by MWAA. While MWAA GSE emissions for Dulles airport were equally divided

1 between Fairfax and Loudoun counties, Reagan National emissions were put mto Arlington J County Aircraft and APU emissions for other counties were provided by the respective states Emissions from locomotives and commercial diesel marine vessels were also provided by the

states.

3.2.5 Biogenic Sources

An important component of the inventory is biogenic emissions. Biogenic emissions are thoseresulting from natural sources. Biogenic emissions are primarily VOCs that are released fromvegetation throughout the day. Biogemc emissions of NO include lightning and forest fires.

EPA used a biogenic computer model (BEIS3.12) to estimate biogenic emissions for each county

in the country for all 12 months ofthe year 2002. Emissions data for Washington, DC PM2.5

nonattainment-area counties were acquired from the EPA Web site

(ftp :1/ftp. epa.gov/Emislnventory/2002finalneilbiogenic_sector_data/). EPA has recommended

that states use these emissions in case they do not have their own estimated biogenic emissions.

The Washington, DC-MD-VA PM2.5nonattainment area decided to use the inventories provided

by the EPA.

3.3 Annual Inventories

The 2002 base year inventories forPM25-Direct, NON, SO2,VOCs, NH3and PM, 0-Direct in