Technical Support Document (TSD) For

Washington County Maryland:

PM2.5 Base Year Inventory.

Submitted June 06, 2008 by the

Maryland Department ofthe Environment

TSD Prepared May 2010

Janet C. Kremer

Office of Air Monitoring and Analysis, 3AP40

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 19103

“Reviewed by Walter Wilkie, Associate Director

Office of Air Monitoring and Analysis (3AP40)

H,3’O

Date Signed
approvability ofthe SIP Base Year Inventory and an evaluation ofthe methods used for

projection year inventories. A SIP Base Year Inventory is the starting point from which

other SIP inventories are derived as well as serving as the benchmark for other SIP

planning activities, such as the establishment of an emissions reduction credit program.

Projection year inventories are essentially used to track progress; the purpose of which isto demonstrate a reduction in emissions ofregulated sources from the Base Year to a

projected year. Washington County is the Maryland portion ofthe Martinsburg, WVHagerstown MD PM2.5 nonattainment area. Maryland Department ofthe Environmenthas submitted the Washington County Maryland PM2.5 Nonattainment SIP with a 2002Base Year Inventory and has requested EPA’s approval.

Any questions pertaining to this technical summary should be directed to Walter

K. Wilkie, Associate Director, Office of Air Monitoring and Analysis at 215-814-2150 or

via email at wilkie.walter(epa.gov.II 2002 SIP Base Year Inventory

The SIP base year inventory is the primary inventory from which other

inventories (3-year cycle inventories, reasonable further progress inventories, modeling

inventories) are derived. The Clean Air Act calls for State, local, and Tribal agencies to

ensure that the base year inventory is comprehensive, accurate, and current for all actual

emissions. 1The base year inventory includes emissions estimates from stationary pointand nonpoint sources, onroad mobile sources, and nonroad mobile sources. For the

PM2.5 NAAQS, the pollutants to be inventoried are VOC, NOx, NH3, S02, PM1O andPM2.5. For the PM2.5 NAAQS emissions should be reported as actual annual emissions.MDE’s base year inventory is for 2002. A significant amount of documentation isrequired for these SIP base year estimates which MDE has provided.

In the MDE SIP, the base year used was 2002. MDE’s Air and Radiation

Management Administration (ARMA) is primarily responsible for compiling the Point

Source data for 2002. ARMA uses several forms ofsource identification. The state’s

primary data source is from its permitting program, which includes permit applications

and equipment registrations. AREVIA also relies on its compliance program, whichinvolves using information gathered from inspections and citizen complaints. ARIvIA

provided its 2002 actual emissions for VOC, NOx , NH3, S02, PM1O and PM2.5 at the

facility level and at the process-level.

For the 2002 Nonpoint Source emissions, also known as “area sources,” ARMA

provided an inventory that contained estimations of emissions by multiplying an emission

“Emissions Inventory Guidance for Implementation ofOzone and Particulate Matter National Ambient

Air Quality Standards (NAAQS) and Regional Haze Regulations” EPA-454/R-05-0O1, August 2005
NONROAD2005 model, version as of 03/21/2006, and EPA emission factors.NONROAD estimates fuel consumption and emissions of total hydrocarbons, carbon

monoxide, nitrogenoxides, sulfur dioxide, and particulate matter for all nonroad mobile

source categories except for aircraft, locomotives, and commercial marine vessels.

ARIVIA provided emission estimates for locomotive engines, aircraft emissions

separately. For locomotive engine and line haul emissions, ARMA requested and

received fuel usage and track mileage data from all 13 railroads operating in Maryland.

Fuel usage was proportioned to each county by the amount oftrack miles each companyutilized in a county. Paired with EPA emission and conversion factors, ARMA calculated

locomotive emissions for the base year. For aircraft emissions, ARMA used several

sources of information: Federal Aviation Administration’s (FAA) Airport ActivityStatistics of Certificated Route Air Carriers; landing and takeoff cycle information by

airport in Maryland; Aviation Administration and the Federal Aviation Administration

Airport License Renewal Applications; and FAA’s Emissions & Dispersion Modeling

System (EDMS). All Nonroad mobile source emissions were provided by SCC.

The Onroad Mobile Source 2002 emissions inventory was developed using the

most current version ofEPA’s highway mobile source emissions model MOBILE 6.2 and

traffic activity data from the Maryland State Highway Administration. ARIVIA also usedPPSUITE, an enhanced version ofthe Post Processor for Air Quality software systems.ARIvIA provided Mobile6.2 input and output files for review. Mobile emissions valueswere given in units oftons per year and were provided by SCC.

ARMA also applied rule effectiveness and rule penetration for its 2002 PM2.5

SIP base year inventories. Rule effectiveness reflects the actual ability of a regulatory

program to achieve the emission reductions required by regulation (or perhaps voluntarily

adopted). ARMA applied rule effectiveness and where applicable, provided a

justification of a higher percentage than EPA’s previous policy (which assumed an 80%

rule effectiveness for applicable sources unless otherwise specified). Rule penetration is

an estimate of percentage of emissions in a source category that are emitted at facilitiessubject to the requirements of a rule. ARMA applied rule penetration for its nonpointsources where applicable.

OAMA staffreviewed the results, procedures, and methodologies for the SIP base

year, and found them to be approvable.